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| number = ML18100A880
| number = ML18100A880
| issue date = 02/10/1994
| issue date = 02/10/1994
| title = Responds to NRC 940110 Ltr Re Violation Noted in Insp Repts 50-272/93-23 & 50-311/93-23.Corrective actions:non-TS Surveillance Will Be Developed to Independently Test Ability of Individual Set of Starting Air Motors to Start EDGs
| title = Responds to NRC Re Violation Noted in Insp Repts 50-272/93-23 & 50-311/93-23.Corrective actions:non-TS Surveillance Will Be Developed to Independently Test Ability of Individual Set of Starting Air Motors to Start EDGs
| author name = Hagan J
| author name = Hagan J
| author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY
| author affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = NLR-N94018, NUDOCS 9402180273
| document report number = NLR-N94018, NUDOCS 9402180273
| title reference date = 01-10-1994
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 10
| page count = 10
}}
}}
See also: [[see also::IR 05000272/1993023]]


=Text=
=Text=
{{#Wiki_filter:Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Ha*ncocks  
{{#Wiki_filter:Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Ha*ncocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations FEB 10 1994 NLR-N94018 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
Bridge, NJ 08038 609-339-1200  
RESPONSE TO'NRC'S NOTICE OF VIOLATION INSPECTION REPORT 50-272/93-23; 50-311/93-23 DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC In~pecti6n Report 50-272/93-23, 50-311/93-2~, dated January lb, 1994.
Vice President  
Within the scope of this report, a Salem Unit 1 and 2 Technical Specification Action Statement 3:8.1.1 violation was identified.
-Nuclear Operations  
Accordingly, in the attachment to this letter, PSE&G submits its assessment and response to the identified violation.
* FEB 10 1994 NLR-N94018  
Should you have any questions regarding this transmittal, please do not hesitate to contact me.
United States Nuclear Regulatory  
1 *7-n r1... '"  
Commission  
~*.. l.J 9402180273 940210 PDR ADOCK 05000272 Q
Document Control Desk Washington, DC 20555 Gentlemen:  
PDR Sincerely,  
RESPONSE TO'NRC'S NOTICE OF VIOLATION  
 
INSPECTION  
Document Control Desk NLR-N94018 Attachment (1) 2 c
REPORT 50-272/93-23;  
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)
50-311/93-23  
USNRC Senior Resident Inspect_or 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 FEB 10 1994  
DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC  
 
Report 50-272/93-23,  
REF:
dated January lb, 1994. Within the scope of this report, a Salem Unit 1 and 2 Technical  
NLR-N94018 STATE OF NEW JERSEY COUNTY OF SALEM  
Specification  
/  
Action Statement  
)  
3:8.1.1 violation  
)
was identified.  
SS.  
* Accordingly, in the attachment  
)
to this letter, PSE&G submits its assessment  
J. J. Hagan, being duly sworn according to law deposes and says:
and response to the identified  
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 knowl~dge, information and belief.
violation.  
Subscribed My Commission expires on KIMBERLY JO BROWN NOT ARY PUBLIC OF NEW JERSEY M, eo1o1:11iosim1 f!xpltes April 21, 1998  
Should you have any questions  
 
regarding  
NLR-N94018 ATTACHMENT I
this transmittal, please do not hesitate to contact me. 1 *7-n r 1 ... '" . '" ... * . .. .. l.J 9402180273  
- During an NRC inspection conducted on October 17 - November 27 1993, violations of NRC requirements were identified.
940210 PDR ADOCK 05000272 Q PDR Sincerely,
In accordance with the "General Statement of Policy and Procedure  
Document Control Desk NLR-N94018  
- for NRC Enforcement Actions," 10 CFR Part 2,* Appendix C ( 1992),
Attachment  
the violations are listed below:
(1) 2 c Mr. J. c. Stone, Licensing  
A.
Project 'Manager U.S. Nuclear Regulatory  
Technical Specification 3.8.1.1.b for each unit requires that for Modes 1, 2, 3, and 4, three separate and independent diesel generators shall be operable.
Commission  
Operability requires that the dual air systems for each diesel be functional and able to operate as designed.
One White Flint North 11555 Rockville  
Technical Specification  
Pike Rockville, MD 20852 Mr. C. S. Marschall (S09) USNRC Senior Resident Inspect_or  
*1 3.8.1.1, Action a. requires that with one less than the required emergency diesel generators operable, PSE&G shall demonstrate the operability of the remaining A.C. sources by performing Surveillance Requirements 4.8.1.1.1.a and 4.8.1.1.2.a.2 within one hour and at least once every 8 hours thereafter.
Mr. T. T. Martin, Administrator  
Contrary to the above, on April 9, 1993, the licensee isolated an air start system for the 2C emergency diesel generator; on May 13, 1993, the licensee isolated an air start system for the lB emergency diesel generator; on August 5, 1993, the licensee isolated an air start system for the lC emergency diesel generator; and on September 12, 1993, the licensee isolated an air start system for the 2B emergency diesel generator.
-Region I U.S. Nuclear Regulatory  
In all these instances, the licensee failed to declare the respective emergency diesel inoperable or take actions required by TS 3.8.1.1, Action a.
Commission  
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.  
475 Allendale  
 
