ML18100B198

Notice of Violation from Insp on 940627.Violation Noted: Licensee Senior SS Failed to Designate Individual Responsible for Control Room Function in Absence of Senior SS

ML18100B198
Person / Time
Site:	Salem
Issue date:	07/06/1994
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18100B197	List: ML18100B196 ML18100B198
References
50-272-94-11, 50-272-94-13, 50-272-94-80, 50-311-94-11, 50-311-94-13, 50-311-94-80, NUDOCS 9407130086
Download: ML18100B198 (5)

Text

ENCLOSURE 1 APPARENT VIOLATIONS CONSIDERED FOR ESCALATED ENFORCEl\\IBNT ACTION (AIT REPORT 50-272, 50-311194-80; AND INSPECTION REPORTS 50-272, 50-311/94-11 AND 50-272, 50-311/94-13)

A.

Technical Specification 6.1.2 requires that the Senior Nuclear Shift Supervisor (SNSS) or, during his absence from the control room, a designated individual, shall be responsible for the control room command function. Technical Specifications require administrative procedures, as referenced in Regulatory Guide 1.33. PSE&G Administrative Procedure NC.NA-AP.ZZ-002(Q), Attachment 32, Shift Management Responsibility for Station Operation, requires, in part, that the SNSS shall remain free to survey and analyze all operating parameters. The procedure further states, "intense involvement in any particular detail may run the risk of losing control and perspective of the overall operation." The following two examples on April 7, 1994, demonstrated a loss of perspective regarding overall plant safety and the command function of the senior nuclear shift supervisor:

1)

The SNSS left the control room during the loss of circulating water transient to override a circulator pump protective interlock, and thereby relinquished the command function in the midst of a significant plant transient. During his absence, operators caused reactor coolant temperature to decrease below the minimum temperature for criticality; and

2)

While the SNSS was absent from the control room, the nuclear shift supervisor (NSS), designated as responsible for the control room command function, assumed the duties of a reactor operator by performing control rod movements. As a result, for the period of time the NSS was manipulating the controls, no individual was properly exercising the control room command function.

B.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires in part, that licensees identify significant conditions adverse to quality, determine their causes, and take corrective action to preclude recurrence. Two examples of failure to meet this requirement occurred:

1) During previous reactor/turbine trips on June 10, 1989, July 11, 1993, and February 10, 1994, the licensee failed to identify and correct the cause of spurious high steam flow signals. As a result, the licensee failed to preclude an unnecessary safety injection actuation on April 7, 1994, in response to a reactor trip; and 9407130086 940706 PDR ADOCK 05000272 G

PDR

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2) In March 1977, the licensee modified the control system for the main steam atmospheric relief valves (MS-lOs) and has since failed to correct deficiencies introduced during the modification. As a result, the licensee failed to preclude a second unnecessary safety injection actuation on April 7, 1994, (precipitated by opening of the main steam safety valves in lieu of the MS-lOs) in response to a reactor coolant system heatup following the initial safety injection actuation.

C.

10 CPR 50.57 requires, in part, that emergency plans and procedures for event classification and notification of offsite authorities be implemented. Salem Emergency Plan and Event Classification Guide, Attachment 8, NRC Data Sheet, requires that specified information regarding the event description be completed, approved, and provided to the designated communicator for transmission (to the NRC) within 60 minutes. The specified information includes, "... systems affected, actuations and their initiating signals, causes, effect of event on plant, actions taken or planned, etc.

Note anything unusual or not under~tood... "

On April 7, 1994, the following information was not communicated or adequately described: (1) the apparent logic mismatch of the protection system and resultant unexpected operation of the emergency core cooling system (ECCS) flow path valves and the unexpected condition of the main steam and feedwater isolation systems; (2) the cause of the reactor trip was not described; (3) the effect of the event on the plant (namely, the resultant filled pressurizer or "solid" RCS condition); and (4) the operator plans to recover from the solid RCS condition.

D.

Technical Specification 6.8.1, requires, in part, that the licensees implement written procedures referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33, Section 6, requires procedures for combating emergencies and other significant events, including expected transients and acts of nature.

During the April 7, 1994, event, the initial response to the grass intrusion at the intake structure and recovery from the subsequent transient were complicated for operators. Procedural guidance was inadequate or nonexistent for the following activities:

1) Recovery of RCS temperature from below the minimum temperature for criticality;

2) Rapid power reductions due to grass intrusion;

3) Recognition of and response to safety injection train logic disagreement; and

4) Recovery from "solid" plant conditions.

