ML20147B274
| ML20147B274 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/11/1995 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Reiter L AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20147B009 | List: |
| References | |
| FOIA-96-351 EA-94-239, NUDOCS 9701300128 | |
| Download: ML20147B274 (21) | |
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UNITED STATES f
g NUCLEAR REGULATORY COMMISSION
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j REGION I 4
475 ALLENDALE ROAD
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KING OF PRUSSIA, PENNSYLVANIA 19406 1415 January 11, 1995 i
EA 94-239 i
Mr. Lawrence Reiter HOME ADDRESS DELETED UNDER 10 CFR 2.790 4
5
SUBJECT:
ENFORCEMENT CONFERENCE RELATIVE TO NRC INVESTIGATION 1-93-021R i
i
Dear Mr. Reiter:
1 l
This letter refers to the investigation conducted at the Salem Nuclear i
Generating Station by Ms. K. L. Monroe of the NRC Office of Investigations l
(01) Field Office, Region I.
The purpose of the investigation was to determine whether certain activities authorized by the licensee were conducted i
3
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i in accordance with NRC requirements. A copy of the synopsis of the l
investigation is enclosed.
Based on the findings of the investigation, apparent violations were l
identified and are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), 10 CFR 2, Appendix C (copy enclosed). The apparent violations involve 10 CFR 50.5 (Deliberate
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misconduct) and 10 CFR 50.7 (Employee protection). 10 CFR 50.5 prohibits licensee employees from engaging in deliberate misconduct that causes the l
licensee to be in violation of any rule or regulation; and 10 CFR 50.7 prohibits the licensee from discriminating against any employee for engaging j
in certain protected activities. The investigation indicates that three f
i former Salem senior managers, including yourself, took deliberate action that j
involved discrimination against two Safety Review Group (SRG) engineers who t
were engaged in protected activities on December 3, 1992. As an agent of the j
licensee, your acts caused the licensee to be in apparent violation of the requirements of 10 CFR 50.7.
1 l
Specifically, on December 3,1992, two SRG engineers attempted to process a j
safety issue, in accordance with station procedures, by submitting an incident j
report (IR) to the General Manager-Sales Operations (GM), and the Operations Manager (OM). The IR questioned the safety-related qualification of 1
l commercial grade air supply pressure setpoint regulators, which control j
service water flow to the containment fan cooling units.
In conversations i
with the SRG engineers, the GM (with various cooperation and advice of the OM) i told the individuals to get out of his office and threatened to have them removed from the site, an action that was interpreted by the SRG engineers as harassing and intimidating. Upon deliberation, the GM wrote a memorandum to j
you, the then General Manager-Quality Assurance and Nuclear Safety Review (GM-QA/NSR), requesting you to have the engineers removed from any direct involvement with Salem station. Subsequently, further apparent discriminating action was directed against the individuals when you deliberated and took action to ' reprimand and counsel the SRG engineers relative to their submittal of the IR and handling of the situation.
In conclusion, the NRC investigation 9701300128 970124 PDR FOIA O'NEILL96-351 PDR
tr se 2
l Mr. Lawrence Reiter detennined information that appears to support th
- taken, by these former senior Salem managers, including yourself.
In accordance with NRC policy, an opportunity is provided to hold an Enforcement Conference with the licensee, and separately with you, to d Since our evaluation is continuing, we are not issuing a Notice of Violation at this time, in recognition that th these matters.
review.
l In accordance with previous discussions between Mr. Stanley LaBruna of Service Electric and Gas Company, and Mr. John White of this office, an l
Enforcement Conference has been scheduled with the licens matter, on February 8,1994, at 10:00 a.m., at our Region I office in King of The conference will be closed to public observation Prussia, Pennsylvania.Though you are not currently an employee of PSE&G, you are and transcribed.
We will schedule the welcome and encouraged to attend the conference.In addition, we plan to conduct a separate arrangements directly with you.
Enforcement Conference between yourself and the NRC to discuss yourSuch involvement in these matters, shortly after the conference with PSE&G.
conference will also be closed to public observation, and will be transcribed.
