ML20090E098
| ML20090E098 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/26/1992 |
| From: | Swanson R Public Service Enterprise Group |
| To: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NLR-N92022, NUDOCS 9203090255 | |
| Download: ML20090E098 (10) | |
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Pubhc Service Electnc tiad Gas Company P 0, Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department (T D.
'E O NLR-N92022 United States Nuclear Regulatory Commission Mgion I 475 Allendale Road King of Prussia, PA 19406 Attention:
Wayne Hodges
Dear Mr. Hodges:
RESPONSE TO ISSUES IDENTIFIED DURING THE ELECTRICAL DISTRIBUTION SYSTEM FUNCTIONAL INSPECTION HOPE CREEK GENERATING STATION OPERATING LICENSE NO. NPF-57 The Nuclear Regulatory Commission conducted an inspection of the electrical distribution system at the Hope Creek Generating Station from January 13 to February 14, 1992.
During this inspection the NRC raised several unresolved items that were identified to Public Service Electric and Gas (PSE&G) at the February 14, 1992 exit meeting.
Per Mr.
L.
Cheung's request, PSE&G is providing the attached additional information in regard to these unresolved items and potential violations.
If you have any questic m regarding this information, please contact us.
Sincerely,
^-
ichard N.
Swanson General Manager -
Engineering and Plant Betterment Attachment i
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9203090255 920226 PDR ADOCK 05000354
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e Mr. Wayne Hodges_-
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- NLR-N92022-C Mr.
T. Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission 475 Allendule Road King of Prussia, PA 19406 Mr.
S.
Dombok,_ Licensing Project Manager - Hope Creek U.
S.
Nuclear Regulatory Commission MS 14 E-23 Washington, DC 20555 Mr. T. Johnson (SO9).
Senior Resident Inspector Mr.
L.
Cheung, Region I, EDSFI Team Leader U.
S. Nuclear = Regulatory Commission 475 Allendale Road King of-Prussia, PA 19406 l
Mr. Kent'Tosch, Chief I
New Jersey Lupartment of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 l
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-Attachment to NLR-N92022 This attachment provides additional information in regards to items identified during the Hope Creek Electrical Distribution System Functional Inspection (EDSFI).
POTENTIAL VIOLATION 1 l
NRC:
--The acceptance criteria for the 125 VDC and 250 VDC Class 1E Batteries 18-month surveillance test allows for the acceptance of voltages down_to 105 VOC and 210 VDC.
These acceptance levels may not be sufficient to provide the loads with-the necessary. voltage levels needed-for operation.
PSE&G1 Surveillance-test results indicate that voltage levels at the battery terminals are above the values currently used in the voltage drap calculation. PSE&G will review the existing 4
voltage drop calculation and the minimum acceptable voltage 5
to components.
The intention of this review will be to
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demonstrate that existing battery test acceptance criteria do in. fact meet the voltage requirements of the associated components.
PSE&G will notify the NRC by March 13, 1992 with i
the results of this review.
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POTENTIAL VIOLATION 2 f
HRC:
During-pre-surveillance maintenance.of the Emergency Diesel Generators (EDG),_the EDGs do not appear capable of
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responding to an automatic start signal.
During this period of time the EDG should be declared inoperable and an LCO should be entered.
Hope Creek does not declare the EDGs inoperable.
PSE&G:
Hope Creek personnel have contacted eleven plants to ascertain their practice concerning LCO entry _for EDG 1 pre-surveillance maintenance ana other similar testing._ Of these eleven plants, ten employed the same. practice as Hope Creek for these cases.
PSE&G believes that our practice of l
not declaring.the EDGo inoperable while' performing the required testing,_with operators _ attending the equipment, is i
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consistent with normal industry practices.
The following information provides a summary of the actions taken to address this concern.
In accordance with vendor recommended practices, Hope Creek performs pre-surveillance maintenance (i.e., barring over of the engine with air to remove accumulated moisture from the I
cylinders prior to running the diesel).
Hope Creek considers that performance of the pre-surveillance maintenance is important since it minimizes the potential for severely damaging an EDG prior to all planned runs.
Hope Creek will enhance our procedures and training to highlight the importance of expediting the pre-surveillance maintenance of the EDG.
Specifically, the intent of following steps will be added as a requirement for the pre-surveillance maintenance.
1.
Before proceeding with the pre-surveillance maintenance notify the SNSS/NSS/NCO that these steps will prevent the EDG from starting.
2.
The NCO shall record the start time and completion time of these steps in the NCO Narrative Log.
3.
While. performing these steps, at least one qualified operator shall remain in the room on elevation 102 with the affected EDG prepared to restore the original configuration if called upon by the control room operators.