Road King of Prussia, PA 19406 Mr. Kent Tosch, Manager, VI New Jersey Department  
NLR-N94018 PSE&G RESPONSE PSE&G disputes the violation as written.
of Environmental  
PSE&G does not agree with the following statements contained in the Notice of Violation, Appendix A, and Inspection Report 50-272/93-23; 50-311/93-23 Section D "Control of Salem Emergency Diesel Generator Maintenance and Surveillance":
Protection  
Operability requires that the dual air systems for e~ch diesel be functional and able to operate as designed."  
Division of Environmental  
"... Since the UFSAR states that the EDG will start on any two air start motors, isolation of any air start system required entry into TS 3.8.1.1, Action a., even if the licensee had performed surveillances demonstrating the EDG capability to start on any two motors... "  
Quality Bureau of Nuclear Engineering  
"**** the licensee performed inadequate surveillances required by Technical Specification 4.8.1.1.2.a.2, in that they failed to demonstrate the capability of the EDG to start on any pair of air start motors, as required by Technical Specification definition of operability and the UFSAR description of the start air system."
CN 415 Trenton, NJ 08625 FEB 10 1994
PSE&G disagrees with the violation as written, because we interpret these statement to infer the following; (1) There is a regulatory requirement to have redundant air systems, (2) Even if satisfactorily tested, the TS action statement still applies if the redundancy is lost, and (3) If redundant systems are provided, they become part of the Technical Specification (TS) operability requirement.
REF: NLR-N94018  
Therefore, they must be tested regardless of the existence of a specific TS requirement.
STATE OF NEW JERSEY COUNTY OF SALEM / ) ) SS. ) J. J. Hagan, being duly sworn according  
BACKGROUND Each Salem unit has three ALCO Emergency Diesel Generators (EDGs) available to supply emergency electrical power to the safety related equipment.
to law deposes and says: I am Vice President  
Each EDG, as specified by PSE&G, supplied and qualified by the vendor, consists of: two starting air compressors, two starting air receiving tanks and two sets of starting air motors.
-Nuclear Operations  
The basis for Technical Specification (TS) 3.8.1.1 requires the operability of the AC power sources to ensure that enough AC power (normal and emergency) is available to the safety related equipment to ensure that design limits on containment pressure, fuel integrity, and reactor coolant system are not exceeded.
of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced  
Salem TS surveillance requirements demonstrate the operability of the EDGs. TS surveillance 4.8.1.1.2 a. demonstrates the EDG's operability by requiring the EDGs to achieve 900 rpm in s 10 seconds from ambient conditions.  
letter, concerning  
 
the Salem Generating  
This surveillance is performed every 31 days and tests the EDGs in their normal configuration with all starting air motors available.
Station, Unit Nos. 1 and 2, are true to the best of my  
EDGs technical specification surveillances do not require independent testing of individual starting air systems (motors).
information  
The Salem Updated Final Safety Analysis Report (UFSAR) Section 9.5, and the Configuration Baseline Documentation (CBD) for the EDG system, state that the EDGs are capable of starting with only one set of starting air motors (i.e: two starting air motors).
and belief. Subscribed  
These statements are based on the manufacturer's testing and documentation, which was provided to PSE&G at the time of purchase.
My Commission  
The documentation indicates the EDG's ability to start and reach 900 rpm in less than 10 seconds with only one set of starting air motors.
expires on KIMBERLY JO BROWN NOT ARY PUBLIC OF NEW JERSEY M, eo1o1:11iosim1  
UFSAR Section 8.3, states that only two EDGs are needed to safely shutdown the facility under design basis conditions considering the presence of a single failure.
f!xpltes April 21, 1998
This is consistent with Salem's current licensing basis.
* NLR-N94018  
Non-TS portions of required surveillances Sl(S2).OP-ST.DG-0006 through 0008 tests the operability of the starting air motors and starting air solenoids.
ATTACHMENT  
This surveillance is performed once per refueling outage and independently tests the operability of each individual starting air motor and solenoid, thus providing operability assurance of each individual solenoid and motor set.
I -During an NRC inspection  
This surveillance was established in response to INPO SOER 80-01, which addressed the potential for passive air start system failures being undetectable (Rancho Seco event).
conducted  
EDG operability is defined as being the capability of starting, accelerating to rated speed, and accepting accident loads and  
on October 17 -November 27 1993, violations  
. carrying those loads *far a prescribed amount of time.
of NRC requirements  
In addition operability requires that certain minimum auxiliary equipment be available.
were identified.  
This minimum supporting equipment has been established by PSE&G and ALCO to assure EDG operability.
In accordance  
PSE&G defines EDG qualification as being the capability of an EDG unit to accomplish its design operability function.
with the "General Statement  
The qualifications establish the limiting environmental conditions and the minimum supporting equipment needed for EDG operability.
of Policy and Procedure  
These statements are consistent with Generic Letter (GL) 91-18, "Resolution of Degraded and Nonconforming Conditions and Operability Determinations", issued October 31, 1993."  
-for NRC Enforcement  
 
