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| issue date = 12/01/1993 | | issue date = 12/01/1993 | ||
| title = Responds to NRC 931103 Ltr Re Violation Noted in Insp Repts 50-272/93-21 & 50-311/93-21.C/As:reviewed Circumstances Surrounding Event W/Personnel Involved & All Other Licensed Operations Personnel During Requalification Training | | title = Responds to NRC 931103 Ltr Re Violation Noted in Insp Repts 50-272/93-21 & 50-311/93-21.C/As:reviewed Circumstances Surrounding Event W/Personnel Involved & All Other Licensed Operations Personnel During Requalification Training | ||
| author name = | | author name = Hagan J | ||
| author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY | | author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY | ||
| addressee name = | | addressee name = | ||
Line 14: | Line 14: | ||
| page count = 12 | | page count = 12 | ||
}} | }} | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations DECO 11993 NLR-N93192 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen: | ||
Vice President | RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/93-21; 50-311/93-21 DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection Report 50-272/93-21; 50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical Specification Action Statement 3.3.2.1 violation was identified. | ||
-Nuclear Operations | Accordingly, in the attachment to this letter, PSE&G submits its assessment and response to the identified violation. | ||
DECO 11993 | Should you have any questions regarding this transmittal, please do not hesitate to contact us. | ||
United states Nuclear Regulatory | Sincerely, | ||
Commission | * ~D3R121A3D0414 931201 (i DCK 05000272 PI)R | ||
Document Control Desk Washington, DC 20555 Gentlemen: | ~ | ||
RESPONSE TO NRC NOTICE OF VIOLATION | Yi | ||
INSPECTION | |||
REPORT 50-272/93-21; | OEC 0 1 7993 ) | ||
50-311/93-21 | Document Control Desk 2 NLR-N93192 Attachment (1) c Mr. J. c. Stone, Licensing Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09) | ||
DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection | USNRC Senior Resident Inspector Mr. T. T. Martin, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department of Environmental Protection | ||
Report 50-272/93-21; | .Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 | ||
50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical | |||
Specification | ._ "* 1 REF: NLR-N93192 | ||
Action Statement | * STATE OF NEW JERSEY COUNTY.OF SALEM | ||
3.3.2.1 violation | )_ | ||
was identified. | ) | ||
Accordingly, in the attachment | ) | ||
to this letter, PSE&G submits its assessment | SS. | ||
and response to the identified | J. J. Hagan, being duly sworn according to law deposes and says: | ||
violation. | I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief. | ||
Should you have any questions | Subscr,bed and wo Do before me | ||
regarding | *~Qf-,_ 'da: o~ Al'* <p~ , 1993 | ||
this transmittal, please do not hesitate to contact us. | - t>*> b.g&-h_~l2J\0U1.-r~ | ||
931201 (i DCK 05000272 | 4 N tary Publ C f New Jersey KIMBERLY JO BROWN NOTARY PUBUC ~F NE~ ~~R~::e My Commission expires on My Commission Exp11es Ppra | ||
Attachment | ,J NLR-N93192 ATTACHMENT I During an NRC inspection conducted on September 5 - October 16, 1993, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix c (1992), | ||
(1) | the violation is listed below: | ||
Project Manager U.S. Nuclear Regulatory | Salem Unit 1 Technical Specification (TS) Action Statement 3.3.2.1 requires that when an Engineered Safety Feature Actuation system instrumentation channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies that when an automatic actuation logic channel for the safety injection, turbine trip and feedwater isolation function is inoperable, the inoperable channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following 30 hours. | ||
Commission | Contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection System Train B Feedwater Isolation Circuit at Salem Unit 1 failed a surveillance test, the failed channel was not subsequently restored to an operable status, and it was not until approximately 12 hours after the test failure that unit operators initiated a plant shutdown due to the | ||
One White Flint North 11555 Rockville | .- inoperable channel. This is a Severity Level IV violation (Supplement 1). | ||
Pike Rockville, MD 20852 Mr. c. s. Marschall (S09) USNRC Senior Resident Inspector | Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; an.d (3) the date when full compliance will be achieved. | ||
Mr. T. T. Martin, Administrator | : ) . | ||
-Region I U.S. Nuclear Regulatory | NLR-N93192 PSE&G RESPONSE PSE&G does not dispute. the violation ROOT CAUSE on July 11, 1993, operators were testing the Slave Relay K601 (Safety Injection circuit) in the "B" train of the Solid State Protection System (SSPS), using surveillance procedure Sl.OP-ST.SSP-0010~ During the performance of this surveillance, operations personnel stopped slave relay testing when a problem occurred in obtaining a test meter reading. Based upon an initial print review and past test circuit problems, operators believed that the problem was in the test circuit portion of the output relay. | ||
