ML18102A931
| ML18102A931 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/20/1997 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N97178, NUDOCS 9703250216 | |
| Download: ML18102A931 (9) | |
Text
Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 Senior Vice President - Nu.clear Operations MAR *201997 LR-N97178 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORTS 50-272/96-18, 50-311/96-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Ladies and Gentlemen:
609-339-5700 Inspection Report Nos. 50-272/96-18 and 50-311/96-18 for Salem Nuclear Generating Station Units Nos. 1 and 2 were transmitted to Public Service Electric & Gas Company (PSE&G) on February 19, 1997.
Within the scope of this report, three violations of NRC requirements were cited.
In accordance with 10CFR2.201, PSE&G is submitting its response to the violations in the attachment to this letter.
An additional violation concerning inadequate implementation of the security plan was discussed in the inspection reports.
PSE&G responded to this violation in a letter dated February 26, 1997 (LR-N97079).
In the cover letter of the above-mentioned inspection report, the NRC indicated concern over the ability to control work to ensure safe plant operation.
We recognize that work control is an integral element of safe plant operations.
Additional steps were recently instituted to improve work control.
As our restart effort moves forward, we will continue to emphasize that effective work control is necessary to meet our objectives.
Should there be any questions regarding this submittal, please contact us.
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Document Control Desk LR-N97178 Attachment 2 -
C Mr. Hubert J. Miller, 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 Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall -
Salem (S09)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Bureau of Nuclear Engineering 33 Artie Parkway CN 415 Trenton, NJ 08625 MAR 2 01997 95-4933
APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Units 1 and 2 Docket Nos:50-272 50-311 License Nos: DPR-70 DPR-75 During an NRC inspection conducted on December 15, 1996 to January 25, 1997, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations and the PSE&G responses are listed below:
A.
Appendix B, Criterion III of 10 CFR 50 requires that licensees establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.
Contrary to the above, during the licensee's re-analysis of the inadvertent safety injection event (evaluation S-2-RC-MEE-1108, dated August 23, 1996), the licensee failed to evaluate the adequacy of the existing pressurizer power-operated relief valve (PORV) accumulator check valves for suitability of application, and failed to revise the accumulator leak test procedure to meet the more stringent test requirements required by the ASME Section XI In Service Testing Program.
This is a Severity Level IV violation (Supplement 1)
PSE&G concurs with the violation (1)
The reason for the violation.
The reason for this violation was personnel error.
(2)
The corrective steps that have been taken.
a)
A review (1988 to present) of the valve maintenance and testing history was performed, and based on this review PSE&G concluded that the PORV check valves can perform their design function in the event of an inadvertent Safety Injection.
b)
The PORV accumulator check valves were satisfactorily tested on January 16, 1997.
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c)
A review determined that other ASME Section XI, Category A valves in the IST Program that were being tested in the same manner meet Code requirements.
d)
Personnel involved with the occurrence were held accountable for their actions in accordance with PSE&G's disciplinary policy.
e)
The test procedures have been revised to include a test method that includes testing at low and high differential pressure in accordance with ASME Code requirements.
(3)
The corrective steps that will be taken to avoid further violations.
No further corrective actions are being implemented.
(4)
The date when full compliance will be achieved.
Full compliance was achieved on January 16, 1997 when the accumulator check valves were satisfactorily tested.
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B.
Technical Specification 3/4.4.0.5 requires, in part, that In Service Testing of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g).
ASME Section XI, 1983 Edition, Article IWV-3000, Test Requirements, Subsection IWV-3400 requires exercise and full stroke time testing of category A and B valves to the position required to fulfill their safety function.
Contrary to the above, as of December 15, 1996, the licensee had not included safety injection valves SJ4 and SJ5 in the Section XI In Service Testing Program for exercise and full stroke time testing.
Valves SJ4 and SJ5 are category B valves that are required to close to terminate SI flow as part of the steam generator tube rupture accident mitigation actions.
This is a Severity Level IV violation (Supplement 1)
PSE&G concurs with the violation (1)
The reason for the violation.
The reason for the violation has been attributed to inadequate communication between the Emergency Operating Procedure (EOP) group and the Inservice Test (IST) reviewers in determining valves manipulated in the EOPs that were required to be included in the IST Program.
(2)
The corrective steps that have been taken.
a)
The Salem EOPs were reviewed to identify if there were other potential IST non-compliances.
Twelve additional valves were identified as not being tested in the IST program in the direction contained in the EOPs.
b)
As a result of these issues and other recently identified IST issues, a plan was developed and implemented to ensure that the Unit 2 IST Program is adequate.
The Unit 2 IST Program was found to be adequate c)
Stroke time tests for the Unit 2 valves identified in the EOP review as not being tested (Corrective Action 2(a))
have been performed.