Actions," 10 CFR Part 2 ,* Appendix C ( 1992) , the violations  
APPLICABLE REGULATORY GUIDANCE PSE&G has reviewed applicable NRC guidance regarding the use of EDGs as onsite electric power sources.
are listed below: A. Technical  
This guidance is contained in Regulatory Guides and IEEE Standards, and appears to have been the basis which established the TS surveillance requirements.
Specification  
Regulatory Guide 1.108 (1977) "Periodic Testing of Diesel Generators Units'Used as Onsite Electric Power Systems at Nuclear Power Plants," Regulatory Guide 1.32 (1977) "Criteria *for Safety-Related Electric Power Systems for Nuclear Power Plants,"
3.8.1.1.b  
Regulatory Guide 1.9 (1971) "Selection of Diesel Generator Set Capacity for Standby Power Supplies", and Regulatory Guide 1.93 (1974) " Availability of Electric Power Sources" were reviewed and there was no requirement found to design the EDGs with redundant air start systems nor were requirements,established to demonstrate the redundancy of starting air systems.
for each unit requires that for Modes 1, 2, 3, and 4, three separate and independent  
IEEE Standard 387-1977 "IEEE Standard Criteria for Diesel-Generators Units Applied as Standby Pow~r Supplies for Nuclear Power Generating Stations, 11 and IEEE Std 308-1980 "IEEE Standard Criteria for Class lE Power Systems for Nuclear Power Generating Stations," were also reviewed and similarly there were no requirements found to design or test redundant starting air systems.
diesel generators  
PSE&G also reviewed NUREG-0600 "Enhancement of On Site Emergency Diesel Generator Reliability," dated December 14, 1979, and NUREG-1431 Vol.1 "Standard Technical Specifications Westinghouse Plants" issued on September 1992, and found no requirements to independently test redundant air systems.
shall be operable.  
PSE&G POSITION With regard to the following;  
Operability  
"*** Since the UFSAR states that the EDG will start on any two air start motors, isolation of any air start system required entry into TS 3.8.1.1, Action a., even if the licensee had performed surveillances demonstrating the EDG capability to start on any two motors... "  
requires that the dual air systems for each diesel be functional  
"... Operability requires that the dual air systems for each diesel be functional and able to operate as designed."
and able to operate as designed.  
It is PSE&G's position that the cited UFSAR statement is an informational statement regarding an enhancement to the Salem EDGs, *and not a regulatory requirement.
Technical  
In addition to design basis information and requirements, the Salem UFSAR also contains systems/components descriptions.
Specification  
These descriptions may include design enhancements originally provided by vendors, which are included in the Salem UFSAR for completeness, and were not intended to infer a design or regulatory requirement.  
*1 3.8.1.1, Action a. requires that with one less than the required emergency  
 
diesel generators  
Accordingly, PSE&G does not believe these enhancements represent a TS operability requirement.
operable, PSE&G shall demonstrate  
PSE&G reviewed NRC Generic Letter (GL) 91-18, "Resolution of Degraded and Nonconforming Conditions and Operability Determinations", issued October 31, 1993.
the operability  
GL 91-18 states that operability determinations shall be made based upon the ability of the system to perform its intended safety function as described in the licensing basis.
of the remaining  
Consequently, entering the Action Statement, when the system is still able to perform its intended safety function_ is not required by the Operability definition or its intent, as indicated in GL 91-18.
A.C. sources by performing  
Given the TS basis (previously stated), the current licensing basis requirement (UFSAR Section 8.3), original vendor data, and recent surveillance testing, the Salem EDGs are able to perform their intended safety related function with only one set of starting air motors.
Surveillance  
Therefore, PSE&G does not believe that entering the Action Statement is required, when one set of starting air motors is unavailable.
Requirements  
The following statement, which was not cited as a violation in Appendix A, refers to the surveillance program and TS requirements of the air systems;  
4.8.1.1.1.a  
"**.. the licensee performed inadequate surveillances required by Technical Specification 4.8.1.1.2.a.2, in that they failed to demonstrate the capability of the EDG to start on any pair of air start motors, as required by Technical Specification definition of operability and the UFSAR description of the start air system." (emphasis added)
and 4.8.1.1.2.a.2  
PSE&G does not disagree with the NRC's concern regarding reliance on original qualification testing to demonstrate EDG operability.
within one hour and at least once every 8 hours thereafter.  
As stated in the Inspection Report, when this concern was brought to management's attention, changes to the monthly diesel TS surveillance were promptly initiated.
Contrary to the above, on April 9, 1993, the licensee isolated an air start system for the 2C emergency  
The TS surveillance procedure 4.8.1.1.2.a.2 was modified to start the EDGs with only one set of starting air motors in service.
diesel generator;  
This modification was conservatively made by PSE&G, while evaluating the concern.
on May 13, 1993, the licensee isolated an air start system for the lB emergency  
All Salem EDGs were satisfactorily tested using the modified procedure, thus validating the original vendor testing and documentation, and PSE&G's operability determination, i.e., that the EDGs were able to meet all design basis requirements with only one set of starting air motors.
diesel generator;  
By testing in this manner, PSE&G has obtained additional assurance regarding the reliability and dependability of the starting air system, and validated the original vendor testing and documentation.  
on August 5, 1993, the licensee isolated an air start system for the lC emergency  
 