Commission | The SSPS system was not declared inoperable at this time, as the test circuit is independent of the normal SSPS function, and a work order was initiated to investigate the problem. Later on this date, .operations shift personnel were informed that the test circuit had not failed and that the surveillance results showed an SSPS circuit failure. | ||
475 Allendale | ** The SSPS (train B) was declared inoperable and the appropriate action statement was entered. Train "A" remained operable for the period such that full protection was available. | ||
Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department | The initial operability determination was based upon the Senior Reactor Operator's (SRO) technical knowledge, past experience, and review of available technical information. However, PSE&G's management review determined that the operability determination of the SSPS slave relay was not accurately diagnosed on July 11, 1993. *Additionally, PSE&G management noted that the SSPS action statement requirements, and the onset of initial troubleshooting were not commenced until the six hour action statement period had expired. Management determined that the initiation of troubleshooting was delayed inappropriately. | ||
of Environmental | It is PSE&G's management expectation that system operability and timely pursuit of problem identification and resolution must be commensurate with the potential safety significance of the issue. | ||
The root cause of this event has been attributed to lack of appropriate oversight regarding the initiation of the troubleshooting activities. The review determined that the SSPS troubleshooting activities delay was inappropriate when considering the importance of the system and the short Technical Specification action statement requirement | |||
of Environmental | * CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED | ||
Quality Bureau of Nuclear Engineering | : 1. Operations Department Management: | ||
CN 415 Trenton, NJ 08625 | Reviewed the circumstances surrounding this event with the personnel involved and all other licensed operations personnel during requalification training. | ||
._ "* 1 | Initiated SSPS surveillance procedure reviews and revision to direct attention to technical specification action statements when system performance is either deficient or operability is questionable. The procedures were revised to require that the system be declared inoperable when any deviation from the expected reading is obtained. Additionally, an Instrument & | ||
STATE OF NEW JERSEY COUNTY.OF | Control technician will be present at all times during system testing. | ||
Via the Night Order Book, issued instructions to all operating personnel regarding the appropriate action statement entry, including instruction to enter the SSPS action statement whenever abnormal readings are encountered during system tests. | |||
to law deposes and says: I am Vice President | : 2. Positive disciplinary action has been taken with the appropriate personnel. | ||
-Nuclear Operations | CORRECTIVE STEPS WHICH WILL BE TAKER TO AVOID FURTHER VIOLATIONS PSE&G management strongly re-emphasized its expectation of taking timely corrective actions, specifically when dealing with Technical Specification systems or equipment. PSE&G believes that adequate controls are now in place to address prompt and timely resolution of operability issues. | ||
of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced | DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance. | ||
letter, concerning | |||
the Salem Generating | Public Service Electric and Gas Jo~eph | ||
Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information | *company | ||
and belief. Subscr,bed | * J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations DECO 11993 NLR-N93192 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen: | ||
and wo Do before me | RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/93-21; 50-311/93-21 DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection Report 50-272/93-21; 50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical Specification Action Statement 3.3.2.1 violation was identified. | ||
'da: Al'* , 1993 -t>*> | Accordingly, in the attachment to this letter, PSE&G submits its assessment and response to the identified violation. | ||
N tary Publ | Should you have any questions regarding this transmittal, please do not hesitate to contact us. | ||
Sincerely, | |||
My Commission | |||
Exp11es Ppra | DEC 0 1 7993 Document Control Desk 2 | ||
NLR-N93192 Attachment (1) c Mr. J. c. Stone, Licensing Project Manager U.S. Nuclear Regulatory Commission one White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09) | |||
ATTACHMENT | USNRC Senior Resident Inspector Mr. T. T. Martin, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 | ||
I During an NRC inspection | |||
conducted | \I REF: NLR-N93192 | ||
on September 5 -October 16, 1993, a violation | * STATE OF NEW JERSEY COUNTY.OF SALEM | ||
of NRC requirements | ) | ||