[
The provision to hold an enforcement conference does not mean that the NRC h determined that a violation has occurred or that enforcement action w The purposes of this conference are to discuss the apparent violations, their cause(s) and safety significance; to provide you the taken.
opportunity to point out any errors in our understanding of the apparent violations; and to provide an opportunity for you to present corrective actions, taken or planned.
In addition, this is an opportunity for you to provide any information concerning your perspectives on the nature of the 3
apparent violations, aggravating or mitigating circumstances that the NRC should consider, and other infonnation that will help the NRC determine the appropriate enforcement action. You will be advised by separate No response correspondence of the result of our deliberations on this matter.
regaroing the apparent violations is required at this time.
As noted, we intend that the Enforcement Conference with the licensee, Public Service Electric and Gas Company, will be held immediately prior to any Enforcement Conference with you or the other involved former Salem senior You are requested to attend the Enforcement Conference with the managers.
If you are asked questions in that meeting, we will arrange for you licensee.
to answer without the licensee's presence, if you desire, in order to preclude You are also welcome to be accompanied by legal any perception of duress.
counsel or representation during the Enforcement Conference.
If you have any questions on this matter, please contact Mr. John R. White of our office at (610) 337-5114 (collect).
P' b
lt,e
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Hr. LawrGnce Reiter 3
A copy of this letter will be provided to Public Service Electric and Gas However, this letter will not be made public or provided to the NRC Company.
j Public Document Room until the NRC staff makes a final enforcement action l
l determination in this particular matter.
Sincerely, 6
Richard W. Cooper, Director i
Division of Reactor Projects Docket Nos. 50-272;50-311
Enclosures:
Investigation Synopsis No. 1-93-021R NRC Enforcement Policy (10 CFR 2, Appendix C) i cc w/ encl:
L. Eliason, Chief Nuclear Officer and President, Nuclear Business Unit j
l i
ATTACHMENT 7
)
I I
l l
NRC ENFORCEMENT CONFERENCE FEBRUARY 8,1995 SALEM GENERA TING STA TION l
PUBLIC SERVICE ELECTRIC AND GAS C.O.
t V
l 0
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ll NRC ENFORCEMENT CONFERENCE AGENDA INTRODUCTION AND OVERVIEW L. ELIASON o
REVIEW OF DECEMBER 3,1992 EVENT J.HAGAN ROOT CAUSE AND CORRECTIVE ACTIONS J.HAGAN
SUMMARY
J.HAGAN CLOSING REMARKS L. EllASON l
PUBLIC SERVICE ELECTRIC AND GAS CO.
1 WW' PAGE 2
'l NRC ENFORCEMENT CONFERENCE
\\
l NRC FINDINGS AND APPARENT. VIOLATIONS l
i SYNOPSIS OF NRC FINDINGS i
e TWO SAFETY REVIEW GROUP ENGINEERS ATTEMPTED TO REPORT j
CONCERNS RELATED TO CONFIGURATION AND SEISMIC QUALIFICAT!ON
'1 OF TUBING AND PRESSURE REGULATORS CONTROLLING SERVICE WATER l
FLOW TO THE CFCU'S IN BOTH SALEM UNITS. FOLLOWING DISCUSSIONS WITH THE SAFETY REVIEW INDIVIDUALS, THE GENERAL MANAGER-SALEM OPERATIONS ( WITH ADVICE AND COOPERATION FROM THE OPERATIONS MANAGER ), TOLD THE SAFETY REVIEW ENGINEERS TO LEAVE HIS OFFICE AND THREATENED TO HAVE THEM REMOVED FROM SITE.
l UPON DELIBERATION, THE GM WROTE A MEMORANDUM TO THE GENERAL
,l e
MANAGER QUALITY ASSURANCE AND NUCLEAR SAFETY REVIEW REQUESTING THAT THE SAFETY REVIEW ENGINEERS BE REMOVED FROM ANY DIRECT INVOLVEMENT WITH SALEM STATION.
