ML18102B367

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Notice of Violation from Insp on 970301-0412.Violation Noted:Post Mod Test Procedures for Caacs Were Not Followed, Required Data Not Recorded & Plant Equipment Restored W/Test Results Outside Acceptance Criteria
ML18102B367
Person / Time
Site: Salem  
Issue date: 05/30/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18102B366 List:
References
50-311-97-06, 50-311-97-6, NUDOCS 9706090092
Download: ML18102B367 (3)


Text

NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Unit 2 Docket No:

50-311 License No: DPR-75 During an NRC inspec_tion conducted on March 1 to April 12, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions/' NUREG-1600, the violations are listed below:

Appendix B, Criterion V of 10 CFR 50 requires that activities affecting quality be prescribed by procedures and shall be accomplished in accordance with those procedures.

Procedure NC.DE-AP.ZZ-0012(0), "Test Program," Revision 6, Section 5.2.c requires testing to be conducted with approved step-by-step Special Test Procedures, existing procedures, or standards. Section 5.2.e requires recording test data on data sheets.

Section 5.2.f requires evaluating test results to ensure they are acceptable prior to restoring plant equipment.

Contrary to the above, post-modification test procedures for the Salem control room area air conditioning system (CAACS) were not followed, required data was not recorded, and plant equipment was restored with test results outside established acceptance criteria, as evidenced by the following examples:

1.

Procedure 1 EC-3505 package No. 1 STP-2, Revision 2, Control Area Air Conditioning System (CAACS) and Emergency Air Conditioning System (EACS) Coil Test Procedure [to verify heat transfer capability of Unit 1 CAACS and Unit 1 EACS cooling coil units], steps 5.5.3. 7 and 5.5.4. 7 required the initiation of an Action Request (AR) to clean the coils if the coil appearance was not "bare metal or shiny appearance." The condition of the coil for 1 HVE200, recorded on Attachment 7.12 was "... covered with white chalky film... " and an AR to clean the coil was not initiated.

2..

Procedure 1 EC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential for leakage into the control room pressure boundary], attachment 7.3 establishes EACS charcoal filter housing and duct maximum allowable leakage test acceptance criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10. 78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established acceptance criteria, but the test results were approved and the EACS system was restored to service.

9706090092 970530 PDR ADOCK 05000311 G

PDR

3.

2 Procedure 1 EC-3505 Package No. 1 STP-4, Revision 3, attachment 7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric pressure recorded in inches of mercury (inHg) and initial boundary pressures in pounds per square foot (psf) absolute (abs.), the

  • test pressures were less than the required 4 inwc.
4.

Procedure 1 EC-3505 Package No. 1 STP-4, Revision 3, Appendix A, steps 2.e and 2.h require recording the initial and final times of the test. The times were not recorded.

5.

Proc.edure 1 EC3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring review of test data by the test engineer was incorrectly deleted by Modification Concern and Resolution 297.

This is a Severity Level IV problem (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Pubic Service Electric and 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 (Notice). This reply should be clearly marked as a "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 achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to 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.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response

3 that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2. 790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated '- King of Prussia, Pennsylvania this30 Clay of #/Jr 1997