ML20091N492
| ML20091N492 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/27/1984 |
| From: | Uderitz R Public Service Enterprise Group |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20091N489 | List: |
| References | |
| NUDOCS 8406120336 | |
| Download: ML20091N492 (3) | |
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~O g psyc Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department April 27, 1984 Regional' Administrator, Region I U.
S.
Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
Mr. Richard W.
Starostecki, Director Division of Project and Resident Programs Gentlemen NRC COMBINED INSPECTION 50-272/84-08 AND 50-311/84-08 SALEM GENERATING STATION NO. 1 AND 2 UNITS DOCKET NOS. 50-272 AND 50-311 During-the subject inspection, conducted on February 7 through March 6, 1984, a violation was identified relating to f ailure to follow an Operating Instruction.
The following is our response to'the Notice of Violation appended to your letter dated March 26, 1984.
ITEM OF VIOLATION:
Technical Specification 6.8.1 requires that written procedures be maintained covering applicable procedures recommended in Appendix'"A" of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix "A" of Regulatory Guide 1.33 requires written procedures for the startup of the shutdown cooling system.
Contrary to the above, at 12:45 p.m. on February 8, 1484, Operating Instruction II.6.3.2, Initiating RHR, was not main-tained, in that the hot leg isolation: valve, 2PH26,.was opened rather than'21SJ49 and 22SJ49, the discharge valves to the cold legs, as required by-step 5.16 of the operating instruction.
REPLY TO ITEM OF VIOLATION:
On February 6, 1984, Performance Surveillance Procedure 4.4.7.2.1 was -initiated to check for leakage from the Reactor Coolant System-(RCS) Pressure Isolation valves.
During the per-formance of this surveillance activity, it was found that 22SJ56
" Safety Injection Discharge to #22 RCS. Cold Leg Check Valve" was leaking. -As a result, Action-Statement 3.4.7.2c was entered and
-testing was continued in order to identify any other check kDhhfol
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M r'. Richard W.
Starostecki 4/27/84 valves which may have been leaking.
RCS pressure and tempera-ture were reduced to 1200 psig and 500'P respectively.
An attempt to flush the seat of 22SJ56 by injecting water through the valve using a Safety Injection Pump was performed.
On February 7, 1984, Surveillance Procedure 4.4.7.2.1 was again performed.
The results indicated that leakage still existed on 22SJ56.
Due to the action statement requirement to be in Cold Shutdown within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after the discovery of the leakage, a plant cooldown was commenced and Mode 5 was entered at 1948 hours0.0225 days <br />0.541 hours <br />0.00322 weeks <br />7.41214e-4 months <br />.
Due to the limited testing of the other Reactor Coolant System Pressure Isolation valves, and the suspicion that some of these might also be leaking; a method of testing these check valves with the unit in Mode 5 was developed.
This method of testing involved the closure of 21SJ49 and 22SJ49 (RHR Discharge to Cold Legs), and the opening of 2RM26 (RHR Discharge to Hot Legs).
It also required some modifications to SP(0)4.4.7.2.1.
On February 8, 1984, a temporary "On-the-Spot-Change" was made to the Surveillance Procedure.
The change to the Surveillance Procedure required that the Residual Heat Removal System needed to be in a Hot Leg to Hot Leg circulation mode in order to per-form the test.
It was decided by Station management that this was a preferable way to operate, as heating up and cooling down to test and fix each of the check valves in question would have caused undue stress on the system.
This decision was based on discussions which included Technical Specification limitations, cooling capability of this arrangement, residual decay heat re-moval, boron stratification considerations, and Reactor Coolant System flow characteristics.
When the testing was completed,
and the leaking Reactor Coolant System Pressure Isolation valves were identified, it was decided to leave the Residual Heat Re-moval System in the Hot Leg to Hot Leg circulation mode of operation until subsequent repairs and testing were completed.
Due to an' oversight, the required changes to the particular Operating Instruction were not made, even though the specific Surveillance Procedure had been properly changed and the con-sequences of the actions analyzed.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVEDt An "On-The-Spot Change" was subsequently made to the operating instruction for RHR (OI II.6.3.2) and a Safety Evaluation was
' performed which confirmed minimal safety significance.
An Information Directive was issued to all licensed operators reemphasizing that when methods of operation outside normal established and approved procedures are contemplated, all procedures and instructions applicable to that system or task shall be reviewed to determine if operation in the proposed manner potentially involves an unreviewed safety question or O.
Ni J 1
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s Mr'.J Richard W.
Starostecki 4/27/84 constitutes operation outside of parameters analyzed in the UFSAR or delineated in the Technical Specification.
If it is determined that'the method proposed is not within approved procedures, prior to placing _the unit in the proposed configu-ration, a procedure change and safety evaluation shall be performed.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
An - evaluation will be conducted to identify an improved mechanism for conducting 10 CPR 50.59 reviews.
DATE FOR-FULL COMPLIANCE:
-We are tiow in full compliance.
Sincerely, e
e E.
A.
Liden Manager - Nuclear Licensing and Regulation
' Attachment C
Director, Of fice' of: Inspection and Enforcement Nuclear Regulatcry Commission Washington, D.C.
.20555 Mr. Donald C.
Fischer
-Licensing Project Manager Mr. James Linville Senior Resident Inspector k
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