THE GM-QA/NSR, DELIBERATED AND TOOK ACTION TO REPRIMAND AND e
COUNSEL SRG ENGINEERS RELATIVE TO THEIR INCIDENT REPORT SUBMITTAL AND HANDLING OF THE SITUATION APPARENT VIOLATIONS e
VIOLATION OF 10CFR50.7 IN THAT THREE FORMER SALEM MANAGERS TOOK ACTIONS TO DISCRIMINATE AGAINST TWO SAFETY REVIEW GROUP ENGINEERS WHO WERE ENGAGED IN PROTECTED ACTIVITIES ON DECEMBER 3,1992.
VIOLATION OF 10CFR 50.5 IN THAT THE ACTIONS OF THE THREE FORMER e
SALEM MANAGERS WERE DEllBERATE PUBLIC SERVICE ELECTRIC AND GAS CO.
M PAGE 3
i NRC ENFORCEMENT CONFERENCE SEQUENCE OF EVENTS DECEMBER 3,1992 INITIAL DISCUSSION BETWEEN OPERATING MANAGER (OM) AND SAFETY REVIEW GROUP (SRG) ENGINEERS LEADING TO CONFRONTATION OVER DOCUMENTATION OF TECHNICAL INFORMATION TO SUPPORT AN OPERABILITY DETERMINATION OM ESCALATES ISSUE TO SALEM GENERAL MANAGER (GM) WHERE FURTHER CONFRONTATION RESULTS IN GM ORDERING SAFETY REVIEW GROUP (SRG) ENGINEERS TO LEAVE HIS OFFICE SALEM GM MAKES INITIAL CONT ACT WITH GENERAL MANAGER-QUALITY ASSURANCE \\ NUCLEAR SAFETY REVIEW (GM-QA/NSR) WHO DELEGATES INVESTIGATION TO THE MANAGER-NUCLEAR SAFETY REVIEW GM DIRECTS OM TO DEVELOP LETTER REQUESTING GM-QA/NSR TO REMOVE SRG ENGINEERS FROM SALEM OVERSIGHT ROLE e
DECEMBER 4,1992 SRG ENGINEER FILES QUALITY CONCERN SALEM GM SIGNS LETTER BUT LETTER IS NOT TRANSMITTED A
PUBLIC SERVICE ELECTRIC AND GAS CO.
W PAGE 4
1 NRC ENFORCEMENT CONFERENCE SEQUENCE OF EVENTS (CONT)
DECEMBER 14,1992 SALEM GM PROVIDES COPY OF LETTER TO THE VICE PRESIDENT-NUCLEAR OPERATIONS (VP-NO)
DECEMBER 16,1992 GM-QA/NSR MEETS WITH SALEM GM, OM AND OTHER SALEM MANAGERS
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RECEIVES FEEDBACK ON SRG PERFORMANCE
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REINFORCES INDEPENDENT NATURE OF SRG FUNCTION DECEMBER 18,1992 CHIEF NUCLEAR OFFICER (CNO) RECEIVES COPY OF LETTER FROM VP-NO DECEMBER 21,1992 CNO READS LETTER AND REQUESTS STATUS FROM GM-QA/NSR GM-QA/NSR MEETS WITH SALEM GM
+
SALEM GM CLARIFIES HIS REQUEST FOR REASSIGNMENT OF SRG ENGINEERS
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GM-QA/NSR INFORMS SALEM GM THAT REQUEST IS INAPPROPRIATE AND WILL NOT BE ACTED ON PUBLIC SER D GAS CO.
