ML18089A409
| ML18089A409 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/29/1983 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Public Service Enterprise Group |
| Shared Package | |
| ML18089A408 | List: |
| References | |
| EA-83-024, EA-83-24, NUDOCS 8310110387 | |
| Download: ML18089A409 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
PUBLIC SERVICE ELECTRIC AND GAS COMPANY )
(Salem Nuclear Generating Station,
)
Units 1 & 2)
)
)
- Docket Nos.
50-272 50-311 License Nos. DPR-70 DPR-75 EA 83-24 ORDER IMPOSING CIVIL MONETARY PENALTIES I
Public Service Electric and Gas Company, 80 Park Plaza, Newark, New Jersey 07101-(the 11 licensee 11
) is the holder of License Nos. DPR-70 and DPR-75 (the 11 licenses 11 ) issued by the Nuclear Regulatory Commission (the 11Commission 11 cir~
11 NRC 11
) which authorizes the licensee to operate the Salem Nuclear Generating Station, Units 1 and 2, at Hancocks Bridge, New Jersey, in accordance with the conditions specified therein.
License No. DPR-70 was issued on August 13, 1976 and has an expiration date of September 2&, 2008.
License No. DPR-75 was issued on May 20, 1981 and also has an expiration date of September 25, 2008.
II An NRC review of the licensee 1s activities under the license was conducted between March 2 and March 6, 1983 to review the circumstances associated with the two anticipated transient without scram (ATWS) events that occurred at Unit 1 on February 22 and 25, 1983.
As a result of the review, it appears that the licensee had not conducted its activities in full compliance with NRC requirements.
A written Notice of Violation and Proposed Imposition of
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PDR PDR.
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2 Civil Penalties was served upon the licensee by letter dated May 5, 1983.
The Notice states the nature of the violations, the provisions of the Nuclear Regulatory Commission requirements that the licensee had violated, and the amount of civil penalty proposed for each violation.
Answers dated July 6, 1983 and July 22, 1983 to the Notice of Violation and Proposed Imposition of Civil Penalties were received from the licensee.
III Upon consideration of the answers received and the statements of fact, explana-tion, and argument for remission or mitigation of the proposed civil penalties contained therein, and as set forth in the Appendix to this Order, the Director of the Office of Inspection and Enforcement has determined that the penalties proposed for the violations designated in the Notice of Violation and Proposed Imposition of Civil Penalties should be imposed.
IV In view of the foregoing and pursuant to Section 234 of the Atomic En~rgy Act of 1954, as amended (42 U.S.C. 2282, PL 96-295), and 10 CFR 2.205, IT IS HEREBY ORDERED THAT:
3 The licensee pay civil penalties in the amount of Eight Hundred and Fifty Thousand Dollars ($850,000) within thirty days of the date of this Order, by check, draft, or money order, payable to the Treasurer of the United States and mailed to the Director of the Office of Inspection and Enforce-ment, USNRC, Washington, D.C.
20555.
v The licensee may, within thirty days of the date of this Order, request a hearing.
A request for a hearing shall be addressed to the Director, Office of Inspection and Enforcement.
A copy of the hearing request shall also be sent to the Executive Legal Director, USNRC, Washington, D.C. 20555.
If a hearing is requested, the Commission will issue an Order designating the time and place of hearing.
Upon failure of the licensee to request a hearing within thirty.days of the date of this Order, the provisions of this Order shall be effective without further proceedings and, if payment has not been made by that time, the matter may be referred to the Attorney General for collection.
VI In the event the licensee requests a hearing as provided above, the issues to be considered at such hear1ng shall be:
4 (a) whether the licensee violated NRC requirements as set forth in the Notice of Violation and Proposed Imposition of Civil Penalties; and (b) whether, on the basis of such violations, this Order should be sustained.
Dated at Bethesda, Maryland this 29 day of September 1983 FOR THE NUCLEAR REGULATORY COMMISSION Office of Inspection and Enforcement
APPENDIX EVALUATIONS AND CONCLUSION Although the licensee e~sentially admits the violations, the licensee's July 6, 1983 and July 22, 1983 responses to the Notice of Violation and Proposed Imposition of Civil Penalties for Salem Nuclear Generating Station, Units 1 and 2, dated May 5, 1983, state that civil penalties were not appropriate in this case, request mitigation of the amount of the civil penalties, and provide the reasons why the licensee believes mitigation of the penalties is appropriate.