3 E.

10 CPR 50, Appendix B, Criterion VIIl, Identification and Control of Materials, Parts, and Components, requires in part, that measures be established for the identification and control of parts and components. These measures shall assure that identification of the item is maintained throughout installation and prevent the use of incorrect parts. The following are two examples that demonstrate a failure to maintain configuration control:

1) During the 1993 Unit 2 outage, power operated relief valve (PORV) internals made of 17-4PH stainless steel (original design material) were installed in valves 2PR1 and 2PR2, in lieu of internals made of type 420 stainless steel (the vendor-recommended and licensee-approved design change replacement material).

2) The post-trip investigation for the April 7, 1994, event identified that the installed summator module for the high steam flow setpoint did not have the proper identification and contained an incorrect electronic part. Although the licensee determined this component did not affect the plant response during the event, it is an example of failure to properly identify components prior to installation.

F.

Technical Specification (fS) 3.5.2 requires two operable emergency core cooling system (ECCS) injection systems, or a plant cooldown to below 350°F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. During the event on April 7 ~ 1994, and following reset of the safety injection actuation signals, automatic actuation capability was not available (and not reinstated) because the reactor trip breakers were not cycled. This occurred because there was no procedural guidance for re-establishing the safety injection logic, nor was it clear that the logic was operable, and because a cooldown could not be completed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> due to the time required to re-establish a pressurizer steam bubble.

This was recognized by the licensee, in that, TS action 3.0.3 was entered, but enforcement discretion was later granted by the NRC in recognition that the plant would not be below 350°F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (or by approximately 5:00 p.m.) of the safety injection actuations that occurred on April 7, 1994.

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ENCLOSURE 2

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,....... o' 1. / vea. v..~~~- us l* Pddq. JulF 10.1 I Notice9 TWO-YW 1'1111 PlvglWR tor ConduCt*nl Opel9 EnfOl--

ConfWl*a.; PolCJ IUl lmeM*'

All l~.NadarileplatorJ commteeiM, ACTIOIC Po1icJ 1tatemlllt.

M 11n11 J 1: SIDd comments ta: The SecntuJ of the Comm*..ton. U.S.

Nuclara.platalJCommillion..

Waabiqtoa. DC ZOU5. A'n'N:

Docbtinl ud Sina Branch.

Hand dellftr comments to: One White Flint North. 11555 Rodcvill* Pike.

Roclmlle. MD betwnn 7:45 a.m. to 4:15 p.m.. Federal workday..

Copiet of commentl may be examined at the NRC Public Document Room. 2120 L Street. NW. (Lower Level).

WubiDltaao DC

'°"...-~TIOllCONTACT:

Jama IJebmaaD. Dtnc:tor, Office of EnfOl'CllMlll. U.S. Nudur Regulatory Comm!eaf.on., Watblngtoa. DC 20555 (301-aot-Z741).

.u1PP1.-1RTITMY..ataMTIOIC The NRC* c:umnt policy OD enforeement coaferenca ii addressed in Sec:tioa V of the latat nvilion to the "General Statemlllt of Pollif and Pnadllrl fat Bnforcemmat Actions."

(Enforcmaallt Polk:y) 10 CFR part 2.

appendix C that wu publi*hed on FebnwJ 11. 198Z (57 FR 5791). The F.nforcemant PobCJ 1tatel that.

.. enfcacemmt coDfenmces will not

.normallJ be op111 to the public."

HC>Wft9', tbe Commtutoa ba1 decided to impllllWd a trial prosram to determine whlthtr to maintain the cummt po&, wltb reprd to en!orcemmt coaferenca or to adopt a new policJ that would allow moat en!mcemmt c:aafenmc:a to be open to attendanca bJ all memben of the public.

PolicJ St*'

9 '

P,,.ilioe

'l'1ll NRC ll implemmtin& a two-year trial prasnm to allow public oblenatioll of Mlected enforcement c:oafanDcll. The NllC will monitor the

~ad deWrmiD9 wtiether to 11tablilh a permanent policy for

~tint op111 enforcement confenncle buecl aa an auessmen t of the followtnl criteria:

MJIBl'ft: 'l'h8 Nuclear bplabXJ Qmmteeim (NllC) II taaiDI tbia poUq etatamlllt an the lmplemmtatiaD of*

two-year trial propam to allow wW enforcemmt confll"IDCel to be oplD to attmd*nc:e by all members of the gemral public. 1bil policy 1tatement desc:ribel tb9 two-year trial prosram and infarma the public of how to I" lnformatian Oil upcomiq Opell enforcement coaferencn.

