ML18102A978
| ML18102A978 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/11/1997 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N97194, NUDOCS 9704220068 | |
| Download: ML18102A978 (5) | |
Text
Public Service Electric and Gas Company APR 11 199/.
Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 Senior Vice President - Nuclear Operations LR-N97194 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-311/96-21 SALEM GENERATING STATION UNIT NO. 2 DOCKET NOS. 50-311 Ladies and Gentlemen:
Inspection Report No. 50-311/96-21 for Salem Nuclear Generating Station Unit No. 2 was transmitted to Public Service Electric & Gas*
Company (PSE&G) on March 12, 1997. *Within the scope of* this report, one violation of NRC requirements was cited.
In accordance with 10CFR2.201, PSE&G is submitting its response to the violation in the attachment to this letter.
The violation.concerns the inadequate p~rformance of Design Change Package acceptance testing.
- should there be any questions regarding this submittal, please contact us.
970422AOD0o8~ 6§86b~11 PDR PDR G
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Printed on Recycled Paper Sincerely, 111111/ llW 11m 11m llWI 111111111111 II Iii II II 0
r 609-339-5700
Document Control Desk LR-N97194 Attachment 2
C Mr. Hubert J. Miller, Administrator -
Region I U. S. Nuclear Regulatory Commission.
475 Allendale Road King of Prussia, PA 19406 Mr. L. N. Olshan, Licensing Project Manager -
Salem
- u. s. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall -
Salem (S09)*
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV.
NJ Department of Environmental Protection Division of Environmental Quality Bureau qf Nuclear Engineering CN 415 Trenton, NJ 08625
STATE OF NEW JERSEY)
)
COUNTY OF SALEM
)
REF: LN-97194.
SS.
L. F. Storz, being duly sworn according to law disposes and says:
I am Senior Vic~ President - Nuclear Operations of Public Service Electric a:nd Gas* Company, and as such, I find the matters set forth in the above referenced letter concerning Salem Generating Station, Unit 2, are true to the best of my knowledge, information*an? be~ief.
r:- otary Publi ~~
. My Commission expires on KIMBERLY JO BROWN.
NOTARY PUBLIC OF NEW JERSEY Mv Cr111111w;sio11 Exnires April 21, 1998
APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Docket Nos:50-311 Salem Nuclear Generating Station Unit 2 License Nos:
DPR~75 During an NRC inspection conducted on December 2, 1996 to January 20, 1997, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy i:!-nd Procedure for.NRC Enforcement.Actions," NUREG-1600, the violation and the PSE&G response is listed below:
Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality shall be prescribed by procedures and shall be*
accomplished in accordance with those procedures.
Procedure NC.DE-AP.ZZ-0012(Q), Rev 6, Test Prografu, ~~ction 4.1 requires tests to verify co~rect installation and proper operations.
Also, Section 5.1.. c requires that.design change Special Test Procedures (STPs) be prepared in accordance with the format and
- guidelines contained in.that procedure.
The requirements include:
"Initial Conditions... such as filling tanks, valve lineups, support system operational status, etc." are to be included in STPs with sign-offs: "The step by step instructions should include a description of expected plant response and specific guidance for when to abort the test and ho.w to do. so... ; " and should "Provide test engineer sign~offs on the a~propriate steps of the data sheets... to ensure that the step was completed."
Contrary to the above, post-modification test procedures for the Salem Control.Room Area air conditioning system did not contain required initial conditions or step sign-off, as evidenced by the following examples;
- 1.
Procedure STP-1, Revision 1 Integrated Test of Control Area Air Conditioning System (CAACS)/Emergency Air*Conditiohing System (EACS) [to verify proper operation of isolation dampers and EACS fansJ, had no provisions for establishing initial conditions for the ventilation system nor support systems, such as power and air.
In additio~, after testing the system in an emergency mode
_and then pressing the "Normal~ control switch, there was no confirmation step to ensure the dampers had returned to the "Normal" position before continuing with the next emergency mode test.
Also, the procedure had no provis~ons for aborting and exiting the test nor for re-entering.the test.
- 2.
Procedure lEC-3505-1 STP-3, Revision 2, CAV Testing and Balancing, had no provisions f~r initial conditions for the ventilation system or support systems, nor did the procedure consistentl~ provide for sign off of steps requiring* the collection of data.
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I
. \\t This is a Severity Level IV violation (Supplement 1)
PSE&G concurs with the violation (1)
The reason for the violation.
This violation was caused by person~el error and inadequate review, in that the guidance contained in NC.DE-AP.ZZ-0012(Q)
"Test Program," was not followed during te~t preparation. *
(2)
The corrective steps that have been taken.
- 1.
The personnel involved in this incident have been held accountable in accordance with PSE&G*policies.
- 2.
The deficiencies in ~he Speci~l Test Procedure-1 (STP-1) were corrected. *
- 3.
The deficiencies in the STP-3 were corrected.*
- 4.
A review of the 0th.er STP' s associated with the Control Room Emergency Air Conc;iitioriing System (CREACS) upgrade was performed.
This review identified a-question on another procedure (STP-4.)
The question on STP-4 was answered without requiring a revision.to the procedure.
- 5.
A review of the DCP acceptance testing for the.Auxiliary Building Modification was completed.
This review did not identify any issues with ~hese tests.
- 6.
An independent review of selected DCP tests* associated with eight systems* has been completed, and no deficiencies* were identified.
- 7.
An additional review of the Unit 1,.Unit 2 and common open DCP acceptance tests to identify simi~ar deficiencies was completed.
Two DCP acceptance tests required revisions.
- 8.
Newly issued. DCP acceptance tests will be independently reviewed for compliance with NC.DE-AP.ZZ-0012(Q), to ensure adequate revi~ws.
(3)
The corrective steps that will be taken to avoid further violations.
No further corrective actions are planned.
(4)
The date when full compliance will be achieved.
Full compliance wa~ achieved when the STP-1 procedure was revised on January 15, 1997, and STP-3 procedure was revised on
_January 22, 1997.
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