IR 05000272/1997018

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-272/97-18 & 50-311/97-18 on 971118

ML18106A241
Person / Time
Site:	Salem
Issue date:	01/08/1998
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Eliason L Public Service Enterprise Group
References
50-272-97-18, 50-311-97-18, NUDOCS 9801160030
Download: ML18106A241 (8)

Text

January 8, 1998

SUBJECT:

Combined Inspection Report 50-272/97-18; 50-311/97-18

Dear Mr. Eliason:

This letter refers to your December 16, 1997 correspondence (LR-N970790), in response to our November 18, 1997 letter regarding the Salem Unit 1 & 2 facilities.

Thank you for informing us of the corrective and preventive actions for the Notice of Violation, as documented in your letter. The violation involved the inadvertent isolation of fire protection water to the Unit 1 and 2 auxiliary buildings and containments which degraded the post-fire safe shutdown capability of Salem Unit 2. Your response to the violation will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Docket Nos. 50-272; 50-311 9801160030 980108 PDR ADOCK 05000272 G

PDR

Sincerely, Original Signed By:

James C. Linville, Chief Projects Branch 3 Division of Reactor Projects 111111111111111111111111111111111 Ill llll

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• Mr. Leon cc:

L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support D. Powell, Director - Licensing/Regulation & Fuels A. C. Tapert, Program Administrator J. McMahon, Director - Quality/Nuclear Training/Emergency Preparedness C. Bakken, General Manager - Salem Operations cc w/cy of Licensee's Letter:

A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.

Jeffrey J. Keenan, Esquire J. A. Isabella, Manager, Joint Generation Atlantic Electric Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township R. Kankus, Joint Owner Affairs Public Service Commission of Maryland State of New Jersey State of Delaware

• Mr. Leon Distribution w/copy of Licensee's Response Letter:

Region I Docket Room (with concurrences)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector PUBLIC M. Leach, OEDO J. Stolz, PD1-2, NRR P. Milano, Project Manager, NRR M. Callahan, OCA J. Linville, DRP S. Barber, DRP D. Screnci, PAO C. O'Daniell, DRP R. Correia, NRR F. Talbot, NRR DOCDESK Inspection Program Branch, NRR (IPAS)

DOCUMENT NAME: G:\\BRANCH3\\9718RESP.LTR To receive a copy of this document, indicate in the box: "C" = Copy without attachmenUenclosure

"E" = Copy with attachmenUenclosure

"N" = No I

copy OFFICE Rl/DRP JI I

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I NAME JLinville/ceoctV I DATE 01/07/98

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01 I /98 01 I /98 01 I 198 01 I /98 OFFICIAL RECORD COPY

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Public Service Electrrc and Gas Company is F. Storz Public Servrce Electric and Gas ComDEC { j* ~gg]6* Hancocks Bridge. NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations

United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 LR-N970790 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/97-18 AND 50-311/97-18 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

Combined Inspection Report No. 50-272/97-18 and 50-311/97-18 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G) on November 18, 1997. Within the scope of this report, one violation of NRC requirements was cited. The violation involved; the inadvertent isolation of fire protection water to the Unit 1 and 2 auxiliary buildings and containments, which degraded the post-fire safe shutdown capability of Salem Unit 2.

Following the voluntary shutdown of May 1995, PSE&G recognized that a key attribute for a successful restart of the Salem Units, as well as the ability to safely and reliably operate the facilities, depended, in part, on being an Operations led organization. To this extent, PSE&G clearly defined what an Operations led organization meant, and in particular having the Operations Department take ownership and accountability of the Salem Plants. This expectation was clearly communicated to all personnel. To achieve this goal significant programs and actions were developed and implemented to establish and cultivate this new culture within the Operations Department. These programs and actions, which have been extensively shared with the NRC, included reorganizing the Operations Department, and placing new personnel at all levels of the department. The successful restart of Salem Unit 2, was in part due to the success of the Operations Department in having achieved this cultural change.

However, as noted in your inspection report, there have been occasions where individuals have failed to meet these expectations. Specifically, Operations personnel failed to properly control the work that was being performed in the control room by contractor personnel.

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Document Control Desk LR-N970790

DEC 1 6 1997 Although, we will continue to search for ways to improve our processes and programs to ensure safe operation, we will also continue to hold all of our personnel accountable for their actions in accordance with the PSE&G's disciplinary policy, and the Management Associated Results Company (MARC) principles. This positive approach to discipline is primarily focused on improving personnel performance. This is accomplished through a multi-stage approach of providing direct employee feedback for their actions via coaching, counseling, verbal and written feedback. Termination of employment is also an option for failure to meet the fundamental expectations.

Additional corrective actions are included in Attachment I to this letter.

In accordance with 1 O CFR 2.201, PSE&G is submitting its response to the cited violation in Attachment I to this letter. Should there be any questions regarding this submittal, please contact us.

Sincerely, Attacrent ( 1 )

C J Mr. Hubert J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Ms. M. Evans - Salem (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering PO Box415 Trenton, NJ 08625

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ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION LR-N970790 Public Service Electric and Gas Company Salem Nuclear Generating Station Docket Nos:

Units 1 and 2 License Nos:

50-272 50-311 DPR-70 DPR-75 During an NRC inspection conducted from September 8, 1997 through October 19, 1997, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

A.

