ML18079A657

Responds to NRC Re Violations Noted in IE Insp Rept 50-272/79-02.Corrective Actions:Recorder Will Be Installed to Supplement Computer Printouts & ETS Will Be Changed

ML18079A657
Person / Time
Site:	Salem
Issue date:	04/06/1979
From:	Schneider F Public Service Enterprise Group
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18079A656	List: ML18079A654 ML18079A657 ML18079A658 ML18079A659 ML18079A660
References
NUDOCS 7908020057
Download: ML18079A657 (7)

Text

I ick W. Schneider Vice President Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Production 0

April 6, 1979 Mr. Boyce H-*. Grier Director*of USNRC Off ice of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Grier:

NRC INSPECTION REPORT 50-272/79-02 INSPECTION DATE JANUARY 8-12 *AND 15-17, 1979 UNIT NO. l SALEM GENERATING STATION We have reviewed the report of your inspection transmitted with your letter dated March 15, 19.79, which was receiv~d on March 19, 1979.

The following information is. provided as a response to_

your report:

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Item A,. Infraction:

Section 2.1.1 of Appendix B, Environmental Technical Specifications (ETS) for Salem Nuclear Generating Station, Unit 1, requires, in part, that the maximum ~T across the con-denser shall not exceed 16.5°F during normal operation with all circulation water pumps operating.

During pump outage, the maximum.

~T across the condenser shall not exceed l6.5°F for more than 24 consecutive hours because of scheduled maintenance and inspection.

In the event that the specification is exceeded, cor-rective action shall be taken to reduce the

~T to within specification.

Contrary to these requirements:

1.

The 16.5°F maximum ~T across the condenser was exceeded during normal operation with all six circulating water pumps on several occasions, in-cluding December 9, 10, 11 and 12, 1978.

Cor-rective actions taken were untimely and/or_in-adequate to reduce the condenser ~T to within specification.

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Boyce H. Grier

- 4-6-79

2.

The 16.5PF maximum AT across the condenser was exceeded for more than 24 consecutive hours on several occasions including November 15 through 19, 1978 (113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br />); November 20 through 23, 1978 (79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br />) and December 4 through 7, 1978 (75 hour8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />s}.* Corrective actions taken were untimely*

• *and/orinadequate to reduce the condenser AT to

• within specification.

Our response to Item "A" is:

1.

2.

3.

The station did not exceed the Environmental Technical Specification (ETS) limits for AT on any of the dates cited.

The cause of this being listed as a noncompliance was that station personnel did not have the proper documents available for*the inspector to review.

-The *computer hourly printouts are used for recording con~

denser AT's as required.by section 2.1.la Appendix B of the ETS.

The hourly printouts are an instantaneous reading of the condenser AT's.

By chance the computer recorded con-sective peak AT's on. its hourly printouts.

This gave the erroneous impression the condensers were operated in excess of the ETS limits.

This is not true, operator logs clearly indicate the condensers were operated within ETS limits_

between computer printouts.

To prevent future items of noncompliance a recorder will be.

installed, which will supplement the computer printout by providing a continuous record of condenser AT; average condenser outlet temperature and the number of circulators in-service.

We are in compliance now.

The recorder will be. in operation by the end*of the refueling outage.

Item B, Deficiency:

Section 5.5.2 of Appendix B, ETS requires, in part, that the plant operating procedures shall include provisions to ensure that the plant and all its systems and components are operated in compliance with the limiting conditions for operation established as part of the ETS.

Section 5.3.2 requires, in part, that the Station Operations Review Conunittee (SORCl shall review plant procedures which have a potential impact on the environment

• Contrary to these requirements, the plant chlorination procedures used to operate the

.e Boyce H. *Grier 4-6-79 cholorination system in compliance with the limiting conditions for operation established in Section 2.2.1 of Appendix B, ETS were not re~

viewed by SORC as required.

Our response to Item "B" is:

1.

The compliance date committed to, in our 1978 response, was extended by the Station Quality Assurance Department.