4.
These steps should be performed as expeditiously as possible.
The objective is to perform these steps within approximately 15 minutes.
S.
If a delay is encountered while performing these steps, the SNSS/NSS/NCO shall be advised so they can direct the restoration of the o'iginal configuration until the reason for the delay is resolved.
This will be covered in our operator requalification training for both our licensed operatcrs (RO and SRO) and non-licensed operators (Equipment Operators).
In addition to the above, PSE&G does control the scheduling of work activities, such as surveillance testing of EDGs, to minimize instances when a surveillance test is performed on 3
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an EDG while redundant safety equipment in other channels are inoperable.
Specifically, pare. graph 5.5.1.a of NC.NA-AP.ZZ-0009(Q), " Work Control Process" states:'
" Maintenance shall be scheduled r.o as not to jeopardize the safety of the reactor.
Scheduling section
-personnel shall consider the possible safety consequences of concurrent or sequential maintenance testing or operations activities."
This practice will be emphasized with the Hope Creek scheduling section with regards to the-EDG pre-surveillance maintenance.
PSE&G considers that the procedures presently in place, the procedure enhancements discussed above, and its resultant training adequately addresses this concern.
PSE&G is also evaluating the need-for a technical specification change in regard to diesel generator testing.
POTENTIAL DEVIATION 1 NRC:
Emergency Diesel Generator (EDG) Day Tank Pump start level:
Section 9.5.4.2.1 of the Hope Creek Ganerating Station (HCGS)
Updated Final Safety Analysis Report (UFSAR) states that the fuel oil storage system is sized in accordance with the requirements of Regulatory Guide (RG) 1.137.
RG 1.137 references ANSI Standard 195 - 1976 which effectively requires 66 minutes of fuel supply from the transfer pump start level.
The current transfer pump start level provides for 47 minutes of operation.
't PSE&G:
PSE&G Engineering will recalculate the transfer pump start setpoint to meet the ANSI-requirement for 66 minutes of operation from transfer pump start.
These changes will be implemented via a design change package no later-than the end of the fourth refueling outage which is currently scheduled for September of 1992.
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' POTENTIAL DEVIATION Z NRC:
Emergency Diesel Generator Load Sequencer Testing:
Section 1.8.1.9 of the Hope Creek Generating Station (HCGS) Updated Final Safety Analysis Report (UFSAR) states that HCGS complies with Regulatory Guide 1.9 and IEEE 387-1977.
Paragraph 6.6 of IEEE 387 states that verification of continued capability of the EDG shoulo be demonstrated.
The 18-month surveillance test procedure does not demonstrate the sequence of loads initiated by the load sequencer.
PSE&G:
HCGS will revise procedures HC.OP-ST.KJ-005, 6,
7, 8:
" Integrated Emergency Diesel Generator 1/ABCD/-G-400 Test".
This revision will provide the steps necessary to demonstrate that dynamic loading complies with UFSAR section 1.8.1.9.
This will be completed before the next scheduled 18-month surveillance-test.
UNRESOLVED JSSUE 1 NRC:
During the slow transfer scheme the possibility exists that a
" flip-flop" condition may occur when loading the 4.16 KV buses with Loss of Coolant Accider.t (LOCA) loads.
The voltage level of the bus could dip below the setpoint of the undervoltage relay and could only. recover to 1% above the pick up point of the relay before a transfer of the bus would be initiated.
PSE&G:
The original degraded grid / load flow computer study was performed using Bechtel proprietary software no longer PSE&G will remodel=the existing degraded
- available to-PSE&G.
grid / load flow computer study to more precisely ascertain recovery voltages-for starting transients.
A review of our infeed breaker, emergency diesel generator breaker, diesel start, and emergency load sequencer logic will be performed
-to determine if the postulated " flip-flop" scenario _is valid.
The completion date of these activities is currently scheduled for May 29, 1992.
At this time a determination will be made if any corrective actions are warranted and/or
-if the compensatory measures taken to date I
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may-be removed. -These compensatory measures (closure of the auto close block push button for the closed breaker and night orders to clarify operator actions) were previously discussed with the NRC inspection team and agreed upon during a February 13, 1992 meeting.
UNRESOLVED ISSUE.2 LBCL The cable leads from emergency diesel generators (EDG)
"A",
"B",
and "C" appear to exhibit some deformation.
The lead for "B"
EDG has been determined to have the greatest potential deformation by visual inspection.
EEE1Q1 PSE&G Engineering has issued an evaluation concluding that based on the components involved, there is very little chance that the leads are deformed.
The cable lead of the "B"
EDG will be inspected during the March 1992 outage.