diesel generator;  
Monthly EDG surveillance testing is performed to demonstrate that the EDGs will start and carry near rated load without evidence of significant degradation or malfunctions that might prevent the  
and on September  
. EDGs from accomplishing their functions.
12, 1993, the licensee isolated an air start system for the 2B emergency  
The monthly tests do not attempt to requalify the EDGs to their maximum capability or to requalify vendor testing by requiring the EDGs to perform in the absence of certain support equipment.
diesel generator.  
Consequently, PSE&G will continue to perform the required technical specification surveillance (4.8.1.1.2.a.2) with all starting air motors available.
In all these instances, the licensee failed to declare the respective  
However, to ensure continued EDG operability with one set of starting air motors unavailable, a special non-technical specification surveillance will be performed utilizing the remaining set of starting air motors.
emergency  
Based on the information presented above, PSE&G disagrees with the underlined portion of the quoted statement since there is no apparent regulatory requirement to have designed the EDGs with redundant starting air systems.
diesel inoperable  
Consequently this requirement is not reflected in a TS surveillance requirement, and therefore, PSE&G does not believe that a Technical Specification violation occurred.
or take actions required by TS 3.8.1.1, Action a. Pursuant to the provisions  
CONCLUSION As noted in the Notice of Violation, PSE&G has followed the practice of removing a set of starting air motors from service without declaring the EDGs inoperable.
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  
The basis for PSE&G's decision to follow this course of action has been discussed above, and it is summarized below:
this Notice, a written statement  
(A) The vendor's qualification testing, which documented to PSE&G the EDG's ability to start in less than 10 seconds with only one set of starting air motors, (B) The satisfactory completion of all Technical Specification surveillances associated with TS 3. 8.1.. 1, including surveillance 4.8.1.1.2 a 2, and (C) The satisfactory completion of surveillance Sl(S2).OP-ST.DG-0006 through 0008.
or explanation  
Based upon all the information presented above, PSE&G does not believe that there is a regulatory requirement to design, test or reverify vendor qualifications on a routine surveillance basis.
in reply, including:  
Therefore, PSE&G believes that a technical specification violation did not occur, and PSE&G remains in compliance with its Technical Specification diesel testing requirement.
(1) the corrective  
However, PSE&G recognizes that its surveillance testing could be further enhanced, and the following actions were immediately taken by PSE&G management.
steps which have been taken and the results achieved;  
Operations Department management:
(2) corrective  
: 1. Reviewed the event with Operations personnel.
steps which will be taken to avoid further violations;  
: 2. Conservatively revised EDG surveillance (4.8.1.1.2. a. 2) testing procedure to require independent testing of the starting air motor set.
and (3) the date when full compliance  
This test has been satisfactorily conducted on all EDGs.
will be achieved.
The following actions will be taken to enhance PSE&G's surveillance program.
NLR-N94018  
: 1. A non technical specification surveillance will be developed to independently test the ability of the individual set of starting air motors to start the EDGs in slO seconds.
PSE&G RESPONSE PSE&G disputes the violation  
This surveillance will bt;= performed every refueling outage.
as written. PSE&G does not agree with the following  
: 2. Whenever a set of starting air motors is removed from service, the EDG will be tested to ensure that the remaining set of starting air motors is still capable to start the EDG in s 10 seconds.
statements  
Successful completion of this test will demonstrate continued EDGs Operability.
contained  
: 3. The monthly TS surveillance requirement 4.8.1.1.2. a. 2 will be revised to test the EDGs in their normal configuration. i.e.: all starting air motors available.}}
in the Notice of Violation, Appendix A, and Inspection  
Report 50-272/93-23;  
50-311/93-23  
Section D "Control of Salem Emergency  
Diesel Generator  
Maintenance  
and Surveillance": " Operability  
requires that the dual air systems for  
diesel be functional  
and able to operate as designed." " ... Since the UFSAR states that the EDG will start on any two air start motors, isolation  
of any air start system required entry into TS 3.8.1.1, Action a., even if the licensee had performed  
surveillances  
demonstrating  
the EDG capability  
to start on any two motors ... " "**** the licensee performed  
inadequate  
surveillances  
required by Technical  
Specification  
4.8.1.1.2.a.2, in that they failed to demonstrate  
the capability  
of the EDG to start on any pair of air start motors, as required by Technical  
Specification  
definition  
of operability  
and the UFSAR description  
of the start air system." PSE&G disagrees  
with the violation  
as written, because we interpret  
these statement  
to infer the following;  
(1) There is a regulatory  
requirement  
to have redundant  
air systems, (2) Even if satisfactorily  
tested, the TS action statement  
still applies if the redundancy  
is lost, and (3) If redundant  
systems are provided, they become part of the Technical  
Specification (TS) operability  
requirement.  
Therefore, they must be tested regardless  
of the existence  
of a specific TS requirement.  
BACKGROUND  
Each Salem unit has three ALCO Emergency  
Diesel Generators (EDGs) available  
to supply emergency  
electrical  
power to the safety related equipment.  
Each EDG, as specified  
by PSE&G, supplied and qualified  
by the vendor, consists of: two starting air compressors, two starting air receiving  
tanks and two sets of starting air motors. The basis for Technical  
Specification (TS) 3.8.1.1 requires the operability  
of the AC power sources to ensure that enough AC power (normal and emergency)  
is available  
to the safety related equipment  
to ensure that design limits on containment  
pressure, fuel integrity, and reactor coolant system are not exceeded.  
Salem TS surveillance  
requirements  
demonstrate  
the operability  
of the EDGs. TS surveillance  
4.8.1.1.2  
a. demonstrates  
the EDG's operability  
by requiring  
the EDGs to achieve 900 rpm in s 10 seconds from ambient conditions.
This surveillance  
is performed  
every 31 days and tests the EDGs in their normal configuration  
with all starting air motors available.  
EDGs technical  
specification  
surveillances  
do not require independent  
testing of individual  
starting air systems (motors) . The Salem Updated Final Safety Analysis Report (UFSAR) Section 9.5, and the Configuration  
Baseline Documentation (CBD) for the EDG system, state that the EDGs are capable of starting with only one set of starting air motors (i.e: two starting air motors). These statements  
are based on the manufacturer's  
testing and documentation, which was provided to PSE&G at the time of purchase.  
The documentation  
indicates  
the EDG's ability to start and reach 900 rpm in less than 10 seconds with only one set of starting air motors. UFSAR Section 8.3, states that only two EDGs are needed to safely shutdown the facility under design basis conditions  
considering  
the presence of a single failure. This is consistent  
with Salem's current licensing  
basis. Non-TS portions of required surveillances  
Sl(S2) .OP-ST.DG-0006  
through 0008 tests the operability  
of the starting air motors and starting air solenoids.  
This surveillance  
is performed  
once per refueling  
outage and independently  
tests the operability  
of each individual  
starting air motor and solenoid, thus providing  
operability  
assurance  
of each individual  
solenoid and motor set. This surveillance  
was established  
in response to INPO SOER 80-01, which addressed  
the potential  
for passive air start system failures being undetectable (Rancho Seco event) . . EDG operability  
is defined as being the capability  
of starting, accelerating  
to rated speed, and accepting  
accident loads and . carrying those loads *far a prescribed  
amount of time. In addition operability  
requires that certain minimum auxiliary  
equipment  
be available.  
This minimum supporting  
equipment  
has been established  
by PSE&G and ALCO to assure EDG operability.  
PSE&G defines EDG qualification  
as being the capability  
of an EDG unit to accomplish  
its design operability  
function.  
The qualifications  
establish  
the limiting environmental  
conditions  
and the minimum supporting  
equipment  
needed for EDG operability.  
These statements  
are consistent  
with Generic Letter (GL) 91-18, "Resolution  
of Degraded and Nonconforming  