Provided below are (1) restatement of each violation, (2) the licensee's assertions in support of mitigation, and (3) the NRC response to each of the licensee's assertions.
Restatement of Violations:
I.
Technical Specification 3.3.1.1 and Table 3.3-1 require two Reactor Trip Breakers be operable when the reactor is operated in Modes 1 and 2.
With one breaker inoperable, and consequently one channel inoperable, the reactor is required to be in Hot Standby within six hours.
Contrary to the above, the Salem Unit 1 plant was operated in Modes 1 and 2 on February 22, 1983 with both RPS reactor trip breakers inoperable in that both RPS reactor trip breakers failed to operate automatically upon receipt of a valid trip signal caused by low-low steam generator level.
The reactor was manually tripped from the control room.
During the post-trip review of the events by Public Service Electric & Gas Company personnel, t~e failure of the reactor to aut6matically shutdown was not recognized and, as a result, the reactor was taken critical on February 23, 1983 without the circumstances surrounding the February 22, 1983 event being properly evaluated in accordance with the Salem Station Administrative Procedures.
Consequently, the Salem Unit 1 plant was again operated in Modes 1 and 2 with both reactor trip breakers inoperable from February 23, 1983 until approximately 12:21 a.m. on February 25, 1983 when both RPS reactor trip breakers again failed to operate upon receipt of a valid trip signal caused by low-low steam generator level.
Each day the reactor operated with inoperable trip breakers constitutes a separate violation for which a civil penalty of $100,000 is proposed.
This is a Severity Level I violation (Supplement I)
Civil Penalty - $400,000 II.
10 CFR Part 50, Appendix B, requires the licensee to establish a quality assurance. program.
Public Service Electric and Gas Company implements a quality assurance program through its Quality Assurance Manual, dated April 28, 1977.
Appendix 2
However, as described below, the licensee did not properly implement cer-tain aspects of its quality assurance program.
This contributed to the reactor trip breakers being inoperable as described in Item I.
A.
Criterion XVI of 10 CFR, Part 50, Appendix B, requires in part, that 11Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions... are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
11 Contrary to the above, Following the breaker failures at Unit 2 on August 20, 1982 and January 6, 1983, the licensee failed to adequately investigate the cause of the breaker failures, and failed to take corrective action with regard to the failed breakers and to inspect and service all of the reactor trip breakers on Units 1 and 2.
This is a Violation.
Civil Penalty - $100,000 B.
Criterion II of 10 CFR 50, Appendix B, requires in part, that 11The applicant shall identify the structures, systems, and components to be covered by the quality assurance program...
11 The station issued the MEL in July, 1981 by incorporation in AP-9, 11Control of Station Maintenance," to be used to classify components included in the Salem Q list as contained in QAI 2.1, Attachment 1, and UFSAR Table 17.2-1, which lists the items to which the operational QA program applies.
Contrary to the above, the licensee did not establish adequate control over the MEL. As a result,
- 1.
The reactor trip breakers and the reactor protection system, which are safety-related, were not listed on the Master Equipment List (MEL), issued in July, 1981.
- 2.
Administrative Procedure AP-19 (Revision 4, September 18, 1980) describes the MEL as containing a list of Salem items and appro-priate safety, seismic and QA-required C'QA 11 ) classification, however the MEL was not issued as a controlled document by the originating Engineering Department and provisions for incorporat-ing additional classifications or updating of the MEL were never implemented.
This is a violation.
Civil Penalty - $80,000
Appendix 3
C.
Criterion IV of 10 CFR 50, Appendix B, requires in part that 11Measures be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment and services....
11 Administrative Procedure AP-19, Revision 4, describes procurement as a two-step process in which (1) the item is identified and classified and the applicable quality requirements are established utilizing the Material Order/Item Classification Form (MO/IC), and (2) the MO/IC is formalized, administrative review is obtained, and approval is obtained in accordance with the appropriate Quality Assurance Instruction (QAI) utilizing the Material Request and Receiving Record (MR/RR).
Contrary to the above,
- 1.
