IR 05000272/1997009
| ML18102B612 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/08/1997 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| Shared Package | |
| ML18102B613 | List: |
| References | |
| 50-272-97-09, 50-272-97-9, 50-311-97-09, 50-311-97-11, 50-311-97-9, EA-97-182, EA-97-257, NUDOCS 9710150188 | |
| Download: ML18102B612 (7) | |
Text
October 8, 1997
SUBJECT:
NOTICE OF VIOLATION AND EXERCISE OF DISCRETION (NRC Inspection Report Nos. 50-272; 50-311/97-09 and 50-311/97-11)
Dear Mr. Eliason:
This letter refers to two NRC inspections conducted at Salem Units 1 and 2 between March 24 and April 18, 1997. The first inspection was a special inspection conducted to examine the emergency core cooling system (ECCS) semi-automatic switchover (from the injection mode to long-term recirculation cooling) and related residual heat removal (RHR)
system flow issues at Unit 2. The second inspection examined certain aspects of your fire protection programs for Units 1 and 2. The findings of these inspections were discussed with Mr. E. Simpson and other members of your staff at exit meetings on April 17, and April 23, 1997, respectively. The inspection reports were forwarded to you on June 3, 1997, and May 22, 1997, respectively. In the letters forwarding these reports, we indicated that it was not necessary to conduct a predecisional enforcement conference (conference) in order to enable the NRC to make an enforcement decision on the apparent violations of NRC requirements that were identified during the inspections.
However, you stated your preference to have a conference. On July 10, 1997, a conference was conducted with Mr. Simpson and other members of your staff to discuss the violations, their causes, and your corrective actions.
With respect to the first inspection which focused on ECCS and RHR design issues, the apparent violations of NRC requirements identified involved: (1) untimely identification and correction of a significant condition adverse to quality; (2) noncompliance with technical specifications (TS) for emergency core cooling systems; (3) three examples of failures to obtain NRC approval for changes to the facility which constituted unreviewed safety questions (USQs); (4) two examples of failure to report unanalyzed conditions outside the Salem Unit 2 design basis; and (5) failure to update the Updated Final Safety Analysis Report (UFSAR).
Based on the information developed during the inspection and the information provided during the conference, two violations associated with the switchover of ECCS from the injection mode to long-term recirculation cooling are being cited. The remaining five violations are not being cited as described herein.
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Public Service Electric and Gas Company
In November 1995, Westinghouse performed an evaluation of the drain-down of the refueling water storage tank (RWST) associated with the switchover of ECCS from the injection mode to long-term recirculation cooling. In March 1996, changes were made to the emergency operating procedures (EOPs) and the UFSAR that reflected the changes in RWST drain down time and operator response time as determined by the Westinghouse evaluation.
That evaluation identified that, under certain conditions, the operators may not have been able to complete the switchover in time to prevent interruption of ECCS flow to the core. This was contrary to the design bases for Unit 2 which assumed uninterrupted flow during the switchover. The interruption of emergency core cooling flow that could occur increased the probability of a failure of the ECCS pumps. Therefore, the changes to the EOPs and the UFSAR that reflected the changes in RWST drain down time and operator response time, involved a USQ. As such, the failure to obtain NRC approval prior to making 'the changes constituted the first example of a violation of 10 CFR 50.59. Additionally, the failure to report the condition that was outside the design bases of Unit 2 constituted the first example of a violation of 10 CFR 50.72 and 10 CFR 50.73. These violations resulted from activities following the shutdown and; therefore, did not meet the criteria for exercise of discretion in accordance with Section Vll.B.2 of the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600. These violations are cited in Section I of the enclosed Notice of Violation (Notice).
The transfer of ECCS pump suctions from the RWST to the containment. sump during the switchover in response to a loss of coolant accident is one of the most risk significant operator actions at Salem. Failure to complete this evolution successfully prior to drain-down of the RWST would result in interruption of ECCS flow to the core, and significant increase in the risk of core damage. The reduced time available to the operators to complete the switchover introduced an increased probability of failure, and decreased the overall available margin to perform these risk-significant operator actions. Therefore, the violations associated with the switchover have been classified in the aggregate as a Severity Level Ill problem in accordance with the Enforcement Policy.
