ML18100A822

Forwards Response to Violation & Deviations Noted in Insp Repts 50-272/93-82 & 50-311/93-82.Corrective Actions: Personnel Involved in Incident Counseled on Need to Comply W/Written Procedures

ML18100A822
Person / Time
Site:	Salem
Issue date:	01/06/1994
From:	Hagan J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N93208, NUDOCS 9401240332
Download: ML18100A822 (9)

See also: IR 05000272/1993082

Text

Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hanr::ocks

Bridge, NJ 08038 609-339-1200

Vice President

-NuClear Operations

JANo a 1sgrf. NLR-N93208

United States Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION

AND NOTICE OF DEVIATION

SALEM GENERATING

STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 On December 7, 1993, Public Service Electric and Gas Company (PSE&G) received NRC Inspection

Report Nos. 50-272/93-82

and

for the Electrical

Distribution

System Functional

Inspection (EDSFI) conducted

from August 16 to September

3, 1993. PSE&G hereby responds to the Notice of Violation

transmitted

as* Appendix A of this inspection

report (Attachment

1) and the Notice of Deviation

transmitted

as Appendix B of this inspection

report (Attachment

2). If you have any questions

regarding

this transmittal, please do not hesitate to contact us. Attachments

(2)

940106 ,, *.. 05000272 PDR ADOCK PDR G Jo l !f 0l l' '\'

• ** Document Control Desk NLR-N93208

2 C Mr. T. T. Martin, Administrator

-Region I U. S. Nuclear Regulatory

Commission

475 Allendale

Road Kin'g of Prussia, PA 19406 Mr. J. c. stone, Licensing

Project Manager U. s. Nuclear Regulatory

Commission

One White Flint North 11555 Rockville

Pike Rockville, MD 20852 Mr. c. Marschall (S09) USNRC Senior Resident Inspector

Mr. K. Tosch, Manager, IV NJ Department

Protection

Division of Environmental

Quality .Bureau of Nuclear Engineering

CN 415 Trenton, NJ 08625 JAN 0 6 1993

• * Attachment

1 RESPONSE TO NOTICE OF VIOLATION

SALEM GENERATING

STATION UNIT NOS. 1 AND 2 DOCKET NOS.

AND 50-311 As a result of the inspection

conducted

from August 16 through September

3, 1993, and in accordance

with the "General .statement

of Policy and Procedure

for NRC Enforcement

Action," 10 CFR Part 2, Appendix c, (Enforcement

Policy) (1993) the following

violation

was identified:

Unit 1 Technical

Specification

6.8.1 requires that written procedures

shall be implemented

for surveillance

and test activities

of safety-related

equipment.

Salem Station Maintenance

Procedure

SC.MD-ST.125-0003(Q), Rev. 4, "Quarterly

Inspection

and Preventive

Maintenance

of Units 1, 2 and 3 125 Volt Station Batteries," requires, as a.prerequisite

for conducting

the test, that the battery should not have had an equalizing

charge completed

less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to taking as-found measurements, which include individual

cell terminal voltage. Salem Station Maintenance

Procedure

SC.MD-PT.ZZ-0013(Q), Rev. o, "Inservice*single

Cell Battery Charger," requires the cell to remain on float charge 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to proceeding

with completing

the post-charge

data collection, which includes individual

cell terminal voltage. Contrary to the above, on August 19, 1993, written surveillance

procedures

for safety-related

batteries

were not implemented (followed)

in that, while conducting

the above quarterly

inspection

procedure

on the Unit 1 "C" 125 Volt battery, individual

cell terminal voltage measurements

for cell 47 were completed

without waiting for the battery to be on float charge for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. RESPONSE PSE&G does not dispute this violation.

The reason for this violation

was personnel

error. Personnel

involved in reporting

the status of lC 125 VDC battery cell 47's post equalize charging to the Senior Nuclear Shift Supervisor/Nuclear

Shift Supervisor

were not in compliance

with prerequisite

2.6 of Quarterly

Battery Procedure

SC.MD-ST.125-0003(Q), Rev. 4 and Step 5.6.7 of Single Cell Battery Charging Procedure

SC.MD-PT.ZZ-0013(Q), Rev. o, since cell 4-7's voltage was measured shortly after the single cell charger was disconnected

and the battery was returned to float voltage. Technical

Specification (TS) requirement

4.8.2.3.2.b.1

for the lC 125 VDC battery was then applied and the battery was declared "operable" since cell 47's voltage met the TS requirement

of " ** cell voltage is greater than. or equal to 2.13 VDC under float charge .** ". Procedure

NLR-N93208

1

requires that, as a prerequisite, the battery should not have completed

an equalizing

charge less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to taking as-found measurements, and procedure

requires the cell to remain on float charge for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before proceeding

with post charge data collection.

