ML20127E280

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-272/84-46 & 50-311/84-46.Corrective & Preventive Actions Will Be Examined During Future Insp

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) i

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

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Public Service Electric & Gas Co. 2

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Region I. Docket Room (with concurrences)

L. Norrholm, Chief, Section #2B, DRP

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0FFICIAL RECORD COPY CRL SALEM 84-46 - 0002.0.0

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OPSEG

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,

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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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c. Missing fire protection wrap (FS-195) from dampers

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

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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.

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c. Missing fire protection wrapping (FS-195) on the

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fire dampers has been replaced,

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.

( 2. Concerning the 77 inadequate fire doors, the

i 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.

l Also the Station Fire Department is now responsible

for performing this functional test and will be

tracking the impairments.

! 4. Concerning the unsealed ventilation duct

i penetrations, design changes will be implemented ,

( upon NRC approval of our January 31, 1985 Appendix R

l exemption request. *

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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

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issue was performed. As a result of discussions

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.