ML18100A822

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

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

Text

Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hanr::ocks Bridge, NJ 08038 609-339-1200 Vice President - NuClear Operations JANo a 1sgrf.

NLR-N93208 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 On December 7, 1993, Public Service Electric and Gas Company (PSE&G) received NRC Inspection Report Nos. 50-272/93-82 and 50-~11/93-82 for the Electrical Distribution System Functional Inspection (EDSFI) conducted from August 16 to September 3, 1993.

PSE&G hereby responds to the Notice of Violation transmitted as*

Appendix A of this inspection report (Attachment 1) and the Notice of Deviation transmitted as Appendix B of this inspection report (Attachment 2).

If you have any questions regarding this transmittal, please do not hesitate to contact us.

Attachments (2)

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~ 05000272 PDR ADOCK PDR G

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Document Control Desk NLR-N93208 2

C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road Kin'g of Prussia, PA 19406 Mr. J. c. stone, Licensing Project Manager U. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. Marschall (S09)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of~Environmental Protection Division of Environmental Quality

.Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 JAN 0 6 1993

RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS.

50~212 AND 50-311 As a result of the inspection conducted from August 16 through September 3, 1993, and in accordance with the "General.statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix c, (Enforcement Policy) (1993) the following violation was identified:

Unit 1 Technical Specification 6.8.1 requires that written procedures shall be implemented for surveillance and test activities of safety-related equipment.

Salem Station Maintenance Procedure SC.MD-ST.125-0003(Q), Rev. 4, "Quarterly Inspection and Preventive Maintenance of Units 1, 2 and 3 125 Volt Station Batteries," requires, as a.prerequisite for conducting the test, that the battery should not have had an equalizing charge completed less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to taking as-found measurements, which include individual cell terminal voltage.

Salem Station Maintenance Procedure SC.MD-PT.ZZ-0013(Q), Rev. o, "Inservice*single Cell Battery Charger," requires the cell to remain on float charge 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to proceeding with completing the post-charge data collection, which includes individual cell terminal voltage.

Contrary to the above, on August 19, 1993, written surveillance procedures for safety-related batteries were not implemented (followed) in that, while conducting the above quarterly inspection procedure on the Unit 1 "C" 125 Volt battery, individual cell terminal voltage measurements for cell 47 were completed without waiting for the battery to be on float charge for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

RESPONSE

PSE&G does not dispute this violation.

The reason for this violation was personnel error.

Personnel involved in reporting the status of lC 125 VDC battery cell 47's post equalize charging to the Senior Nuclear Shift Supervisor/Nuclear Shift Supervisor were not in compliance with prerequisite 2.6 of Quarterly Battery Procedure SC.MD-ST.125-0003(Q), Rev. 4 and Step 5.6.7 of Single Cell Battery Charging Procedure SC.MD-PT.ZZ-0013(Q), Rev. o, since cell 4-7's voltage was measured shortly after the single cell charger was disconnected and the battery was returned to float voltage.

Technical Specification (TS) requirement 4.8.2.3.2.b.1 for the lC 125 VDC battery was then applied and the battery was declared "operable" since cell 47's voltage met the TS requirement of " ** cell voltage is greater than. or equal to 2.13 VDC under float charge.** ".

Procedure NLR-N93208 1

SC~MD-ST.125-0003(Q) requires that, as a prerequisite, the battery should not have completed an equalizing charge less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to taking as-found measurements, and procedure SC.MD-PT.zz~oo13(Q) requires the cell to remain on float charge for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before proceeding with post charge data collection.

CORRECTIVE ACTIONS TAKEN Personnel involved with this incident have been counseled on the necessity to comply with written procedures.

CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE Maintenance and Technical Department personnel will be reminded of the need to comply with procedures.

This discussion will include a review of the above violation by January 15, 1.994.

PSE&G has reviewed battery charging procedures to clarify when a cell is "fully charged" and when voltage measurements can be taken to verify battery operability.

These procedure changes are described below.

Procedure SC~MD-CM.ZZ-0009(Q), "Battery Equalize Charge," was revised on October 16, 1993, to add the requirement to verify that all battery*cells are "fully charged" in accordance with the battery manufacturer specifications.

That is, during equalize charging, the cell's electrolyte specific gravities are measured and temperature corrected to 77°F in addition to recording cell voltages.

If temperature corrected specific gravities are equal to or greater than 1.215 and no cell voltage is more than 0.05 VDC below the average cell voltage, the battery is considered "fully charged" and battery loads can be reconnected after placing battery on float charge.

Procedure SC.MD-PT.ZZ-0013(Q) will be revised to include that specific gravity measurements be greater than or equal to 1.215 to prove cell is "fully charged".

After cell equalizing is complete, cell float voltage measurements will be taken until stable to verify TS voltage compliance. - Revision to procedure SC.MD-PT.ZZ-0013(Q) will be completed by January 31, 1994.

PSE&G is also developing a License Change Request (LCR) to revise TS 3.8.2.3, 11125 Volt D.C. Distribution," for both Salem Unitp 1 and 2, to provide for better monitoring of the 125 VDC batteries.

The LCR will include new battery acceptance criteria, corresponding allowed outage times, and additional surveillance requirements as recommended by NUREG-1431, "Standard Technical Specifications - Westinghouse NLR-N93208 2

Plants."

The revised TS will provide more specific battery cell parameters to establish overall battery acceptability, provide 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 31 days to ensure cell values are within category A, B, and/or C values as defined in NUREG-1431, and allow adequate time for the electrolyte to degas (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> minimum) so that specific gravity level corrections can be performed.

PSE&G is in full compliance.

