ML18096A576
| ML18096A576 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/17/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096A575 | List: |
| References | |
| EA-92-007, EA-92-7, NUDOCS 9203240087 | |
| Download: ML18096A576 (3) | |
Text
NOTICE OF VIOLATION Public Service Electric and Gas.Company Salem, Unit 2 Docket No.
50-311 License No.
DPR-75 EA 92-007 Hancocks Bridge, New Jersey During.an NRC Augmented Inspection Team (AIT) inspection conducted on November 10 through December -3, 1991, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2; Appendix C (1991), the violations are set forth below:
Technical Specification 6.8.1 requires that written procedures be.
established, implemented, and maintained covering the activities r_eferenced in the applicable procedures recommended in Appendix A of Regulatory Guide
- 1. 33*, Revision 2, February 1978.
A.
Regui atory Gui de 1. 33, Appendix A, Section 2, specifies Genera 1 Pl ant Operating Procedures for operations activities, including, Hot Standby to Minimum Load (nuclear plant startup) and Turbine Startup and Synchronization of the Generator.
Regulatory Guide 1.33, Appendix A, Section 1, specifies Administrative Procedures describing requirements for Procedure Adherence.
Step 5.33 of In'egrated Operating Procedure*roP-3, Revision 8, "Hot Standby to Minimum Load, 11 written to satisfy the requirements of Regulatory Guide 1. 33, Appendix A, directed operators to 11 *** PLACE turbine on the line IAW [in accordance with] OP III-1.3.1, Turbine Generator Operation" relativ~ to startup of the turbine-generator system.
Step 5.1.13 of OP III-1.3.1 directed operators to test the turbine Overspeed Protection Control (OPC) circuit by observing that the Interceptor Valves close rapidly when the OPC key switch is turned to the TEST position; and that the valves reopen when the OPC key test switch is returned to the IN SERVICE position.
Nuclear Administrative Procedure NC.NA-AP.ZZ-0005(Q), "Station Operating Practices," Section 5.7.4, written to satisfy the require-ments of Regulatory Guide 1.33, Appendix A, requires written proce-dur~s to be followed exactly as written, in the order specified, without deviation except as described in NC.NA-AP.ZZ-OOOl(Q),
"Nuclear Department Procedure System."
Contrary to the above, during a Unit 2 reactor plant and turbine-generator startup on October 20, 1991, IOP-3 and OP III-1.3.1 were not completely implemented (followed) as written relative to the startup activities. Specifically, two licensed Nuclear Plant Operators each conducted the OPC test as described by Step 5.1.13 of OP III-1.3.1, but observed that the Interceptor Valves did not close as expected.
Although this matter was further discussed with three OFFICIAL RECORD COPY PROP SALEM 2/10/92 - 0006.0.0 03/10/92 9203240087 920317 PDR ADOCK 05000311 Q
1-.
other senior licensed individuals (i.e., the Unit 2 Shift Supervisor, the Senior Shift Supervisor, and the Operations Ehgineer}, none
- of these licensed individuals effected, directed, or caused the procedure to be followed exactly as written in that reactor plant and turbihe-generator startup operations were continued without the test discrepancy being resolved.
B.
Regulatory Guide 1.33, Appendix A, specifies Administrative Procedures for administrative activities involving Temporary Change Methods and Procedure Review and Approval.
Nuclear Administrative Procedure NC.NA-AP.ZZ-0005(Q), Section 5.7.. 4.
indicates that if a procedure cannot b~ performed as written, the activity should be stopped and supervisory personnel consulted.
Further, NC.NA-AP.ZZ-0005(Q) directs that changes to a written procedure be performed in accordance with NC.NA-AP.ZZ-0032(Q),
11 Preparation, Review and Approval of Procedures.
11 NC.NA-AP.ZZ-00.32(Q),
Section 5.1.1, requires, in part, that a user organization request revision of an existing procedure when problems are encountered in using that procedure.
Contrary to ihe above, during a Uriit 2 reactor plant and turbine-generator startup on October 20, 1991, licensed operators failed to establish and implement changes to IOP-3, 11Hot Standby to Minimum.
- Load, 11 and the procedure it referenced, OP III-1.3.1, "Turbine Generator Operation, 11 to effect completioo of the turbine-generator startup activities as originally written and approved.
Specifically,_
although licensed operations personnel did not complete Step 5.1.13 of OP IlI.1.3.1 as written, the individuals did not request an approved revision to the procedure in accordance*with the requirements of NC.NA-AP.ZZ-0032(Q).
This is a Severity Level III problem (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company (Licensee) is hereby req0ired to submit a written statement or explana-tion to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region I, and a copy to the Sal~m NRC Resident Inspector, within 30 days of the letter trans-mitting this Notice of Violation (Notice).
This reply should be clearly marked as a 11 Reply to a Notice of Violation 11 and should include for each violation:
(1) the reason for the violation; or if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to.avoid further viola-tions, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or a demand for information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should OFFICIAL RECORD COPY PROP SALEM 2/10/92 - 0006.1.0 03/10/92
Noti~e ~f Violation 3
not be taken.
Where good cause is shown, consideration will be given to extending the response time.. ~nder the authority of Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Dated at King of Prussia, P~nnsylvania this /?
day of March 1992 OFFICIAL RECORD COPY PROP SALEM 2/10/92 - 0007.0.0 03/10/92