ML18101A390

Notice of Violation from Insp on 940912-1021.Violations Noted:Inservice Testing of Certain Code Class 2 Check Valves Not Performed in Accordance W/Asme Code Section Xi.Page 3 Corrected to Ref Public Svc Electric & Gas Co

ML18101A390
Person / Time
Site:	Salem
Issue date:	12/09/1994
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18101A388	List: ML18101A387 ML18101A390
References
50-272-94-21, 50-311-94-21, NUDOCS 9412200019
Download: ML18101A390 (3)

Text

-'*

APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Units 1 and 2 Docket Nos.

50-272; 50-311 License Nos. DPR-70; DPR-75 During an NRC inspection conducted at Salem Units 1 and 2 from September 12 to September 16, 1994 and October 19 to October 21, 1994, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

A.

10 CFR Part 50.55a(f) requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific written relief has been requested by the licensee and granted by the Commission.

ASME Code Section XI, Subarticle IWV-3521, "Test Frequency,"

requires that -check valves shall be exercised at least once every 3 months, except as provided by IWV-3522.

ASME Code Section XI, Subarticle IWV-3522, "Exercising Procedure,"

requires that check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation. If only limited operation is practical, during plant operation the check valve shall be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns.

Generic Letter (GL) No. 89-04, "Guidance On Developing Acceptable Inservice Testing Programs," Attachment 1, Position 2, "Alternative To Full Flow Testing Of Check Valves,~ states that valve disassembly and inspection can be used as a positive means of determining that a valves's disk will full stroke exercise open, and that disassembly and inspection may be performed during reactor refueling outages.

Such an approach (for check valves 1(2)PR25) was approved in the NRC's safety evaluation, dated October 29, 1992, and committed to in a PSE&G letter, dated October 12, 1993.

Contrary to the above, as of October 21, 1994, inservice testing of certain Code Class 2 check valves was not performed in accordance with ASME Code Section XI, as ev*i denced by the following examples:

1.

Since October 12, 1993, check valves 1SJ3 and 2SJ3 were not part-stroke exercised during plant operation or full-stroke exercised during cold shutdowns.

9412200019 941209 PDR ADOCK 05000272 G

PDR

Appendix A 2

2.

Since October 9, 1992, check valves 1PR25 and 2PR25 were not full-stroke exercised during cold shutdowns, or disassembled and inspected during reactor refueling outages.

This is a Severity Level IV violation.

(Supplement I)

B.

10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action,".

requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.

In the case of significant conditions adverse to quality, the measur~s shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, significant conditions adverse to quality were not promptly identified, causes were not' determined, or corrective actions were not taken to preclude repetition, as evidenced by the following examples:

1.

Failure to establish new vibration reference values, or to reconfirm old reference values, following corrective maintenance on safety-related pumps was identified, and corrective action requests were initiated, during Quality Assurance Department inservice test program audits performed in 1988 and 1990.

Corrective actions taken to preclude repetition of this condition adverse to quality were not effective in that new reference values were not established, or old reference values reconfirmed, following corrective maintenance on the No. 21 component cooling water pump on July 6, 1993.

2.

During performance of a surveillance test of No. 21 safety injection pump on March 31, 1994, apparent leakage through a pump discharge relief valve to the pressurizer relief tank was observed, which potentially could have diverted makeup water from the reactor coolant system during the injection phase of an accident.

The cause of this condition adverse to quality was not identified and corrected promptly resulting in recurrence of the condition during subsequent performance of the surveillance test on June 22, 1994.

This is a Severity Level IV violation.

(Supplement I)

Appendix A 3

Pursuant to the provisions of 10 CFR 2.201, Public Service Electric & Gas Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C.. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting _this Notice of Violation. This reply should be clearly marked as, "Reply to a Notice of Violation" 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 violations, and (4) the date when full compliance will be achi.eved.

If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.