ML18106A573

From kanterella
Jump to navigation Jump to search
Responds to NRC 980402 Ltr Re Violations Noted in Insp Repts 50-272/98-01 & 50-311/98-01.Corrective Actions:New Service Water Reliability Program Manager Has Been Assigned
ML18106A573
Person / Time
Site: Salem  PSEG icon.png
Issue date: 04/29/1998
From: Storz L
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-272-98-01, 50-272-98-1, 50-311-98-01, 50-311-98-1, LR-N980197, NUDOCS 9805040460
Download: ML18106A573 (14)
v • d • e


Text

P~o11c Service E:ec1c:c and Gas Cc<Toany Louis F. Storz Pu:::ii1c Service Electric and Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-5700 Senior Vice Pres.de;,t - N*. . . c 1ear Opeat.or::s APR 2 9 1998 LR-N980197 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Combined Inspection Report No. 50-272/98-01 and 50-311/98-01 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G) on April 2, 1998. Within the scope of this report, three violations of NRC requirements were cited. The violations involved; 1) a violation of 10 CFR 50, Appendix B, Criterion XVI, 2) a violation of Technical Specification 6.8.1.and 3) a violation of Technical Specification 3.8.1.1.b.2.

I am cognizant that over the last few months the number of events caused by human error may be increasing. From a human performance point of view, my expectations relative to problem identification and procedure adherence remain unchanged. My expectations include proper implementation of PSE&G's disciplinary policy in accordance with the Management Associated Results Company (MARC) principles.

This positive approach to discipline is primarily focused on improving personnel performance through a step wise discipline approach leading up to and including termination of employment .

Notwithstanding these expectations, I am also cognizant that based on industry experience, organizational, and programmatic contributions to human error must be examined for corrective actions to ensure that factors creating error (precursors) and error likely situations are identified and corrected. People are fallible. Even the best \ . \

performers make mistakes. Open communications and positive reinforcement of desired behaviors are the most effective tool in achieving excellence in human performance. PSE&G's corrective action program examines these factors. The depth of our examination is determined by a cause analysis. For example, the violation cited *\

9805040460 980429 PDR ADOCK 05000272 G PDR IZ\. Printed on

~ Recycled Paper

APR 2 9 1998

. Document Control Desk LR.:N980197 against 10 CFR 50 Appendix B Criterion XVI was determined to be a significance level 1 condition report (examination).

The Nuclear Business Unit will continue to search for ways to improve its processes and programs to ensure safe operation. I will also continue to emphasize personal accountability, while searching forways to improve personnel performance utilizing recognized industry good practice experience.

In accordance with 10 CFR 2.201, PSE&G is submitting its response to the cited violations in Attachment II to this letter. Attachment I contains the Notice of Violation as cited by the NRC. Should there be any questions regarding this submittal, please contact us.

Sincerely, Attachments (2)

C Mr. Hubert J. Miller, Administrator - Region I U. S. Nuclear Regulatory Con:imission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville; MD 20852 Mr. S. Morris - 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 85-4933

ATTACHMENT I

  • APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Docket Salem Nuclear Generating Station Nos:50-272 50-311 Units 1 and 2 License Nos: DPR-70 DPR-75 During an NRC inspection conducted on February 2, 1998 through March 15, 1998, three violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for.NRG Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part that conditions adverse to quality are promptly identified and corrected.

Contrary to the above, from January 25, 1998 until February 25, 1998, a condition adverse to quality existed at Salem without initiating aggressive action to identify and correct the causes. Degraded service water strainers and lack of service water reliability program oversight resulted in accelerated rates of biofouling in service water cooled heat exchangers. Grass from the Delaware River clogged the inlet tube sheet of a safety related chiller condenser and contributed to the chiller's inoperability. During this period, several other instances of biofouling in service water cooled heat exchangers were observed and a missing strainer filter media was identified without initiating an action request. However, the licensee failed to take prompt action to determine the causes.

This is a Severity Level IV Violation (Supplement I).

B. Technical Specification (TS) 6.8.1 requires, in part, that written procedures be implemented for the safety-related equipment recommended in Appendix "A" of Regulatory Guide (RG) 1.33, Revision 2, February 1978. RG 1.33 recommends that equipment control of safety-related systems, including emergency diesel generators, be covered by written procedures.