Conditions  
and Operability  
Determinations", issued October 31, 1993."
APPLICABLE  
REGULATORY  
GUIDANCE PSE&G has reviewed applicable  
NRC guidance regarding  
the use of EDGs as onsite electric power sources. This guidance is contained  
in Regulatory  
Guides and IEEE Standards, and appears to have been the basis which established  
the TS surveillance  
requirements.  
Regulatory  
Guide 1.108 (1977) "Periodic  
Testing of Diesel Generators  
Units'Used  
as Onsite Electric Power Systems at Nuclear Power Plants," Regulatory  
Guide 1.32 (1977) "Criteria  
*for Safety-Related  
Electric Power Systems for Nuclear Power Plants," Regulatory  
Guide 1.9 (1971) "Selection  
of Diesel Generator  
Set Capacity for Standby Power Supplies", and Regulatory  
Guide 1.93 (1974) " Availability  
of Electric Power Sources" were reviewed and there was no requirement  
found to design the EDGs with redundant  
air start systems nor were requirements ,established  
to demonstrate  
the redundancy  
of starting air systems. IEEE Standard 387-1977 "IEEE Standard Criteria for Diesel-Generators  
Units Applied as Standby  
Supplies for Nuclear Power Generating  
Stations, 11 and IEEE Std 308-1980 "IEEE Standard Criteria for Class lE Power Systems for Nuclear Power Generating  
Stations," were also reviewed and similarly  
there were no requirements  
found to design or test redundant  
starting air systems. PSE&G also reviewed NUREG-0600 "Enhancement  
of On Site Emergency  
Diesel Generator  
Reliability," dated December 14, 1979, and NUREG-1431  
Vol.1 "Standard  
Technical  
Specifications  
Westinghouse  
Plants" issued on September  
1992, and found no requirements  
to independently  
test redundant  
air systems. PSE&G POSITION With regard to the following;  
"*** Since the UFSAR states that the EDG will start on any two air start motors, isolation  
of any air start system required entry into TS 3.8.1.1, Action a., even if the licensee had performed  
surveillances  
demonstrating  
the EDG capability  
to start on any two motors ... " " ... Operability  
requires that the dual air systems for each diesel be functional  
and able to operate as designed." It is PSE&G's position that the cited UFSAR statement  
is an informational  
statement  
regarding  
an enhancement  
to the Salem EDGs, *and not a regulatory  
requirement.  
In addition to design basis information  
and requirements, the Salem UFSAR also contains systems/components  
descriptions.  
These descriptions  
may include design enhancements  
originally  
provided by vendors, which are included in the Salem UFSAR for completeness, and were not intended to infer a design or regulatory  
requirement.
** Accordingly, PSE&G does not believe these enhancements  
represent  
a TS operability  
requirement.  
PSE&G reviewed NRC Generic Letter (GL) 91-18, "Resolution  
of Degraded and Nonconforming  
Conditions  
and Operability  
Determinations", issued October 31, 1993. GL 91-18 states that operability  
determinations  
shall be made based upon the ability of the system to perform its intended safety function as described  
in the licensing  
basis. Consequently, entering the Action Statement, when the system is still able to perform its intended safety function_  
is not required by the Operability  
definition  
or its intent, as indicated  
in GL 91-18. Given the TS basis (previously  
stated), the current licensing  
basis requirement (UFSAR Section 8.3), original vendor data, and recent surveillance  
testing, the Salem EDGs are able to perform their intended safety related function with only one set of starting air motors. Therefore, PSE&G does not believe that entering the Action Statement  
is required, when one set of starting air motors is unavailable.  
The following  
statement, which was not cited as a violation  
in Appendix A, refers to the surveillance  
program and TS requirements  
of the air systems; "** .. the licensee performed  
inadequate  
surveillances  
required by Technical  
Specification  
4.8.1.1.2.a.2, in that they failed to demonstrate  
the capability  
of the EDG to start on any pair of air start motors, as required by Technical  
Specification  
definition  
of operability  
and the UFSAR description  
of the start air system." (emphasis  
added) PSE&G does not disagree with the NRC's concern regarding  
reliance on original qualification  
testing to demonstrate  
EDG operability.  
As stated in the Inspection  
Report, when this concern was brought to management's  
attention, changes to the monthly diesel TS surveillance  
were promptly initiated.  
The TS surveillance  
procedure  
4.8.1.1.2.a.2  
was modified to start the EDGs with only one set of starting air motors in service. This modification  
was conservatively  
made by PSE&G, while evaluating  
the concern. All Salem EDGs were satisfactorily  
tested using the modified procedure, thus validating  
the original vendor testing and documentation, and PSE&G's operability  
determination, i.e., that the EDGs were able to meet all design basis requirements  
with only one set of starting air motors. By testing in this manner, PSE&G has obtained additional  
assurance  
regarding  
the reliability  
and dependability  
of the starting air system, and validated  
the original vendor testing and documentation.
* Monthly EDG surveillance  
testing is performed  
to demonstrate  
that the EDGs will start and carry near rated load without evidence of significant  
degradation  
or malfunctions  
that might prevent the . EDGs from accomplishing  
their functions.  
The monthly tests do not attempt to requalify  
the EDGs to their maximum capability  
or to requalify  
vendor testing by requiring  
the EDGs to perform in the absence of certain support equipment.  
Consequently, PSE&G will continue to perform the required technical  
specification  
surveillance  
(4.8.1.1.2.a.2)  
with all starting air motors available.  
However, to ensure continued  
EDG operability  
with one set of starting air motors unavailable, a special non-technical  
specification  
surveillance  
will be performed  
utilizing  
the remaining  
set of starting air motors. Based on the information  
presented  
above, PSE&G disagrees  
with the underlined  
portion of the quoted statement  
since there is no apparent regulatory  
requirement  
to have designed the EDGs with redundant  
starting air systems. Consequently  
this requirement  
is not reflected  
in a TS surveillance  
requirement, and therefore, PSE&G does not believe that a Technical  
Specification  
violation  
occurred.  
CONCLUSION  
As noted in the Notice of Violation, PSE&G has followed the practice of removing a set of starting air motors from service without declaring  
the EDGs inoperable.  
The basis for PSE&G's decision to follow this course of action has been discussed  
above, and it is summarized  
below: (A) The vendor's qualification  
testing, which documented  
to PSE&G the EDG's ability to start in less than 10 seconds with only one set of starting air motors, (B) The satisfactory  
completion  
of all Technical  
Specification  
surveillances  
associated  
with TS 3. 8 .1 .. 1, including  
surveillance  
4.8.1.1.2  
a 2, and (C) The satisfactory  
completion  
of surveillance  
Sl(S2) .OP-ST.DG-0006  
through 0008. Based upon all the information  
presented  
above, PSE&G does not believe that there is a regulatory  
requirement  
to design, test or reverify vendor qualifications  
on a routine surveillance  
basis. Therefore, PSE&G believes that a technical  
specification  
violation  
did not occur, and PSE&G remains in compliance  
with its Technical  
Specification  
diesel testing requirement.  
However, PSE&G recognizes  
that its surveillance  
testing could be further enhanced, and the following  
actions were immediately  
taken by PSE&G management.  
Operations  
Department  
management:  
1. Reviewed the event with Operations  
personnel.
, 2. Conservatively  
revised EDG surveillance  
(4.8.1.1.2.  
a. 2) testing procedure  
to require independent  
testing of the starting air motor set. This test has been satisfactorily  
conducted  
on all EDGs. The following  
actions will be taken to enhance PSE&G's surveillance  
program. 1. A non technical  
specification  
surveillance  
will be developed  
to independently  
test the ability of the individual  
set of starting air motors to start the EDGs in slO seconds. This surveillance  
will bt;= performed  
every refueling  
outage. 2. Whenever a set of starting air motors is removed from service, the EDG will be tested to ensure that the remaining  
set of starting air motors is still capable to start the EDG in s 10 seconds. Successful  
completion  
of this test will demonstrate  
continued  
EDGs Operability.  
3. The monthly TS surveillance  
requirement  
4.8.1.1.2.  
a. 2 will be revised to test the EDGs in their normal configuration.  
i.e.: all starting air motors available.
}}