In accordance with the Enforcement Policy, a civil penalty is considered for a Severity Level Ill problem. However, because a significant enforcement action ($600,000 civil penalty issued in October 1995) has already been taken based on similar deficiencies in your engineering programs, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regulatory Effectiveness, to exercise discretion in accordance with Section Vll.B.6 of the Enforcement Policy to not propose a civil penalty in this case.
In deciding to exercise discretion, the NRC also considered that, subsequent to identification of the concerns by the NRC, your corrective actions were prompt and effective. These corrective actions included, but were not limited to: (1) revision of EOPs to accomplish the ECCS switchover within licensed times and without interruption of flow to the core; (2)
improvements to your 50.59 program; (3) establishment of a design and licensing basis review project; (4) establishment of Site. Operations Review Committee (SORC) expectations for maintenance of the licensing basis; and (5) improved reportability reviews.
Public Service Electric and Gas Company
The other deficiencies identified during the ECCS inspection involved your actions associated *
with an identified RHR excessive flow condition. As of October 19, 1992, information was available to your staff which indicated that the functionality of long-term ECCS cooling was in question due to predicted RHR pump runout and the loss of net positive suction head (NPSH) that would result from the excessive flow condition. A modification to correct the condition was not implemented until July 1994. This delay in addressing an identified significant condition adverse to quality constitutes a violation of 10 CFR Part 50, Appendix B, Criterion XVI. The runout concern with the RHR pumps caused the facility to be in violation of its TS in that two independent RHR subsystems were not capable of supplying reactor coolant system (RCS) hot leg recirculation cooling from identification of the condition in October 1992 until the modification was made in July 1994. Upon recognition of the runout condition in October 1992, your.failure to report operation of the facility in this unanalyzed condition pursuant to 10 CFR 50. 72 and 10 CFR 50. 73 constituted the second example of a violation of these NRC reporting requirements.
In addressing related concerns with increased RHR system flows predicted during the initiation of the cold leg recircula.tion mode, it was found that changes in the EOPs and the UFSAR were needed to reflect the higher predicted flows. These changes were based on calculations that credited containment overpressure for maintenance of required NPSH. The reliance on containment overpressure was inconsistent with the licensing basis for Unit 2, and constituted an unreviewed safety question (USQ).
The change constituted an USO because the probability of a malfunction of the RHR pumps was increased. Failure to obtain NRC approval prior to implementing a change that involved an USO, is the second example of a violation of 10 CFR 50.59.
The violations involving the potential RHR pump runout condition and the crediting of containment overpressure in RHR pump NPSH calculations, are not being cited in accordance with the criteria of Section Vll.B.2 of the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600. These violations are not being cited because they stem from licensed activities prior to the shutdown period and have since been addressed by broad comprehensive PSE&G programs underway at Salem to identify and correct such problems.
The elimination of a hot leg recirculation flowpath to address the RHR pump runout concern was identified as the third apparent violation of 10 CFR 50.59 involving an USO. The NRC determined through subsequent discussions with PSE&G staff and confirmed at the conference, that the elimination of the hot leg recirculation flowpath did not increase the susceptibility of single failure of the hot leg recirculation function, and therefore the modification did not involve an USO. Consequently there was no violation of 10 CFR 50.59.
Another violation stemming from this ECCS inspection, involving the failure to update the UFSAR to reflect the semi-automatic switchover of ECCS pump suction sources from the RWST to the containment sump following approval of License Amendment No. 69, is being treated as a Non-Cited Violation (NCV) consistent with Section Vll.B.1 of the Enforcement Policy. The failure to update the UFSARwas identified by your staff during the Salem UFSAR Project, and appropriate corrective actions were taken to revise the UFSAR.
- Public Service Electric and Gas Company
During the fire protection program inspection of April 1997, two apparent violations were identified, involving ( 1) inadequate post-fire alternative shutdown system design which relied on a significant number of repairs to achieve and maintain hot-standby plant conditions; and (2) failure to adequately qualify installed electrical raceway fire barrier systems (ERFBSs).
