ML18102B542

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Forwards NOV Discrepancies Identified in 970411,0630 & 0716 Responses to Nov.Discrepancies Suggest That More Attention to Detail May Be Warranted When Preparing Responses to Violations
ML18102B542
Person / Time
Site: Salem  
Issue date: 08/22/1997
From: Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Eliason L
Public Service Enterprise Group
References
NUDOCS 9709020076
Download: ML18102B542 (5)


Text

-... t August 22, 1997 Mr. Leon R. Eliason Chief Nuclear Officer & President Nuclear Business Unit Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

RESPONSES TO NOTICES OF VIOLATION (REPLY)

Dear Mr. Eliason:

We have reviewed your responses to Notices of Violation, dated April 11, June 30, and July 16, 1997. In addition, we have conducted independent reviews of your corrective actions during onsite inspections at the Salem Nuclear Generating Station.

Although we found your overall actions acceptable, we have identified several discrepancies in your responses and would like to take this opportunity to bring them to your attention. The discrepancies we have identified are listed in Enclosure 1. These discrepancies suggest that more attention to the detail may be warranted when preparing responses to violations.

Specifically, if your staff identifies new relevant information that bears on a reply to a Notice of Violation, that new information ought to be considered for incorporation into the reply.

Please call me at (610) 337-5357 or William H. Ruland at (610) 337-5376 if you would like to discuss this matter further.

Docket Nos. 50-272; 50-311 9709020076 970822 PDR ADOCK 05000272 G

PDR Sincerely, ORIGINAL SIGNED BY:

James T. Wiggins, Director Division of Reactor Safety

\\ \\\\\\\\\\\\ \\\\\\\\\\ \\\\\\\\\\ \\\\\\\\\\\\)\\\\\\ \\\\\\\\\\ \\\\\\\\ \\\\\\\\

1--

.I Mr. Leon R. Eliason 2

cc:

L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.

D. Garchow, General Manager - Salem Operations J. McMahon, Director - Quality Assurance & Nuclear Safety Review D. Powell, Manager, Licensing and Regulation R. Kankus, Joint Owner Affairs A. Tapert, Program Administrator J. J. Keenan, Esquire J. A. Isabella, Manager, Joint Generation Atlantic Electric Consumer Advocate, Office of Consumer Advocate William Con~lin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland State of New Jersey State of Delaware

~...

Mr. Leon R. Eliason Distribution:

Region I Docket Room (with concurrences)

C. O'Daniell, DRP Nuclear Safety Information Center (NSIC)

J. Linville, DRP S. Barber, DRP L. Harrison, DRP G. Kelly, DRS N. Della Greca, DRS NRC Resident Inspector PUBLIC L. Olshan, NRA W. Dean, OEDO J. Stolz, PDl-2, NRA M. Callahan, OCA Inspection Program Branch, NRR (IPAS)

R. Correia, NRR.

F. Talbot, NRA C. Miskey, DRS DOCUMENT NAME: A:\\SALNOVS.REP 3

To receive 11 copy of this document, lndlcete In the box: *c* = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRS I

RI/DRS I

Rl/DRP I IJ RI/DRS J

NAME A Fuhrmeister WRuland Jlinville %.fil Tl' l-JWiggins~)""

DATE 08/13/97 08/J5'197 08/J5f97 08/Z.lf97 08/ /97 OFFICIAL RECORD COPY I

ENCLOSURE 1 Notice of Violation Discrepancies

1.

In the attachment to your April 11, 1997, response letter, LR-N97194, on page 2, under corrective steps that have been taken, item 4 states: "A review of the other STPs associated with the Control Room Emergency Air Conditioning 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."

During our onsite review of your activities, we determined that condition report 970326255, documenting an inadequacy in Special Test Procedure 1 EC-3505, Pkg. 1, STP-4, was issued March 26, 1997. This deficiency would require a change to the procedure during Part "B" closure, according to the information in your corrective action database.

2.

In addition, you stated that full compliance was achieved when the STP-1 procedure was revised on January *15, 1997, and STP-3 procedure was revised on January 22, 1997.

During our onsite reviews, we identified Condition Report 97041'5322, which was issued subsequent to your response, which states that 1 EC-3505, Pkg. 1., STP-4 is inadequate to establish the design bases, due to, among other problems, not having enough details and signoffs.

3.

In the attachment to your June 30, 1997, response, PSE&G letter LR-N970371, under corrective steps that have been taken, you stated, "In response to the issues in CAV STPs, the TRB reviewed ten non-HVAC system STPs in the following five systems: Fire Protection; 11 5 VAC; Emergency Diesel Generators; Safety Injection; and Service Water. These STPs were conducted prior to corrective actions being implemented. No other examples of noncompliance to acceptance criteria were identified."

r During our onsite reviews, we reviewed Condition Report 970606323, issued June 6, 1997. This condition report identified that during testing of the 1 B diesel generator, the test was not performed in accordance with test procedure criteria.

4.

In the attachment to your July 16, 1997, response, PSE&G letter LR-N970449, on page 3, under corrective actions taken, paragraph 2 states, "Modification Concern and Resolution (MCR) 193 to the design change test procedure revised the leakage rate acceptance criterion based on Control Room Dose Calculation... "

i j1.

-I, 2

NRC Combined Inspection Report 50-272/97-06, 50-311 /97-06, in Section E4.1, on page 4 states, "The test results were accepted, but the MCR neither changed the test procedure acceptance criterion nor updated the UFSAR." This statement is in reference to MCR 193, and formed one of the bases for the NOV issued with IR 97-06. Our reviews of the corrective actions actually performed determined that the acceptance criterion was, in fact, revised by an administrative change issued on June 10, 1997, at the time of final closure of the package.