The extension was granted in view of the problems being_ en-countered with the operation of the chlorination system.

• Failure.of the station to meet the commitment date was not

• brought to the attention of the station Manager.

The pro-cedure has now been reviewed by SORC, approved and implemented.*

2.

To preyent future items of noncompliance the SQAE has taken action to improve the effectiveness of the Outstanding Items

• List (0. I.) as a means of insuring implementation of cor-rective actions.

These include:

a)

The O.I. list has been computerized and now clearly indicates the commitments, required corrective actions and who is responsible for them.

b)

If the corrective action for an NRC item will not be complete by the committed date the SQAE will notify the station Manager.

3.

We are presently in compliance.

Item C, Deficiency:

Section 2.2.2 of Appendix B, ETS requires, in part, that the average suspended solids concentration in the effluent from the Nonradioactive Chemical Liquid Waste Disposal System, (NLWDS),

shall not exceed 25 mg/liter on an annual basis.

Contrary to these requirements, the annual (1978) average for suspended solids concentration in the effluent of the NLWDS exceeded 25 mg/liter.

Our response to Item "C" is:

1.

This noncompliance was caused by using water with a high total suspended solids (TSS) to quench the steam generator blowdown.

Corrective action was initiated in early April 1978 by discontinuing the use of quench water.

This action resulted in TSS levels <25 mg/liter from April through the end of 1978.

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4-6 2.

To prevent future items of noncompliance the steam generator blowdown quench water will remain secured.

A change to the ETS is being processed which wou.ld align the ETS TSS limit for the Nonradioactive Waste'Basin effluent with the EPA limit of 30 ppm (net) as in the present EPA-NPDES permits.

3.

We are in compliance now and the data collected for 1979 does.not indicate that we will have a problem in this area.

Item D, Deficiency:

Section 5 *. 6

• 2 of Appendix B, ETS requires, in part, that a report shall be submitted in the event that a limiting condition for operation is exceeded.

The event shall-be reported within 30 days by a written report to the Director of the Regional In-

• spection and Enforcement Office (with a copy to the Director of Nuclear Reactor Regulation).

Contrary to these requirements, on several occasions, *including those instances *indicated in item A of.this Appendix, the ex~

ceeding of the condenser AT limiting condition for operation was not reported as* required.

Our response to Item "D" is:

1.

As indicated in Item A station personnel did not have the proper documents available for the inspector to review.

The

• station did not fail to report exceeding ~T limits.

Station Incident Reports document all instances of exceeding AT limit.

These incident reports provide the reason for ex-ceeding the AT limit and the justification for the de-termination that the incident was not reportable.

To cor-rect 'the situation all pertinent documents.are now available for review by the inspector.

2.

Future items of noncompliance will be prevented by the re-corder to which we connnitted to in reply to Item A.

3.

We are operating in compliance now and the recorder will *be in operation by* the end of the refueling outage.

I-tem E, Deficiency:

Section 5. 5.1 of Appendix B, ETS requires*,. in pa.rt, that detailed written procedures, including applicable checklists and instruc-tions,. shall* be prepared and followed for all activities involved in carrying out the*ETS. - Procedures for the environmental sur-veillance and*special study*programs described in Section 3 and 4 shall be prepared*by*personnel responsible £or the particular

11>.....

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Boyce H. Grier

-s-4-6-79 monitoring program.

Section 5.3.2 requires, in part, that the Station Operations Review Committee (SORC} shall review plant procedures which have a potential impact on the environment.

Section 3.1.1.S* of the ETS requires, in part, that a physical i;nventory of identif"iable chemicals, *excluding*spent *laboratory reagents and condenser*tube corrosion products, discharged directly to*the river shal:l be maintained and submitted as part of the annual report.

Contrary to these requirements, procedures for physical inventory or identifiable chemicals discharge directly to the river.were not reviewed by SORC* as required.

Our response to Item "E" is:

I.

The compliance date committed to, in our 1978 response, was extended by the Station Quality Assurance Department.

