ML18100A880
| 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
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.