DATU: 1hla trial pfOllUl II effective Oil July 10. 198Z. while comments on the program al9 bein8 received. Submit comment. oa or before the completion of the trial program scheduled for July

11. 1992. Commentl received after thil date will be considered if it ii practical to do ao. but the Commi11ion ii able to a11ute consideration only for c5mments received on or before thi* date.

(1) Whetblr PM fact that the confennce wu opm impaded the NRC'1 abilitr to conduct a meaningful confenDcl Ud/m implement the NRC's enforcemmt prosram:

(2) WhetMr the open conference impacted the licmMe'I participation in the confenacc (3) Whetb8r the NRC expended a significant amount of re10urce1 in maldna the c:oaferenC8 public; and (4) 'Iba extmt of public interest i~

• openin& the enforcement conference.

F..._.. Rtl' I 1tvo1. 17. No. 138 I Fridq, July ta. *

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I wa1ea..... will not be to tM paWillif &be -

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individul. QI if &Jae actioa. tboatb not taken qaimt an indtviduaL tuma cm.

whelta.r an mdMdaal ha.I cmnm*tted wroqdoias (2) lavolva 1iptftc.ant pencmne1 Callum wb.ln the NRC ha.I requested that tbe iDdiYidul(I) involvtd be preMDt at tba CODfeNDC8:

(3) Ia bued on tbe Dndlnp of ID NRC Office of lznatipfian (OI) l'l1'0lt ar (4) lravolva..,....... iDfOl'lll.ltiaQ.

Privacy Act iDformatloa. or otlm informatioll whicb eoaJd be camid8ncl P~:=.,,. caaferenca 1nvoJvm, medJcal mlaadmlalmatiom or ovarapwunl will be opa aa1DlliDI the ccmf'INDOI CU be c:oaduc:ted withoat d1tcloliDI Iha expoMd individual'* name. Jn addition.

enfUl'U twafa I NI will not be open to tbe pabllc If the confereDCI wtD be condacted bJ tlJepboae OI' the confannc:e will be coaducUd at

• relative!J aWl Ucnwee'1 fac:ilit7.

E FlnaUJttv.~asr:=::..

cam.r.nc. will not be pabtic ta tpedal CUft toodCIUle bu a.a...

elllr bal*nc:t"I the 1lmdl ol pU1ic obMndcmapimt-dae potatial 1lllpMI on tha aamcr'* anlorcemul 8CtiaD.iD a particular calL.-

The NRC will 1t:riw to conduct open enforcement c:oafeumca dmial die-two-rear &rial p&'Olralll in ac:cardaw wi tb tba followiill &brw9..,.Js.-

(1) ~

%5 pm:aalof all eligibl8 anforcemeal canf...-

conduded bf *tbe HIC will be apa lar public obaarwaaaa; (2) Al laa,at GM opm liaforcmml conference will be mndnded ia Mela of the regional offices; and (3) Open enfou:emat cxim.nnc.

will be conducted with* ftrietr al tbe cype. of licellMft.

To avoid po"9Dtial blu 111 the 1election proces1 and to attempt lo meet the three pll 1t1ted abaft...._,

fourth elisible enfcM *'+N cam....

involvin& one of three categoriH of licenaeH will......Dy be opm tD lbe public darinl the trial prosram.

However, lD ca... where there i9 a ongol.nl adjudicatory proc:eedinl wtth one or more illtll'ftDOl'I. enforamnmt confenmcee llM>binl imul9 related to ht-ct matter of the onaaiDI

'cation may ai.o be openeci For pwpoM9 of lhia trial prosram. u..

NUCL1AR MQUl..ATORY COMY*ttON PridaJ, JulJ 17, 1992 Two-Yw Trtll Progrma far Conducting Open l.nfolC*IMlll Coldw*teMi Poley Statement Conw:tJaa ID. notice do<Wll~t 9%-16233 beginning on pqe 30182 ID the l.uue of Friday, JulJ, 10. 188Zo cm pap 307'IZ. in~

MCODd cahnn under DATa. ~

lD lbe flftb U-... July 11, 1~

ahoald rad "July tt. 191M...