(3)
The corrective steps that will be taken to avoid further violations.
a)
The revised surveillance test for the valves identified in corrective action 2(a) will be performed prior to Unit 1 entering the mode when the valve is required to be operable.
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b)
The Operations Department Emergency/Abnormal Operating Procedure Program procedure, SC.OP-AP.ZZ-0113, will be revised to include IST notification of proposed changes.
This will be completed by May 5, 1997.
(4)
The date when full compliance will be achieved.
Stroke time testing in the closed direction for the valves identified in the inspection report and the EOP review has been incorporated into the IST program.
Implementing procedures have been completed and the valves tested; therefore, compliance was achieved by March 12, 1997.
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C.
Technical Specification 3.9.4 for Salem Unit 2 requires that during core alterations or movement of irradiated fuel within the containment, the containment building penetrations providing direct access from the containment atmosphere to the outside atmosphere shall be either (1) closed by an isolation valve, blind flange, or manual valve, or (2) be capable of being closed by an operable automatic containment isolation valve.
Contrary to the above, the licensee moved irradiated fuel within the containment building from December 17, 1996 to December 19, 1996, with service water penetrations providing a direct access from the containment atmosphere to the outside atmosphere, with the manual service water isolation valves (24SW269 and 24SW63) inside the containment penetration open and the service water isolation valve (24SW223) outside containment removed with no blind flange or manual valve installed in its place and no operable automatic containment isolation valve in the access path.
This is a Severity Level IV violation (Supplement 1)
PSE&G concurs with the violation (1)
The reason for the violation.
The causes of this occurrence are attributed to inadequate implementation of outage scheduling and risk management requirements, and inadequate review of work in progress.
Upon investigation into this event, it was determined that other Containment breaches had occurred earlier as a result of improper activities associated with this work.
The work was authorized (and planned to be complete) prior to establishing Containment closure; however, the work was delayed due to scheduling and planning conflicts.
The effect of the schedule delays was not reviewed for impact based on existing plant conditions.
(2)
The corrective steps that have been taken.
a)
Fuel handling activities in the Containment were suspended and the Gate Valve in the fuel transfer canal was closed upon determination that a breach of Containment had occurred.
Containment closure was reestablished using alternate isolation points.
b)
All work activity in the plant was stopped, and the work groups were directed to obtain authorization from the Work Control Center prior to resumption of work.
c)
The following actions were taken prior to resuming fuel movement at Unit 2:
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Procedure S2.0P-ST.CAN-0007 "Refueling Operations -
Containment Closure" was revised to incorporate posting of the penetration areas to restrict work in penetration areas during Core Alterations, and to provide clarification of criteria for determining that a system is intact.
In addition, the procedure was enhanced to specify that a review of work in progress shall be performed.
Procedure S2.0P-ST.CAN-0007 was re-performed (following revision) to verify containment closure.
The equipment out of service tags possibly affecting Containment closure were reviewed in detail to ensure there was no further impact on Containment closure.
Shiftly meetings between the Senior Nuclear Shift Supervisor and the work group supervisors were initiated.
The meetings provide a mechanism to review planned work for the shift to ensure that current plant conditions support performance of the work.
d)
The Shutdown Safety Plan System Score Card has been added to the key plant schedules to heighten personnel awareness to equipment required to be available for plant safety.
e)
The details of this event were required reading for Operations, Outage Management and Planning and Scheduling personnel.
f)
Outage Management and Planning and Scheduling personnel reviewed the requirements of the Salem Outage Risk Management Program subsequent to this incident.
(3)
The corrective steps that will be taken to avoid further violations.
a)
All approved outage work will be re-reviewed against the requirements of the Shutdown Safety Plan prior to Unit 2 entering Mode 4.
b)
A continuing training program will be developed and implemented for Outage Management and Planning and Scheduling personnel concerning the Outage Risk Managem~nt Program.
The program will be developed prior to June 1, 1997.
c)
The Unit 1 Containment closure procedure (Sl.OP-ST.CAN-0007) will be revised prior to its next use to address the changes noted above for the Unit 2 procedure.
(4)
The date when full compliance will be achieved.
Full compliance was achieved on December 19, 1996 when the Senior Nuclear Shift Supervisor suspended fuel movement.
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e REF:
LR-N97178 STATE OF NEW JERSEY SS.
COUNTY OF SALEM Louis F. Storz, being duly sworn according to law deposes and says:
I am Senior 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, Units 1 and 2, are true to the best of my knowledge.
My Commission expires on KIMBERL V JO BROWN NOTARY PUBLIC OF NEW JERSEY My Commission E~pires April 21, 1998