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See also: [[followed by::IR 05000272/1993021]]


=Text=
=Text=
{{#Wiki_filter:Joseph J. Hagan Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200  
{{#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 * NLR-N93192  
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 Yi PI)R .'*** . ......._ Sincerely,  
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
. -Document Control Desk NLR-N93192  
 
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) 2 c Mr. J. c. Stone, Licensing  
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.
Protection .Division  
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 OEC 0 1 7993 ) * * * 
Reviewed the circumstances surrounding this event with the personnel involved and all other licensed operations personnel during requalification training.
._ "* 1 * * * REF: NLR-N93192  
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.
SALEM )_ ) SS. ) J. J. Hagan, being duly sworn according  
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 4 Cf New Jersey My Commission
Should you have any questions regarding this transmittal, please do not hesitate to contact us.
expires on KIMBERLY JO BROWN NOTARY PUBUC  
Sincerely,
My Commission  
 
Exp11es Ppra
DEC 0 1 7993 Document Control Desk 2
.-NLR-N93192  
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. ,J * * * 
: ) . * ** * 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  
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.  
------------------------* * * 
' .. *  
J. Hagan Public Service Electric and Gas *company 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,
' .. * * * Document Control Desk NLR-N93192  
Attachment  
(1) 2 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 DEC 0 1 7993 
' ' . \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 before me , da: 0:0 00 Yp /(l.,vi , 1993 -1* 1 J bv1._f.z  
OU l -'; \..._ N tary Publ 4 Cf New Jersey KIMBERLY JO BROWN My Commission  
expires on NOTARY PUBLIC OF NEW JERSEY
. \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 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 * 
. '. * * * 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  
*
}}

Latest revision as of 05:05, 3 February 2020

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
ML18100A753
Person / Time
Site: Salem  PSEG icon.png
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)
v • d • e


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

)_

)

)

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

)

)

)

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

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 *

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