PAGE 5
I i
NRC ENFORCEMENT CONFERENCE SEQUENCE OF EVENTS (CONT) e DECEMBER 22,1992 T
GM-QA/NSR RECEIVES COPY OF LETTER FROM CNO AND RESPONDS TO REQUEST FOR STATUS. INDICATES HE IS WORKING WITH SALEM GM TO RESOLVE ISSUES e
DECEMBER 30,1992 GM-QA/NSR RECEIVES FORMAL TRANSMITTAL OF SALEM GM LETTER
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e JANUARY 6,1993 GM-QA/NSR PROVIDES RESPONSE TO SAFETY CONCERN; SRG ENGINEER NOT SATISFIED WITH RESPONSE i
e JANUARY 27,1993 SRG ENGINEER ESCALATES ISSUES TO SENIOR VICE PRESIDENT-ELECTRIC BUSINESS UNIT e
JANUARY 28,1993 CNO DIRECTS GM-INFORMATION SERVICES / EXTERNAL AFFAIRS TO INITIATE FORMAL INVESTIGATION CNO, VP-NO AND SALEM GM BRIEF NRC SENIOR RESIDENT INSPECTOR ON ISSUES PUBLIC SERVICE ELECTRIC AND GAS CO.
AL PAGE 6
i NRC ENFORCEMENT CONFERENCE PSE&G ASSESSMENT OF THE DECEMBER 3,1992 EVENT NUCLEAR DEPARTMENT ACTIONS TO RESOLVE ISSUES BETWEEN DECEMBER 3,1992 AND JANUARY 27,1993 WERE UNTIMELY AND INEFFECTIVE i
ONCE THE IMPLICATIONS OF THE EVENT WERE RECOGNIZED, CNO INITIATED AN AGGRESSIVE INTERNAL INVESTIGATION OF THE CIRCUMSTANCES AND UNDERLYING ISSUES ASSOCIATED WITH THE EVENT CHARTER DEVELOPED BY SENIOR VICE PRESIDENT AND GENERAL
[
COUNSEL i
INDEPENDENT TASK FORCE OPERATED UNDER DIRECTION OF GENERAL MANAGER INFORMATION SYSTEMS / EXTERNAL AFFAIRS 30 INDIVIDUALS INTERVIEWED TO ESTABLISH FACTS AND RELEVANT INFORMATION REQUIRED TO ADDRESS CHARTER ISSUES CONDUCTED BETWEEN JANUARY 27 AND APRIL 2,1993 INVESTIGATION CONCLUDED THE SRG ENGINEERS ACTIONS WERE CONSISTENT WITH MANAGEMENT EXPECTATIONS REGARDING THE IDENTIFICATION AND
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RESOLUTION OF SAFETY CONCERNS THE 2 SRG ENGINEERS WERE HARASSED AND INTIMIDATED BY STATEMENTS AND ACTIONS OF SALEM OM AND GM ON AND SUBSEQUENT TO DECEMBER 3,1992 PUBLIC SERVICE ELECTRIC AND GAS CO.
C,0NR M PAGE 7
n j
NRC ENFORCEMENT CONFERENCE 1
PSE&G ASSESSMENT OF DECEMBER 3,1992 EVENT (CONT) 1 l
WITH RESPECT TO THE ACTIONS OF THE SALEM GM AND OM e
ACTIONS WERE UNPROFESSIONAL AND INAPPROPRIATE WHILE THE SALEM OM AND GM DID HARASS AND INTIMIDATE THE SRG ENGINEERS, WE DO NOT BELIEVE THAT THESE ACTIONS WERE DELIBERATE
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SALEM OM AND GM FAILED TO RECOGNIZE THE 50.7 IMPLICATIONS ASSOCIATED WITH THEIR ACTIONS AND STATEMENTS WITH RESPECT TO THE ROLE OF THE GM-QA/NSR ACTIONS TO RESOLVE SITUATION WERE UNTIMELY AND INEFFECTIVE A FORMAL REPRIMAND WAS DRAFTED FOR ONE SRG ENGINEER, BUT NOT ISSUED GM-QA/NSR DID DISCUSS WITH THE ONE SRG ENGINEER, INAPPROPRIATE NATURE OF COMMENTS HE MADE TO THE SALEM GM REGARDING THE ENGINEERING DISCREPANCY EVALUATION PROCESS i
e k
PUBLIC SERV CE E S CO.