was identified. | ) | ||
In accordance | ) | ||
with the "General Statement | SS. | ||
of Policy and Procedure | J. J. Hagan, being duly sworn according to law deposes and says: | ||
for NRC Enforcement | I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief. | ||
Actions," 10 CFR Part 2, Appendix c (1992), the violation | Subscr;bed and wo ~o before me | ||
is listed below: Salem Unit 1 Technical | <~Qi:,, , da: 0:0 00 Yp /(l.,vi , 1993 | ||
Specification (TS) Action Statement | - 1* 1 J bv1._f.z ~ 1YJ~ OU l -'; \..._ | ||
3.3.2.1 requires that when an Engineered | 4 N tary Publ C f New Jersey KIMBERLY JO BROWN My Commission expires on NOTARY PUBLIC OF NEW JERSEY | ||
Safety Feature Actuation | ~~~M~y~co=mm=-1ss~10~11E"xMpir~e'~~~pr~il*21.........,19~9~8~~~ | ||
system instrumentation | |||
channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies | . ~. | ||
that when an automatic | \I NLR-N93192 ATTACHMENT I During an NRC inspection conducted on September 5 - October 16, 1993, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), | ||
actuation | the violation is listed below: | ||
logic channel for the safety injection, turbine trip and feedwater | Salem Unit 1 Technical Specification (TS) Action statement 3.3.2.1 requires that when an Engineered Safety Feature Actuation system instrumentation channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies that when an automatic actuation logic channel for the safety injection, turbine trip and feedwater isolation function is inoperable, the inoperable channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following 30 hours. | ||
isolation | contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection System Train B Feedwater Isolation Circuit at Salem Unit 1 failed a surveillance test, the failed channel was not subsequently restored to an operable status, and it was not until approximately 12 hours after the test failure that unit operators initiated a plant shutdown due to the | ||
function is inoperable, the inoperable | * inoperable channel. This is a Severity Level IV violation (Supplement 1). | ||
channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following | Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved | ||
30 hours. Contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection | * NLR-N93192 PSE&G RESPONSE PSE&G does not dispute the violation ROOT CAUSE On July 11, 1993, operators were testing the Slave Relay K601 (Safety Injection circuit) in the "B" train of the Solid State Protection System (SSPS), using surveillance procedure Sl.OP-ST.SSP-0010. During the performance of this surveillance, operations personnel stopped slave relay testing when a problem occurred in obtaining a test meter reading. Based upon an initial print review and past test circuit problems, operators believed that the problem was in the test circuit portion of the output relay. | ||
System Train B Feedwater | The SSPS system was not declared inoperable at this time, as the test circuit is independent of the normal SSPS function, and a work order was initiated to investigate the problem. Later on this date, .operations shift personnel were informed that the test circuit had not failed and that the surveillance results showed an SSPS circuit failure. | ||
Isolation | The SSPS (train B) was declared inoperable and the appropriate | ||
Circuit at Salem Unit 1 failed a surveillance | * action statement was entered. Train "A" remained operable for the period such that full protection was available. | ||
test, the failed channel was not subsequently | The initial operability determination was based upon the Senior Reactor Operator's (SRO) technical knowledge, past experience, and review of available technical information. However, PSE&G's management review determined that the operability determination of the SSPS slave relay was not accurately diagnosed on July 11, 1993. | ||
restored to an operable status, and it was not until approximately | * Additionally, PSE&G management noted that the SSPS action statement requirements, and the onset of initial troubleshooting were not commenced until the six hour action statement period had expired. Management determined that the initiation of troubleshooting was delayed inappropriately. | ||
12 hours after the test failure that unit operators | It is PSE&G's management expectation that system operability and timely pursuit of problem identification and resolution must be commensurate with the potential safety significance of the issue. | ||
initiated | The root cause of this event has been attributed to lack of appropriate oversight regarding the initiation of the troubleshooting activities. The review determined that the SSPS troubleshooting activities delay was inappropriate when | ||
a plant shutdown due to the inoperable | * considering the importance of the system and the short Technical Specification action statement requirement . | ||
channel. This is a Severity Level IV violation (Supplement | |||
1). Pursuant to the provisions | CORRECTIVE ACTIONS TAKEN AN.D THE RESULTS ACHIEVED | ||
of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted | : 1. Operations Department Management: | ||