Latest revision as of 01:43, 6 January 2025

Responds to NRC Re Violation Noted in Insp Repts 50-272/93-23 & 50-311/93-23.Corrective actions:non-TS Surveillance Will Be Developed to Independently Test Ability of Individual Set of Starting Air Motors to Start EDGs
ML18100A880
Person / Time
Site: Salem  PSEG icon.png
Issue date: 02/10/1994
From: Hagan J
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N94018, NUDOCS 9402180273
Download: ML18100A880 (10)
v • d • e


Text

Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Ha*ncocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations FEB 10 1994 NLR-N94018 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO'NRC'S NOTICE OF VIOLATION INSPECTION REPORT 50-272/93-23; 50-311/93-23 DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC In~pecti6n Report 50-272/93-23, 50-311/93-2~, dated January lb, 1994.

Within the scope of this report, a Salem Unit 1 and 2 Technical Specification Action Statement 3:8.1.1 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 me.

1 *7-n r1... '"

~*.. l.J 9402180273 940210 PDR ADOCK 05000272 Q

PDR Sincerely,

Document Control Desk NLR-N94018 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 Inspect_or 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 FEB 10 1994

REF:

NLR-N94018 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 knowl~dge, information and belief.

Subscribed My Commission expires on KIMBERLY JO BROWN NOT ARY PUBLIC OF NEW JERSEY M, eo1o1:11iosim1 f!xpltes April 21, 1998

NLR-N94018 ATTACHMENT I

- During an NRC inspection conducted on October 17 - November 27 1993, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure

- for NRC Enforcement Actions," 10 CFR Part 2,* Appendix C ( 1992),

the violations are listed below:

A.

Technical Specification 3.8.1.1.b for each unit requires that for Modes 1, 2, 3, and 4, three separate and independent diesel generators shall be operable.

Operability requires that the dual air systems for each diesel be functional and able to operate as designed.

Technical Specification

  • 1 3.8.1.1, Action a. requires that with one less than the required emergency diesel generators operable, PSE&G shall demonstrate the operability of the remaining A.C. sources by performing Surveillance Requirements 4.8.1.1.1.a and 4.8.1.1.2.a.2 within one hour and at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

Contrary to the above, on April 9, 1993, the licensee isolated an air start system for the 2C emergency diesel generator; on May 13, 1993, the licensee isolated an air start system for the lB emergency diesel generator; on August 5, 1993, the licensee isolated an air start system for the lC emergency diesel generator; and on September 12, 1993, the licensee isolated an air start system for the 2B emergency diesel generator.

