ML18101A824
| ML18101A824 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/14/1995 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| Shared Package | |
| ML18101A825 | List: |
| References | |
| EA-95-062, EA-95-62, NUDOCS 9507210047 | |
| Download: ML18101A824 (6) | |
See also: IR 05000272/1995010
Text
July 14, 1995
EA No. 95-62
Mr. Leon R. Eliason
President and Chief Nuclear Officer
Public Service Electric and Gas Company
P.O. Box 236
Hancocks Bridge, NJ
08038
SUBJECT:
SALEM RESIDENT INSPECTION NOS. 50-272/95-10; 50-311/95-10
Dear Mr. Eliason:
The enclosed report documents an inspection for public health and safety,
conducted by Mr. C. Marschall, Senior Resident Inspector and other members of
the NRC resident and regional staff at the Salem Nuclear Generating Station.
The report covers the period between May 7, 1995 and June 23, 1995.
The
inspectors discussed the findings of this inspection with Messrs. J. Summers,
General Manager-Salem operations, and other members of your staff in an
inspection exit meeting on June 23, 1995.
These apparent violations (as
described in the Appendices) were discussed between Messrs. Joseph Hagan, Vice
President-Nuclear Operations, Mr. Jeffrey Benjamin, Director-Quality Assurance
and Nuclear Safety Review, and Mr. John White of our office on July 11, 1995.
During this period, Salem management and staff continued to demonstrate
significant weakness in performing operability determinations for degraded
safety-related equipment, and implementing prompt and effective corrective
actions.
Two of these latest examples involved degraded equipment affecting
switchgear ventilation equipment in Unit 1, and residual heat removal (RHR)
minimum flow recirculation valves in Unit 2.
In these cases, your staff
failed to respond promptly when component failures affecting these systems
were first identified in December 1994 and January/February 1995,
respectively.
Even after it became more imperative to address these component
issues, your staff delayed operability decision-making until it was apparent
that a basis could not be established to justify continued operation.
Subsequently, the units were shutdown in accordance with license requirements
on May 16 and June 7, 1995, respectively.
Additionally, ineffective corrective actions, due to previously deficient root
cause efforts, continue to be identified as equipment problems recur.
For
example, the previous repetitive failures of jacket water instrument lines on
one or more emergency diesel generators were not effectively diagnosed as to
cause; and previous observations of anomalous noise from RHR system valves
(RH-10) were not evaluated relative to potential safety impact.
In these
cases, your organization accommodated the conditions without effective root
cause assessment or understanding of the nature of the problems since 1992.
These latest examples of poor operability decision-making and corrective
action ineffectiveness appear to be similar in nature to your organization's
approach to problem resolution that failed to effectively resolve degraded
equipment issues and deficient conditions that were factors in previous events
such as: the Unit 2 turbine-generator failure in November 1991, caused, in
. .. . ,.. . . . .
9507210047 950714
ADOCK 05000272
-'
Leon R. Eliason
2
- part, by your organization's delay of planned maintenance and failure to
resolve abnormal equipment performance response; the multiple rod control
system failures during Unit 2 start-up in May 1993, caused by your
organization's failure to understand the nature and reason for the abnormal
system response; and the Unit 1 plant trip in April 1994, the recovery from
which was exacerbated, in part, by multiple operator work-aro.unds that were
willingly accommodated by your organization without resolution.
In view of the numerous other exampJes of your failure to properly respond to,
and effectively correct, degraded safety-related system performance (brought
to your attention in previous NRC Inspection Reports 50-272[311]/95-02 and 95-
07), and the inadequacy of your actions to promptly resolve known technical
issues associated with the pressurizer overpressure protection system
(identified in NRC Inspection Report 50-272[311]/94-32), we question your
willingness and ability to promptly and critically assess anomalous
conditions, suspect component reliability, or other degraded equipment issues.
From our perspective, your organization has demonstrated a proclivity to avoid
prompt problem resolution, and operability and corrective action decision-
making, by failing to process emergent issues in accordance with your
established procedures in a timely manner, subjecting the matters to lengthy
analysis and indeterminate conclusion, or attempting to justify continued
operation with insufficient basis. Further, your approach to *operability
decision-making is often biased toward a positive determination without
reference to, or consideration of, the applicable design basis.
Consequently, the matters described in Appendix A are being considered for
escalated enforcement action (in addition to other matters brought to your
attention in previous inspection reports) in accordance with the "General
Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement
Policy), (60 FR 34381; June 30, 1995). Accordingly, no Notice of Violation is
presently being issued for these inspection findings.
The number and
characterization of apparent violations described in Appendix A and the
enclosed inspection report may change as a result of further NRC review.
A predecisional enforcement conference to discuss these apparent violations
has been scheduled for July 28, 1995.
This conference will be closed to
public observation.
The decision to hold a predecisional enforcement
conference does not mean that the NRC has determined that these violations
have occurred or that enforcement action will be taken. This conference is
being held to obtain information to enable the NRC to make an enforcement
decision, such as a common understanding of the facts, root causes, missed
opportunities to identify the apparent violations sooner, corrective actions,
significance of the issues and the need for lasting and effective corrective
action.
You should also be prepared to address our concerns about your
performance as characterized in this letter.