this Notice, a written statement | Reviewed the circumstances surrounding this event with the personnel involved and all other licensed operations personnel during requalification training. | ||
or explanation | Initiated SSPS surveillance procedure reviews and revision to direct attention to technical specification action statements when system performance is either deficient or operability is questionable. The procedures were revised to require that the system be declared inoperable when any deviation from the expected reading is obtained. Additionally, an Instrument & | ||
in reply, including: | Control technician will be present at all times during system testing. | ||
(1) the corrective | Via the Night Order Book, issued instructions to all operating personnel regarding the appropriate action statement entry, including instruction to enter the SSPS action statement whenever abnormal readings are encountered during system tests. | ||
steps which have been taken and the results achieved; | : 2. Positive disciplinary action has been taken with the appropriate personnel . | ||
(2) corrective | * CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS PSE&G management strongly re-emphasized its expectation of taking timely corrective actions, specifically when dealing with Technical Specification systems or equipment. PSE&G believes that adequate controls are now in place to address prompt and timely resolution of operability issues. | ||
steps which will be taken to avoid further violations; | DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance * | ||
an.d (3) the date when full compliance | *}} | ||
will be achieved. | |||
: ) . | |||
PSE&G RESPONSE PSE&G does not dispute. the violation | |||
ROOT CAUSE on July 11, 1993, operators | |||
were testing the Slave Relay K601 (Safety Injection | |||
circuit) in the "B" train of the Solid State Protection | |||
System (SSPS), using surveillance | |||
procedure | |||
During the performance | |||
of this surveillance, operations | |||
personnel | |||
stopped slave relay testing when a problem occurred in obtaining | |||
a test meter reading. Based upon an initial print review and past test circuit problems, operators | |||
believed that the problem was in the test circuit portion of the output relay. The SSPS system was not declared inoperable | |||
at this time, as the test circuit is independent | |||
of the normal SSPS function, and a work order was initiated | |||
to investigate | |||
the problem. Later on this date, .operations | |||
shift personnel | |||
were informed that the test circuit had not failed and that the surveillance | |||
results showed an SSPS circuit failure. The SSPS (train B) was declared inoperable | |||
and the appropriate | |||
action statement | |||
was entered. Train "A" remained operable for the period such that full protection | |||
was available. | |||
The initial operability | |||
determination | |||
was based upon the Senior Reactor Operator's (SRO) technical | |||
knowledge, past experience, and review of available | |||
technical | |||
information. | |||
However, PSE&G's management | |||
review determined | |||
that the operability | |||
determination | |||
of the SSPS slave relay was not accurately | |||
diagnosed | |||
on July 11, 1993. *Additionally, PSE&G management | |||
noted that the SSPS action statement | |||
requirements, and the onset of initial troubleshooting | |||
were not commenced | |||
until the six hour action statement | |||
period had expired. Management | |||
determined | |||
that the initiation | |||
of troubleshooting | |||
was delayed inappropriately. | |||
It is PSE&G's management | |||
expectation | |||
that system operability | |||
and timely pursuit of problem identification | |||
and resolution | |||
must be commensurate | |||
with the potential | |||
safety significance | |||
of the issue. The root cause of this event has been attributed | |||
to lack of appropriate | |||
oversight | |||
regarding | |||
the initiation | |||
of the troubleshooting | |||
activities. | |||
The review determined | |||
that the SSPS troubleshooting | |||
activities | |||
delay was inappropriate | |||
when considering | |||
the importance | |||
of the system and the short Technical | |||
Specification | |||
action statement | |||
requirement | |||
* | |||
CORRECTIVE | |||
ACTIONS TAKEN AND THE RESULTS ACHIEVED 1. Operations | |||
Department | |||
Management: | |||
Reviewed the circumstances | |||
surrounding | |||
this event with the personnel | |||
involved and all other licensed operations | |||
personnel | |||
during requalification | |||
training. | |||
Initiated | |||
SSPS surveillance | |||
procedure | |||
reviews and revision to direct attention | |||
to technical | |||
specification | |||
action statements | |||
when system performance | |||
is either deficient | |||
or operability | |||
is questionable. | |||
The procedures | |||
were revised to require that the system be declared inoperable | |||
when any deviation | |||
from the expected reading is obtained. | |||
Additionally, an Instrument | |||