PAGE 8
i 4
NRC ENFORCEMENT CONFERENCE ROOT CAUSE ROOT CAUSE NUCLEAR DEPARTMENT MANAGEMENT FAILED TO SET AND ENFORCE e
UNIFORM STANDARDS OF PERFORMANCE RELATIVE TO THE TREATMENT OF ALL INDIVIDUALS WHO RAISE SAFETY / QUALITY CONCERNS CONTRIBUTING FACTORS e
A CONFRONTATIONAL ENVIRONMENT EXISTED BETWEEN CERTAIN SALEM MANAGERS AND SAFETY REVIEW GROUP PERSONNEL e
SALEM OPERATIONS MANAGER FAILED TO FOLLOW THE ESTABLISHED PROCESS FOR INCIDENT REPORT EVALUATION AND DISPOSITION e
INEFFECTIVE TRAINING OF MANAGEMENT PERSONNEL ON SAFEGUARDS AFFORDED PROTECTED ACTIVITIES l
PUBLIC SERVICE ELECTRIC AND GAS CO.
@ JF:OENT! V PAGE 9 1
i 5
J NRC ENFORCEMENT CONFERENCE NEAR TERM CORRECTIVE ACTIONS AGGRESSIVE, SELF-INITIATED INTERNAL INVESTIGATION UNDERTAKEN TO e
BRING ISSUE TO RESOLUTION AND IDENTIFY UNDERLYING ISSUES AND CAUSES. PERIODIC UPDATES PROVIDED TO NRC ON INVESTIGATION I
RESULTS DISCIPLINARY ACTION TAKEN FOR NUCLEAR DEPARTMENT MANAGEMENT e
PERSONNEL INVOLVED ALL LEVELS OF MANAGEMENT, CNO TO LINE MANAGERS
{
CNO MET WITH SRG ENGINEERS ON FEBRUARY 11 AND ON APRIL 22,1993 TO PERSONALLY REASSURE THEM THAT THEIR ACTIONS WERE APPROPRI. TE CNO ISSUED LETTERS TO SRG ENGINEERS REAFFIRMING THAT THEIR ACTIONS WERE APPROPRIATE LETTERS OF APOLOGY WERE ISSUED FROM THE STATION GM AND OM TO THE SRG ENGINEERS J
PUBLIC SE GAS CO.
PAGE 10 m
I J
NRC ENFORCEMENT CONFERENCE NEAR TERM CORRECTIVE ACTIONS (CONT) e PRESENTATION TO NUCLEAR DEPARTMENT MANAGERS APRIL 23,1993 CNO REAFFIRMED PSE&G'S COMMITMENT TO MAINTAINING A WORK ENVIRONMENT WHICH IS CONDUCIVE TO FILING SAFETY CONCERNS EMPHASIZED THAT ACTIONS OF THE SRG ENGINEERS WERE IN ACCORDANCE WITH MANAGEMENT'S EXPECTATIONS REVIEWED DECEMBER 3,1992 EVENT INCLUDING, SEQUENCE OF EVENTS, MANAGEMENT'S RESPONSE, LESSONS LEARNED, AND
SUMMARY
OF INVESTIGATION REPORT CONCLUSIONS SALEM OM AND GM ACKNOWLEDGED THEIR ACTIONS WERE l
INAPPROPRIATE PRESENTATION BY THE MANAGER-LICENSING AND REGULATION ON EMPLOYEE RIGHTS AND RESPONSIBILITIES VP-NO REINFORCED EXPECTATIONS FOR INCIDENT REPORT PROCESSING MANAGERS REQUIRED TO ROLL-DOWN INFORMATION FROM APRIL 23, 1993 MEETING TO ALL EMPLOYEES ONE-ON-ONE FOLLOW-UP BY CURRENT VP NO WITH SALEM MANAGERS ON ROLL-DOWN OF APRIL 23,1993 MEETING INFORMATION, INCLUDED DISCUSSION OF THE ELEMENTS OF INTIMIDATION PUBLIC SERVICE ELECTRIC AND AS CO.