Based on information developed during the inspection and the information provided at the conference, two violations involving your failure to assure that ERFBSs were installed -in accordance with NRC guidelines and failure to maintain compensatory measures for degraded fire barriers. are being cited and one violation involving your failure to meet electrical independence requirements for the post-fire alternative shutdown system design is not being cited;
In May 1993, the inspectors found that the fire resistive capability of three-types of one hour ERFBSs was in question.
These conclusions were based on the fact that the installed configurations of the ERFBSs were not representative of the tested configurations approved by the NRC. During the fire protection program inspection in April 1997, the inspectors found that the qualification status of each fire barrier type remained unchanged since the 1993 inspection. Firewatch patrols, required to compensate for the unqualified fire barriers, were in place at the time of the 1993 inspection; however, on April 8, 1997, you discovered :that the fire watches had not been maintained. Apparently, the fire watches were terminated following completion of the fire damper project in April 1994. Based on the information developed during the inspections, and the information provided during the conference, the NRC has concluded that the failure to assure that the installed ERFBS configurations replicated the tested configurations and the failure to maintain appropriate compensatory measures constituted violations of NRC fire protection program requirements. Because both Units were shutdown during most of the time that compensatory measures were not in* place, the violations have been classified at Severity Level IV in accordance with the Enforcement Policy.
We determined that you had several opportunities to address the technical issues associated with the qualification of the ERFBSs, including via three Information Notices (IN 93-40, IN 93-41 and IN 95-52), a Generic Letter (GL 92-08), and, most notably, your own self assessment, dated March 1 996, which identified the same technical problems noted by the NRC in 1993.
The failure to initiate corrective action for these problems until April 1997, reflected current performance, and therefore, the criteria for exercise of discretion in accordance with Section Vll.B.2 of the Enforcement Policy were not met in this case. The violations are cited in Section II of the enclosed Notice.
Also, in May 1993, the NRC ldentified concerns related to the post-fire alternative shutdown system design. Following a meeting in February 1996, and review of your written responses, the staff concluded, in a letter dated March 17, 1997, that the alternative shutdown system did not meet the NRC electrical independence requirements (contained in a license condition for Unit 2 and 10 CFR Part 50, Appendix R for Unit 1 ). The NRC has determined that the reliance on repairs for post-fire alternative shutdown systems; the failure to consider one or more circuit failures (e.g., hot shorts, shorts to ground, open circuits); and the insufficient protection of motor-operated valves (MOVs) constituted a violation of your Unit 2 license condition and 1 O CFR Part 50, Appendix R. However, the violation is not being cited based on Section Vll.B.6 of the NRC Enforcement Policy. Even though you were notified in January
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Public Service Electric and Gas Company DISTRIBUTION:
PUBLIC SECY CA LCallan, EDO AThadani, DEDE JLieberman, OE HMiller, RI FDavis, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators RI, Rll, Riii, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP HBell, OIG TMartin, AEOD OE:EA NU DOCS DScrenci, PAO-RI NSheehan, PAO-RI Nuclear Safety Information Center (NSIC)
NRC Resident Inspector - Salem
Public Service Electric and Gas Company
1996, that your alternative shutdown system did not meet regulatory requirements, we have concluded that the violation stems from activities prior to the shutdown period and was addressed promptly when brought to the attention of current licensee management in March 1997. Corrective actions have been taken for Unit 2 and are planned for Unit 1, involving installation of isolation transfer switches which eliminate the reliance on repairs, and rewiring torque and limit switches on MOVs to address the electrical independence inadequacies. We have also considered the potential generic aspects of compliance with the "hot shorts" provisions of Appendix R in making our decision to exercise discretion.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2. 790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Docket Nos. 50-272; 50-311 License Nos. DPR-70; DPR-75 Enclosure: Notice of Violation Regional Administrator
- Public Service Electric and Gas Company cc w/encl:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support A. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
D. Garchow, General Manager - Salem Operatio_ns J. McMahon, Director - Quality Assurance & Nuclear Safety Review D. Powell, Manager, Licensing and Regulation R. Kankus, Joint Owner Affairs A. Tapert, Program Administrator J. Keenan, Esquire J. Isabella, Manager, Joint Generation Atlantic Electric Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland State of New Jersey State of Delaware