ML18101A497
| ML18101A497 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/16/1995 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N95001, NUDOCS 9501250130 | |
| Download: ML18101A497 (10) | |
Text
- * ------
Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations JAN 16 1995 LR-N95001 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:
RESP:PNSE.TO NRC*S NOTICE OF VIOLATION INSPECTION REPORT 50-272/94-21; 50-311/94-21 DOCKET NOSc 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the NRC Inspection Report 50-272/94-21, 50-311/94-21, dated November 30, 1994.
Within the scope of this report, two violations were identified.
One violation of 10CFR50.55a(f).Inservice Testing and one violation of 10CFR50 Appendix B, Criterion XVI, Corrective Action were noted.
During a telephone conversation between F. X. Thomson, Jr, PSE&G Manager - Licensing and Regulation and J. White, NRC Region 1 Reactor Projects Section Chief, it was agreed to extend the response due date until January 16, 1995. to this letter restates the violations as identified to PSE&G, and our assessment and response to the identified.
violations.
Should you have any questions regarding this transmittal, please do not hesitate to contact me.
("~ " :
r r.:~
...... '::.: d ~ *.. "t 9501250130 950116 PDR ADOCK 05000272 Q
PDR Sincerely,
Docwnerit Control Desk LR~N95001 2
.~*
C Mr. T. T. Martin, Administrator - Region I
- u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager - Salem
- u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville,-
MD 20852 Mr. C.* Marschall -
Salem (S09)
USNRC Senior -Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 JAN 161995 95-4933
STATE OF NEW JERSEY COUNTY OF SALEM
)
)
SS.
)
REF:
LR-N95001 J. J. Hagan, being duly sworn according to law deposes and says:
I am Vice President -;.;;.- Nuclear Operations of Public service Electric and Gas company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribed and Swo th.is
-ti)
,Jersey My Commission expires on me 1995 KIMBERLY JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission Expires April 21 1998
LR-N95001 ATTACHMENT 1 NOTICE OF VIOLATION During an NRC inspection conducted at Salem Units 1 and 2 from September 12 to 16, 1994 and October 19 to 21, 1994, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
A~
10 CFR Part 50.55a(f) requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves shall be perf armed in accordance w.i th.Section XI of th~ ~,ASME Boiler and Pressure Vessel Code arid applicable addenda, except where specific written relief has been requested by the licensee and granted by the Commission.
ASME Code Section XI, Sub article IWV-3521, "Test Frequency," requires that check valves shall be exercised at least once every 3 months, except.as provided by IWV-3522.
ASME Code Section XI, Sub article IWV-3522, "Exercising Procedure," requires that check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.
If only limited operation is practical, during plant operation the check valve shall be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns.
Generic Letter (GL) No. 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," Attachment 1, Position 2, "Alternative To Full Flow Testing Of Check Valves," states that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full stroke *axercise open, and that disassembly and inspection may be performed during reactor refueling outages.
Contrary to the above, as of October 21, 1994, inservice testing of certain Code Class 2 check valves was not performed in accordance with ASME Code Section XI. as evidenced by the following examples:
- 1.
Since October 12, 1993, check valve 1SJ3 and 2SJ3 were not part-stroke exercised during plant operation or full-stroke exercised during cold shutdowns.
LR-N95001 ATTACHMENT 1 2
- 2.
Since October 9, 1992, check valves 1PR25 and 2PR25 were not full-stroked exercised during cold shutdowns, or disassembled and inspected during reactor refueling outages.
This is a Severity Level IV violation.
(Supplement 1)
PSE'G RESPONSE PSE&G does not dispute the violation.
The root cause of this violation has been attributed to personnel error due to inadequate attention to detail.
BACKGROUND By letter dated June 26, 1987, PSE&G submitted the proposed Salem Generating Station, Units 1 and 2, Inservice Testing (IST) Program for the second teri year interval.
In a letter dated October 3, 1989, PSE&G responded to NRC Generic Letter 89-04, Guidance On Developing Acceptable Inservice Testing Programs, which included a revision to the proposed IST Program.
Three additional submittals dated February 28, 1990, March 14, 1991 and May 16, 1991 were provided to the NRC during the re*~iew process.
On October 9, 1992, the NRC provided a Safety Evaluation of the Salem IST Program including the proposed Relief Requests.
SJ3 SAFETY INJECTION PUMP SUCTION FROM REFUELING WATER STORAGE TANK SUCTION CHECK VALVES The NRC Safety Evaluation, dated October 9, 1992, required response from PSE&G for 19 identified anomalies and for denial of the relief request for the SJ3 valves backflow test. PSE&G provided a response to the identified anomalies.
In attempting to withdraw this relief request, on October 13, 1993 PSE&G incorrectly withdrew the entire relief request.
This withdrawal of the open exercise test frequency relief was an oversight by PSE&G personnel and not our intent.
Therefore, tne SJ3 valves open exercise test was being performed on a frequency specified in the relief request that was inadvertently withdrawn.
LR-95001 ATTACHMENT 1 3
1(2)PR25 RELIEF VALVE DISCHARGE TO PRESSURIZER RELIEF TANK CHECK VALVE The October 9, 1992 NRC Safety Evaluation (SER) also provisionally approved the relief request for the PR25 valves to allow disassembly in lieu of exercising provided post-maintenance testing is performed.
In the PSE&G October 12, 1993 letter, PSE&G committed to perform post-maintenance testing.
However, at the time of the submittal, PSE&G personnel did not create a recurring task in the maintenance control computer system to address disa$sembly of the PR25 valves.
Therefore, no work order was generated and the valves were not tested in accordance with the SER.
CORRECTIVE STEPS TAREN AND CORRECTIVE STEPS TAREN TO AVOID FUTURE VIOLATIONS PSE&G has developad a relief request for the SJ3 valve open exercise test to be submitted to the NRC.
