ML20101M837
| ML20101M837 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/08/1984 |
| From: | Liden E Public Service Enterprise Group |
| To: | Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20101M835 | List: |
| References | |
| NUDOCS 8501030272 | |
| Download: ML20101M837 (4) | |
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Ad Pubbc Service Floctne and Gas Ccmpany PO Rc,236 Hancccu Brutge Ne.v.lerse,0/1038 Nuclear Department November 8, 1984 Regional Administrator, Region 1 U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
Mr. Harry B.
Kister, Chief Projects Branch No. 2 Division of Project and Resident Programs Gentlemen:-
NRC COMBINED INSPECTION 50-272/84-32 AND 50-311/H4-32 SALEM GENERATING STATION UNITS NO. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 In the course of the referenced inspection, conducted on August 14 - September 24, 1984, two violations were identified involving failure to tollow radiation protection procedures tor posting high-radiation areas and failure to follow surveillance testing procedures for turbine stop and governor valves.
PSe&G's response to these violations is as follows:
NOTJCR OF VIOLATION ltem A Technical' Specification 6.8.1 requires that written procedures for. surveillance and test activities of safety related equipment be implemented.
Surveillance Procedures SP(0)4.3.4.2, Turbine Overspeed Protection, requires that turbine Valve Tests be performed in accordance with Operating Instruction (OI) III-1.3.3, Turbine valve Tests, by depressing and releasing the "close TV" pushbuttons associated with the Stop-Governor Valve assemblies to cycle the valves.
SP(0)4.3.4.2 also indicates that the procedure shall be
-considered satisfactory.if all valves operato as required by 01-11-1.3.3.
In addition, Administrative Procedure No. 12, Technical Specification Surveillance Program requires that a
work order be initiated per AP 9, Control of Station Maintenance, when a survoillance test does not satisfy the dCCeptance Criteria.
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Mr.
H.
H.
Kister' 11/8/84 Contrary to the Above:
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.Nos.+22 and 23.stop and governor valve assemblies did not open when the "close TV" pushbutton was released during testing on September 4, 1984 The SP(0)4.3.4.3 test was documented as satisfactory, and no. work order was initiated to correct this 3
deficiency.
' RESPONSE TO ITEM A:
In. regard to this violation, the following facts are presented.
The proposed notice of violation labeled as A is written'-in two parts, our response will address these os separate items.
1)
"So(0) 4.3.4.2 indicates that the procedure shall be considered satisfactory if all valves operate as tequired
,by-01 III-1.3.3."
The valves fulfilled the procedural requirements by closing on demand.
The fact that two of the valves required operator intervention in order to reopen does not constitute an unsatisfactory surveillance.
The intent of the surveillance is clearly i
'seen Dy looking at the basis as. stated in the Technical Specifications:
"This specification is provided to ensure that the turbine overspeed protection instrumentation and the turDine speed control valves are' operable and will protect the, turbine from excessive overspeed.
Protection trom turbine excessive overspeed is required since excessive overspeed of the turbine could generate potentially damaging missiles which could impact and damage safety-related components,' equipment or structures."
It is-therefore concluded that the valves must close on demand without operator assistance.
Hogever, the re-opening of the valves does_not, in any way, add to or detract trom the safety significance of the components as
. stated in the Technical Specifications.
As such, the opening of the valves can be~ performed with operator assistance.
2)
"In addition, Administrative Procedure No. 12, Technical Specification Surveillance Program, requires that a work order be initiated as per AP-9, Control of Station Maintenance, when a surveillance test does-not satisfy
.the acceptance criteria." -Since the test results were considered satisfactory, no work order was required to be
_ generated.
The problem experienced during the perform-ance of this surveillance has been seen betore.
The
')
-valves are normally inspected and repaired, if necessary, f during the course or a unit outage.
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Mr.
H.
B.
Kister 11/8/84 Work orders have been written to inspect each of the turbine stop valves curing the current outage on Unit No.
2.
The purpose of the Turbine Valve Test procedure will be claritied to more specifically indicate that valve closure on demand fultills the acceptance criteria for the' test.
Item B Technical Specification 6.11, Radiation Protection Program requires that procedures shall be adhered to for all operations involving personnel radiation exposure.
Administrative Procedure (AP) 24, Radiological Protection Program, Section 6.1.2 requires that personnel comply with all radiation warning signs, instructions and other postings.
m Contrary to the Above:
~
On September 6, 1984, personnel failed to comply with a radiological posting in that they remained in an area on the 84 foot elevation of the Unit 1 Auxiliary building to perform work.
The area was posted as a high radiation area -
no loitering and the Extended Radiation Exposure Permit used by the individuals did not specitically authorize work for these conditions.
RE'8PONSE TO ITEM B 1.
CORRECTIVE S2;PS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The work in question on September 6, 1984, was terminated when Radiation Protection'was notified of the occurrence.
The area in question has been reposted to more clearly domarcate the high radiation area.
A special caution was added to the Extended Radiation Exposure Permit (EREP) in question to more clearly state that work in high radiation areas was not permitted.
The personnel involved have been instructed on the procedures for working on an l
EREP in general and Specifically the EREP that they were using.
With regard to the specific occurrence, all exposures as measured by self-reading dosimeters tor the workers who remained in the area were less than 10mR.
The entire incident was investigated by Radiatio'n Protection Department staff and by the Radiation Assessor - Radiation Protection Services.
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Mr.
H.
B.
Kister 11/8/84 2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Reinforcement of the necessity and importance of adequate briefings to personnel reGarding the meaning and content of the Radiation Exposure Permits and Extended Radiation Exposure Permits will be made.
These instructions shall also be reviewed with contractor foremen, shop stewards, and supervisory personnel.
3.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
PSE&G will be in full compliance by January 31, 1985.
Sincerely,
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(1)
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E.
A Liden
%. Manger - Nuclear Licensing and Regulation C
Mr. Donald C.
c'i s,he r Licensing Project Manager Mr. James Linville Senior Resident Inspector l
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