ML18081A652

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Responds to NRC Re Violations Noted in IE Insp Rept 50-272/79-15.Corrective Actions:Identified Fire Hose Stations Inspected & Stressed Importance of Submitting Incident Repts on Time
ML18081A652
Person / Time
Site: Salem PSEG icon.png
Issue date: 09/21/1979
From: Schneider F
Public Service Enterprise Group
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18081A651 List:
References
NUDOCS 7912030239
Download: ML18081A652 (4)


Text

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i Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Mr. Boyce H. Grier Director of USNRC September 21, 1979 Off ice of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Grier:

NRC INSPECTION REPORT NO. 50-272/79-15 APRIL 22 -

May 26, 1979 UNIT NO. 1 SALEM NUCLEAR GENERATING STATION We have reviewed the report of your inspection conducted on April 22 -

May 26, 1979 which was transmitted with your letter of August 29, 1979 and received on September 4, 1979.

Our response to Appendix B of your inspection report is still under review.

Since the material in Appendix B of your report is covered by Section 2.790(d) of the NRCs "Rules of Practice" Part 2, Title 10, Code of Federal Regulations this response will be submitted to you separately.

our response to the Items of Noncompliance in Appendix A of your inspection report is as follows:

Item A, Infraction:

Technical Specification 4.7.10.4 states in part, 11Each of the fire hose stations shown in Table 3.7-11 shall be demonstrated OPERABLE:

a)

At least once per 31 days by visual inspection of the station to assure all required equipment is at the station.

TABLE 3.7-11 1-1/2 11* FIRE HOSE STATIONS lFP-89 lFP-96 Zl. 130 Cont. *l El. 130 Cont. #1 Contrary to the above, on May 10, 1979, no evidence could be identified to demonstrate that the above two fire hose

_.* Boyc;:e 9-21-79 stations had been inspected since March 21, 1979, a period exceeding 39 days (31 days plus 25%)

  • Reply to Item A:
1.

The cause of the deficiency was failure to maintain adequate control of partially completed surveillance items.-

The sur-veillance was completed with the exception of the two stations in the containment, by the end of March.

The Operating De-partment planned to complete the two remaining stations during the planned outage.

Due to the volume of work generated by the shutdown, the surveillance on the two identified stations was overlocked.

2.

To correct the situation, the identified fire hose stations have been inspected.

3._

To Prevent future items of noncompliance, all partially completed surveillances will be kept in a separate file.

The Operations Directive Manual (ODM) will be revised to include a requirement for a periodic check of this file.

4.

We are in compliance now.

The revision of the ODM will be complete by October 1, 1979.

Item B, Deficiency:

Facility Operating License DPR-70, Appendix A and Appendix B, Technical Specifications detail the following require-ments for event reports to the NRC:

"6.9.1.8 The types of events listed below shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegraph, mailgram, or facsimile transmission to the Director of the Regional Office, or his designate no later than the first working day following the event, with a written followup report within 14 days *.*

b)

Operation of the unit or affected systems when any parameter or operation subject to a limiting condition for operation is less conservative than the least conservative aspect of the limiting condition for operation established in the technical specifications."

"6.9.1.9 The types of events listed below shall be the subject of written reports to the Director of the Regional Office within thirty days of occurrence of the event *..

b)

Conditions leading.to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation."

Boyce a. Grier '

9-21-79 "5.6.2.1 Nonroutine Environmental.Operating Reports A report shall be submitted in t~e event that (a) a limiting condition for operation is exceeded (as specified in Section 2._ O, "Limiting Conditions for Operation"), (b) a report level is reached (as specified in Section 3.0, "Environ-.

mental Surveillance"), or (c) an unusual or important event occurs that causes a significant environmental impact, that affects potential environmental impact from plant operation, or that has high public or potential public interest con-cerning environmental impact from plant operation.

Reports shall be submitted under one of the report schedules described below:

30-Day Report:*

Those events not requiring a prompt report shall be reported within 30 days by a written report to the Director of Regional Inspection and Enforcement Office (with copy to the Director, Office of Nuclear Reactor Regulation.)"

Contrary to the above, the following Licensee Event Reports were submitted to the NRC later than the time specified:

LER Number 79-21/03L 79-23/04L 79-25/03L 79-27/0lT 79-32/03L 79-34/03L Reply to Item B:

Reported pursuant to 6.9.1.9 5.6.2.1.

6.9.1.9 6.9.l.8 6.9.1.9 6.9.1.9 Event Date 3/2/79 3/12/79 3/15/79 3/25/79 3/30/79 3/31/79 Report Date 4/2/79 4/12/79 4/18/79 4/9/79 4/30/79 5/1/79

1.

The cause of the deficiency was associated with the report preparation cycle as identified below:

a)

In order to properly investigate an LER event infor-mation may be required from numerous and diverse

.sources.

Often this investigation cannot be completed in the time allotted by the NRC for preparation of the report.

b)

In order to provide the NRC with as much information as possible it was the policy to hold the LER report at the station as long as possible to insure all available information would be included in the report.

c) d)

General Office staff responsibility changes which occurred during the period covered by the overdue reports caused some reports to be delayed

  • The stat.ion's LER coordinator is currently a

Boyce -

9-21-79

2.
3.

person outside of the Operating Department.

Since most of the information and research for the reports is obtained from the operating shifts*,

some of the reports were delayed.

To correct the situation, it has been impressed upon those personnel involved with Incident Reports and LERs the importance of submitting the report within the time allotted by the NRC even if the investigation is incomplete.

To prevent future items of noncompliance, the following actions will be implemented:

a)

LERs will be finalized by the station's coordi-nator 7 days prior to the LERs due date based upon information available to the coordinator at that time.

Information applicable to the report which becomes available after this cutoff date will be submitted to the NRC as a supplemental report.

b)

The station LER coordinator function will be as-signed to a member of the Operating Department staff.

c)

Future staff responsibility changes will include specific instructions to the prospective LER coordinator on the appropriate reporting requirements.

4.

We are in compliance now.

The assignment of the station LER coordinator function to a member of the Operating Department staff will be completed by January l, 1980.

If you require additional information, we will be pleased to dis-cuss it with you.

Sincerely, CC Director, Offi~e of Inspection and Enforcement USNRC Washington, DC 20555