ML20070C328

Responds to NRC Re Violations Noted in IE Insp Repts 50-272/82-25 & 50-311/82-24.Corrective Actions:Tech Spec 3.0.4 Will Be Discussed W/Personnel.Tech Spec 3.3.3.5 Limiting Condition for Operation Not Violated

ML20070C328
Person / Time
Site:	Salem
Issue date:	11/05/1982
From:	Uderitz R Public Service Enterprise Group
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20070C300	List: ML20070C328
References
NUDOCS 8212140133
Download: ML20070C328 (4)

Text

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Richard A. Uderitz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 935 6010 Vice President -

Nuclear November 5, 1982 Mr. Ronald C. Haynes, Regional ~ Administrator Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Haynes:

NRC COMBINED INSPECTION 50-272/82-25, 50-311/82-24 SALEM GENERATING STATION UNITS NO. 1 AND 2 SEPTEMBER 1 THRU SEPTEMBER 27, 1982 We have reviewed the items of violation which were identified in the subject inspection and described in Appendix A of your letter dated October 6, 1982. The following are our responses to those identified items:

ITEMS OF VIOLATION Item A.1 Technical Specification 6.9.1.9.b requires the submittal of a written report within 30 days of operation in a degraded mode i permitted by a limiting condition for operation. Technical Specification 3.3.3.5 permits operation of up to seven days

, with a steam generator level channel at the Hot Shutdown

! Panel out of service.

Contrary to the above:

No report was submitted by September 22, 1982 for a f ailure of Steam Generator 23 Wide Range Level i

instrumentation at the Hot Shutdown Panel which was discovered on July 27, 1982 and repaired on i July 28, 1982.

l i Reply to Item A.1

The failure of the No. 23 Steam Generator Level Channel on July 27, 1982, and the subsequent repair on July 28, 1982 was l a referenced item in the No. 2 Unit Monthly Operating Report-(, August, 1982. An Action Statement was not entered into and j subsequently a Licensee Event Report was not prepared.

l 8212140133 821206 DR ADOCM 0500G272 .

PDR l.

Mr. Ronald C. Haynes, Regional Administrator U. S. Nuclear Regulatory Commission 11/5/82 Reply to Item A.1 (continued)

This situation was pointed out by the NRC Senior Resident Inspector; but, due to oversight, was not investigated promptly. Upon investigation, it was determined that there was no violation of the Limiting Condition for Operation for Technical Specification 3.3.3.5 since the No. 23 Steam Generator Level Channel which failed was 2LI-1642 which is a narrow range, Hot Shutdown indication. The wide range indication, Channel 2LI-503, is a Technical Specification item; but, it was functioning properly. Also, there is another narrow range indication for tinis Steam Gelerator in the Hot Shutdown Panel. This indication was also functioning properly. We therefore met the Technical Specification requirements of 1 wide range and 1 narrow range indication.

Item A.3 Technical Specification 3.0.4 and 3.3.1.1 prohibit closing the reactor trip breakers unless both source range nuclear instrument charnels are operable.

Contrary to the above:

On August 9, 1982, with Source Range Channel N31 inoperable in Mode III, the trip breakers were shut for testing. No rods were withdrawn.

Reply to Item A.2 Following a Unit No. 1 reactor trip on August 9, 1982 with Source Range Channel N31 inoperable, a restart was delayed until the channel was repaired and verified operable. While N31 waa inoperable, the reactor trip breakers were closed to test th P-4 interlock. This was, in fact, a violation of Technica l Specification 3.0.4. During this incident no rod withdrawals took place and Limiting Condition for Operation 3.3.1.1 Action 40 was entered.

l The licensed operators on duty were aware of Technical Specification 3.0.4 and therefore, did not attempt to change modes until Channel N31 was once again operable. The operating personnel inadvertently overlooked the portion of

[ Technical Specification 3.0.4 which prohibits entry into any l "other specified condition" unless the Limiting Condition for Operation is met without reliance on the provisions of the Action Statements.

l l _ -

.r-

6 . .

4 Mr. Ronald C. Haynes, Regional Administrator U. S. Nuclear Regulatory Commission 11/5/82 Reply to Item A.2 (continued)

The corrective action to be taken which will eliminate future violations of this type is as follows: .

The violation listed above and the' conditions leading up to it, as well as a discussion of Technical Specification 3.0.4, its basis, and its various ramifications will be presented to all licensed operating personnel.

This presentation will take place on a shift by shift basis at the weekly shift meeting. The Operating Engineer and/or the Senior shift Supervisor-Days will discuss this problem with the Senior Shift Supervisor and the Shift Supervisors of a particular shift who will conduct a discussion with the Nuclear Control Operators on their shift. The Training Department will also be made aware of this situation and will discuss it with the licensed operating personnel currently assigned to the Nuclear Training Center for licensing requalification.

The above mentioned discussions are anticipated to be completed with all licensed shift operating personnel by January 1, 1983.

l Sincerely, i

M CC: Director, Office of Inspection and Enforcement Nuclear Regulatory Commission Washington, D.C. 20555 l

l NRC Senior Resident Inspector - Salem L.

< . . 9 4-STATE OF NEW JERSEY )

) SS. COUNTY OF SALEM COUNTY OF SALEM

RICHARD A. UDERITZ, being duly sworn according to law deposes

, and says:

I am a Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our response dated November 4, 1982, to the NRC's combined inspection report 50-272/82-25 and 50-311/82-24 are true to the best of my knowledge information and belief.

)

W

' RICHARD A. UDEFITV z

l Subscribed and sworn to before me this' @ day of M W 1982

$ n-u Af"E5e d

"" Notary Public' of New Jersey l BRIAN Mci'EEVER NOTARY PU3uc 0F fiEW JERSEY My Commission expires on ,.

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