License Conditions 2.C(5) (Unit 1) and 2.C(10) {Unit 2) require that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR).

UFSAR, Section 9.5.1.4.1, describes systems and components which are necessary for post-fire safe shutdown of Salem Units 1 and 2, including the auxiliary feedwater (AFW) pumps and other safety-related equipment. UFSAR Section 9.5.1. 7.2, describes the water-based fire suppression systems which are utilized at Salem Units 1 and 2, and the components which they protect. For example, the AFW pumps are protected by two water sprinkler systems.

Procedure SC.FP-SV.FS-003(0), "Fire Water Flowpath Verification," requires that the fire protection isolation valves to the Unit 1 and 2 auxiliary building and containments, 1FP186and1FP187, be in the open_position.

Contrary to the above, from approximately September 9-16, 1997, valves 1FP186 and 1FP187 were closed, which isolated all fire protection water to the Salem Unit 1 and 2 auxiliary buildings and containments. This isolated water to the water-based suppression systems in those buildings, rendering the systems inoperable, and adversely affecting the licensee's ability to achieve and maintain safe shutdown in the event of a fire.

This is a Severity Level IV violation (Supplement 1 ).

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ATTACHMENT I RESPONSE TO NOTICE OF VIOLATION LR-N970790 PSE&G concurs with the violation (1)

The reason for the violation.

The exact cause of how the 1FP186 and 1FP187 valves were closed, and could have potentially been closed from September 1, 1997, through September 16, 1997, could not be determined. These dates represent the times when the 1FP186 and 1FP187 valves were field verified open by Loss Prevention personnel. However from a timeline of the events developed during the root cause investigation, the most probable cause for the inadvertent closure of the 1FP186 and 1FP187 valves was rel amping activities on 1 RPS panel on September 9, 1997. Therefore, the cause of this occurrence is attributed to inadequate control of the 1 RPS relamping maintenance activity by Operations.

Shift personnel, particularly the Control Room Supervisor, failed to exercise adequate control over work in the control room. Specifically, the supervisor allowed a contract maintenance technician to relamp control switch assemblies on 1 RPS without direct Operations supervision.

The cause for this condition going unidentified for the period from September 9, 1997, through September 16, 1997 is attributed to human error due to inattention to detail by the Nuclear Control Operators and the Loss Prevention Operators during subsequent panel reviews. The reviews did not focus on valve position indication, but were focused on verification of alarm status and lamp functionality.

(2)

The corrective steps that have been taken.

The valves were opened at 2237 hrs on September 16, 1997, and locally verified open by Loss Prevention personnel at 2243 hrs.

An event notice was issued to Operations, Work Control, Loss Prevention and Station Planning to share the lessons learned from this event.

On September 18, 1997, Loss Prevention personnel completed a lineup verification of Fire Protection valves (C02 and Water) at Salem station, and as a temporary compensatory measure, initiated position verification of the 1FP186 and 1FP187 valves on a twice per shift (every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) basis pending completion of the revision of procedure ND.FP-DD.ZZ-0014(Z), "Conduct of Shift Turnovers."

• ATIACHMENTI RESPONSE TO NOTICE OF VIOLATION LR-N970790 On October 24, 1997, S1.0P-DL.ZZ-0002(Q), "Control Room Log - Mode S, 6 and Defueledn was revised to include a twice per shift verification of the position of 1FP186 and 1FP187 by the Unit 1 Control Room Operator. This corrective action may be removed upon completion of procedure ND. FP-DD.ZZ-0014(Z) revision.

Procedure ND.FP-DD.ZZ-0014(Z), "Conduct of Shift Turnovers" was revised to include verification of the 1FP186 and 1FP187 indicator lamp once per shift at the 1 RPS panel, and a once per shift verification of actual valve position.

In accordance with the PSE&G disciplinary process, Operations personnel involved in allowing maintenance workers to relamp 1 RPS without direct Operations supervision were held accountable for their actions.

(3)

The corrective steps that will be taken to avoid further violations.

Operators received training on the controls associated with the 1FP186 and 1FP187 valves. Additionally, the Nuclear Training Center was requested to provide licensed operators training on the controls associated with Fire Protection equipment and the License Commitments relative to Fire Protection.

The following corrective actions are intended to address the expectations identified in the cover letter for this response.

The Operations Superintendents or appropriate operations personnel will assess shift compliance with SC.OP-AP.ZZ-0114, Rev. 0, "Event Identification and Investigation,"

particularly with regard to the use of critiques and supervisor interviews, and arrange for (or perform) additional training as necessary. This activity will be completed by January 31, 1998.

Appropriate management personnel will discuss with their crews (operations, planning and loss prevention personnel) the lessons learned from this event regarding NC.NA-AP.ZZ-OOOS(Q), "Station Operating Practices," department ownership of the plant and control of maintenance activities. This activity will be completed by January 30, 1998.

(4)

The date when full compliance will be achieved.

PSE&G achieved compliance when the valves were opened at 2237 hrs on September 16, 1997, and locally verified open by Loss Prevention personnel at 2243 hrs.

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