On January 27, 1982 Purchase Order No. 839270 was issued to purchase items identified in MO/IC 9944 issued on June 1, 1981 for a DB-50 type A circuit breaker and separate components (except UV attachment), without following this process in that:
(a)
MO/IC 9944 incorrectly classified the DB-50 Type A circuit breaker and separate components (except the UV attachment) as Seismic Category 2.
Because under the Updated Final Safety Analysis Report (UFSAR), Section 3.2, the. reactor protection system is Seismic Clas~ 1.
(b)
MO/IC 9944 was neither reviewed by the Station Quality Assurance Engineer (SQAE) nor the Sponsoring Engineer contrary to QAI 4-1 and QAI 4-3.
- 2.
Notwithstanding Section 4.4.3 of AP-19 which provides that an item cannot be classified as a Commercial Catalog Item (CCI) if it is not on a document which identifies it as an authorized replacement for the original or existing item, on August 27, 1982 MO/IC 20299 and MR/RR 7518 for Purchase Order 866077, classified undervoltage (UV) trip attachments for the reactor trip circuit breakers, components of the RPS, as CCI even though no document existed which identified the UV trip attachments ordered as authorized replacements.
- 3.
Notwithstanding the requirement of Section 4.4.3 of AP-19 stated above, on February 25, 1983, MO/IC 28445 was issued for eight UV trip attachment components for the reactor protection system.
These components were classified as CCI even though a document did not exist which identified the UV trip attachment as authorized replacements for the original or existing items.
These components were received onsite per MR/RR 1644-M, and
Appendix 4
rece1v1ng inspection was not performed for these delivered
. components prior to providing them to the requesting department~
contrary to AP-19 requirements.
This is a violation.
Civil Penalty - $60,000 D.
Criterion V of 10 CFR 50 Appendix B, requires in part, that 11Activi-ties affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
11 Contrary to the above,
- 1.
Administrative Procedure AP-9, 11Control of Station MaintenaQc;..e, 11 requires the Master Equipment List (MEL) to be used for equipment classification.
However, maintenance department personnel were not using the MEL.
Consequently on January 10, 1983 Work Order No. 925774 was issued to perform the following work:
disassemble, inspect and clean, reassemble and test the Unit 1 reactor trip breakers.
The maintenance department used Project Directive 7 (PD-7) instead of the MEL and was unable to locate the reactor trip breakers on the PD-7 (although they were listed and properly classified on PD-7) to determine the safety classification.
As.a consequence, Work Order 925774 was classified as non-safety-related.
- 2.
Administrative Procedure AP-9, 11Control of Station Maintenance, 11 requires notification of the QA staff prior to performing safety-related work and a QA review of completed safety-related work orders.
For all safety-related work orders on the reactor trip and bypass breakers, prior notification was made; however, work orders TM-0053 (for Unit 2 prior to receipt of operating license), 902975, 917753, and 936238 did not receive QA review after work was completed.
- 3.
From initial operation in December 1976 of Unit 1, and from August, 1980 for Unit 2 until January 1983, the licensee did not perform preventive maintenance on reactor trip and bypass breakers.
For the maintenance performed in January 1983 the maintenance was conducted without an appropriate procedure, although the reactor trip breakers are safety-related.
This is a violation.
Civil Penalty - $60,000
Appendix 5
E.
Criterion VIII of 10 CFR 50, Appendix 8, requires in part, that "Measures shall be established for the identification and control of materials.... These measures shall assure that identification... is maintained... or records traceable to the item, as required through-out... use of the item."
Contrary to the above, As of February 25, 1983 the licensee had not maintained a system to trace breaker location (i.e., which breaker is in which location).
However, the reactor trip breakers were switched with the bypass breakers and with reactor trip breakers in the other Unit.
Any of the eight breakers involved (four for each Unit), could be interchanged.
This is a violation.
Civil Penalty - $50,000 F.
Technical Specification Table 4.3-1 (21), Reactor Trip Instrumentation Surveillance Requirements, requires that each reactor trip breaker be functionally tested bi-monthly and within 7 days prior to startup.
Contrary to the above,*
On February 22, 1983, the 118 11 reactor trip bypass breaker was placed in service as the 118 11 reactor trip breaker, even though the breaker should have been considered inoperable because the bypass trip breaker was not functionally tested prior to startup on February 22, 1983 to determine its ability to trip automatically on undervoltage.
This is a violation.
