ML18101A894
| ML18101A894 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/14/1995 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N95117, NUDOCS 9508180113 | |
| Download: ML18101A894 (10) | |
Text
1
-*--*----;1..... ~
.. _.._,....,,..,.;..-_... ____. *-**-.. -,;....,.......,.,..,.... ____..................... *... ~._.............. -.........._............. *-**** -** --***---*.**-******* __...
OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit AUG 14 1995 LR-N95117 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/95-10; 50-311/95-10 SALEM GENERATING STATION UNIT NOS. 1 AN 2 DOCKET NOS. 50-272 AND 50-311 By letter dated, July 14, 1995 (ref: EA No. 95-62), the NRC Resident Inspection Report Nos. 50-272/95-10; 50-311/95-10 for Salem Nuclear Generating Statioris Units Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G).
Within the scope of this report, *two violations of NRC.
regulations were cited.
Pursuant to the provisions of 10CFR2.201, PSE&G submits its response to the aforementioned violations in Attachments 1 and 2 to this letter.
Should there be any questions with regard to this submittal, please do not hesitate to contact U$.
\\
Senior Vice President -
Nuclear Operations
DOCUMENT CONTROL DESK LR-N95117 2
c
/iMr. T. T. Martin, Administrator - Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 AUG 14 1995 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
DOCUMENT CONTROL DESK LR-N95117 VIOLATION A:
ATTACHMENT 1 Technical Specification 6.8.1 requires, in part, that written
.procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33 requires written procedures to control safety related maintenance and surveillances.
During the inspection period, the following examples of failure to adhere to procedures occurred:
l*
Salem Maintenance procedure SC.MD-ST.DG-0003, Eighteen Month Diesel Engine Inspection Maintenance, step 5.15.8.G requires that the maintenance technician unlatch the cylinder fuel pump rack once the compression pressure is obtained.
Contrary to the above, at approximately 10:00 p.m. on June 14, 1995, after obtaining the compression pressure for cylinder 4R on no. lC emergency diesel generator, the technician failed to unlatch the cylinder fuel pump rack.
As a result, the licensee operated the diesel with essentially no fuel to the 4R cylinder, 1 of 18 cylinders.
In such condition, a potential existed for an adverse affect on the reliability of the lC emergency diesel generator.
- 2.
Salem surveillance procedure S2.0P-ST.DG-0003, 2C Diesel Generator Surveillance Test, provides instructions necessary to prove operability of the 2C diesel generator.
Step 5.3.45 of S2.0P-ST.DG-0003 requires diesel generator restoration in accordance with Attachment 6.
to 82.0P-ST.DG-0003 requires placing the fuel rack linkage to the "open" position.
Contrary to the above, at 5:55 a.m. on May 16, 1995, the licensee restored the 2C diesel generator to service following surveillance testing and failed to ensure that the fuel rack linkage remained placed in the "open" position.
REASON FOR THE VIOLATION PSE&G does not dispute the violation.
Both of the examples given in the violation are discussed separately below.
DOCUMENT CONTROL DESK LR-N95117 J 2
ATTACHMENT 1 EXAMPLE 1 - Failure to unlatch the cylinder fuel pump DISCUSSION OF THE CIRCUMSTANCES The Emergency Diesel Generators.(EOG) are ALCO 251 V18 diesel engines supplied with fuel by individual fuel injector pumps connected to a control shaft and a Woodward EGA/EGB governor control system.
Design features include the ability to "lock out" or place to zero fuel admission each individual fuel injection pump for troubleshooting or maintenance activities.
During a surveillance run to return lC EOG to service following a maintenance outage which included checking and recording cylinder compression pressures, the Nuqlear Equipment Operator identified that the 4R cylinder was operating with an exhaust temperature of approximately 165 degrees F.
Normal temperature is 860 to 960 degrees F at rated speed and load for the surveillance.
The Nuclear Shift Supervisor was notified.
Investigation by the*
System Engineer and ~aintenance personnel identified that the 4R cylinder fuel pump was locked out.
The EOG was retained in an inoperable status.
Subsequently, an engineering evaluation concluded that operation of the EOG 4R cylinder in the zero fuel position did not impose excessive stresses on the EOG and that an internal inspection was not required.
The root cause of this event was personnel error.
EOG cylinder compression checks are performed in, accordance with Maintenance Procedure SC.MD-ST.DG-0003(Q) Section 5.15.8.
This procedure includes steps to unlatch the fuel rack from the zero fuel position and to place the latch in the down position following the completion of compression checks.
Unlatching of the fuel rack or failure to place the latch in the down position to prevent re-latching of 4R cylinder was not performed as required by the procedure.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN Appropriate levels of discipline (consistent with company personnel policies) were provided to the maintenance technician.
Maintenance procedure SC.MD-ST.DG-OOOJ(Q) was reviewed for adequacy.
The procedure was determined to be satisfactory for the training and knowledge level of the personnel who perform it.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance.
DOCUMENT CONTROL DESK LR-N95117 3
ATTACHMENT 1 CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID RECURRENCE Maintenance procedure SC.MD-ST.DG-0003(Q) will be enhanced by revising the procedure to require independent verification that the fuel rack is unlatched and the latch is in the down position to prevent re-latching.