The extension was granted +/-n*view of the existing station work-lo.ad and that the 1978 Annual F.eport was not due until April 1979.

Failure of the station to meet the commitment date was not brought to the attention of* the station Manager.

The procedure has now"been reviewed by SORC,*approved, and implemented.

r) 2.

To prevent future items of noncompliance the SQAE.has taken action to improve.the effectiveness of the Outstanding Items

(.O.I.) List as a means of insuring*implementation of cor-rective actions.

These include:

___.J~/

a.

The O.I. list has been computerized and now clearly indicates the commitments,.required corrective action*s and who* is. responsible for them.

b.

If the corrective*action for an NRC item will not be complete* by the. committed date the SQAE will notify the. station Manager.

3.

We are presently in compliance.

Item F, Deficiency:

Section 2.2.2 of Appendix B, ETS requires, in part, that a grab sample shall be taken once 'per day from the coll,ectin9 basin discha~ge pipe and analyz~d for suspended solids usirig a method which is acceptable to EPD. '* Samples shall be taken during periods of actual discharge.

Contrary to these requirements, *daily.sam:g>les collected from the collecting basin discharge pipe *during :g>eriods of actual dis-charge on November 8, October 24.and September 26, 1978,.were not

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Boyce 4-6-79_

analyzed for suspended solids as required.

_Our response to item "F" is:

1.

Station records indicate that -all required TSS samples were

,taken.

The samples, were shipped. to an outside laboratory for analysis.

• We determined that this laboratory was not -

reliable and therefore we* are currently seeking a qualified replacement.

During the"interim the analysis is being per-formed at the-station.

A review of the records since January 1, 1979 indicates compliance with the requirements of section 2.2.2 of the ETS.

2.

To prevent reoccurrence a copy of the chemistry schedule has been posted in the Chemistry Lab *. This posting clearly indicates the required chemistry;samples and their due dates.

A proposed change in the ETS has been prepared for approval, changing the sampling and analysis schedule to agree with requirements contained in'the,present EPA-NPDES. permits.

3.

We are presently in compliance.

Item G, Deficiency:

Section 3.1.1 of Appendix B, ETS requires, in part,,that g:rab samples shall be taken weekly--(weather permittingt during a chlorination cycle and analyzed for free and total. residual chlorine.

The samples shall be taken in the vicinity of the circulating water discharge,* -from the station intake water, and from a point that is outside* and down stream of *the discharge water mixing zone.

Contrary.to these requirements, grab samples were not taken and analyzed for free and total residual chlorine during,any of the chlorination cycles performed during August 1~78.

Our response to item "G" is:

1.

During the month of August 1~78 the common chlorination system for the Main Condenser and Service Water System was not in normal, daily operation.

During the period August 1 to 15, 1978 the system was operated*:for five* short weriods of time to identify the system problems *. From August 16 to 31, 1978 the system reni-ained out of service.

During these test periods the Energy Laboratory was not notified that the system had been o:rperated.

The noncompliance was reviewed with the supervisor*in charge of the chlorination system and it was emphasized that he must coordinate the operation of the system to insure the required samples are obtained even during test periods.

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Boyce 4-6-79

2.

To prevent future noncompiiances the present river water sampling schedule will be reviewed and ETS changes requested to formulate a new sampling schedule.

This will provide all the necessary data for reports, eliminate duplication and

• assure future compliance.

3.

We are presently in compliance.

Effectiveness of Management Controls The following actions have been. taken to improve mana.gement control at the station and to insure compliance with the ETS.

Directions have been issued to install additional recording equipment to provide the operator with better* condenser temperature data and* produce permanent continuous records.

ETS change requests are being process.ea to elimi-nate excessively restrictive and confusing ETS

• requirements.

A computer program has been initiated to track outstanding (O.I.) items for better management control.

The SQAE has been directed to closely monitor the computer O.I. list and when it appears that an item is not being properly acted upon, he will bring that item to the attention of the station Manager.

CC Directer, Office of

• InsJ?ection and Enforcement Sincerely,