will be present at all times during system testing. Via the Night Order Book, issued instructions | |||
to all operating | |||
personnel | |||
regarding | |||
the appropriate | |||
action statement | |||
entry, including | |||
instruction | |||
to enter the SSPS action statement | |||
whenever abnormal readings are encountered | |||
during system tests. 2. Positive disciplinary | |||
action has been taken with the appropriate | |||
personnel. | |||
CORRECTIVE | |||
STEPS WHICH WILL BE TAKER TO AVOID FURTHER VIOLATIONS | |||
PSE&G management | |||
strongly re-emphasized | |||
its expectation | |||
of taking timely corrective | |||
actions, specifically | |||
when dealing with Technical | |||
Specification | |||
systems or equipment. | |||
PSE&G believes that adequate controls are now in place to address prompt and timely resolution | |||
of operability | |||
issues. DATE WHEN FULL COMPLIANCE | |||
WILL BE ACHIEVED PSE&G is in full compliance. | |||
J. Hagan | |||
-Nuclear Operations | |||
DECO 11993 NLR-N93192 | |||
United States Nuclear Regulatory | |||
Commission | |||
Document Control Desk Washington, DC 20555 Gentlemen: | |||
RESPONSE TO NRC NOTICE OF VIOLATION | |||
INSPECTION | |||
REPORT 50-272/93-21; | |||
50-311/93-21 | |||
DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection | |||
Report 50-272/93-21; | |||
50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical | |||
Specification | |||
Action Statement | |||
3.3.2.1 violation | |||
was identified. | |||
Accordingly, in the attachment | |||
to this letter, PSE&G submits its assessment | |||
and response to the identified | |||
violation. | |||
Should you have any questions | |||
regarding | |||
this transmittal, please do not hesitate to contact us. Sincerely, | |||
Attachment | |||
(1) | |||
Project Manager U.S. Nuclear Regulatory | |||
Commission | |||
one White Flint North 11555 Rockville | |||
Pike Rockville, MD 20852 Mr. c. s. Marschall (S09) USNRC Senior Resident Inspector | |||
Mr. T. T. Martin, Administrator | |||
-Region I U.S. Nuclear Regulatory | |||
Commission | |||
475 Allendale | |||
Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department | |||
of Environmental | |||
Protection | |||
Division of Environmental | |||
Quality Bureau of Nuclear Engineering | |||
CN 415 Trenton, NJ 08625 | |||
STATE OF NEW JERSEY COUNTY.OF | |||
to law deposes and says: I am Vice President | |||
-Nuclear Operations | |||
of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced | |||
letter, concerning | |||
the Salem Generating | |||
Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information | |||
and belief. Subscr;bed | |||
and wo before me , da: 0:0 00 Yp /(l.,vi , 1993 -1* 1 J bv1._f.z | |||
OU l -'; \..._ N tary Publ | |||
expires on NOTARY PUBLIC OF NEW JERSEY | |||
. | |||
ATTACHMENT | |||
I During an NRC inspection | |||
conducted | |||
on September 5 -October 16, 1993, a violation | |||
of NRC requirements | |||
was identified. | |||
In accordance | |||
with the "General Statement | |||
of Policy and Procedure | |||
for NRC Enforcement | |||
Actions," 10 CFR Part 2, Appendix C (1992), the violation | |||
is listed below: Salem Unit 1 Technical | |||
Specification (TS) Action statement | |||
3.3.2.1 requires that when an Engineered | |||
Safety Feature Actuation | |||
system instrumentation | |||
channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies | |||
that when an automatic | |||
actuation | |||
logic channel for the safety injection, turbine trip and feedwater | |||
isolation | |||
function is inoperable, the inoperable | |||
channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following | |||
30 hours. contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection | |||
System Train B Feedwater | |||
Isolation | |||
Circuit at Salem Unit 1 failed a surveillance | |||
test, the failed channel was not subsequently | |||
restored to an operable status, and it was not until approximately | |||
12 hours after the test failure that unit operators | |||
initiated | |||
a plant shutdown due to the inoperable | |||
channel. This is a Severity Level IV violation (Supplement | |||
1). Pursuant to the provisions | |||
of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted | |||
this Notice, a written statement | |||
or explanation | |||
in reply, including: | |||
(1) the corrective | |||
steps which have been taken and the results achieved; | |||
(2) corrective | |||
steps which will be taken to avoid further violations; | |||
and (3) the date when full compliance | |||
will be achieved | |||
PSE&G RESPONSE PSE&G does not dispute the violation | |||
ROOT CAUSE On July 11, 1993, operators | |||
were testing the Slave Relay K601 (Safety Injection | |||
circuit) in the "B" train of the Solid State Protection | |||
System (SSPS), using surveillance | |||
procedure | |||
Sl.OP-ST.SSP-0010. | |||
During the performance | |||
of this surveillance, operations | |||
personnel | |||
stopped slave relay testing when a problem occurred in obtaining | |||
a test meter reading. Based upon an initial print review and past test circuit problems, operators | |||
