ML20028C985
| ML20028C985 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/22/1982 |
| From: | Uderitz R Public Service Enterprise Group |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20028C981 | List: |
| References | |
| NUDOCS 8301140375 | |
| Download: ML20028C985 (6) | |
Text
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A Cichard A. Uderitz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 935-6010
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December 22, 1982 Mr. Ronald C. Haynes, Regional Administrator Region'I - Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Richard N. Starostecki, Director Division of Project and Resident Programs Gentlemen:
NRC COMBINED INSPECTION 50-272/82-27, 50-311/82-26 SALEM GENERATING STATION UNITS NO. 1 AND 2 SEPTEMBER 28 THRU NOVEMBER 8, 1982 The following is our response to the items of violation identified during the subject inspection.
ITEMS OF VIOLATION Item A Technical Specification 4.0.3 states that failure to perform a surveillance requirement within the specified time interval shall constitute a failure to meet the operability require-ments.
Technical Specification 3.3.3.6 requires that fire detection instrumentation for each required fire detection zone shall be operable or compensatory measures be established.
Technical Specification 4.3.3.6.1 requires the accessible fire detection instruments shall be demonstrated operable at least once per 6 months by performance of a functional test.
Contrary to the above:
As of October 25, 1982, there was a failure to meet operability requirements, and required compensatory measures were not established, for fire detection instruments in the zones containing the " Iodine Re-moval System" and the " Pressure Relief System" in that surveillance functional tests had not been per-formed since March 18, 1979.
8301140375 830112 U
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1 Mr.
R.
C. Haynes,s Regional Administrator
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U.S.
Nuclear Regulatory Commission 12/22/82 Reply to Item A At 1615 nours, October 25, 1982, it was discovered that the thermal detectors for the Units 1 and 2 Iodine Removal Systems and Pressure Relief Systems had not been included-in'the fire detection instrumentation surveillance procedures.
Conse-quently, testing of the detectors in accordance with Units 1 and 2 Technical Specification Surveillance Requirements 4.3.3.6.1 had not been performed since system installation.
Following discovery of the problem, containment air tempera-tures were monitored on an hourly basis.
Fire watch patrols were established to inspect the pressure relief charcoal filter areas until the detectors could be tested.
Surveillance of the detectors was satisfactorily completed on October 27, 1982.
The detectors were determined to be operable, thereby providing reasonable assurance that they have been operable since installation, and.that no risk to the health and safety of the general public existed.
The instrumentation was inadvertently omitted from the surveil-lance procedures at the time of writing.
The oversight appar-ently occurred during a review of the technical specifications for the purpose of determining testing requirements.
The omission was subsequently overlooked during the performance of the surveillance.
Upon discovery of the omission, additional protection was provided by the surveillance of containment temperatures and fire watch patrols.
A review of fire detection instrumentation surveillance re-vealed no additional inadequacies.
New procedures were written for testing the iodine removal and pressure relief detectors; they are presently in the review process.
Implementation is expected to be complete before the surveillance is next due.
Item B Technical Specification 4.0.2 requires each Surveillance Re-quirement be performed within the specified interval with a maximum extension not to exceed 25% of the inter'al and the combined time interval for any 3 consecutive surveillance intervals not to exceed 3.25 times the specified surveillance interval.
Contrary to the above:
As of October 26, 1982, the following Surveillance Require-ments had not been perfomed within their respective specif-ied surveillance intervals.-
5
/
Mr.-R. C.
Haynes,' Regional Administrator U.S.
Nuclear Regulatory Commission 12/22/82 1.
4.4.7.2.d Performance of Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (Unit 2).
This surveillance was performed 4:10 a.m., October 16, 1982.
It was then re-quired by 10:10 p.m.,
October 19 ~(including 25%
extension) and was performed satisfactorily at 7:53 a.m.,
October 20, 1982.
2.
4.4.7.2.d Performance of Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ( Un i t. :2 ).
This surveillance was performed at 4:10 a.m., October 16, 7:53 a.m.,
October 20, and 4:46 a.m., October 23,.1982, respectively.
It was then required by 10:10 p.m., October 25 (determined by 3.25 times interval for 3 consecu-tive surveillance intervals) and was performed satisfactorily at 11:52 a.m.,
October 25, 1982.
3.
4.1.1.2.b Performance of Shutdown Margin calcu-lation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when in Mode 5 (Unit 1).
This surveillance was performed at 9:15 a.m., October 17, 1982.
It was then re-quired by 3:15 p.m., October 18 (including 25%
extension) and was performed satisfactorily at 9:00 p.m.,
October 18, 1982.