Civil Penalty - $50,000 Violations A through F, when viewed in the aggregate, have been categorized at a Severity Level II (Supplement I).
The Commission has determined that these contributors to the events of February 22 and 25 are as significant as the events themselves and should be assessed a cumulative civil penalty equivalent to the amount assessed for Item I.
The amount assessed for each violation is based on the relative significance of each violation to the other violations included in this Item.
Cumulative Civil Penalty - $400,000 III. 10 CFR 50.72 requires, in part, that each licensee notify the NRC Opera-tions Center as soon as possible, and in all cases within one hour of (1) any event resulting in manual automatic actuation of Engineering Safety Features, including the RPS, and (2) any event that results in the nuclear power plant not being in an expected condition while operating or shut down.
~I
~
I Appendix 6
Contrary to the above, Tlfe NRC Operations Center was not notified within one hour of events which required such notification in accordance with 10 CFR 50.72 as evidenced by the fo 11 owing:
A.
On January 30, 1983 at approximately 5:50 p.m., a safety injection occurred during cooldown of the reactor and the NRC Operations Center was not notified until 7:27 p.m.
B.
On February 22, 1983 at approximately 9:56 p.m., the plant was shut down because of not being in an expected condition (loss of a reactor coolant pump, loss of a main feed pump, loss of a substantial amount of nonsafety instrumentation indication, and steam generator levels dropping rapidly), and the NRC Operations Center was not notified until 11:34 p.m.
Also, although there was a safety injection and the PORVs lifted at 10:11 p.m., this was not reported to the NRC until February 23, 1983 at 12:12 a.m.
C.
On February 25, 1983 at 12:22 a.m., the plant was shut down manually, 25 seconds after it failed to shut down automatically upon receipt of a valid shutdown signal, and the NRC Operations Center was not notified of this unexpected condition until 1:46 a.m.
This is a Severity Level III violation (Supplement I)
Civil Penalty - $50,000 Licensee 1s Assertion:
Given the 11 remedial 11 nature of civil penalties authorized by the Atomic Energy Act, the Commission must have an adequate factual basis upon which to conclude that the imposition of a large civil penalty will serve such a remedial purpose.
In this case, the proposed penalty is unnecessary be-cause significant corrective actions were either completed or committed to as part of a comprehensive remedial program prior to issuance of the Notice of Vio-lation and Proposed Imposition of Civil Penalties.
Thus, imposition of the civil penalties will not contribute to achieving compliance with NRC regulations.
NRC Response:
The Commission addressed the remedial purpose of civil penalties in its decision in the Atlantic Research case, CLI-80-7, 11 NRC 413, 419-21 (1980).
In that case, the licensee argued that any civil penalty was punitive and, therefore, beyond the Commission 1s authority because the licensee had promptly taken appropriate measures to avoid a repetition of the incident before imposition of the penalty.
The Commission found that so long as the NRC can rationally relate the imposition of a civil penalty to potential improvement of conduct, either of the licensee or other persons in similar positions, in furthering the purposes of the Atomic Energy Act, then the penalty is within the authority of §234 of the Atomic Energy Act.
The NRC proposed civil penal-ties in this case because it believes that such penalties will contribute to continued efforts toward long-term compliance with the Commission requirements by PSE&G and other licensees.
Thus, imposition of civil penalties in this case is in accord with the Commission 1s statutory authority.
Furthermore, although
Appendix 7
many of the corrective actions enumerated in the licensee 1 s response had already been completed when the civil penalty was issued, the Commission believed that a civiT penalty was necessary to emphasize the significance that the NRC attaches to the events at Salem and to ensure sustained attention to implementation of long-term corrective actions necessary to prevent additional problems.
Licensee 1s Assertion:
It is unreasonable for the Commission to assess a civil penalty for four days of violation for Item I.
Although the licensee operated in violation of its Technical Specifications o-n four different calendar days, the total elapsed time of such operation was only approximately 51 hours5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br />.
NRC Response:
Under its statutory authority, the Commission may impose a civil penalty of up to $100,000 for each violation.
The statute also provides that where a violation continues, each day of such violation shall constitute a sep-arate violation for the purpose of computing a civil penalty.
Although the term 11day 11 is not defined, the Commission has consistently interpreted that term in the context of its enforcement cases as referring to calendar days.