In addition, this is an
opportunity for you to point out any errors in our inspection report and for
you to provide any information concerning your perspectives on 1) the severity
of the violations, 2) the application of the factors that the NRC considers
when it determines the amount of a civil penalty that may be assessed iri
accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other
application of the Enforcement Policy to this case, including the exercise of
discretion in accordance with Section VII.
You will be advised by separate
Leon R. Eliason
3
correspondence of the results of our deliberations on this matter.
No
response regarding the apparent violations is required at this time.
Based on the findings of this inspection, the NRC determined that violations
of NRC requirements occurred. These violations are cited in Appendix B,
Notice of Violation (Notice). The circumstances surrounding these matters are
described in detail in the subject inspection report. The violations are of
concern because these matters indicate continuing weaknesses relative to
control of maintenance activities and procedural adherence.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
Your response may reference or
include previous docketed correspondence, if the correspondence adequately
addresses the required response. After reviewing your response to this
Notice, 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.
The responses to the apparent violations described in Appendix B and the
enclosed inspection report are not subject to the clearance procedures of the
Office of Management and Budget as required by the Paperwork Reduction Act of
1980, Pub. L. No. 96.511.
In accordance with 10 CFR 2.790 of the NRC's "Rules
of Practice," a copy of this letter and its enclosure will be placed in the
NRC Public Document Room.
Your cooperation with us is appreciated.
Docket Nos. 50-272
50-311
Enclosures:
Sincerely,
ORIGINAL SIGNED BY:
Richard W. Cooper II, Director
Division of Reactor Projects
1.
Appendix A, Apparent Violations Considered for Escalated Enforcement
Action
2.
Appendix B, Notice of Violation
3.
NRC Inspection Report Nos. 50-272/95-10; 50-311/95-10
Leon R. El i a son
4
cc w/encls:
J. J. Hagan, Vice President-Operations
E. Simpson, Senior Vice President - Nuclear Engine~ring and Plant Betterment
C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.
General Manager - Information systems & External Affairs
J. Summers, General Manager - Salem Operations
J. Benjamin, Director - Quality Assurance & Safety Review
F. Thomson, Manager, Licensing and Regulation
R. Kankus, Joint Owner Affairs
A. Tapert, Program Administrator
R. Fryling, Jr., Esquire
M. Wetterhahn, Esquire
P. MacFarland Goelz, Manager, Joint Generation
Atlantic Electric
Consumer Advocate, Office of Consumer Advocate
William Conklin, Public Safety Consultant, Lower Alloways Creek Township
Public Service Commission of Maryland
State of New Jersey
State of Delaware
- Mr. Leon R. Eliason
5
Distribution w/encls:
Region I Docket Room (with concurrences)
Kay Gallagher, DRP
Nuclear Safety Information Center (NSIC)
D. Screnci, PAO (2)
NRC Resident Inspector
K. Kolaczyck, DRS (section 2.1)
L. Scholl, DRS (section 2.1)
PUBLIC
Distribution w/encls: (Via E-Mail)
L. 01 sh an, NRR
W. Dean, OEDO
J. Stolz, PDl-2, NRR
M. Callahan, OCA
Inspection Program Branch, NRR (IPAS)
DOCUMENT NAME:
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OFFICE
NAME
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APPENDIX A
APPARENT VIOLATIONS CONSIDERED FOR ESCALATED ENFORCEMENT ACTION
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part,
that licensees shall promptly identify and correct conditions adverse to
quality, and for significant conditions adverse to quality, the licensee shall
also determine the cause, take action to preclude repetition, document the
corrective action, and notify appropriate levels of management.
Contrary to the above, the Salem staff did not promptly identify, correct,
determine the cause, notify appropriate levels of management, or initiate
corrective action to preclude recurrence for the following conditions:
A.
From January 26, 1995, for the 22 RHR pump minimum recirculation flow
valve and from February 9, 1995 for the no. 21 RHR pump minimum
recirculation flow valve, until June 7, 1995 plant staff failed to
correct or determine the cause of the failure of the valves to
automatically open on low RHR flow as required to prevent RHR pump
failure.
As a result, both trains of RHR for Salem Unit 2 were
inoperable from February 9, 1995 until June 7, 1995.
B.
.From December 12, 1994 until May 16, 1995, plant staff failed to correct
or determine the cause of failure of the no. 12 safety related
switchgear ventilation supply fan.
As a result from December 12, 1994
until May 16, 1995, the licensee operated Salem Unit 1 with a safety
related electric power system incapable of withstanding a single failure
and continuing to perform its intended function.
C.
On March 6, 1995, May 3, 1995, and May 8, 1995, the Salem Unit 1 staff
failed to correct, determine the cause, or prevent recurrence of failure
of the Containment 100 foot elevation personnel airlock to pass its
local leak rate test. As a result, from March 6, 1995 until May 8,
1995, the containment boundary was incapable of withstanding a single
failure and continuing to perform its intended function.
D.
From February 29, 1992 until June 7, 1995, Salem Unit 1 staff failed to
correctly determine the cause or take action to preclude recurrence of
failures of instrument lines connected to the jacket water cooling
system for the no. lB and no. lC emergency diesel generators.
E.
From July 11, 1992 until June 10, 1995 Salem staff failed to determine
the cause, correct, or- take action to preclude recurrence of impact
noises from the interior of the no. 21 Residual Heat Removal discharge
manual isolation valve (21RH10) .