Text

Discusses Safety Insp Repts 50-272/90-22 & 50-311/90-22 on 900816-1001.Util Has Not Provided Sufficient Basis for Withdrawing Violation & Therefore,Nrc Has Decided Not to Withdraw Violation.Response Requested within 45 Days
	ML18096A587
Person / Time
Site:	Salem
Issue date:	03/17/1992
From:	Hehl C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Miltenburger S; Public Service Enterprise Group
References
	NUDOCS 9203300027
	Download: ML18096A587 (4)
	v • d • e

MAR 1 7 1992

Public Service Electric and Gas Company

A TIN:

Mr. Steven E. Miltenburger

Vice President and Chief Nuclear Officer

P.O. Box 236

Hancocks Bridge, New Jersey, 08038

Subject: NOTICE OF VIOLATION (Inspection Nos. 50-272/90-22 and 50-311/90-22)

Gentlemen:

During a routine resident safety inspection (50-272/90-22; 50-311/90-22) conducted between

August 16 and October 1, 1990, our inspectors evaluated Unresolved Item (UNR) No. 50-

272 and 311/90-81-23.

This UNR pertained to the possible misapplication of 10 CFR 50.59

as identified in a previous Integrated Performance Assessment Team (IP AT) inspection

conducted May 14-29, 1990. The IPAT inspection identified that PSE&G failed to perform

an evaluation as required by 10 CFR 50.59 relative to a non-code repair of corrosion in a

containment fan cooling unit (CFCU No. 23). Specifically, Belzona "R" metal, an epoxy-

based surface sealant, was used to repair pits of corrosion on the tube sheet affecting the

service water side of the motor cooler; but a written safety evaluation supporting that the

repair did not involve an unresolved safety question (USQ) was not documented as required

by 10 CFR 50.59.

The violation was originally cited in a letter dated November 1, 1990. A response was not

required based on the staff's understanding of PSE&G's program and corrective actions.

However, in a later management meeting on December 4, 1990, it became apparent that the

staff might have misunderstood the licensee's intention relative to the disposition and

resolution of USQ matters. As a result of that discussion, the NRC staff requested PSE&G

to formally respond to the portion of the original violation involving the repair of CFCU No.

23.

Accordingly, PSE&G responded in correspondence dated February 1, 1991, and provided a

rationale for denying the violation. PSE&G asserted that their application of a screening test

(which determined that the repair of the CFCU No. 23 did not constitute a change to the

facility or an USQ) was in conformance with NSAC-125, "Guidelines for 10 CFR 50.59

Safety Evaluations," and sufficient to meet the regulatory requirments. NRC Region I

acknowledged this submittal in a letter dated March 1, 1991.

From our review of your submittal, we determined that you have not provided sufficient

basis for withdrawing the violation. While we believe that your process for performing 10

CFR 50.59 safety reviews is adequate, your application of NSAC-125 in this instance

9203300027 920317

PDR

ADOCK 05000272

G

PDR

2

appears less conservative than allowed and intended. From a conservative reading of NSAC-

125, the repair to the CFCU had the potential to affect the design and function of the CFCU

as described in the Final Safety Analysis Report, and consequently would have required a

safety review. Further, the violation in this instance was based on lack of documentation

relative to the USQ determination. Your submittal admitted that the matter was not

sufficiently documented in accordance with your procedure. As a result, you subsequently

provided additional training and direction to your staff and revised the procedure.

Therefore, NRC Region I has decided not to withdraw the original violation. We request

that you respond, within 45 clays, to inform us of your corrective measures to ensure that

future repairs similar to the one cited will receive written safety evaluations.

In addition to addressing the violation, we request that you address the following:

1.

Describe the use of the 10 CFR 50.59 screening process to limit changes to the

facility that are reviewed by SORC and the independent (i.e., independent from the

preparing organization) controls that are in place to ensure changes are not

inappropriately screened from SORC review.

2.

How do you assure that changes, tests, or experiments that are screened from 10 CFR

50.59 applicability, and therefore from the requirement to prepare a safety evaluation,

receive an adequate evaluation and engineering safety review?

Should you have additional questions on this matter, please call Mr. John White of my staff

at (215) 337-5114. Your cooperation with us is appreciated.

Sincerely,

n~-~~.!.,.r., (\\f-....,-. ... 1 f:'i*r*

\\.Ii ._,_r.;.;

c.~-~~.;.J u .... :

Charles W. Hehl, Director

Division of Reactor Projects

'

3

cc w/encl:

S. LaBruna, Vice President - Nuclear Operations

C. Vondra, Manager, Salem Operations

C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.

F. Thomson, Manager, Licensing and Regulation

J. Robb, Director, Joint Owner Affairs

A. Tapert, Program Administrator

L. Reiter, General Manager, QA and Nuclear Safety Review

M. Wetterhahn, Esquire

R. Fryling, Jr., Esquire

J. Isabella, Director, Generation Projects Department,

Atlantic Electric Company

Licensing Project Manager, NRR

D. Wersan, Assistant Consumer Advocate, Office of Consumer Advocate

J. Lipot, State of New Jersey

Lower Alloways Creek Township

K. Abraham, PAO (24) SALP Reports and (2) All Inspection Reports

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of New Jersey

bee w/encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

J. Joyner, DRSS

M. Conner, DRP (SALP Reports Only)

R. Blough, DRP

J. White, DRP

B. Norris, DRP

W. Oliveira, (SALP Reports Only)

DRS SALP Coordinator

DRSS SALP Coordinator

J. Stone, NRR

R. Lobel, EDO

Paul Boehnert, Chairman, ACRS (AIT Reports Only)

Ken Raglin, Technical Training Center (AIT Reports Only)

RI:DRP

JWhite

3/6/92

RI:DRP

NRR

RBlough

3/ /92

JS tone