believed that the problem was in the test circuit portion of the output relay. The SSPS system was not declared inoperable | |||
at this time, as the test circuit is independent | |||
of the normal SSPS function, and a work order was initiated | |||
to investigate | |||
the problem. Later on this date, .operations | |||
shift personnel | |||
were informed that the test circuit had not failed and that the surveillance | |||
results showed an SSPS circuit failure. The SSPS (train B) was declared inoperable | |||
and the appropriate | |||
action statement | |||
was entered. Train "A" remained operable for the period such that full protection | |||
was available. | |||
The initial operability | |||
determination | |||
was based upon the Senior Reactor Operator's (SRO) technical | |||
knowledge, past experience, and review of available | |||
technical | |||
information. | |||
However, PSE&G's management | |||
review determined | |||
that the operability | |||
determination | |||
of the SSPS slave relay was not accurately | |||
diagnosed | |||
on July 11, 1993. * Additionally, PSE&G management | |||
noted that the SSPS action statement | |||
requirements, and the onset of initial troubleshooting | |||
were not commenced | |||
until the six hour action statement | |||
period had expired. Management | |||
determined | |||
that the initiation | |||
of troubleshooting | |||
was delayed inappropriately. | |||
It is PSE&G's management | |||
expectation | |||
that system operability | |||
and timely pursuit of problem identification | |||
and resolution | |||
must be commensurate | |||
with the potential | |||
safety significance | |||
of the issue. The root cause of this event has been attributed | |||
to lack of appropriate | |||
oversight | |||
regarding | |||
the initiation | |||
of the troubleshooting | |||
activities. | |||
The review determined | |||
that the SSPS troubleshooting | |||
activities | |||
delay was inappropriate | |||
the importance | |||
of the system and the short Technical | |||
Specification | |||
action statement | |||
requirement . | |||
ACTIONS TAKEN AN.D THE RESULTS ACHIEVED 1. Operations | |||
Department | |||
Management: | |||
Reviewed the circumstances | |||
surrounding | |||
this event with the personnel | |||
involved and all other licensed operations | |||
personnel | |||
during requalification | |||
training. | |||
Initiated | |||
SSPS surveillance | |||
procedure | |||
reviews and revision to direct attention | |||
to technical | |||
specification | |||
action statements | |||
when system performance | |||
is either deficient | |||
or operability | |||
is questionable. | |||
The procedures | |||
were revised to require that the system be declared inoperable | |||
when any deviation | |||
from the expected reading is obtained. | |||
Additionally, an Instrument | |||
will be present at all times during system testing. Via the Night Order Book, issued instructions | |||
to all operating | |||
personnel | |||
regarding | |||
the appropriate | |||
action statement | |||
entry, including | |||
instruction | |||
to enter the SSPS action statement | |||
whenever abnormal readings are encountered | |||
during system tests. 2. Positive disciplinary | |||
action has been taken with the appropriate | |||
personnel . CORRECTIVE | |||
STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS | |||
PSE&G management | |||
strongly re-emphasized | |||
its expectation | |||
of taking timely corrective | |||
actions, specifically | |||
when dealing with Technical | |||
Specification | |||
systems or equipment. | |||
PSE&G believes that adequate controls are now in place to address prompt and timely resolution | |||
of operability | |||
issues. DATE WHEN FULL COMPLIANCE | |||
WILL BE ACHIEVED PSE&G is in full compliance | |||
* | |||
}} |
Latest revision as of 06:05, 3 February 2020
ML18100A753 | |
Person / Time | |
---|---|
Site: | Salem ![]() |
Issue date: | 12/01/1993 |
From: | Hagan J Public Service Enterprise Group |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
References | |
NLR-N93192, NUDOCS 9312130414 | |
Download: ML18100A753 (12) | |
Text
Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations DECO 11993 NLR-N93192 United states Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/93-21; 50-311/93-21 DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection Report 50-272/93-21; 50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical Specification Action Statement 3.3.2.1 violation was identified.
Accordingly, in the attachment to this letter, PSE&G submits its assessment and response to the identified violation.
Should you have any questions regarding this transmittal, please do not hesitate to contact us.
Sincerely,
- ~D3R121A3D0414 931201 (i DCK 05000272 PI)R
~
Yi
OEC 0 1 7993 )
Document Control Desk 2 NLR-N93192 Attachment (1) c Mr. J. c. Stone, Licensing Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09)
USNRC Senior Resident Inspector Mr. T. T. Martin, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department of Environmental Protection
.Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
._ "* 1 REF: NLR-N93192
- STATE OF NEW JERSEY COUNTY.OF SALEM
)_
)
)
SS.