Such a read-ing of the statute is not unreasonable and in the circumstances of this cas_e.., the NRC staff believes it is appropriate to impose a separate penalty for each calen-dar day that the licensee operated in violation of its Technical Specifications.*
Licensee's Assertion:
Many of the problems that led to the ATWS events at Salem are generic as documented in NUREG-1000, "Generic Implications of ATWS Events at the Salem Nuclear Power Plant.
11 The generic applicability of these problems is reinforced by the NRC 1s Generic Letter 83-28 dated July 8, 1983 which requires the industry to take certain actions based on the generic implications of the Salem incidents.
PSE&G has already taken action on the major elements of Generic Letter 83-28 and hence, the imposition of the proposed civil penalties cannot reasonably be viewed as serving a remedial purpose.
NRC Response:
The fact that many of the problems at Salem have generic implica-tions focuses the need for the NRC and the industry to learn from the Salem in-cidents and establish and/or emphasize remedial actions which will prevent a similar occurrence.
It does not dismiss the fact that many of the problems at Salem involved violations of NRC requirements which led to the reactor trip breaker failures.
As noted above, the Commission believes that a civil penalty for violations of NRC requirements is necessary to emphasize the significance that the NRC attaches to the events at Salem and to ensure sustained attention to implementation of the long-term corrective actions.
Licensee's Assertion: There were numerous significant problems requ1r1ng evalua-tion after the February 22 incident, so the focus of individuals evaluating the incident was on resolving those problems. Additionally, the operators acted promptly to shut down the plant, thereby masking the trip breaker failures since the manual trip occurred only 3.6 seconds after the automatic trip signal.
Finally the sequence-of-events (SOE) recorder which provided the only evidence available of the trip header failures, is not required equipment, nor is one installed at all plants.
Appendix 8
NRC Reseonse:
All of the above information was revealed during the investigation of the incidents and was taken into consideration in determining the level of the civil penalty. The NRC staff recognizes the difficulty in resolving the prob-lems associated with the February 22 *event.
However, the plant was restarted without a complete understanding of the incident although information was avail-able to provide such understanding.
Other actfvities associated with the event were also not explained.
Based upon discussions with the operator who initiated the manual trip, it was his belief that his action had in fact caused the plant to trip.
A proper evaluation of the SOE recorder subsequent to the February 25 event indicated that the plant had been tripped manually on February 22 and con-firmed the operator 1s judgment.
Additionally, the first-out panel was cleared without recognizing which first-out annunciator was lit. These facts should have prompted a more detailed investigation prior to plant restart.
The fact that the SOE recorder is not required equipment does not mean that the licensee should be excused for its failure to use information provided by the recorder to analyze the causes of the February 22 event.
The SOE was available to the licen-see and should have been used to conduct the necessary review prior to restart.
Licensee 1s Assertion: The Enforcement Policy provides that licensees are not normally cited for violations resulting from matters not within their control, i.e., equipment failures, that were not avoidable by reasonable licensee quality assurance measures or management controls. PSE&G 1s position is that the breaker design contributed to its failures in that the short life span for undervoltage trip (UVT) attachment and the potential reliability problems were not previously known by the industry or NRC until the Salem events. Additionally., the vendor 1 s technical manual did not address UVT attachment lubrication and Salem was not the only plant not maintaining the trip breakers in accordance with the Westinghouse Technical Bulletin and NSD Data Letter 74-2.
NRC Response: The NRC staff disagrees with the assertion that these equipment failures* resulted from matters beyond licensee 1s control. As delineated in Item II of the Notice of Violation, there were many quality assurance problems related to the reactor trip breakers which contributed to the trip breaker failures.
Additionally, there were previous undervoltage trip attachment failures in DB 50 breakers at Salem and other plants which indicated potential reliability problems with this device, yet no preventive maintenance program or other actions other than surveillance testing were instituted on the reactor trip breakers from initial operation until January 1983.
In particular, the UVT attachment failures in August 1982 were not fully investigated so as to develop effective remedial measures.
Licensee 1s Assertion:
Item I of the Notice of Violation should be classified as Severity Level II because the manual reactor trip worked and, therefore, there was not a total loss of safety function. The manual trip is required and it actuates the shunt trip device as well as the UVT attachment. This situation is similar to the Haddam Neck case in which the UVT attachments failed but the shunt attachments on both breakers were determined to be operable, and hence that event did not constitute a compl~te failure of the trip system.
