ML18100A603
| ML18100A603 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 08/30/1993 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| References | |
| NUDOCS 9309150239 | |
| Download: ML18100A603 (6) | |
See also: IR 05000272/1993008
Text
Docket Nos. 50-272
50-311
50-354
Mr. Steven E. Miltenberger
Vice President and Chief Nuclear Officer
Public Service Electric and Gas Company
P.O. Box 236
Hancocks Bridge, NJ 08038
Dear Mr. Miltenberger:
AUG 3 0 199j
SUBJECT:
NOTICE OF VIOLATION CONTAINED IN INSPECTION REPORT NOS.
50-272/93-08, 50-311/93-08,AND 50-354/93-06, SALEM NUCLEAR
GENERATING STATION, UNITS 1 AND 2, AND HOPE CREEK
GENERATING STATION
This responds to your letter of June 7, 1993, which was written in response to the Notice of
Violation (NOV) contained in the subject combined inspection report. This NOV cited a
failure to properly implement the requirements of 10 CPR 50.59 (b) (1). In your letter you
stated that you did not dispute that a violation occurred; but you disagreed with two of the
three examples cited i~ the NOV.
The staff has reviewed your response to the NOV concerning the two cited examples of not
providing a written safety evaluation that you claim were in compliance with industry
guidance, plant specific guidance, and lOCFR 50.59 requirements. The staff disagrees with
your assertion that these two instances are. not examples of the violation, as described below.
Hope Creek. Use-as-is Disposition for Unqualified Gauges:
If a proposed change, test, or experiment changes the facility as described in the UFSAR,
then a 10 CPR 50.59 safety evaluation (i.e., an unreviewed safety question determination) is
required. In this particular case, UFSAR Figure 6.3-2 depicts the gauges in question as
being "Q" gauges (i.e., the gauges are clearly shown within the "Q" boundary and the root
valves to the gauges are clearly shown as being normally open). The proposed change to the
facility (i.e., allowing the use of non-qualified gauges instead of the qualified gauges and
placing the root valves in a normally closed position) did change the facility as described in
the UFSAR and therefore, did require a 10 CFR 50.59 safety evaluation.
As noted in the inspection report, the safety significance of this particular issue is minor.
The violation states that the UFSAR describes the gauges as being safety related and that the
root valves for the gauges as being normally open. The issue is the UFSAR description, not
.
.
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Public Service Electric and Gas Company
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the actual qualification of the gauges. The inspector was presented with enough information
during the inspection to determine that the gauges were not actually safety related.
However, your 10 CFR 50.59 applieability review should have-reviewed UFSAR Figure 6.3-
2 and should have noted that the figure describes the gauges as being safety related and
subsequently resolved the apparent error. Further, your original 10 CFR 50.59 applicability
review should have referenced UFSAR Table 3.2-1, since this table provides the
classification of the structures, systems and components at Hope Creek. Accordingly, we
believe that the original 10 CFR 50.59 applicability review was not performed satisfactorily.
In this case, the figure that depicts the system, and the table that provides the classification
for the components in question, were not referenced and were not addressed in the 10 CFR
50.59 applicability review to validate the correct configuration and description.
Salem Unit 2. Temporary Modification CT-MOD) TMR 92-043:
In your response, you state that the installation of the blank flange in the service water
system was a maintenance activity. Maintenance, as defined in PSE&G Administrative
Procedure NC.NA-AP.ZZ-0059, Rev. 0, (NAP-59) "(c)onsists of activities to prevent or
correct the malfu.nction of a structure, system, or component (SSC) which involves no design
or configuration change (i.e., the SSC must be returned to its original condition or
con.figuration). Maintenance includes calibration, refurbishment, exact replacement-in-kind,
and housekeeping." The maintenance work was performed on the 22 SW return header, not
the flange in question. Therefore, it is the staffs position that this was not a maintenance
activity, but an activity required to support a maintenance activity. It should be noted that.if
the interpretation of maintenance, as stated by PSE&G in the June 7, 1993 letter, is correct,
then the installation of temporary power in T-MOD TMR 92-031 would also be a
maintenance activity. In that case you have already agreed that it should have had a 50.59
safety evaluation.