CORRECTIVE

ACTIONS TAKEN Personnel

involved with this incident have been counseled

on the necessity

to comply with written procedures.

CORRECTIVE

ACTIONS TAKEN TO PREVENT RECURRENCE

Maintenance

and Technical

Department

personnel

will be reminded of the need to comply with procedures.

This discussion

will include a review of the above violation

by January 15, 1.994. PSE&G has reviewed battery charging procedures

to clarify when a cell is "fully charged" and when voltage measurements

can be taken to verify battery operability.

These procedure

changes are described

below. Procedure "Battery Equalize Charge," was revised on October 16, 1993, to add the requirement

to verify that all battery*cells

are "fully charged" in accordance

with the battery manufacturer

specifications.

That is, during equalize charging, the cell's electrolyte

specific gravities

are measured and temperature

corrected

to 77°F in addition to recording

cell voltages.

If temperature

corrected

specific gravities

are equal to or greater than 1.215 and no cell voltage is more than 0.05 VDC below the average cell voltage, the battery is considered "fully charged" and battery loads can be reconnected

after placing battery on float charge. Procedure

SC.MD-PT.ZZ-0013(Q)

will be revised to include that specific gravity measurements

be greater than or equal to 1.215 to prove cell is "fully charged".

After cell equalizing

is complete, cell float voltage measurements

will be taken until stable to verify TS voltage compliance.

-Revision to procedure

SC.MD-PT.ZZ-0013(Q)

will be completed

by January 31, 1994. PSE&G is also developing

a License Change Request (LCR) to revise TS 3.8.2.3, 11 125 Volt D.C. Distribution," for both Salem Unitp 1 and 2, to provide for better monitoring

of the 125 VDC batteries.

The LCR will include new battery acceptance

criteria, corresponding

allowed outage times, and additional

surveillance

requirements

as recommended

by NUREG-1431, "Standard

Technical

Specifications

-Westinghouse

NLR-N93208

2

Plants." The revised TS will provide more specific battery cell parameters

to establish

overall battery acceptability, provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 31 days to ensure cell values are within category A, B, and/or C values as defined in NUREG-1431, and allow adequate time for the electrolyte

to degas (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> minimum) so that specific gravity level corrections

can be performed.

• PSE&G is in full compliance.

Additional

actions to prevent recurrence

will be completed

by January 31, 1994. NLR-N93208

3

• . Attachment

2 RESPONSE TO NOTICE OF DEVIATION

SALEM GENERATING

STATION UNIT NOS. 1 AND 2 DOCKET NOS .. 50-272 AND 50-311 Deviation

1 *Salem Updated Final Safety Analysis Report (UFSAR), Section 9.5.4, states that each 30,000 gallon fuel oil storage tank can supply one diesel with enough oil to run it for seven days at full load. Contrary to the above, on September

3, 1993, there was no evidence that each 3.0, ooo gallon fuel oil storage tank can supply one diesel with enough fuel oil to.run it for seven days at full load. The actual duration for which one storage tank can supply one diesel to run at full. load is unknown since the licensee's

analysis took credit for the fuel available

in the nonsafety-related

(20,000 barrel) tank to comply with the seven day

• This deviation

applies to Units 1 and 2 . Response The seismic category I emergency

diesel generator (EDG) fuel oil storage and transfer system consists of two 30,000 gallon EDG fuel oil storage tanks, two transfer pumps, three 550 gallon day tanks and associated

piping to supply fuel oil to the three EDGs for each unit. * Normal make-up to the * EDG fuel oil storage tanks* is supplied by the on-site 20,000 barrel fuel oil storage tank. The 20,000 barrel fuel oil storage tank piping and valves are classified

as non-safety

related up to the individual

EOG fuel oil storage tank fill line isolation

valves.

