ML20127E280
| ML20127E280 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/17/1985 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil Public Service Enterprise Group |
| References | |
| NUDOCS 8506240504 | |
| Download: ML20127E280 (2) | |
See also: IR 05000272/1984046
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JUN 171985
Docket Nos. 50-272
50-311
Public Service Electric and Gas Company
ATTN: Mr. Corbin A. McNeill, Jr.
Vice President - Nuclear
P. O. Box 236
Hancock's Bridge, New Jersey 08038
Gentlemen:
Subject:
Inspection Report Nos. 50-272/84-46and56-311/84-46
This refers to your letter dated May 2,1985, in response to our letter dated
April
2,- 1985.
Thank you for informing us of the corrective and preventive actions documented
in your letter.
These actions will be examined during a future inspection of
your licensed program.
Your cooperation with us is appreciated.
Sincerely,
/
Stewart D. Ebneter, Director
Division of Reactor Safety
cc:
R. L. Mittl, General Manager - Nuclear Assurance and Regulation
J. M. Zupko, Jr., General Manager - Salem Operations
E. A. Liden, Manager - Nuclear Licensing and Regulation
C. P. Johnson, Manager - Quality Assurance Nuclear Operations
P. M. Krishna, Manager - Nuclear Review Board
A. J. Pietrofitta, General Manager, Power Production Engineering, Atlantic
Electric
M. J. Wetterhahn, Esquire
R. Fryling, Jr. , Esquire
Public Document Room (PDR)
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Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
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OFFICIAL RECORD COPY
CRL SALEM 84-46 - 0001.0.0
06/11/85
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Public Service Electric & Gas Co.
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Region I. Docket Room (with concurrences)
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0FFICIAL RECORD COPY
CRL SALEM 84-46 - 0002.0.0
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Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge. NJ 08038 609 339-4800
Corbin A. McNelli Jr. Vice President - Nuclear
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May 2,
1985
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Dr. Thomas E.
Murley, Regional Administrator
Region 1
U.S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
Dear Dr. Murley:
NOTICE OF VIOLATION - NON-FUNCTIONAL FIRE BARRIERS
COMBINED INSPECTION REFORT NOS. 50-272/84-46 AND
50-311/84-46
SALEM GENERATING STATION
DOCKET NOS. 50-272 AND 50-311
Public Service Electric and Gas Company is in receipt of
your letter dated April 2,
1985 which transmitted a Notice
of Violation on non-functional fire barriers.
Pursuant to the requirements of 10 CFR 2.201, our response
to the items of violation is included in attachment 1.
Sincerely,
%~
Attachment
pq^52Tfi~i5 !'P
The Energy People
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ATTACHMENT 1
10 CPR PART 2.201 INFORMATION
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
SALEM GENERATING STATION
RESPONSE TO NOTICE OF VIOLATION
Your letter of April 2, 1985, identified a violation of
Technical Specification 3.7.11 involving non-functional fire
barriers.
This involved degraded fire doors, fire dampers
and unsealed penetrations.
A special report as required by
the technical specification was not submitted.
The
following is a response to the Notice of Violation and
constitutes the special report required by Technical Specification 3.7.11.
1.
PSE&G DOES NOT DISPUTE THIS VIOLATION
2.
THE ROOT CAUSE OF THIS VIOLATION WAS INADEOUATE
MANAGEMENT ATTENTION TO FIRE PROTECTION REQUIREMENTS
WHICH ALLOWED THE FOLLOWING CONDITIONS TO BE LEFT
UNATTENDED FOR AN EXCESSIVE PERIOD OF TIME:
a.
Inoperable fire doors due to broken or
non-functional hardware,
b.
Missing UL labels on fire doors,
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Missing fire protection wrap (FS-195) from dampers
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c.
at electrical cable tray penetrations.
d.
Unsealed ventilation duct penetrations through
stairwell walls.
e.
