Text

Responds to NRC 931103 Ltr Re Violation Noted in Insp Repts 50-272/93-21 & 50-311/93-21.C/As:reviewed Circumstances Surrounding Event W/Personnel Involved & All Other Licensed Operations Personnel During Requalification Training
	ML18100A753
Person / Time
Site:	Salem
Issue date:	12/01/1993
From:	Hagan J; Public Service Enterprise Group
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	NLR-N93192, NUDOCS 9312130414
	Download: ML18100A753 (12)
	v • d • e

Joseph J. Hagan Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200

Vice President

-Nuclear Operations

DECO 11993 * NLR-N93192

United states Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION

INSPECTION

REPORT 50-272/93-21;

50-311/93-21

DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection

Report 50-272/93-21;

50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical

Specification

Action Statement

3.3.2.1 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 us.

931201 (i DCK 05000272 Yi PI)R .'*** . ......._ Sincerely,

. -Document Control Desk NLR-N93192

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 Inspector

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 OEC 0 1 7993 ) * * *

._ "* 1 * * * REF: NLR-N93192

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 knowledge, information

and belief. Subscr,bed

and wo Do before me

'da: Al'* , 1993 -t>*>

N tary Publ 4 Cf New Jersey My Commission

expires on KIMBERLY JO BROWN NOTARY PUBUC

My Commission

Exp11es Ppra

.-NLR-N93192

ATTACHMENT

I During an NRC inspection

conducted

on September 5 -October 16, 1993, a violation

of NRC requirements

was identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRC Enforcement

Actions," 10 CFR Part 2, Appendix c (1992), the violation

is listed below: Salem Unit 1 Technical

Specification (TS) Action Statement

3.3.2.1 requires that when an Engineered

Safety Feature Actuation

system instrumentation

channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies

that when an automatic

actuation

logic channel for the safety injection, turbine trip and feedwater

isolation

function is inoperable, the inoperable

channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following

30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . Contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection

System Train B Feedwater

Isolation

Circuit at Salem Unit 1 failed a surveillance

test, the failed channel was not subsequently

restored to an operable status, and it was not until approximately

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the test failure that unit operators

initiated

a plant shutdown due to the inoperable

channel. This is a Severity Level IV violation (Supplement

1). 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;

an.d (3) the date when full compliance

will be achieved. ,J * * *

) . * ** * NLR-N93192

PSE&G RESPONSE PSE&G does not dispute. the violation

ROOT CAUSE on July 11, 1993, operators

were testing the Slave Relay K601 (Safety Injection

circuit) in the "B" train of the Solid State Protection

System (SSPS), using surveillance

procedure

During the performance

of this surveillance, operations

personnel

stopped slave relay testing when a problem occurred in obtaining

a test meter reading. Based upon an initial print review and past test circuit problems, operators

believed that the problem was in the test circuit portion of the output relay. The SSPS system was not declared inoperable

at this time, as the test circuit is independent

of the normal SSPS function, and a work order was initiated

to investigate

the problem. Later on this date, .operations

shift personnel

were informed that the test circuit had not failed and that the surveillance

results showed an SSPS circuit failure. The SSPS (train B) was declared inoperable

and the appropriate

action statement

was entered. Train "A" remained operable for the period such that full protection

was available.

The initial operability

determination

was based upon the Senior Reactor Operator's (SRO) technical

knowledge, past experience, and review of available

technical

information.

However, PSE&G's management

review determined

that the operability

determination

of the SSPS slave relay was not accurately

diagnosed

on July 11, 1993. *Additionally, PSE&G management

noted that the SSPS action statement

requirements, and the onset of initial troubleshooting

were not commenced

until the six hour action statement

period had expired. Management

determined

that the initiation

of troubleshooting

was delayed inappropriately.

It is PSE&G's management

expectation

that system operability

and timely pursuit of problem identification

and resolution

must be commensurate

with the potential

safety significance

of the issue. The root cause of this event has been attributed

to lack of appropriate

oversight

regarding

the initiation

of the troubleshooting

activities.

The review determined

that the SSPS troubleshooting

activities

delay was inappropriate

when considering

the importance

of the system and the short Technical

Specification

action statement

requirement

CORRECTIVE

ACTIONS TAKEN AND THE RESULTS ACHIEVED 1. Operations

Department

Management:

Reviewed the circumstances

surrounding

this event with the personnel

involved and all other licensed operations

personnel

during requalification

training.

Initiated

SSPS surveillance

procedure

reviews and revision to direct attention

to technical

specification

action statements

when system performance

is either deficient

or operability

is questionable.

The procedures

were revised to require that the system be declared inoperable

when any deviation

from the expected reading is obtained.

Additionally, an Instrument

& Control technician

will be present at all times during system testing. Via the Night Order Book, issued instructions

to all operating

personnel

regarding

the appropriate

action statement

entry, including

instruction

to enter the SSPS action statement

whenever abnormal readings are encountered

during system tests. 2. Positive disciplinary

action has been taken with the appropriate

personnel.

CORRECTIVE

STEPS WHICH WILL BE TAKER TO AVOID FURTHER VIOLATIONS

PSE&G management

strongly re-emphasized

its expectation

of taking timely corrective

actions, specifically

when dealing with Technical

Specification

systems or equipment.

PSE&G believes that adequate controls are now in place to address prompt and timely resolution

of operability

issues. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED PSE&G is in full compliance.