1, J
L Appendix 9
NRC Response:
The Salem ATWS events (Item I) are properly classified as Severity Level I. There was a complete failure of the automatic reactor trip system to perform its intended safety function when called upon to work. The automatic reactor trip system is a safety-grade system relied upon to prevent core damage in the event of design-basis accidents as discussed in the Final Safety Analysis Report.
The manual trip at Salem provides an additional means to trip the plant, but it cannot fulfill the same safety functions as the automatic reactor trip system, and hence, it is not redundant to the automatic trip system.
In addition, the automatic trip system at Salem actuates only the UVT attachment, whereas the manual trip actuates both a shunt trip attachment and the UVT attachment.
As noted in the PSE&G submittal, the shunt trip attachments are part of the Haddam Neck automatic reactor trip system, and hence, *there was not a total failure of the automatic trip system*at Haddam Neck.
Licensee's Assertion:
PSE&G objects to the NRC position that the violations in Item II of the Notice of Violation are as serious as the Item I violations and argues that the Item II violations should not result in a civil penalty equiva-lent to that proposed for Item I.
PSE&G questions whether any penalty is
-~
appropriate for certain violations in Item II and further argues that there are strong mitigating factors which must be considered for the Jtem II violations.
NRC Response:
The problems related to reactor trip breaker maintenance, pro-curement and testing which are delineated in Item II of the Notice, in our view, significantly contributed to the reactor trip breaker failures.
Since the Commission considers the cause of the ATWS events to be as significant as the events themselves, the penalties for Item II were made equal to those proposed for Item I.
For the reasons provided in this response, we disagree with the licensee's assertions that mitigation is warranted for the specific parts of Item II which were addressed in the licensee's response.
Hence, the licensee has provided insufficient justification for mitigation of the Item II penalties.
Licensee 1s Assertion: Item II.A, concerning failure to adequately investigate the cause of the breaker failures and failure to take corrective action with regard to the failed breakers, should not result in a civil penalty. Actions to correct the specific breaker failures of August 20, 1.982 and January 6, 1983 were taken. Following the January 6 failure, all Unit 1 trip breakers and bypass breakers were serviced either by a Westinghouse representative or pursuant to his direction. The reactor trip breakers on Unit 2 were subsequently serviced during the Unit 2 outage.
NRC Response:
The January 6, 1983 reactor trip breaker failure was the third failure of a UVT attachment at Salem (the first was February 1979 in startup testing), yet no comprehensive investigation as to the cause of the failures was undertaken. Even after the January 6 failure, Unit 2 remained in operation
Appendix 10 with no inspection or servicing of the remaining trip breakers.
Given the significance of reactor trip breakers, insufficient actions were taken, in the staff 1s view, to comply with Appendix B Criterion XVI with respect to the trip breakers.
Licensee 1s Assertion:
With respect to Item II.0.3, preventive maintenance was not performed on reactor trip and bypass breakers because of specific instructions in the manual and because the vendor failed to update maintenance procedures for the breakers.
NRC Response: PSE&G as the licensee is responsible for all activities affecting quality at the Salem station. Even though work may be delegated to contractors and vendors, PSE&G retains responsibility for the quality of their activities.
Licensee 1s Assertion: With respect to Item II.E, which concerns breaker tracea-bility, the Salem events demonstrate that the item for which traceability is critical is the UVT attachment. However, the vendor provided no means by which UVT attachments which incorporate all design modifications could be distin-guished.
NRC Response:
The PSE&G practice of switching reactor trip breakers with bypass breakers and with trip and bypass breakers of the other unit, probably resulted in placing untested or only partially tested breakers into reactor trip breaker positions which would make the breaker technically inoperable according to technical specifications. Without documentation to determine breaker position at any particular time, it would not be possfble to determine if the breakers were fully tested to ensure operability.
The functional testing conducted after breaker switching was not sufficient to test all aspects of breaker operability.
In particular, no testing was done to ascertain the operability of the UVT attachment.
It is this aspect of traceability that is the basis for this violation.
Conclusion The violations occurred as originally stated.
The licensee has not provided sufficient basis for mitigation of the proposed peni=J.lty of $850,000.
The NRC staff concludes that an $850,000 civil penalty should be imposed.