Fire doors remaining open due to excessive pressure
differential.
3.
IMMEDIATE CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED
A comprehensive review of the degraded fire barrier
penetrations was performed.
Af ter an extensive UL fire
door audit in August 1984, a detailed program was
initiated in January 1985 for the repair of inoperable
fire doors.
The actions completed to date are:
a.
For those fire doors having UL labels and with
broken hardware, new hardware has been purchased and
installed.
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b.
Fire doors either missing a UL label or having
hardware inconsistent with UL label requirements,
per UL audit, are being replaced in total.
There
are 77 doors in this category.
All doors have been
ordered with approved UL hardware and are on site.
As of this date, 58 new doors have been installed.
c.
Missing fire protection wrapping (FS-195) on the
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fire dampers has been replaced,
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d.
Design changes concerning the unsealed ventilation
duct penetrations through stairwell walls have been
initiated.
These design changes call for the
addition of one and one-half hour fire rated dampers
on all discharge ducts into stairwells.
These
design changes are described in our January 31, 1985
Appendix R exemption request.
e.
A . review of the pressure differential problem has
been initiated.
Some improvement has occurred.
Certain improper operations of the ventilation
systems have been identified and corrected.
Controllers have been found misoperating and have
been corrected.
4.
LONG TERM CORRECTIVE ACTIONS TO AVOID FURTHER VIOLATIONS
A.
The following additional specific actions are being
taken to correct specific deficiencies:
1.
An on-going maintenance program has been
established.
A folio system for maintaining a
sufficient inventory of spare UL fire door hardware
has been instituted in conjunction with a computer
program designating specific hardware required for
each door with a folio reference.
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2.
Concerning the 77 inadequate fire doors, the
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remaining 19 doors are being installed.
3.
Fire Damper Functional Test Procedures are being
revised to require immediate reinstallation of the
removed fire wrap after completion of testing.
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Also the Station Fire Department is now responsible
for performing this functional test and will be
tracking the impairments.
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4.
Concerning the unsealed ventilation duct
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penetrations, design changes will be implemented
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upon NRC approval of our January 31, 1985 Appendix R
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5.
In order to resolve the excessive pressure
differential problem, a review is being conducted of
related operating and maintenance procedures.
In an
effort to identify any system incompatibilities, air
flow tests are being performed on individual
systems.
A review of the system's design is being
conducted to improve system characteristics.
This
should limit the pressure differentials which will
result in less impact upon fire door operation.
B.
An indepth review of the entire Fire Protection
issue was performed.
As a result of discussions
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between the Vice President - Nuclear, General
Manager - Salem Operations and his staff, increased
attention and awareness of requirements for
maintaining the Fire Protection Systems operability
has been reinforced.
An aggressive program is in
place to identify and rectify design and operational
concerns associated with the Auxiliary Building
ventilation System, which in the past has impacted
proper Fire Door operation.
A contributing factor
related to this problem was the large number of
outages that have occurred on both Units since
October 1982, which directly affected Fire
Protection priority status.
The increased number of
contractor support personnel also aggravated the
amount of maintenance needed to keep the Fire Doors
in an operable condition.
In addition, there are no
effective mechanisms in place to determine the
length of time that Fire Barriers are,in,a degraded
condition, or to indicate to management that the
number of degraded Fire Barriers is becoming
excessive.
Such mechanisms will be instituted.
5.
FULL COMPLIANCE FOR ITEMS 4.A.1, 4.A.2 AND 4.A.3 WILL BE
ACHIEVED BY MAY 31, 1985.
COMPLIANCE WITH ITEM 4.A.4
WILL BE COMPLETE WITHIN 7 MONTHS OF NRC APPROVAL.
RESULTS FROM ITEM 4.A.5 SHOULD BE AVAILABLE BY AUGUST 1,
1985.
COMPLIANCE WITH 4.B WILL BE ACHIEVED BY MAY 31,
1985.