Changes, as defined in NAP-59, Section 6.2, "(a) re modifications that affect the design,
function or method of peiforming the function of a structure, system or component described
in the SAR." In addition, NAP-59, Section 6.2.1 states "(c)hanges include the following:
Temporary design changes (i.e., jumpers, lifted leads, disconnected piping/tubing;
installation or removal of components and appunenances, temporary lead shielding on pipes
and equipment, temporary blocks and bypasses, temporary suppons, and equipment used on
a temporary basis)." In this case the isolation function was changed by the temporary
installation of a blank flange. Accordingly, the staff concludes that the temporary installation
of the blank flange was a change to the facility as described in the UFSAR and should have
undergone a safety evaluation as required by lOCFR 50.59 .
. --- _:-I
AUG 3 0 1993
Public Service,Electric and Gas Company
3
Based on the above, the staff determined that the "use-as-is" disposition for the installation of
unqualified gauges at Hope Creek, and the installation of the blank flange in the service
- water system at Salem 2 are valid examples of failure to properly implement the
requirements of lOCFR 50.59 (b) (1).
Accordingly, your corrective actions, as stated in the response to the NOV, may not be
sufficient. Please review the actions you have taken to date and determine if additional
modifications to your program are appropriate, and inform this office accordingly, 'within
thirty days of the date of this letter.
You a.Te required to respond to this letter and should follow the instructions specified in the
Notice enclosed with the subject inspection report when preparing your response. In your
response, you should document the specific actions taken and any additional actions you plan
to prevent recurrence. After reviewing your revised response, including your proposed
corrective actions and the results of future inspections, the NRC will determine whether
further NRC enforcement action is necessary to ensure compliance with NRC regulatory
requirements.
-In accordance with 10 CFR 2. 790 of the NRC's "Rules of Practice," a copy of this letter and
its enclosures will be placed in the NRC Public Document Room.
The response directed by this letter and the enclosed Notice are not subject to the clearance
-procedures of the Office of Management and Budget as required by the Paperwork reduction
Act of 1980, Public Law No. 96.511.
~
Your cooperation with us is appreciated.
Sincerely,
Original Signed By:
/IJ¥!_ I~ P-,
Richard W. Cooper, II, Director
_ Division of Reactor Projects
A ur, 3 (} 19!:t3
Public Service Electric and Gas Company
4
cc:
J. Hagan, Vice President - Nuclear Operations
C. Vondra, General Manager, Salem Operations
R. Hovey, General Manager, Hope Creek Operations
F. Thomson, Manager, Licensing and Regulation
J. Robb, Director, Joint Owner Affairs
A. Tapert, Program Administrator
R. Swanson, General Manager, Quality Assurance and Nuclear Safety Review
cc w/cy of Licensee's Letter:
C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
- M. Wetterhahn, Esquire
R. Fryling, Jr., Esquire
P. J. Curham, Manager, Joint Generation Department, Atlantic Electric Company
Consumer Advocate, Office of Consumer Advocate
William Conklin, Public Safety Consultant, Lower Alloways Creek Township
K. Abraham, Public Affairs Officer
Public Document Room (PDR)
~al Public. Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
)*
I ,
.
.; ***
""AUG 3- 0 1993
Public Service Electric and Gas Company
bee w/cy of Licensee's Letter:
Region I Docket Room (with concurrences)
E. Wenzinger, DRP .
J. White, DRP
J. Stone, NRR
S. Dembek, NRR
M. Boyle, PDI-2D, NRR
D. Holody, ORA
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OFFICIAL RECORD COPY
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bee w/cy of Licensee's Letter:
Region I Docket Room (with concurrences)
, E. Wenzinger, DRP
J. White, DRP
J. Stone, NRR
S. Dembek, NRR
M. Boyle, PDI-2D, NRR
D. Holody, ORA
- RJ:DRP
- RI:DRP'
JWhite
EWenzinger
8/ /93
8/ /93
RI: ORA
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DHo1ody
R oo r
8~&'93
8!'f{'J93
OFFICIAL RECORD COPY
- See Prev_ious Concurrence Page
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