ML18093A787
| ML18093A787 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/29/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A786 | List: |
| References | |
| EA-88-044, EA-88-44, NUDOCS 8804120438 | |
| Download: ML18093A787 (4) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Public Service Electric and Gas Company Docket No. 50-311 License No. DPR-75 EA 88-44 S~lem Generating Station Unit 2 During an NRC inspection conducted on September 14 - 18 and December 15 - 18, 1987, NRC inspectors reviewed the circumstances associated with violations of NRC requirements identified by the licensee and reported to the NRC.
During the inspection, other violations of NRC requirements were identified.
In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1987), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
I.
Violations Assessed a Civil Penalty License Condition 2.C.10.a requires, in part, that the licensee install concurrently in Salem Unit 2 all modifications to Salem Unit 1 implemented to comply with the requirements set forth in Sections III.G, III.J, III.L, and III.0 of 10 CFR Part 50, Appendix R.
Salem Unit 2 mdofications were to be completed before September 18, 1987.
A.
10 CFR Part 50, Appendix R, Section III.G.l requires that fire protection features shall be provided for structures, systems and components important to safe shutdown.
These features shall be capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control stations is free of fire damage.
Section III.G.2 requires, in part, that, where cables or equipment,
_including associated non-safety circuits that could prevent operation or cause maloperation due to induced shorts, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, a means of maintaining one of the trains free of fire damage shall be provided.
Contrary to the above, as of September 18, 1987, numerous instances existed at Unit 2 where cables and equipment (of redundant trains of systems necessary to achieve hot shutdown) were located within the same fire area outside of primary containment, and a means of maintaining one of the trains free of fire damage was not provided nor was an alternative or dedicated shutdown capability provided.
Specific examples of these failures include the following:
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2
- 1.
Control cables for the carbon dioxide fire suppression system for the Emergency Diesel Generator (EOG) room were located in the same fire areas (in the vestibule area to the EOG control room and in the Relay room) without the required separation.
A short circuit could cause this system to actuate and inject carbon dioxide in all three EOG rooms, which in turn could could (a) cause overheating and thus prevent the operation of the EDGs, and (b) prevent the operators from entering the area to perform required action to bring the EDGs on line.
The EDGs are needed to achieve and maintain hot shutdown in that they provide emergency AC power.
- 2.
Power and control cables for all six service water pumps were located in the same fire area in the Service Water Pipe Tunnel without adequate separation.
The operation of at least two of these pumps is needed to supply service water to the EDGs needed to achieve and maintain hot shutdown.
- 3.
Power feeds from two (
118 11 and 11C 11
) EDGs to the 4160 volt switch-gear were located in the same area in the Fuel Oil Storage Room without adequate separation.
Power from at least two out of the three EDGs is needed to achieve and maintain hot shutdown in that they provide the emergency AC power source.
- 4.
Power cables for both fuel oil transfer pumps (
11A 11 and 118 11 )
were located in the same fire area in the carbon dioxide equip-ment room without adequate separation.
The operation of the transfer pumps is needed to achieve and maintain hot shutdown in that they provide fuel oil for the EDGs, which in turn provide the emergency AC power source.
- 8.
10 CFR Part 50, Appendix R, Section III.L.7, requires that, for alternative and dedicated shutdown capability, safe shutdown equip-ment and systems for each fire area shall be known to be isolated from associated non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits will not prevent operation of the safe shutdown equipment.
Contrary to the above, as of September 18, 1987, for alternative and dedicated shutdown capability, the safe shutdown equipment and systems for each fire area were not known to be isolated from asso-ciated non-safety circuits in the fire area so that hot shorts, open circuits, or shorts to ground in the associated circuits would not prevent operation of the safe shutdown equipment.
Specifically, an adequate analysis had not been performed to verify that adequate breaker coordination existed to ensure that the safe shutdown systems were adequately isolated from the associated non-safety circuits in the fire area.
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II.
3 C.
10 CFR Part 50, Appendix R, Sections III.L.1 and III.L.3, require that an alternative or dedicated shutdown capability provided for a specific fire area shall be able to achieve and maintain hot standby conditions and that procedures shall be in effect to implement this capability.
Contrary to the above, as of September 18, 1987, adequate procedures were not in effect to ensure that hot standby conditions could be achieved and maintained using an alternate shutdown capability from outside the control room in the event of a fire in the relay room.
The procedures were deficient in that they relied on radio.communi-cations between operators to perform the shutdown tasks, and these radio communications could be lost in the event of a fire in the relay room because the power source for the radio transmitter is located in that room.
Collectively, these violations have been categorized in the aggregate as a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $50,000 (assessed equally among the violations).
Violation Not Assessed a Civil Penalty 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances.
Contrary to the above, as of September 18, 1987, Abnormal Operating Procedure No. AOP-EVAC-2, 11 Control Room Evacuation Due to Fire in the Control Room or Relay Room, 11 was inadequate in that the Comments/
Contingency Actions column of the procedure provided numerous erroneous references to the Fire Hazard Books and Sections.
Abnormal Operating Procedure No. AOP-EVAC-2 prescribes a procedure for an activity affecting quality in that the Fire Hazard Books are used to provide detailed explanation to the operators on how to perform the Emergency Equipment Operation.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may OFFICIAL RECORD COPY CP PKG SALEM 3/25 - 0008.0.0 03/29/88
4 be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation 11 and may:
(1) deny the violations listed in this Notice in whole or in part, (2) demon-strate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1987), should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, and a copy to the NRC Resident Inspector at the Salem Generating Station.
FOR THE NUCLEAR REGULATORY COMMISSION Originai Signed By VlILLI1L'~
11 1
l~JSSjlLL William T. Russell Regional Administrator Dated at King of Prussia, Pennsylvania this ~1 day of March 1988 OFFICIAL RECORD COPY CP PKG SALEM 3/25 - 0009.0.0 03/29/88