in the process qf issuing a detailed calculation

to determine

the worst case consumption.rate

of the EDGs. Based on this consumption

rate calculation, *psE&G has determined

that each 30,000 gallon EDG fuel oil storage tank does not provide a sufficient

amount of fuel oil for one EDG to operate for seven days at full load. At the present technical

specification

minimum level of 20,000 gallons, each EDG fuel oil storage tank would provide for approximately

four days of continuous

operation

of a one EDG at full load. Current administrative

controls requires that a minimum c;>f 27200 gallons of fuel oil be maintained

in the EDG fuel oil storage tanks. At this fuel oil level, each EDG fuel oil storage tank will provide for approximately

5 'days of continuous

operation

of a one EDG at full load. NLR-N93208

Corrective

Actions PSE&G is performing

a calculation

to determine

the usable volume of fuel oil in the EDG fuel oil storage tanks. Based on this calculation, PSE&G will submit a technical

specification

change to increase the minimum level of fuel oil required in the EDG fuel oil storage tanks. At this new level, each EDG fuel oil storage tank should provide for approximately

5 days of continuous

operation

of one EDG at full load. An evaluation

to assess alternate

means (e.g., fuel oil delivery by tanker or barge, fuel oil from Hope Creek, etc.) to replenish

the EDG fuel oil storage tanks is being prepared.

This evaluation

will identify.any

procedure

changes necessary

to implement

the replenishment

of the EDG fuel oil storage tanks. PSE&G is also preparing

a revision to* the UFSAR to clarify the amount of time that each EDG fuet oil storage tank can provide for continuous

operation

of one EDG at full load. This UFSAR change will also include a description

of the necessary

actions to replenish*the

EDG fuel oil storage tanks. This UFSAR change is being evaluated

under 10 CFR 50.59 and if it is determined

that this change involves an Unreviewed

Safety Question (USQ), PSE&G will submit these changes for NRC approval in accordance

with 10 CFR 50.90. The above actions will be completed

by June 30, 1994. Deviation

2 Salem UFSAR, Appendix 3A, states the Unit 2 complies with Regulatory

Guide 1.117 -Tornado Design Classification, which specifies

that the emergency

diesel generator (EDG) *must be protected

against tornadoes.

This regulatory

guide further states that, "protection

of designated

structures, systems, and components

may generally

be accomplished

by designing

of protective

barriers to preclude the tornado damage *** If protective

barriers are not installed, the structures, systems, and components

themselves

should be designed to withstand

the effects of the tornado including

strikes." NLR-N93208

5

Contrary-to

the above, on September

3, 1993, there was no evidence that the Unit 2 EDG combustion

air exhaust pipe and intake louvers were protected

against tornado generated

missiles, or were capable of withstanding

the effects of these missiles.

• This deviation

applies to Unit 2 only. Response PSE&G does not despute this deviation.

Engineering

Evaluation

No. S-C-ZZ-MEE-0789

was issued on October 19, 1993, to assess the Unit 2 EDG combustion

air intake and exhaust piping. In this evaluation, PSE&G calculated

the frec;iuency

of a significant

tornado event at the Sa!gm site during the next 18 months to be less than 1.7 x 10 per year. The frequency

of a tornado generated

missile damaging the air i!!gake and air exhaust_IJiping

for a single E.DG are 9.58 x 10 /year and 1.45 x 10

respectively.

These frequencies

are conservatively

calculated

for tornadoes

encompassing

wind speeds of 73 mph to 300 mph. A historical

review of reported tornadoes

from 1952 to 1992 in a 50 mile radius of the Salem site showed that only two tornadoes

greater than 158 mph have occurred.

Although the air intake and exhaust structures

• for the Unit 2 EDGs do not fully protect against the effects of tornado generated

missiles, PSE&G considers

the Unit 2 EDGs to be able to perform their intended design functions

until the corrective

actions can be implemented.

This determination

was based on: NLR-N93208

1. The major components

of the combustion

air piping are located inside a building (Auxiliary

Building)

designed for tornado wind and missile loads. 2 .. In the event that a tornado does occur and the air intake and/or exhaust piping outside the Auxiliary

Building)

is damaged, there are mitigating

actions which PSE&G can take to assure EDG availability.

3. The probability

of a tornado missile striking any of the exhaust _IJipes or intake louver_s is extremely

low at 2.4 x 10 /year. 6

Actions Structural

modifications

will be implemented

for Salem Unit 2 during the eighth refueling

outage (currently

scheduled

to begin in September

of 1994) to protect -the EDG intake and exhaust structures

against tornado generated

missiles .

7