1. Contrary to the above, on February 19 and 22, 1998, the licensee did not properly implement maintenance procedure SC.MD-ST.DG-0003, "Eighteen Month Diesel Engine Inspection Maintenance." Specifically, the technician did not sign off step 5.17.4 to verify the 2A emergency

ATTACHMENT I

  • diesel generator (EOG) petcocks were closed before turning the engine over to operations; in step 5.17.9.M, technicians performed an initial check that the 2A EOG fuel pump racks were unlatched and did not sign this off, and did not perform the required independent verification of the racks.
2. Contrary to the above, on February 20, 1998, the licensee did not properly implement operations procedure SC.OP-PT.DG-0001, "Diesel Generator Manual Barring." Specifically, nuclear equipment operators did not verify that 2A EOG petcocks were properly closed before starting the engine.

This is a Severity Level IV Violation (Supplement I).

C. Salem Unit 1 Technical Specifications (TS), Section 3.8.1.1.b.2, requires, in part, that three separate and independent diesel generators with two fuel transfer pumps be operable in Modes 1-4.

Contrary to the above, from 8:35 a.m. on February 18, 1998, until 2:31 a.m. on February 20, 1998, Salem Unit 1 operated in Mode 4 with one operable fuel transfer pump.

This is a Severity Level IV Violation (Supplement I) .

ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 PSE&G RESPONSE TO VIOLATION A PSE&G does not dispute this violation (1) The reason for the violation.

The reason for this violation is stated in root cause number 3 below, and includes inadequate management oversight of the GL 89-13 commitments, and untimely implementation of the SW biofouling DIP test program.

On February 25, 1998, the 22 Chiller tripped with a "high pressure" alarm illuminated.

Troubleshooting activities, to determine the cause of the condition, were initiated by the Salem maintenance and system engineering. When the 22 Chiller condenser was opened, the inlet tube sheet was found to be partially covered by a thin layer of river grass. In response to this finding, PSE&G initiated a systematic evaluation of other heat exchangers cooled by service water. During these inspections, detritus loading was observed in the 21 Charging Pump Gear Oil and Lube Oil Coolers. As a result of these self-identified indications, coupled with increases in other secondary temperatures, PSE&G initiated a level 1 Condition Report (CR), and suspended start-up activities.

The level 1 root cause investigation revealed three apparent root causes for the grass intrusion into the service water (SW) system. These root causes were identified as follows:

1. Two missing strainer filter media discs were identified on 22 service water strainer.

The 22 service water pump was identified as having significant in-service hours during periods of high river detritus levels. This resulted in the admission of the grass into the service water system.

2. Excessive filter basket - wear ring clearance was identified on 21 service water strainer. This increased clearance allows river water to bypass the filter basket resulting in admission of grass into the service water system
3. Insufficient programmatic controls were in place to address high detritus levels or proactively identify strainer bypassing incidents.

1

  • ATTACHMENT II
  • RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 Following the completion of the level 1 CR, additional investigation revealed that improper installation (over torquing) of the service water retaining rings was the most likely cause of root cause number 1. Although, the installation of the service water retaining rings was performed in accordance with the vendor technical manual, PSE&G established a methodical inspection program to inspect all of the service water strainers. This inspection delayed the Unit 2 start up for approximately 7 days.

As result of Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment," PSE&G established a program to address the requirements of the generic letter. This program included testing of safety related heat exchangers, and temperature and pressure trending of other components (i.e.; safety related pump lube oil coolers, SW pump motor coolers, and diesel generator jacket water and lube oil coolers). Although PSE&G implemented all its GL 89-13 commitments, the trending program was inadvertently and temporarily discontinued after the startup of Unit 2 in August 1997. Procedure NC.NA-AP.ZZ-0039, Rev. 0, "Service Water Reliability Program," specifies that Specialty Engineering isresponsible for the implementation of the program, and that a program manager is responsible for oversight, control, and technical adequacy of the program. However, as a result of the recent Engineering reorganization, the Specialty Engineering group was eliminated and no* program manager was assigned to ensure proper program implementation.

In addition to GL 89-13 commitments, PSE&G voluntarily established a SW biofouling DIP test program in January 1998. This program was based on industry experience for monitoring of macro biological fouling. However, this program was not fully implemented at the time of this event.

(2)

  • The corrective steps that have been taken.
1. A new service water reliability program manager has been assigned.
2. Procedural enhancements have been incorporated into procedure SC.MD-PM.SW~

0003(0) "Service Water Auto Strainer Adjustment, Inspection, Repair and Replacement" to prevent damaging the filter media. This revision was issued on April 8, 1998.

2

ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION.

INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197

3. The trending responsibilities associated with the pump lube oil coolers have been re-assigned to the Salem In-Service Testing program manager.
4. A new Abnormal Operating Procedure SC.OP-AB.ZZ-0003, Rev. 0, "Component Biofouling," was implemented. This procedure specifies operator actions to be taken for excessive river grass loading.
5. While SC.OP-AB.ZZ-0003, Rev. 0 is in effect, a normal task of the system manager is to perform periodic strainer effluent monitoring to detect strainer bypassing by monitoring for excessive particles larger than filter media diameter
6. A systematic evaluation of the Salem unit 2 service water system was conducted by maintenance, operations and engineering personnel to determine the extent of bio-fouling within the system. Heat exchanger degradation was evaluated by differential pressure testing and/or boroscopic examination. Heat exchangers determined to be degraded were opened and cleaned, and none were found inoperable.
7. Asimilar scope of inspections was performed for the unit 1 service water components, with similar results as 6 above.

(3) The corrective steps that will be taken to avoid further violations.

1. A review of the service water intake structure will be performed for system and component optimization.
2. A process to establish communiqitions between System Engineer and Operations will be established to discuss status of service water heat exchangers, while procedure SC.OP-AB.ZZ-0003 is in effect.

(4) The date when full compliance will be achieved.*

PSE&G achieved full compliance when the new service water reliability program manager was assigned and trending responsibilities were initiated .

.3

ATTACHMENT II

  • RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 PSE&G RESPONSE TO VIOLATION 81 PSE&G concurs with the violation (1) The reason for the violation.

The reason for the violation is attributed to inattention to detail by maintenance personnel during performance of SC.MD-ST.DG-0003, "Eighteen Month Diesel Engine Inspection Maintenance."

On February 19, 1998, maintenance technicians completed maintenance activities on the 2A Emergency Diesel Generator (EOG) in accordance with SC.MD-ST.DG-0003.

Step 5.17.4 of SC.MD-ST.DG-0003 requires that the petcocks be closed in preparation for returning the diesel to operation. The maintenance technician inappropriately continued on to the next step without signing off step 5.17.4 as required.

Similarly, inattention to detail by maintenance personnel resulted in inappropriately signing off step 5.17.9.M of SC.MD-ST.DG-0003 procedure. Step 5.17.9.M requires that cylinder fuel pump racks be checked unlatched (not locked out) and independently verified (IV). A review of the procedure showed that the IV line was signed off, but not the initial check. Additionally, the maintenance supervisor signed the procedure without recognizing that the step 5.17.9.M initial check was not signed off.

Interviews with the technicians revealed that the verification of the fuel pumps being unlatched was completed but not signed off. The independent verification was not performed. Inattention to detail led to 1) placing the initials in the wrong place, and 2) failing to recognize that an independent verification was needed. Sign offs for these activities are adjacent to each other within the procedure.

(2) The corrective steps that have been taken.

1. This event was reviewed for lessons learned with maintenance personnel during the first quarter Maintenance lnservice Training.
2. Personnel involved in this event have been held accountable in accordance with
  • PSE&G's procedures and policies:

4

ATTACHMENT II

  • RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 (3) The corrective steps that will be taken to avoid further violations.
1. Procedure SC.MD-ST.DG-0003, "Eighteen Month Diesel Engine Inspection Maintenance." will be revised to clearly indicate the need to sign off for the initial fuel pump verification and for the performance of the independent verification. This revision will be completed by July 1, 1998.

(4) The date when full compliance will be achieved.

PSE&G achieved compliance on February 20, 1998, when step 5.17.4 was signed and the* independent verification was completed prior to running 2A EOG successfully .

  • 5

ATTACHMENT II

  • RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 PSE&G RESPONSE TO VIOLATION 82 PSE&G concurs with the violation (1) The reason for the violation.

The reason for the violation is attributed to personnel error (failure to demonstrate a questioning attitude).

On February 20, 1998 at approximately 0300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> and following a pre-evolution brief, personnel from Operations, Maintenance and Engineering began preparations for a 15 minute unloaded test run of the 2A EOG. Procedure SC.OP-PT.DG-0001 (Q), "Diesel Generator Manual Barring," was used by the Nuclear Equipment Operator (NEO) assigned to support the run. The procedure required that the-petcocks be opened prior to barring the EOG. The NEO became confused by the reverse threading of the petcock stems (i.e., stems rise when closed) and closed versus opened the petcocks.

He then rotated the engine several times using a pneumatic wrench. No mist was observed from any engine cylinder (the petcocks were closed at the time) and no abnormal noises were heard. The NEO repositioned the petcocks to open versus their required position of closed. The petcocks were then incorrectly independently verified in this position by another NEO.

At 0359, an attempt was made to start 2A EOG which failed on "Engine Overcrank."