In all these instances, the licensee failed to declare the respective emergency diesel inoperable or take actions required by TS 3.8.1.1, Action a.

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-N94018 PSE&G RESPONSE PSE&G disputes the violation as written.

PSE&G does not agree with the following statements contained in the Notice of Violation, Appendix A, and Inspection Report 50-272/93-23; 50-311/93-23 Section D "Control of Salem Emergency Diesel Generator Maintenance and Surveillance":

Operability requires that the dual air systems for e~ch diesel be functional and able to operate as designed."

"... Since the UFSAR states that the EDG will start on any two air start motors, isolation of any air start system required entry into TS 3.8.1.1, Action a., even if the licensee had performed surveillances demonstrating the EDG capability to start on any two motors... "

"**** the licensee performed inadequate surveillances required by Technical Specification 4.8.1.1.2.a.2, in that they failed to demonstrate the capability of the EDG to start on any pair of air start motors, as required by Technical Specification definition of operability and the UFSAR description of the start air system."

PSE&G disagrees with the violation as written, because we interpret these statement to infer the following; (1) There is a regulatory requirement to have redundant air systems, (2) Even if satisfactorily tested, the TS action statement still applies if the redundancy is lost, and (3) If redundant systems are provided, they become part of the Technical Specification (TS) operability requirement.

Therefore, they must be tested regardless of the existence of a specific TS requirement.

BACKGROUND Each Salem unit has three ALCO Emergency Diesel Generators (EDGs) available to supply emergency electrical power to the safety related equipment.

Each EDG, as specified by PSE&G, supplied and qualified by the vendor, consists of: two starting air compressors, two starting air receiving tanks and two sets of starting air motors.

The basis for Technical Specification (TS) 3.8.1.1 requires the operability of the AC power sources to ensure that enough AC power (normal and emergency) is available to the safety related equipment to ensure that design limits on containment pressure, fuel integrity, and reactor coolant system are not exceeded.

Salem TS surveillance requirements demonstrate the operability of the EDGs. TS surveillance 4.8.1.1.2 a. demonstrates the EDG's operability by requiring the EDGs to achieve 900 rpm in s 10 seconds from ambient conditions.

This surveillance is performed every 31 days and tests the EDGs in their normal configuration with all starting air motors available.

EDGs technical specification surveillances do not require independent testing of individual starting air systems (motors).

The Salem Updated Final Safety Analysis Report (UFSAR) Section 9.5, and the Configuration Baseline Documentation (CBD) for the EDG system, state that the EDGs are capable of starting with only one set of starting air motors (i.e: two starting air motors).

These statements are based on the manufacturer's testing and documentation, which was provided to PSE&G at the time of purchase.

The documentation indicates the EDG's ability to start and reach 900 rpm in less than 10 seconds with only one set of starting air motors.

UFSAR Section 8.3, states that only two EDGs are needed to safely shutdown the facility under design basis conditions considering the presence of a single failure.

This is consistent with Salem's current licensing basis.

Non-TS portions of required surveillances Sl(S2).OP-ST.DG-0006 through 0008 tests the operability of the starting air motors and starting air solenoids.

This surveillance is performed once per refueling outage and independently tests the operability of each individual starting air motor and solenoid, thus providing operability assurance of each individual solenoid and motor set.

This surveillance was established in response to INPO SOER 80-01, which addressed the potential for passive air start system failures being undetectable (Rancho Seco event).

EDG operability is defined as being the capability of starting, accelerating to rated speed, and accepting accident loads and

. carrying those loads *far a prescribed amount of time.

In addition operability requires that certain minimum auxiliary equipment be available.

This minimum supporting equipment has been established by PSE&G and ALCO to assure EDG operability.

PSE&G defines EDG qualification as being the capability of an EDG unit to accomplish its design operability function.

The qualifications establish the limiting environmental conditions and the minimum supporting equipment needed for EDG operability.

These statements are consistent with Generic Letter (GL) 91-18, "Resolution of Degraded and Nonconforming Conditions and Operability Determinations", issued October 31, 1993."

APPLICABLE REGULATORY GUIDANCE PSE&G has reviewed applicable NRC guidance regarding the use of EDGs as onsite electric power sources.

This guidance is contained in Regulatory Guides and IEEE Standards, and appears to have been the basis which established the TS surveillance requirements.

Regulatory Guide 1.108 (1977) "Periodic Testing of Diesel Generators Units'Used as Onsite Electric Power Systems at Nuclear Power Plants," Regulatory Guide 1.32 (1977) "Criteria *for Safety-Related Electric Power Systems for Nuclear Power Plants,"

Regulatory Guide 1.9 (1971) "Selection of Diesel Generator Set Capacity for Standby Power Supplies", and Regulatory Guide 1.93 (1974) " Availability of Electric Power Sources" were reviewed and there was no requirement found to design the EDGs with redundant air start systems nor were requirements,established to demonstrate the redundancy of starting air systems.

IEEE Standard 387-1977 "IEEE Standard Criteria for Diesel-Generators Units Applied as Standby Pow~r Supplies for Nuclear Power Generating Stations, 11 and IEEE Std 308-1980 "IEEE Standard Criteria for Class lE Power Systems for Nuclear Power Generating Stations," were also reviewed and similarly there were no requirements found to design or test redundant starting air systems.

PSE&G also reviewed NUREG-0600 "Enhancement of On Site Emergency Diesel Generator Reliability," dated December 14, 1979, and NUREG-1431 Vol.1 "Standard Technical Specifications Westinghouse Plants" issued on September 1992, and found no requirements to independently test redundant air systems.

