ML18107A272

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Notice of Violation from Investigation Between 980303- 990119.Violation Noted:On 980103 & 980223,release Rate Calculations to Support Release of Liquid Waste Changed by Chemistry Supervisor
ML18107A272
Person / Time
Site: Salem 
Issue date: 04/30/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18107A271 List:
References
EA-99-035, EA-99-35, NUDOCS 9905110068
Download: ML18107A272 (3)


Text


ENCLOSURE 1 NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Unit 1 Docket No.

50-272 License No.

DPR-70 EA 99-035 Durin*g an NRG investigation conducted by the NRG Office of Investigations (01) between March 3, 1998 and January 19, 1999, a violation of NRG requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRG Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50.9 requires, in part, that information required by the Commission's regulations to be maintained by the licensee shall be complete and accurate in all material respects.

Salem Unit 1 Technical Specification (TS) 6.8.1.a requires that written procedures be implemented covering activities referenced in Regulatory Guide 1.33, Revision 2, February 1978. Appendix A of Regulatory Guide 1.33 specifies, in Section 7.a(3), written procedures for discharging liquid radioactive waste to effluents. Appendix A of Regulatory Guide 1.33 also specifies, in Section 1.h, written procedures for record retention.

Salem Operations procedure S1.OP-SO.WL-0001 (Q), Revision 9, "Release of Radioactive Liquid Waste From 11 CVCS Monitor Tank" requires that two independent verifications of radioactive liquid release rate calculations are to be completed and that the release records are retained in accordance with nuclear procedure NC.NA-AP.ZZ-0003(Q). Salem Unit 1 TS 4.11.1.1.2 requires the results of radioactivity analyses to be used in accordance with the Offsite Dose Calculation Manual (ODCM) to assure concentrations at the point of*

release are maintained within TS limits.

Contrary to the above, on January 3, 1998 and February 23, 1998, release rate calculations to support the release of liquid waste were changed by a chemistry supervisor, and

1.

. the conservatism factor, specified in the procedure and the ODCM to account for non-gamma emitting radio nuclides, was omitted for the release rate calculations for two releases on January 3, 1998, and an intended release on February 23, 1998; and

2.

the Release and Approval record for the intended release on February 23, 1998, was not accurate in all material* respects in that it indicated that there were two independent verifications of the Radioactive Liquid Release Rate calculations, when, in fact, not all independent verifications had been done. The records were material because they provide verification that the release would not exceed Technical Specification limits. (01014)

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

9905110068 990430

~DR ADOCK 05000272 PDR 2

The NRC has concluded that the information regarding the reasons for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full

  • compliance was achieved is already adequately addressed in the letter transmitting this NOV.

However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that

  • ease, or if you choose to contest this enforcement action, clearly mark your response as a "Reply to a Notice of Violation," and send it 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).

If you choose to contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

If you choose to respond, your response will be placed in the NRC Public Document Room (PDR).

Therefore, 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.

Dated ft King of Prussia, PA thi~O.fh day of April 1999

r

~ ENCLOSURE 2 SYNOPSIS This investigation was initiated by the U.S. Nuclear Regulatory Commission (NRC), Office of

  • Investigations (01), Region I (RI), on March 3, 1998, to determine if a Public Service Electric and Gas (PSE&O) Chemistry Supervisor at the Salem <Jenerating Station, made false statements regarding technical specification (tee~ spec) requirements for the release of a Chemical Volume Control System (CVCS) Monitor Tank.

Based on the evidence developed during the investigation, 01 concludes that there is insufficient evidence to substantiate that a Chemistry Supervisor knowingly and deliberately made false statements regarding tech spec requirements in regards to the line out and pen and ink changes which he made to Chemistry Procedure SC.CH-TI.ZZ..0140-1. However, testimonial and documentary evidence developed leads 01 to the concb.i:sion that a Chemistfy Supervisor, on February 23, 1998, knowingly and deliberately fidsified Sections 2.1.2.A and 2.1.3 of the Operations Procedure Sl.OP-SO.WL-0001 (Q) Rev. 9 indicating that two independent verifications of Radioactive Liquid Release Rate calculations and all Chemistry requirements for the release bad-been completed and authorizing release, when he knew that they bad not been completed.