Personnel present in the room with the EOG heard loud noises from engine cylinders and observed some fire plumes from several cylinders indicating that the cylinder petcocks were open instead of closed. Subsequent investigation revealed that all 18

  • cylinder petcocks were open.

(2). The corrective steps that have been taken.

1. On February 20, 1998 at 0456 the cylinder petcocks were closed and a satisfactory test run was commenced.
2. The appropriate supervisor(s) reviewed this event With the responsible individuals .
  • 3. Lessons learned from this event were rolled out to Operations personnel.

6

ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197

4. The diesel generator barring procedure was reviewed with Nuclear Equipment Operators. The training included the operation of the diesel generator's petcocks.

(3) The corrective steps that will be taken to avoid further violations.

1. The tra*ining department will evaluate the need to enhance operator training in the use of QV&V to promote a questioning attitude in a structured fashion.

(4) The date when full compliance will be achieved.

PSE&G achieved compliance on February 20, 1998, wheh the 2A diesel generator cylinder petcocks were closed and the diesel generator test run commenced.

7

ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 PSE&G RESPONSE TO VIOLATION C PSE&G concurs with the violation (1) The reason for the violation.

The apparent cause of this event was the failure of planning and maintenance personnel to verify that the corred replacer:nent switch was identified, staged, and installed for the 12 Fuel Oil Transfer Pump (FOTP) Off-Auto-Manual selector switch.

Additionally, the specified post-maintenance retest was not adequate because the installation of an incorrect switch was not identified. The post-maintenance retest also was not adequate in that it did n*ot verify the operability of the FOTP following maintenance.

On January 30, 1998, maintenance personnel replaced a degraded control switch for the 12 Diesel Fuel Oil Transfer Pump (DFOTP).

On February 18, 1998, at approximately 08:35, Unit 1 entered Mode 4. Technical Specifications (TS) 3.8.1.1.b.2 requires two Diesel Fuel Oil Transfer Pumps (DFOTP).

to be operable in Mode 4.

On February 19, 1998, while performing the 31-day surveillance run on the DFOTP, the pump would not start in automatic control when the Fuel Oil Day Tank dropped to the appropriate level. Troubleshooting revealed that the wrong control switch was installed on January 30, which prevented the automatic start of the DFOTP, rendering it a

inoperable. Therefore, entering Mode 4 on February 18 was violation of Technical Specifications.

The 12 DFOTP was restored to operable status on February 20, 1998 at approximately 02:31 a.m.

(2) The corrective steps that have been taken.

1. A field inspection was performed to verify the configuration of the switches for the 11, 21, and 22 FOTPs. The Off-Auto-Manual switch for the 21 FOTP was found to 8

ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 have an incorrect part number. However, this switch had been modified, and the pump was operable based on surveillance test performance since the switch was installed.

2. The correct Off-Auto-Manual switch (part number 91 OPGC513) was installed via Work Order 98021907 4, and the operability of the 12 FOTP was verified.
3. The requirement to review drawings to verify that parts being staged are correct has been reinforced with planning personnel.
4. Planning personnel have also been reminded of ,their responsibility to specify the, appropriate testing requirements on work orders in accordance with; NC.NA-AP.ZZ-0050(Q), "Station Testing Program", NC.NA-TS.ZZ-0050(0), "Station Testing Program Matrix".
5. Operations Department personnel received a rollout discussion to emphasize the importance of reviewing completed work against planned work to ensure that adequate retests are performed. This was accomplished on March 19, 1998, via a night order book entry.
6. The correct Off-Auto-Manual switch was installed for the 21 FOTP via Work Order 980227082 on April 7, 1998.
7. All personnel involved have been held accountable in accordance with PSE&G's procedures and policies.
3) The corrective steps that will be taken to avoid further violations.
1. An inspection will be performed of a random sampling of thirty switches in safety related applications to determine if any other instances of incorrect switch configuration exist. The results of this sampling will serve as the basis for further inspection.
2. As a part of second quarter In-service Day training, Maintenance Department personnel will receive a rollout discussion on the importance of (1) ensuring that
  • replacement parts are correct by comparing them to the Bill Of Materials and by 9

. *l ATTACHMENT II RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-01 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980197 comparison to the removed parts, (2) verifying the correct contact switch configuration on new contacts, (3) performing modifications to replacement parts only in accordance with approved procedures.

(4) The date when full compliance will be achieved.

PSE&G achieved compliance when the 12 DFOTP was restored to operable on February 20, 1998.

10

Retrieved from "https://kanterella.com/w/index.php?title=ML18106A573&oldid=2407409"