* * *

' .. *

J. Hagan Public Service Electric and Gas *company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200

* Vice President

-Nuclear Operations

DECO 11993 NLR-N93192

United States Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION

INSPECTION

REPORT 50-272/93-21;

50-311/93-21

DOCKET NOS. 50-272; 50-311 Public Service Electric and Gas (PSE&G) has received the NRC Inspection

Report 50-272/93-21;

50-311/93-21, dated November 3, 1993. Within the scope of this report, a Salem Unit 1 Technical

Specification

Action Statement

3.3.2.1 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 us. Sincerely,

' .. * * * Document Control Desk NLR-N93192

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 Inspector

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 DEC 0 1 7993

' ' . \I * * * REF: NLR-N93192

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 knowledge, information

and belief. Subscr;bed

and wo before me , da: 0:0 00 Yp /(l.,vi , 1993 -1* 1 J bv1._f.z

OU l -'; \..._ N tary Publ 4 Cf New Jersey KIMBERLY JO BROWN My Commission

expires on NOTARY PUBLIC OF NEW JERSEY

. \I * * * NLR-N93192

ATTACHMENT

I During an NRC inspection

conducted

on September 5 -October 16, 1993, a violation

of NRC requirements

was identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRC Enforcement

Actions," 10 CFR Part 2, Appendix C (1992), the violation

is listed below: Salem Unit 1 Technical

Specification (TS) Action statement

3.3.2.1 requires that when an Engineered

Safety Feature Actuation

system instrumentation

channel is inoperable, the Action shown in Table 3.3-3 of the TS must be taken. Table 3.3-3 specifies

that when an automatic

actuation

logic channel for the safety injection, turbine trip and feedwater

isolation

function is inoperable, the inoperable

channel must be restored to an operable status within six hours or the plant must be in Hot Standby within the next six hours and in Cold Shutdown within the following

30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . contrary to the above, at 5:30 a.m. on July 11, 1993, the Solid State Protection

System Train B Feedwater

Isolation

Circuit at Salem Unit 1 failed a surveillance

test, the failed channel was not subsequently

restored to an operable status, and it was not until approximately

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the test failure that unit operators

initiated

a plant shutdown due to the inoperable

channel. This is a Severity Level IV violation (Supplement

1). 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-N93192

PSE&G RESPONSE PSE&G does not dispute the violation

ROOT CAUSE On July 11, 1993, operators

were testing the Slave Relay K601 (Safety Injection

circuit) in the "B" train of the Solid State Protection

System (SSPS), using surveillance

procedure

Sl.OP-ST.SSP-0010.

During the performance

of this surveillance, operations

personnel

stopped slave relay testing when a problem occurred in obtaining

a test meter reading. Based upon an initial print review and past test circuit problems, operators

believed that the problem was in the test circuit portion of the output relay. The SSPS system was not declared inoperable

at this time, as the test circuit is independent

of the normal SSPS function, and a work order was initiated

to investigate

the problem. Later on this date, .operations

shift personnel

were informed that the test circuit had not failed and that the surveillance

results showed an SSPS circuit failure. The SSPS (train B) was declared inoperable

and the appropriate

action statement

was entered. Train "A" remained operable for the period such that full protection

was available.

The initial operability

determination

was based upon the Senior Reactor Operator's (SRO) technical

knowledge, past experience, and review of available

technical

information.

However, PSE&G's management

review determined

that the operability

determination

of the SSPS slave relay was not accurately

diagnosed

on July 11, 1993. * Additionally, PSE&G management

noted that the SSPS action statement

requirements, and the onset of initial troubleshooting

were not commenced

until the six hour action statement

period had expired. Management

determined

that the initiation

of troubleshooting

was delayed inappropriately.

It is PSE&G's management

expectation

that system operability

and timely pursuit of problem identification

and resolution

must be commensurate

with the potential

safety significance

of the issue. The root cause of this event has been attributed

to lack of appropriate

oversight

regarding

the initiation

of the troubleshooting

activities.

The review determined

that the SSPS troubleshooting

activities

delay was inappropriate

when * considering

the importance

of the system and the short Technical

Specification

action statement

requirement .

' ... * * * CORRECTIVE

ACTIONS TAKEN AN.D THE RESULTS ACHIEVED 1. Operations

Department

Management:

Reviewed the circumstances

surrounding

this event with the personnel

involved and all other licensed operations

personnel

during requalification

training.

Initiated

SSPS surveillance

procedure

reviews and revision to direct attention

to technical

specification

action statements

when system performance

is either deficient

or operability

is questionable.

The procedures

were revised to require that the system be declared inoperable

when any deviation

from the expected reading is obtained.

Additionally, an Instrument

& Control technician

will be present at all times during system testing. Via the Night Order Book, issued instructions

to all operating

personnel

regarding

the appropriate

action statement

entry, including

instruction

to enter the SSPS action statement

whenever abnormal readings are encountered

during system tests. 2. Positive disciplinary

action has been taken with the appropriate

personnel . CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

PSE&G management

strongly re-emphasized

its expectation

of taking timely corrective

actions, specifically

when dealing with Technical

Specification

systems or equipment.

PSE&G believes that adequate controls are now in place to address prompt and timely resolution

of operability

issues. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED PSE&G is in full compliance

ML18100A753

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