J. J. Hagan, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscr,bed and wo Do before me
- ~Qf-,_ 'da: o~ Al'* <p~ , 1993
- t>*> b.g&-h_~l2J\0U1.-r~
4 N tary Publ C f New Jersey KIMBERLY JO BROWN NOTARY PUBUC ~F NE~ ~~R~::e My Commission expires on My Commission Exp11es Ppra
,J NLR-N93192 ATTACHMENT I During an NRC inspection conducted on September 5 - October 16, 1993, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix c (1992),
the violation is listed below:
Salem Unit 1 Technical Specification (TS) Action Statement 3.3.2.1 requires that when an Engineered Safety Feature Actuation system instrumentation channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies that when an automatic actuation logic channel for the safety injection, turbine trip and feedwater isolation function is inoperable, the inoperable channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection System Train B Feedwater Isolation Circuit at Salem Unit 1 failed a surveillance test, the failed channel was not subsequently restored to an operable status, and it was not until approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the test failure that unit operators initiated a plant shutdown due to the
.- inoperable channel. This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; an.d (3) the date when full compliance will be achieved.
- ) .
NLR-N93192 PSE&G RESPONSE PSE&G does not dispute. the violation ROOT CAUSE on July 11, 1993, operators were testing the Slave Relay K601 (Safety Injection circuit) in the "B" train of the Solid State Protection System (SSPS), using surveillance procedure Sl.OP-ST.SSP-0010~ During the performance of this surveillance, operations personnel stopped slave relay testing when a problem occurred in obtaining a test meter reading. Based upon an initial print review and past test circuit problems, operators believed that the problem was in the test circuit portion of the output relay.
The SSPS system was not declared inoperable at this time, as the test circuit is independent of the normal SSPS function, and a work order was initiated to investigate the problem. Later on this date, .operations shift personnel were informed that the test circuit had not failed and that the surveillance results showed an SSPS circuit failure.
- The SSPS (train B) was declared inoperable and the appropriate action statement was entered. Train "A" remained operable for the period such that full protection was available.
The initial operability determination was based upon the Senior Reactor Operator's (SRO) technical knowledge, past experience, and review of available technical information. However, PSE&G's management review determined that the operability determination of the SSPS slave relay was not accurately diagnosed on July 11, 1993. *Additionally, PSE&G management noted that the SSPS action statement requirements, and the onset of initial troubleshooting were not commenced until the six hour action statement period had expired. Management determined that the initiation of troubleshooting was delayed inappropriately.
It is PSE&G's management expectation that system operability and timely pursuit of problem identification and resolution must be commensurate with the potential safety significance of the issue.
The root cause of this event has been attributed to lack of appropriate oversight regarding the initiation of the troubleshooting activities. The review determined that the SSPS troubleshooting activities delay was inappropriate when considering the importance of the system and the short Technical Specification action statement requirement
- CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED
- 1. Operations Department Management:
Reviewed the circumstances surrounding this event with the personnel involved and all other licensed operations personnel during requalification training.
Initiated SSPS surveillance procedure reviews and revision to direct attention to technical specification action statements when system performance is either deficient or operability is questionable. The procedures were revised to require that the system be declared inoperable when any deviation from the expected reading is obtained. Additionally, an Instrument &
Control technician will be present at all times during system testing.
Via the Night Order Book, issued instructions to all operating personnel regarding the appropriate action statement entry, including instruction to enter the SSPS action statement whenever abnormal readings are encountered during system tests.
- 2. Positive disciplinary action has been taken with the appropriate personnel.
CORRECTIVE STEPS WHICH WILL BE TAKER TO AVOID FURTHER VIOLATIONS PSE&G management strongly re-emphasized its expectation of taking timely corrective actions, specifically when dealing with Technical Specification systems or equipment. PSE&G believes that adequate controls are now in place to address prompt and timely resolution of operability issues.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance.
Public Service Electric and Gas Jo~eph
- company
- J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations DECO 11993 NLR-N93192 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/93-21; 50-311/93-21 DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection Report 50-272/93-21; 50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical Specification Action Statement 3.3.2.1 violation was identified.
Accordingly, in the attachment to this letter, PSE&G submits its assessment and response to the identified violation.