Recurring tasks have been created to address disassembly of the PR25 valves.
The 2SJ3 amd 2PR25 valves were tested during the just completed Unit 2 refueling outage.
The 1SJ3 and 1PR25 will be tested during the upcoming Unit 1 refueling outage.
Technical Department Management:
- 1.
Reviewed the event with personnel involved and stressed the importance of attention to detail.
Appropriate actions have been taken in accordance with PSE&G personnel practices.
- 2.
Temporarily increased staffing for the responsible group to assist in upgrading the IST Program.
- 3.
Revised the IST Program review process to clarify the responsibilities of personnel and to ensure components are tested as required.
- 4.
Will complete a formal self-assessment of the IST Program during the first quarter of 1995.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance.
PSE&G has addressed the discrepancies identified and believes that the self-assessment will reinforce the assurance that testing is being performed in accordance with the ASME Code.
-J LR-95001 ATTACHMENT 1 NOTICE OF VIOLATION 4
B.
10CFR Part so, Appendix B, Criterion XVI, "Corrective Action," requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, significant conditions adverse to-gJiality were not promptly identified-, causes were not determined or corrective actions were not taken to preclude repetition, as evidenced by the following examples:
- 1.
Failure to establish new vibration reference values, or to reconfirm old reference values, following corrective maintenance on safety-rela~ed pumps was identified, and corrective action requests were initiated, during Quality Assurance Department inservice test program audits performed in 1988 and 1990.
Corrective actions taken to preclude repetition of this condition adverse to quality were not effective in that new reference values were not established, or old reference values reconfirmed, following corrective maintenance on the No. 21 component cooling water pump on July 6, 1993.
- 2.
During performance of a surveillance test on No. 21 safety injection pump on March 31, 1994, apparent leakage through a pump discharge relief valve to the pressurizer relief tank was observed, which potentially could have diverted makeup water from the reactor coolant system during the injection phase of an accident.
The cause of this condition adverse to quality was not identified and corrected promptly resulting in recurrence of the condition during subsequent performance of the surveillance test on June 22, 1994.
This is a Severity Level IV violation.
(Supplement 1)
- J LR-95001 ATTACHMENT 1 PSE&G RESPONSE I~ -
5 PSE&G does not dispute the violation.
The root cause of the failure to establish proper baseline data following maintenance on a pump was that established administrative controls were not effective.
The root cause of the Safety Injection Pump relief valve leakage concern was a less than adequate review of the problem ;and the. _lack:, of further testing that.wqu,ld have-resulted in the identification of the repairs needed.
Proper followup to an identified corrective maintenance problem would have resulted in success.
SELF-ASSESSMENTS AND AUDITS PSE&G's Quality Assurance Department performs audits of the IST Program on a routine basis (approximately every two years).
These audits are comprehensive and self-critical.
A recurring concern identified during the recent audits was failure to perform new baseline data or re-confirm previous baseline following maintenance as required by the ASME Code.
In spite of this identification of three previous occurrences of failure to establish new baseline data, PSE&G failed to establish new vibration reference values following corrective maintenance on 21 Component Cooling Pump on July 6, 1993.
A copy of the test data was not provided to the IST Coordinator.
Therefore, new baseline data was not determined.
SAFETY INJECTION PUMP DISCHARGE RELIEF VALVE 'LEAKAGE Operators first noted leakage during testing of 21 Safety Injection Pump on March 31, 1994.
Continuous monitoring of the Pressurizer Relief Tank (PRT) was in progress due to a previous action request concern associated with reactor head vent leakage.
During the Safety Injection Pump test a significant increase in leakage into the PRT was noted.
When the test was completed, the leakage returned to the pre-test value.
An action request was initiated to investigate the problem.
The Shift Supervisor determined that no operability concern existed.
,/
LR-95001 ATTACHMENT 1 6
On April 3, 1994, a new shift was reviewing the logs and identified to management that the leakage was a possible operability concern.
Maintenance was notified and a special troubleshooting procedure was performed.
No leakage was noted.
The operators concluded the safety injection system was operable, the action.
request was closed, and no further evaluations were performed. On April 4, 1994 a* System Engineering Assistance Transmittal requesting evaluation of.the potential leakage was generated.
However, no priority was assigned to the request.
- On June 22, 1994, during surveillance testing, PRT level increase was again noted.
Troubleshooting was initiated and the leakage was determined to. have been caused by relaxation of the Safety Injection Pump relief valve operating spring.
The valve was refurbished and tested satisfactorily.
An Engineering Memorandum 94-11, dated July 13, 1994, concluded that the safety injection system had been operable while the relief valve was degraded.
Despite the results of the Engineering Memorandum, corrective actions were not accomplished and actions to prevent recurrence were not performed in a timely manner.
CORRECTIVE STEPS TAKEN AND CORRECTIVE STEPS TAKEN TO AVOID FUTURE VIOLATIONS
- 1.
Operations will revise IST procedu~es to include a step that the IST Coordinator be notified whenever a test is being performed post-maintenance.
. 2.
PSE&G has conducted timely operability determination training for licensed operators, system engineers, and other appropriate personnel.
- 3.
Operations Department Management has stressed the importance of proper operability and root cause determinations.
Operability determinations are documented and maintained in the Control Room.
A flow chart has been developed to assist in the adequacy of the determination.
- 4.
An engineering evaluation was performed which verified the operability of the Safety Injection System.
LR-95001 ATTACHMENT 1 7
- 5.
PSE&G has investigated the recurring problem of leakage associated with thermal relief valves and is implementing improved practices for cleaning and lift set testing ~o prevent recurrence.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance.
Lessons learned will be shared with Hope Creek *