ML18100A880

Responds to NRC 940110 Ltr Re Violation Noted in Insp Repts 50-272/93-23 & 50-311/93-23.Corrective actions:non-TS Surveillance Will Be Developed to Independently Test Ability of Individual Set of Starting Air Motors to Start EDGs

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)

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 In~pecti6n Report 50-272/93-23, 50-311/93-2~, 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.

Sincerely,

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9402180273 940210 PDR ADOCK 05000272 Q PDR

FEB 10 1994 Document Control Desk 2 NLR-N94018 Attachment (1) 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

REF: NLR-N94018

/

STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

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 knowl~dge, information and belief.

Subscribed KIMBERLY JO BROWN My Commission expires on 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 e~ch 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 Pow~r 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 Westinghouse 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.