Acceptance criteria to evaluate the integrity of the cable insulation will be developed prior to the inspection.
Based upon the findings of the "B" EDG cable inspection, the need for an action plan and schedule will be assessed for "A" and "C"
EDGs.
UNRESOLVED ISSUE 3 NRCL Testing of the Emergency Diesel Generators (EDG) does not include KVAR loading.
PSE&G:
PSE&G will start loading the EDGs to a power factor of 0.85 at full load (i.e. include KVAR loading) during the surveillance testing starting April 1992.
The existing diesel generator load calculation will be revised to add exact VAR loading requirements.
Since it is expected that the calculation will result in a power factor in the 0.85 to 0.90 range, use of a 0.85 power factor in the surveillance testing is conservative.
Revision of the diesel generator load calculation will be complete by July 30, 1992.
Based upon the results of the load calculation revision, the surveillance test may be revised to reflect actual KVAR loading.
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UNRESOLVED ISSUE 4' NRCi Addition of new emergency diesel generator (EDG) fuel oil to the EDG fuel oil storage tanks before all Technical Specification test results are available and reviewed.
ESE&G:
Hope Creek Technical Specification 4.8.1.1.2.f.2 & 3 allows for one and two weeks,- respectively to obtain results of fuel oil analysis testing.
Hope Creek intends to add the fuel oil to our EDG fuel oil storage tanks after we have the results of these tests showing that the oil meets the specifications.
PSE&G is currently in the process of evaluating the best method to-implement this requirement.
After this evaluation is complete, the process will ce administratively controlled via procedures.
UNRESOLVED-ISSUE 5 NRC:
During the 1986 Preoperational Testing for the Emergency Diesel Generator (EDG), PTP-BB-3(Part A), several acceptance criteria were not met and no documentation could be provided to determine if this situation had been corrected.
PSE&G:
Hope Creek will evaluate the 22 exceptions listed in the EDG preoperational test and take appropriate corrective actions.
PSE&G will complete this evaluation by September 30,-1992, at which time, the evaluation results will be available for NRC review.
UNRESOLVED ISSUE 6 HEC 1 Perform testing to demonstrate acceptability of computer analysis for the-fast bus transfer scheme.
PSE&G:
PSE&G Engineering is developing a data gathering test to lua implemented at Hope Creek's next refueling outage for the-purpose of verifying the results of our computer model with actual test data.
This test will include voltages, phase
angle, and time during transfers 1along with a determination of the exact loading of the electrical distribution system prior to the transfer.
This data will be collated and fed back through the existing computer model to verify similar results to those obtained by the test in order to confirm the validity of the model.
This comparison will be complete within 2 months of the completion of the refueling outage.
UNRESOLVED ISSyf;_2 NRC:
Several undervoltage relays on the 125 VDC system are not being adequately tested or maintained.
PSE&G:
These relays are identified on current vendor drawings.
An evaluation will be performed to determine if current maintenance performed (i.e.,
cleaning and inspecting) should be enhanced or if the identified relays should be removed.
If it is determined that increased maintenance of these relays is warranted, this increased maintenance will be initiated by the end of'1992.
If it is determined that these relays are to be removed, a design change will be initiated by June of 1992.
The design change will then be evaluated in accordance vith Nuclear Department procedures to determine the safety and operability significance of this change and will be appropriately scheduled for implementation.
UNRESOLVED ISSUE q NPC:
No evidence exists that EDG maintenance matches (Colt Industries) SIL C.4 for shaft currents in accordance with the manufacturers recommendations PSE&G:
PSE&G is presently revising procedure !!C.MD.KJ-005 to o
incorporate Colt Ir.dustries SIL C.4.
The testing of the shaft / bearing insulation will be fully implemented by the end of-the fourth refueling outage beginning-in September of 1992.
4' LWRESOLVED ISSUE 9 NRC:
The emergency diesel generator (EDG) exhaust piping from the crankcase to the atmosphere is not seismically qualified.
PSE&G:
PSE&G is currently evaluating the specific issues that need to be addressed to resolve this concern.
A schedule for completion of acti'.ities necessary to resolve this concern will-be developed by March 31, 1992.
UNRESOLVED ISSUE 10 NRC:
Revise the Degraded Grid Voltage Study, Calculation E15.1 to ensure proper voltage levels are available at the 480 V buses.-
r PSE&G:
PSE&G will revise the degraded grid study by May 29, 1992 as indicated'in-response to unresolved issue 1.
Based upon the results of the revision to degraded grid study, other calculations may require reconfirmation or revision.
If it is determined that these calculations do in fact need to be reconfirmed or revised, PSE&G will establish by June 30, 1992, a schedule for completion of this activity.
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