PSE&G POSITION With regard to the following;

"*** Since the UFSAR states that the EDG will start on any two air start motors, isolation of any air start system required entry into TS 3.8.1.1, Action a., even if the licensee had performed surveillances demonstrating the EDG capability to start on any two motors... "

"... Operability requires that the dual air systems for each diesel be functional and able to operate as designed."

It is PSE&G's position that the cited UFSAR statement is an informational statement regarding an enhancement to the Salem EDGs, *and not a regulatory requirement.

In addition to design basis information and requirements, the Salem UFSAR also contains systems/components descriptions.

These descriptions may include design enhancements originally provided by vendors, which are included in the Salem UFSAR for completeness, and were not intended to infer a design or regulatory requirement.

Accordingly, PSE&G does not believe these enhancements represent a TS operability requirement.

PSE&G reviewed NRC Generic Letter (GL) 91-18, "Resolution of Degraded and Nonconforming Conditions and Operability Determinations", issued October 31, 1993.

GL 91-18 states that operability determinations shall be made based upon the ability of the system to perform its intended safety function as described in the licensing basis.

Consequently, entering the Action Statement, when the system is still able to perform its intended safety function_ is not required by the Operability definition or its intent, as indicated in GL 91-18.

Given the TS basis (previously stated), the current licensing basis requirement (UFSAR Section 8.3), original vendor data, and recent surveillance testing, the Salem EDGs are able to perform their intended safety related function with only one set of starting air motors.

Therefore, PSE&G does not believe that entering the Action Statement is required, when one set of starting air motors is unavailable.

The following statement, which was not cited as a violation in Appendix A, refers to the surveillance program and TS requirements of the air systems;

"**.. the licensee performed inadequate surveillances required by Technical Specification 4.8.1.1.2.a.2, in that they failed to demonstrate the capability of the EDG to start on any pair of air start motors, as required by Technical Specification definition of operability and the UFSAR description of the start air system." (emphasis added)

PSE&G does not disagree with the NRC's concern regarding reliance on original qualification testing to demonstrate EDG operability.

As stated in the Inspection Report, when this concern was brought to management's attention, changes to the monthly diesel TS surveillance were promptly initiated.

The TS surveillance procedure 4.8.1.1.2.a.2 was modified to start the EDGs with only one set of starting air motors in service.

This modification was conservatively made by PSE&G, while evaluating the concern.

All Salem EDGs were satisfactorily tested using the modified procedure, thus validating the original vendor testing and documentation, and PSE&G's operability determination, i.e., that the EDGs were able to meet all design basis requirements with only one set of starting air motors.

By testing in this manner, PSE&G has obtained additional assurance regarding the reliability and dependability of the starting air system, and validated the original vendor testing and documentation.

Monthly EDG surveillance testing is performed to demonstrate that the EDGs will start and carry near rated load without evidence of significant degradation or malfunctions that might prevent the

. EDGs from accomplishing their functions.

The monthly tests do not attempt to requalify the EDGs to their maximum capability or to requalify vendor testing by requiring the EDGs to perform in the absence of certain support equipment.

Consequently, PSE&G will continue to perform the required technical specification surveillance (4.8.1.1.2.a.2) with all starting air motors available.

However, to ensure continued EDG operability with one set of starting air motors unavailable, a special non-technical specification surveillance will be performed utilizing the remaining set of starting air motors.

Based on the information presented above, PSE&G disagrees with the underlined portion of the quoted statement since there is no apparent regulatory requirement to have designed the EDGs with redundant starting air systems.

Consequently this requirement is not reflected in a TS surveillance requirement, and therefore, PSE&G does not believe that a Technical Specification violation occurred.

CONCLUSION As noted in the Notice of Violation, PSE&G has followed the practice of removing a set of starting air motors from service without declaring the EDGs inoperable.

The basis for PSE&G's decision to follow this course of action has been discussed above, and it is summarized below:

(A) The vendor's qualification testing, which documented to PSE&G the EDG's ability to start in less than 10 seconds with only one set of starting air motors, (B) The satisfactory completion of all Technical Specification surveillances associated with TS 3. 8.1.. 1, including surveillance 4.8.1.1.2 a 2, and (C) The satisfactory completion of surveillance Sl(S2).OP-ST.DG-0006 through 0008.

Based upon all the information presented above, PSE&G does not believe that there is a regulatory requirement to design, test or reverify vendor qualifications on a routine surveillance basis.

Therefore, PSE&G believes that a technical specification violation did not occur, and PSE&G remains in compliance with its Technical Specification diesel testing requirement.

However, PSE&G recognizes that its surveillance testing could be further enhanced, and the following actions were immediately taken by PSE&G management.

Operations Department management:

1. Reviewed the event with Operations personnel.
2. Conservatively revised EDG surveillance (4.8.1.1.2. a. 2) testing procedure to require independent testing of the starting air motor set.

This test has been satisfactorily conducted on all EDGs.

The following actions will be taken to enhance PSE&G's surveillance program.

1. A non technical specification surveillance will be developed to independently test the ability of the individual set of starting air motors to start the EDGs in slO seconds.

This surveillance will bt;= performed every refueling outage.

2. Whenever a set of starting air motors is removed from service, the EDG will be tested to ensure that the remaining set of starting air motors is still capable to start the EDG in s 10 seconds.

Successful completion of this test will demonstrate continued EDGs Operability.

3. The monthly TS surveillance requirement 4.8.1.1.2. a. 2 will be revised to test the EDGs in their normal configuration. i.e.: all starting air motors available.
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