Reply to Items B1 and B2 At 0001 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, October 20, 1982, during routine operation, the Control Room Operator observed that Surveillance Procedure SP(O)4.4.7.2.d, Reactor Coolant System (RCS) Water Inventory, had not been performed within the time interval required by the Technical Specifications.
The previous RCS water inventory had been performed at 0410 hours0.00475 days <br />0.114 hours <br />6.779101e-4 weeks <br />1.56005e-4 months <br />, October 16, 1982; at 2210 hours0.0256 days <br />0.614 hours <br />0.00365 weeks <br />8.40905e-4 months <br />, October 19, 1982, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> surveillance interval plus 25%
allowance had elapsed.
An RCS inventory was immediately commenced; surveillance of the containment sump pump and containment radioactivity monitor demonstrated RCS leakage was within limits.
Before the RCS inventory could be completed, a small forced load reduction occurred.
The load reduction was due to a decrease in condenser vacuum.
Due to the load change, steady state RCS conditions could not be maintained.
These conditions are required for satisfactory performance of the surveillance procedure.
The surveillance was subsequently performed when. conditions stabi-lized, and the RCS leak rate was determined to be satisfactory at 0753 hours0.00872 days <br />0.209 hours <br />0.00125 weeks <br />2.865165e-4 months <br />, October 20, 1982.
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-Mr.
R.
C.- Haynes, Regional Administrator-U.S.
Nuclear Regulatory Commission ' 12/22/82 Reply to Items B1 and B2 (continued)
At 0446_ hours, October 26, 1982, the Control Room Operator noted that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> had elapsed since the previous performance of the RCS. inventory.
The surveillance could not be performed at that time, however, due to a load reduction resulting from planned maintenance on the circulators.
Further investigation revealed that the RCS inventory was overdue.
Technical Specification 4.0.2.b requires that the combined time for any 3 consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval.
The inventory.
had been performed, as noted, at 0410 hours0.00475 days <br />0.114 hours <br />6.779101e-4 weeks <br />1.56005e-4 months <br />, October 16, 1982.
The third consecutive surveillance was, therefore, due at 2210 hours0.0256 days <br />0.614 hours <br />0.00365 weeks <br />8.40905e-4 months <br />, October 25, 1982, not on the following day as assumed.
.The leak rate was again verified to be in specification using the containment sump and radioactivity monitor' systems.
When operating conditions stabilized, the RCS inventory was per-formed satisfactorily at 1152 hours0.0133 days <br />0.32 hours <br />0.0019 weeks <br />4.38336e-4 months <br />, October 26, 1982.
In both instances, timely performance of the test was over-looked.
The situation was aggravated by the failure of the sur-veillance requirement to make allowance for routine, unavoidable transients which preclude performance of the surveillance.
License Change Request 82-14 was submitted on October 5, 1982 to eliminate the Technical Specification inventory requirement during non-steady state operation.
Operations personnel involved in the incidents were counseled concerning the Technical Specification surveillance require-ment.
Finally, to insure completion within the surveillance interval, performance of the RCS water inventory was scheduled on a regular, reduced interval basis.
Reply to Item B3 On October 18, 1982, during routine shutdown operations, it was discovered that the shutdown margin calculation had not been performed within the interval required by Technical Specifi-cation Surveillance Requirement 3.1.1.2.
The calculation had been satisfactorily completed at 0915 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.481575e-4 months <br />, October 17, 1982, and was due, including the 25% allowance, at 1515 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.764575e-4 months <br />, October 18, 1992.
The surveillance was satisfactorily performed at 2100 hou <, October 18, 1982; the shutdown margin was greater than 1.0% delta k/k,
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-h Mr._R. C.'Haynes, Regional' Administrator U.S.
Nuclear Regulatory l Commission 12/22/82 Reply to Item B3 (continued)
The_ shutdown margin calculation-was not performed due to personnel oversight.
A review of the administrative and procedural controls involved in the scheduling and performance of periodic surveillances revealed no major problems.
No recent similar occurrences were noted, and the event was determined to be of an isolated. nature-and posed no risk to the health and safety of_-the general public.
Personnel involved with the incident were counseled concerning the Technical Specification surveillance requirements for shutdown margin.
In view of the nature of the occurrence, no further action was deemed necessary.
Very truly yours, CC:
Director, Office of Inspection and Enforcement U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Leif J.
Norrholm NRC Senior Resident Inspector i
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RICHARD A. UDERITZ,.being duly sworn according'tio' 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 December 20, 1982, to the NRC's combined L
' inspection report 50-272/82-27 and-50-311/82-26 are true to the-best of my knowledge information and belief.
_1 RICHARD A.
U DERITF -
Subscribed and sworn to before me this 27th day of hemhe.c 1982 l
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