Additional actions to prevent recurrence will be completed by January 31, 1994.

NLR-N93208 3

. Attachment 2 RESPONSE TO NOTICE OF DEVIATION SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS.. 50-272 AND 50-311 Deviation 1

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

Contrary to the above, on September 3, 1993, there was no evidence that each 3.0, ooo gallon fuel oil storage tank can supply one diesel with enough fuel oil to.run it for seven days at full load.

The actual duration for which one storage tank can supply one diesel to run at full. load is unknown since the licensee's analysis took credit for the fuel available in the nonsafety-related (20,000 barrel) tank to comply with the seven day commitment~

This deviation applies to Units 1 and 2.

Response

The seismic category I emergency diesel generator (EDG) fuel oil storage and transfer system consists of two 30,000 gallon EDG fuel oil storage tanks, two transfer pumps, three 550 gallon day tanks and associated piping to supply fuel oil to the three EDGs for each unit.

• Normal make-up to the

• EDG fuel oil storage tanks* is supplied by the on-site 20,000 barrel fuel oil storage tank.

The 20,000 barrel fuel oil storage tank piping and valves are classified as non-safety related up to the individual EOG fuel oil storage tank fill line isolation valves.

PSE&G~is in the process qf issuing a detailed calculation to determine the worst case consumption.rate of the EDGs.

Based on this consumption rate calculation, *psE&G has determined that each 30,000 gallon EDG fuel oil storage tank does not provide a sufficient amount of fuel oil for one EDG to operate for seven days at full load.

At the present technical specification minimum level of 20,000 gallons, each EDG fuel oil storage tank would provide for approximately four days of continuous operation of a one EDG at full load.

Current administrative controls requires that a minimum c;>f 27200 gallons of fuel oil be maintained in the EDG fuel oil storage tanks.

At this fuel oil level, each EDG fuel oil storage tank will provide for approximately 5

'days of continuous operation of a one EDG at full load.

NLR-N93208

Corrective Actions PSE&G is performing a calculation to determine the usable volume of fuel oil in the EDG fuel oil storage tanks.

Based on this calculation, PSE&G will submit a technical specification change to increase the minimum level of fuel oil required in the EDG fuel oil storage tanks.

At this new level, each EDG fuel oil storage tank should provide for approximately 5 days of continuous operation of one EDG at full load.

An evaluation to assess alternate means (e.g., fuel oil delivery by tanker or barge, fuel oil from Hope Creek, etc.)

to replenish the EDG fuel oil storage tanks is being prepared.

This evaluation will identify.any procedure changes necessary to implement the replenishment of the EDG fuel oil storage tanks.

PSE&G is also preparing a revision to* the UFSAR to clarify the amount of time that each EDG fuet oil storage tank can provide for continuous operation of one EDG at full load.

This UFSAR change will also include a description of the necessary actions to replenish*the EDG fuel oil storage tanks.

This UFSAR change is being evaluated under 10 CFR 50.59 and if it is determined that this change involves an Unreviewed Safety Question (USQ), PSE&G will submit these changes for NRC approval in accordance with 10 CFR 50.90.

The above actions will be completed by June 30, 1994.

Deviation 2 Salem UFSAR, Appendix 3A, states the Unit 2 complies with Regulatory Guide 1.117 - Tornado Design Classification, which specifies that the emergency diesel generator (EDG)

• must be protected against tornadoes.

This regulatory guide further states that, "protection of designated structures, systems, and components may generally be accomplished by designing of protective barriers to preclude the tornado damage *** If protective barriers are not installed, the structures, systems, and components themselves should be designed to withstand the effects of the tornado including torna~o.missile strikes."

NLR-N93208 5

Contrary-to the above, on September 3, 1993, there was no evidence that the Unit 2 EDG combustion air exhaust pipe and intake louvers were protected against tornado generated missiles, or were capable of withstanding the effects of these missiles.

• This deviation applies to Unit 2 only.

Response

PSE&G does not despute this deviation.

Engineering Evaluation No. S-C-ZZ-MEE-0789 was issued on October 19, 1993, to assess the Unit 2 EDG combustion air intake and exhaust piping.

In this evaluation, PSE&G calculated the frec;iuency of a significant tornado event at the Sa!gm site during the next 18 months to be less than 1.7 x 10 per year.

The frequency of a tornado generated missile damaging the air i!!gake and air exhaust_IJiping for a single E.DG are 9.58 x 10

/year and 1.45 x 10

/year~ respectively.

These frequencies are conservatively calculated for tornadoes encompassing wind speeds of 73 mph to 300 mph.

A historical review of reported tornadoes from 1952 to 1992 in a 50 mile radius of the Salem site showed that only two tornadoes greater than 158 mph have occurred.

Although the air intake and exhaust structures *for the Unit 2 EDGs do not fully protect against the effects of tornado generated missiles, PSE&G considers the Unit 2 EDGs to be able to perform their intended design functions until the corrective actions can be implemented.

This determination was based on:

NLR-N93208

1. The major components of the combustion air piping are located inside a building (Auxiliary Building) designed for tornado wind and missile loads.

2.. In the event that a tornado does occur and the air intake and/or exhaust piping outside the Auxiliary Building) is damaged, there are mitigating actions which PSE&G can take to assure EDG availability.

3. The probability of a tornado missile striking any of the exhaust _IJipes or intake louver_s is extremely low at 2.4 x 10 /year.

6

• ~orrective Actions Structural modifications will be implemented for Salem Unit 2 during the eighth refueling outage (currently scheduled to begin in September of 1994) to protect -the EDG intake and exhaust structures against tornado generated missiles.

NLR~N93208 7