-e0WPtefRT PAGE 11
m 4
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NRC ENFORCEMENT CONFERENCE NEAR TERM CORRECTIVE ACTIONS (CONT) 1 e
LETTER ISSUED BY CNO APRIL 26,1993 TO ALL NUCLEAR DEPARTMENT EMPLOYEES REEMPHASIZING THAT EMPLOYEES SHOULD CONTINUE TO PURSUE SAFETY CONCERNS.
e GM-QA/NSR MET WITH HIS EMPLOYEES TO EMPHASIZE THAT THE ACTIONS OF THE SRG ENGINEERS WERE APPROPRIATE AND, IN PARTICULAR; THAT ESCALATION TO SENIOR MANAGEMENT FULLY MET EXPECTATIONS AND WAS CONSISTENT WITH SAFETY CONCERN RESOLUTION PROCESS.
e GENERAL EMPLOYEE TRAINING PROGRAM REVISED JULY 14,1993 TO ENHANCE ELEMENTS ON EMPLOYEE RIGHTS AND RESPONSIBILITIES e
PROCEDURAL REVISIONS TO NAP-6 WHICH REQUIRE GM-IS&EA TO INVESTIGATE QUALITY CONCERNS INITIATED BY QA/NSR PERSONNEL e
PUBLIC SERVICE ELECTRIC AND GAS CO.
MIDEMT4AF PAGE 12 l
l
t NRC ENFORCEMENT CONFERENCE ONGOING ACTIONS TO IMPROVE ENVIRONMENT CURRENT ACTIONS OF THE NUCLEAR BUSINESS UNIT (NBU) DIRECTED AT PROVIDING FOR CONTINUED IMPROVEMENT IN THE SAFETY / QUALITY CONCERNS REPORTING ENVIRONMENT AT SALEM AND HOPE CREEK ARE FOCUSSED IN THE FOLLOWING AREAS IMPROVnD COMMUNICATIONS AND FEEDBACK FORMATION OF EMPLOYEE CONCERN GROUP 4
MANAGEMENT / SUPERVISORY TRAINING ASSESSMENT / MEASUREMENT TOOLS INDICATIONS ARE THAT ENVIRONMENT HAS IMPROVED THE NBU RECOGNIZES THE NEED FOR CONTINUAL IMPROVEMENT IN THE WORKING ENVIRONMENT TO ASSURE THAT ALL PERSONNEL ARE i
ENCOURAGED TO IDENTIFY SAFETY / QUALITY CONCERNS PUBLIC SERVICE ELECTRIC AND GAS CO.
W PAGE 13
t NRC ENFORCEMENT CONFERENCE
SUMMARY
SELF INITIATED INTERNAL INVESTIGATION OF EVENT WAS CONDUCTED BY e
INDEPENDENT TASK FORCE WITH STRONG MANAGEMENT SUPPORT.
PSE&G WAS PROACTIVE IN COMMUNICATING THE ISSUES TO THE NRC, e
INCLUDING PERIODIC UPDATES ON RESULTS OF PSE&G INVESTIGATION
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WHILE HARASSMENT AND INTIMIDATION DID OCCUR, OUR INVESTIGATION CONCLUDED THAT THE 3 PSE&G MANAGERS DID NOT ENGAGE IN DELIBERATE MISCONDUCT SRG ENGINEERS ACI' IONS WERE IN ACCORDANCE WITH MANAGEMENT EXPECTATIONS FOR PURSUING RESOLUTION OF SAFETY CONCERNS NO ADVERSE ACTION WAS TAKEN AGAINST THE SRG ENGINEERS e
DISCIPLINARY ACTIONS WERE TAKEN TO ADDRESS INAPPROPRIATE i
MANAGEMENT ACTIONS ON AND SUBSEQUENT TO DECEMBER 3,1994 COMPREHENSIVE CORRECTIVE ACTIONS WERE TAKEN TO ADDRESS THE SPECIFIC ISSUES RESULTING FROM THE EVENT NUCLEAR BUSINESS UNIT MANAGEMENT IS COMMITTED TO CONTINUED IMPROVEMENT TO ENSURE AN ENVIRONMENT EXISTS WHERE EMPLOYEES ARE FREE TO RAISE SAFETY CONCERNS
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PUBLIC SERVICE ELECTRIC AND GAS CO.
