ML18079A657

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Responds to NRC 790315 Ltr 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 PSEG icon.png
Issue date: 04/06/1979
From: SCHNEIDER F W
Public Service Enterprise Group
To: GRIER B H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18079A656 List:
References
NUDOCS 7908020057
Download: ML18079A657 (7)


See also: IR 05000272/1979002

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

on March 19, 1979. The following

information

is . provided as a response to_ your report: : :.. 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 across the denser shall not exceed 16.5°F during normal operation

with all circulation

water pumps operating.

During pump outage, the maximum. 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, rective action shall be taken to reduce the to within specification.

Contrary to these requirements:

1. The 16.5°F maximum across the condenser

was exceeded during normal operation

with all six circulating

water pumps on several occasions, cluding December 9, 10, 11 and 12, 1978. rective actions taken were untimely

adequate to reduce the condenser to within specification.

  • (_) * -. . Boyce H. Grier --2-4-6-79 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

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 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 -3-4-6-79 cholorination

system in compliance

with the limiting conditions

for operation

established

in Section 2.2.1 of Appendix B, ETS were not 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_ 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 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 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.

  • ' . --1 Boyce H. Grier -4-\... 4-6-79-2. 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 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 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 limits. Station Incident Reports document all instances

of exceeding

AT limit. These incident reports provide the reason for ceeding the AT limit and the justification

for the termination

that the incident was not reportable.

To rect 'the situation

all pertinent

documents .are now available

for review by the inspector.

  • 2. Future items of noncompliance

will be prevented

by the 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 tions,. shall* be prepared and followed for all activities

involved in carrying out the*ETS. -Procedures

for the environmental veillance

and*special

study*programs

described

in Section 3 and 4 shall be prepared*by*personnel

responsible

£or the particular

  • 11> ..... i \ ' . 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 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 rective actions. These include:

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

pipe and

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 charge on November 8, October 24 .and September

26, 1978, .were not

  • () * . ' -Boyce H. Grier -6-4-6-79_ 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 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

Our response to item "G" is: 1. During the month of August

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. * ,_*

--** \.', * .... * i .. -. Boyce H. Grier -7-4-6-79 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 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,