Example 2.,.. Failure to place fuel rack in open position DISCUSSION OF THE CIRCUMSTANCES On May 16, 1995, the monthly surveillance test of 2C EDG was performed in accordance with procedure S2.0P-ST.DG-0003(Q).
The procedure was completed satisfactorily with all procedure steps signed off by the Nuclear Equipment Operator (NEO).
One of the.
sections of Attachment 6, Restoration Checklist, requires the fuel rack linkage position be checked in the Open (down) position.
This step is performed in the EDG surveillances to ensure that the fuel rack is in the full fuel position for optimum starting acceleration.
Later on the same day, the NRC Resident Inspector questioned the difference in appearance between the EDG fuel racks.
Upon further investigation, it was discovered that the 2C EDG fuel rack linkage was not in the full down position.
The fuel rack was then placed in the full down position.
on July 13, 1995, a similar condition was noted on lC EDG.
In both events, the NEOs involved completed and signed all procedure steps.
Following both events, the NEOs were interviewed and stated that they had positioned the fuel racks as required.
The NEO involved in the 2C EDG surveillance and other operators have stated that occasionally the fuel rack would spring back slightly and have to be pulled down a second time.
A root cause analysis of the mis-positioning of the fuel rack was performed by Salem Engineering.
The root cause was indeterminate.
Potential causes identified included personnel errors such as omission or inadvertent actions, and equipment causes such as unrelieved hydraulic and mechanical stresses within the governor fuel rack and the fuel pump assemblies.
An independent assessment performed by a contractor concurred* with the results of the PSE&G root cause analysis.
The independent assessment identified the most probable cause as personnel error with mechanical stresses as a contributing factor.
DOCUMENT CONTROL DESK LR-N95117 4
ATTACHMENT 1 As part of the investigation, the governor for 1C EDG was removed and replaced.
The governor that was removed was analyzed by the vendor and representatives of PSE&G t.o identify any mechanism that would inadvertently reposition the fuel racks.
No such mechanisms within the governor were identified.
The design of the fuel rack has an air-operated plunger that will move the fuel rack downwards when a start signal is received.
The plunger is supplied with compressed air at the same time as the EDG starting air motors.
Due to problems identified with the with the original fuel rack plunger air supply, failures of the EDGs to achieve rated speed in the required time occurred.
Procedure steps were added to have the NEO manually move the lever to the fully down position after the EDG surveillance was completed.
This would ensure that the EDG would receive full fuel for the start.
After the EDG starts, the governor operates the fuel rack per design.
Design changes have been completed to enhance the performance of the fuel rack plunger in order to ensure that the rated speed is achieved within the required time.
Upon completion of the design change, the procedure steps to position the fuel racks could have been deleted, but were not.
As stated previously, the design of the EDG automatically positions the fuel rack in the full down position upon a start signal.
Manual actions are no longer required.
This has been verified during the performance (every 18 months) of surveillance procedures Sl ( S2). OP-ST. DG-0019 (Q), 0020 (Q), 0021 (Q), * "A/B/C Diesel Generator Hot Restart Test".
During tl1ese tests, the EDG
- is run for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 2500-2600 KW, stopped and then restarted within five minutes.
Between the stop and start of the EDG, the fuel rack linkage is not manually positioned by the NEO.
The acceptance criteria for starting acceleration is to achieve rated speed within the required time.
This starting acceleration would not be possible if the fuel rack was not properly positioned automatically by the plunger.
Based on the above, PSE&G. concludes that the circumstances had minimal safety significance.
During the review of this event, a non-conformance with Nuclear Administration Procedure NC.NA-AP.ZZ-0005(Q)
(NAP-5) Station Operating Practices was identified.
NAP-5 requires that independent verification be performed on listed systems whenever components that are manipulated are restored to normal.
The procedure used to perform restoration did not contain an independent verification of the EDG fuel rack position as required by NAP-5.
DOCUMENT CONTROL DESK LR-N95117 5
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN ATTACHMENT 1 The fuel racks were placed in the procedurally required position upon discovery.
The other EDGs were inspected for similar problems at the time of discovery and no other discrepancies were noted.
CORRECTIVE ACTIONS THAT WILL BE TAKEN TO AVOID RECURRENCE All applicable EDG procedures will be revised to delete the manual positioning of the fuel racks.
The modifications that have been performed ensure that the EDG will achieve rated speed within the required time.
The independent assessment of the root cause analysis also concurred that it was not necessary to manually adjust the fuel racks.
Operations Department Procedures for systems requiring independent verification will be reviewed to ensure compliance with NAP-5.
DATE WHEN F.ULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved when appropriate Operations Department procedures have been reviewed and revised *as necessary.
PSE&G will complete the review and revision prior to entering Mode 4 from the current outage, but no later than December 31, 1995.
