ML18100A880

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

ML18100A880
Person / Time
Site:	Salem
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)

See also: IR 05000272/1993023

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

Report 50-272/93-23,

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 r 1 ... '" . '" ... * . .. .. 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

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

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.