Should you have any questions regarding this transmittal, please do not hesitate to contact us.
Sincerely,
DEC 0 1 7993 Document Control Desk 2
NLR-N93192 Attachment (1) c Mr. J. c. Stone, Licensing Project Manager U.S. Nuclear Regulatory Commission one White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. s. Marschall (S09)
USNRC Senior Resident Inspector Mr. T. T. Martin, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
\I REF: NLR-N93192
- STATE OF NEW JERSEY COUNTY.OF SALEM
)
)
)
SS.
J. J. Hagan, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscr;bed and wo ~o before me
<~Qi:,, , da: 0:0 00 Yp /(l.,vi , 1993
- 1* 1 J bv1._f.z ~ 1YJ~ OU l -'; \..._
4 N tary Publ C f New Jersey KIMBERLY JO BROWN My Commission expires on NOTARY PUBLIC OF NEW JERSEY
~~~M~y~co=mm=-1ss~10~11E"xMpir~e'~~~pr~il*21.........,19~9~8~~~
. ~.
\I NLR-N93192 ATTACHMENT I During an NRC inspection conducted on September 5 - October 16, 1993, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992),
the violation is listed below:
Salem Unit 1 Technical Specification (TS) Action statement 3.3.2.1 requires that when an Engineered Safety Feature Actuation system instrumentation channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies that when an automatic actuation logic channel for the safety injection, turbine trip and feedwater isolation function is inoperable, the inoperable channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection System Train B Feedwater Isolation Circuit at Salem Unit 1 failed a surveillance test, the failed channel was not subsequently restored to an operable status, and it was not until approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the test failure that unit operators initiated a plant shutdown due to the
- inoperable channel. This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit to this office within 30 days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved
- NLR-N93192 PSE&G RESPONSE PSE&G does not dispute the violation ROOT CAUSE On July 11, 1993, operators were testing the Slave Relay K601 (Safety Injection circuit) in the "B" train of the Solid State Protection System (SSPS), using surveillance procedure Sl.OP-ST.SSP-0010. During the performance of this surveillance, operations personnel stopped slave relay testing when a problem occurred in obtaining a test meter reading. Based upon an initial print review and past test circuit problems, operators believed that the problem was in the test circuit portion of the output relay.
The SSPS system was not declared inoperable at this time, as the test circuit is independent of the normal SSPS function, and a work order was initiated to investigate the problem. Later on this date, .operations shift personnel were informed that the test circuit had not failed and that the surveillance results showed an SSPS circuit failure.
The SSPS (train B) was declared inoperable and the appropriate
- action statement was entered. Train "A" remained operable for the period such that full protection was available.
The initial operability determination was based upon the Senior Reactor Operator's (SRO) technical knowledge, past experience, and review of available technical information. However, PSE&G's management review determined that the operability determination of the SSPS slave relay was not accurately diagnosed on July 11, 1993.
- Additionally, PSE&G management noted that the SSPS action statement requirements, and the onset of initial troubleshooting were not commenced until the six hour action statement period had expired. Management determined that the initiation of troubleshooting was delayed inappropriately.
It is PSE&G's management expectation that system operability and timely pursuit of problem identification and resolution must be commensurate with the potential safety significance of the issue.
The root cause of this event has been attributed to lack of appropriate oversight regarding the initiation of the troubleshooting activities. The review determined that the SSPS troubleshooting activities delay was inappropriate when
- considering the importance of the system and the short Technical Specification action statement requirement .
CORRECTIVE ACTIONS TAKEN AN.D THE RESULTS ACHIEVED
- 1. Operations Department Management:
Reviewed the circumstances surrounding this event with the personnel involved and all other licensed operations personnel during requalification training.
Initiated SSPS surveillance procedure reviews and revision to direct attention to technical specification action statements when system performance is either deficient or operability is questionable. The procedures were revised to require that the system be declared inoperable when any deviation from the expected reading is obtained. Additionally, an Instrument &
Control technician will be present at all times during system testing.
Via the Night Order Book, issued instructions to all operating personnel regarding the appropriate action statement entry, including instruction to enter the SSPS action statement whenever abnormal readings are encountered during system tests.
- 2. Positive disciplinary action has been taken with the appropriate personnel .
- CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS PSE&G management strongly re-emphasized its expectation of taking timely corrective actions, specifically when dealing with Technical Specification systems or equipment. PSE&G believes that adequate controls are now in place to address prompt and timely resolution of operability issues.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G is in full compliance *