DOCUMENT CONTROL DESK LR-N95117 VIOLATION B:
ATTACHMENT 2 10CFR50.73 requires, in part, that licensee shall submit a Licensee Event Report within 30 days, for the completion of any plant shutdown required by the plant's Technical Specifications, or any condition that resulted in the nuclear power plant being in an unanalyzed condition.
Contrary to the above, as a result of inoperable switchgear supply fans, from December 12, 1994 until May 16, 1995, the licensee operated the Salem Unit 1 in an unanalyzed condition.
On May 16, 1995, the licensee completed. a shutdown of Salem Unit 1 as required by Technical Specification 3.0.3, and licensee did not report within 30 days the unanalyzed condition, or the shutdown required by Technical Specification 3.0.3.
REASON FOR THE VIOLATION PSE&G does not dispute the violation.
DISCUSSION OF THE CIRCUMSTANCES At 2126 hours0.0246 days <br />0.591 hours <br />0.00352 weeks <br />8.08943e-4 months <br /> on May 16, 1995, a Salem Unit No. 1 controlled shutdown was initiated as required by Technical Specification 3.0.3.
Entry into specification 3.0.3 had resulted from the determination that two of three switchgear and Penetration Area Ventilation system (SPAVS) supply fans (Nos 12 and 13) were inoperable.
The NRC was notified on May 16, 1995 in accordance with 10CFR50.72.
A Significant Event Response Team (SERT) was convened on May 17, 1995 by the General Manager -
Salem Operations to perform a root cause analysis.
on May 24, 1995, the Salem Technical Department which at that time had responsibility for LER management, conducted an alignment meeting to assign responsibilities for development of the LER.
It was determined that significant input to the LER would be contained in the SERT report.
The draft SERT report was also issued on that day.
On June 1; 1995, the final SERT report was issued and a draft LER was distributed for review by station management.
The LER was added to the agenda for the next regularly scheduled SORC meeting, which was June 14, 1995.
On June 14, 1995, the scheduled SORC meeting was postponed until June 16, 1995.
This was the date required to submit the report to meet ~he requirements of 10CFR50.73.
DOCUMENT CONTROL DESK LR-N95117 2
ATTACHMENT 2 During the SORC review of the LER, concerns were identified with the adequacy of the information to support the causal factors and the assignment of responsibility for corrective actions.
Based on these concerns, SORC did not recommend approval of the LER.
The SORC Chairman directed the Station Licensing Engineer to notify the NRC of the late LER.
Because ~t was Friday evening, the Station Licensing Engineer made a decision not to notify the NRC until Monday morning.
The NRC Senior Resident Inspector and NRC Region I personnel were notified by telephone of the late LER on Monday morning, June 19, 1995.
At that time, the NRC was notified that the LER should be issued by June 23, 1995.
On June 19, 1995, the Station Licensing Engineer notified the LER Coordinator of the commitment to provide the response within one week.
Later in the same day, the LER Coordinator provided this information to his supervisor.
However, the Station Licensing Engineer did not follow up to ensure the _LER was issued as required.
From June 26, 1995 until July 1~, 1995, despite discussions between the LER Coordinator and his direct supervisor, no substantial progress was. made in completing the LER.
During this time, the plant manager was unaware of the missed commitment.
A recent organizational change had realigned the Licensing Department under the Director -
QA/NSR.
It was his expressed intent that Licensing assume responsibility for development of LERs.
Prior to assuming that responsibility, during*the week of July 10, 1995, Licensing conducted a review to determine the status of all in process LERs.
The.review identified two LERs that were overdue.
After reporting this finding to senior management, the LERs were completed.and submitted on July 14, 1995.
The root cause of the event has been attributed to inadequate management oversight of the LER process.
Contributing factors included:
Inadequate line management focus on LER reporting requirements.
Lack of follow up by the Station Licensing Engineer on a known NRC commitment.
Lack of ownership and accountability for the LER process by the LER Coordinator, the Evaluation Manager and the responsible departments.
LER submittal strategy was flawed -
Submittal process should have been managed to provide a response within 30 days with additional information to be addressed in a s~pplemental LER, if necessary.
1 DOCUMENT CONTROL DESK LR-N95117 3
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN ATTACHMENT 2 All overdue LERs have been completed and submitted.
LERs 50-272/95-006-00 and 50-272/95-008-00 were submitted to the NRC on July 14, 1995.
Appropriate levels of discipline (consistent with company personnel policies) were provided to the LER Evaluation Manager, LER Coordinator, and Station Licensing Engineer.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN TO AVOID RECURRENCE Responsibility for the LER Program has been transferred from the Salem Engineering Department to the Nuclear Licensing Department.
LER processing under the revised Corrective Action Program contains the controls to ensure proper management attention and sufficient time to complete, review, and approve LERs prior to exceeding the 30 day requirements of 10CFR50.73.
The new process includes the following:
Establishment of an Evaluation Manager from station management personnel in accordance with the newly established Corrective Action Program.
Timely completion of a scoping meeting between LER Coordinator, Evaluation Manager and other personnel as necessary.
LER status reporting to identify current status of all LERs and supplemental LERs required to be submitted to the NRC.
This report will be distributed as necessary to ensure proper management attention to completing the LERs within the required time period~