ML18102B614
| ML18102B614 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/08/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18102B613 | List: |
| References | |
| 50-272-97-09, 50-272-97-9, 50-311-97-09, 50-311-97-9, EA-97-182, EA-97-257, NUDOCS 9710150197 | |
| Download: ML18102B614 (3) | |
Text
ENCLOSURE NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Docket Nos. 50-272/50-311 License Nos. DPR-70/DPR-75 EA Nos.97-182 and 97-257 Units 1 and 2 During NRC inspections conducted May 17 to 21, 1993, July 19, 1993, and March 24 to April 18, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the following violations were identified:
I.
VIOLATIONS ASSOCIATED WITH ECCS SUCTION SWITCHOVER A.
1 O* CFR 50.59, Changes, tests, and experiments, permits licensees to make changes to the facility and to procedures, as described in the Safety Analysis Report, without prior Commission approval, provided that the proposed changes do not involve an unreviewed safety question. A proposed change, test, or experiment shall be deemed to involve an unreviewed safety question if the probability of occurrence of a malfunction of equipment important to safety evaluated in the safety analysis report may be increased.
Contrary to the above, on March 16, 1996, the licensee made changes to the facility and procedures as described in the Updated Final Safety Analysis Report (UFSAR) that increased the probability of an occurrence of a malfunction of equipment important to safety and resulted in an unreviewed safety question, without prior Commission approval.
Specifically, changes were made to procedure 2-EOP-LOCA-3, Transfer to Cold Leg Recirculation, and to the UFSAR to reflect changes in refueling water storage tank drain down time and operator response time that resulted, in certain cases, in interruption of emergency core cooling flow to the reactor core. The interruption of ECCS flow to the core increased the probability of a malfunction of the ECCS pumps. (01013)
B.
10 CFR 50. 72 and 50. 73 require the NRC to be notified within one hour, and a Licensee Event Report to be submitted within 30 days, respectively, for any event or condition that results in the nuclear power plant being in a condition that is outside the design basis of the plant, or for any event or condition that alone could have prevented the fulfillment of the safety function of systems that are needed to remove residual heat.
Contrary to the above, as of April 17, 1997, the licensee did not notify the NRC within one hour, or submit a Licensee Event Report within 30 days, of conditions that resulted in the nuclear power plant being in a condition that is outside the design basis of the plant and a condition that alone could have prevented the fulfillment of the safety function of systems that are needed to remove residual heat.
Specifically, in certain cases, the time available to complete switchover of reactor coolant system cold leg recirculation cooling from the refueling water storage tank to the containment sump was not 9710150197 971008 PDR ADOCK 05000272 G
Enclosure 2
sufficient to ensure that emergency core cooling system flow to the reactor core would not be interrupted. This was not consistent with the design basis for License Amendment No. 69 which specified uninterrupted flow to all ECCS pumps during the switchover. With the reduced time available to complete the switchover, it was more likely that the switchover would not be completed successfully. The failure to successfully complete the switchover prior to drain-down of the RWST could have prevented the RHR system from performing its function of removing residual heat during long-term recirculation cooling. These conditions were identified on November 1, 1995; however, they had not been reported to the NRC as of April 17, 1997. (01023)
Violations I.A and l.B are classified in the aggregate as a Severity Level Ill problem (Supplement I).
II.
VIOLATIONS ASSOCIATED WITH FIRE BARRIER SYSTEMS 10 CFR 50.48, "Fire Protection" requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, which includes Salem Unit 1, have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR Part 50 and that fire protection features required to satisfy Criterion 3 of Appendix A meet the requirements of Appendix R to 10 CFR Part 50.
For Salem Unit 2, facility operating license DPR-75, license condition 2.C.10, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR).
Section 9.5.1 of the UFSAR, common to both units, describes the fire protection program and features. Section 9.5.1.1.5 of the UFSAR, "Quality Assurance Program for Fire Protection," states, in part, that the Quality Assurance (QA) program at Salem Generating Station assures that the requirements for installation for the fire protection program for safety-related areas are satisfied and that the QA program for fire protection is part of the overall station QA program.
A.
Section 9.5.1.1.5 of the UFSAR, requires, in part, that design control measures are established to assure that applicable NRC guidelines are included in design, and that design changes and deviations are adequately reviewed and approved.
Contrary to the above, prior to April 18, 1997, design deviations were not adequately reviewed and approved for the fire protection program electrical raceway fire barrier systems (ERFBSs).
Specifically, the installed configurations of. certain Kaowool, FS-195, and lnteram E-50 ERFBSs were not consistent with the configurations in which the ERFBSs were tested and the deviations were not resolved by representative testing. As a result, it could not be assured that the ERFBSs met the NRC guidelines for compliance with the requirements of 10 CFR Part 50, Appendix R, Section 111.G.2.c for one hour rated fire barriers. (02014;
r Enclosure 3
B.
10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed by and accomplished in accordance with
, documented instructions or procedures.
Nuclear Fire Protection procedure SC.FP-AP.ZZ-0003(0), Rev. 5, "Actions For Inoperable Fire Protection - Salem Station," section 5.2 and Attachment 1, specify that, with an inoperable fire barrier in Class 1 (safety-related) areas, firewatch patrols must be established within one hour.
Contrary to the above, from April 1994, until April 8, 1997, fire watch patrols were not properly implemented or maintained for inoperable fire barriers during such time as the capability of the three types of one hour ERFBSs was in question as described in II.A above. (03014)
These are Severity Level IV violations (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric & Gas Company (Licensee) 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 have been 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 of 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.
Under the authority of Section 182 of the ACT, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Because your response will be placed in the NRC Public Docket 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. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at King of Prussia, Pennsylvania this 8th day of October 1997
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