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Chronology Of POPS Evaluation By PSE&G j
March 15, 1993 Westinghouse issues NSA-93-005B on cold overpressure i
mitigation system nonconservatisms July 26, 1993 NRC Infomation Notice 93-58, "Nonconservatism In Low-Temperature Overpressure Protection For Pressurized-Water Reactors," is issued.
December 30, 1993 PSE&G memo MEC-93-917 recommends restricting the number
]
of RCPs in operation, while in Mode 5, to no more than two RCPs. The memo takes credit for ASME Code Case N514 and closes the ATS item on NSAL-93-0058.
April 19, 1994 Discrepancy Evaluation 94-0060 was initiated after it was recognized that NRC approval is necessary for use of the Code Case. Memo points out that even with 1 RCP operating in Mode 5, the existing POPS analysis shows a calculated peak pressure in excess of the Technical Specification limit. Memo also points out that the plant i
design basis relies on one PORV set at 375 psig, and that l
with the current plant configuration the RHR relief valve
[
(RH3) would be available to mitigate LTOP transients.
PSE&G did not consider the DEF an operability concern, taking credit for the Code Case. DEF recommends either i
getting the Code Case approved for use at Salem by the NRC or, completing the calculations for LTOP using the j
RH3 valve and revising the plant design basis, i
May 26, 1994 PSE&G memo MEC-94-630 was issued, superseding MEC-93-917, and dispositions the issue based on an assessment that
[
did not account for the setpoint error introduced by RCPs running during the mass addition transient.
Interviews with licensee personnel indicate that because operation of a RCP when RCS is water solid is precluded procedurally, the mass addition transient analysis did not account for the setpoint error associated with running RCPs. On this basis, the memo recloses the ATS item for the NSAL.
June 29, 1994 During the evaluation of an unrelated DEF by a different department, the licensee determines that the Configuration Baseline Document for CVCS contains an error concerning control of the positive displacement charging pump. The document incorrectly states that the PDP is tripped by an SI signal.
If the PDP is running when the SI signal is initiated, and offsite power is available, the pump will not trip. In addition, engineering review had detemined that trip signals to the PDP will be blocked until the SI signal is reset.
1
i September 27, 1994 Problem Report No. 940927126 was initiated when a new worst case scenario was identified, during efforts to take credit for RH3. The scenario is: RCS in Mode 5 with i
a pressurizer bubble and one RCP running; then an inadvertent SI signal starts the centrifugal charging i
pump, collapses the bubble, and the RCP continues to run.
The PR recognizes that the current design basis transient is not plausible and provides analysis showing the new 1
worst case scenario results in acceptable peak pressu: t s.
The PR states that PSE&G will pursue revising the current plant design basis and also seek a license change to take credit for RH3 (to add margin for future revisions of the PT curve limits). The PR requests that the Code Case approval be sought, to alleviate infringement on the current design basis without reanalysis.
September 28, 1994 PSE&G meno NLR-194900 requests engineering provide additional analysis. The licensing engineers recognize that analyses have relied on the use of two PORVs and RH3 to mitigate the transient (two out of three valves would provide sufficient relief and meeting single failure criterion). Memo also questions new worst case not i
starting with a water solid RCS.
Issue left open pending further engineering analysis and plans are made to apply for a license change (add RH3 to TS) and approval of the Code Case for both Salem units.
November 17, 1994 PSE&G initiates Incident Report No.94-419 and makes a 10CFR50.72 notification for Unit 1 being in an unanalyzed condition. The licensee recognizes that the PDP design discrepancy effects their analysis for POPS. The additional mass input from the runn'ing PDP causes a peak pressure for the mass addition transient of 474 psig.
This analysis was for a single PORY (due to single failure considerations) since no licensing action had been taken to have RH3 included in the design basis.
From a safety perspective: the licensee has three valves available, any two of which will mitigate the effects of an LTOP transient.
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