ML20154D422
| ML20154D422 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/21/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| Shared Package | |
| ML20154D394 | List: |
| References | |
| FOIA-88-92 EA-84-036, EA-84-36, NUDOCS 8809150271 | |
| Download: ML20154D422 (6) | |
See also: IR 05000272/1983037
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION I
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475 ALLENDALE ROAD
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KING OF PRUS$1 A, PENNSYLVANIA 19406
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March 21, 1988
Docket No. 50-272
License No. OPR-70
EA 84-36
Public Service Electric & 'las Company
ATTN: Steven E. Miltenberer
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Vicu President, Nuci .ar Operations
P.O. Box 236
Hancocks Bridge, NJ 08038
Gentlemen:
Subject: Notice of Violation (Inspection No. 50-272/83-37)
This refers to your letter dated July 15, 1987, in response to the Notice of
Violation sent to you with our letter dated June 15, 1937. Our letter and
Notice described three violations of fire protection program requiremen+.s at
Salem. The violations were classified in the aggregate as a Severity Level III
problem, but a civil penalty was not proposed.
In your response, you do not agree that these items should be classified as
violations, and you request that the aggregate Severity level of the violations
be reduced from level III to Level IV, claiming that the violations appear to
be based more upon alleged deficiencies in interpretation of 10 CFR "O,
Appendix R implementation guidance rather than the regulation itself.
Further
you state that configurations described in the Notice involve items which ,
subsequent to the NRC reviews, have become the subject of exemption requests,
and are also similar to those approved at other plants as exemptions to the
rule or as engineering evaluations without NRC approval.
After careful consideration of your response, we have concluded, for the
reasons provided in the enclosed Appendix, that the violations occurred as
stated in the Notice, and were appropriately classified in the aggregate at
Thank you for informing us of the corrective and preventive actions documented
in your letter.
These actions wil? be examined during a future inspection of
your licensed program.
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JONES 88-92
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Public Service Electric
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and Gas Company
In accordance with Section 2.790, of the NRC's "Rules of Procedure", Part 2,
Title 10, Code of Federal Regulations, a copy of this letter will be placed in
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the NRC's Public Document Room.
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Sincerely,
h"[)h-ik
William T. Russell
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Regional Administrator
cc w/ enc 1:
Thomas S. Shaw, Jr. , Vice President - Production
J. M. Zupko, Jr. , General Manager - Salem Operations
B. A. Preston, Manager, Licensing and Regulation
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S. E. Miltenberger, Vice President - Nuclear Operations
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General Manager - Nuclear Safety Review
M. J. Wetterhahn, Esquire
R. Fryling, Jr., Esquire
Public Document Room (PDR)
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Local Public Document Room (LPDR)
Nuclear Safety Information Ce-ter (NSIC)
NRC Resident Inspector
State of New Jersey
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Public Service Electric
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and Gas Compa'ny
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b:c w/ encl:
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Region I Oceket Room (with concurrences)
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' Fanagement Assistant, ORMA (w/o encl)
CRP Section, Chief
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- Robert J. Bores, DRSS
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D. Holody, R1
J. Lieben..an, OE
J. Goldberg, OGC
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F. Mira.2 1a, NRR
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Appendix
Evaluation and Conclusig
In a letter dated July 15, 1987, the licensee responded to a Notice of
Violation issued on June 15, 1987 concerning the tailure to adhere to certain
fire protection requirements set forth in 10 CFR Part 50, Appendix R.
In the
licensee's response, they (1) deny the violations, and (2) request that if the
violations remain as stated, the aggregate Severity Level should be reduced
from Level III to level IV.
Provided below is (1) a summary of the licensee's reasons for denying each of
the violations and the NRC response regarding these denials; (2) a summary of
licensee's reasons for seeking a reduction in the Severity level and the LC
response to that request; and (3) the overall NRC conclusion regarding the
licensee's response.
I.
SUMMARY OF LICENSEE RESPONSE CONCERNING VIOLATION A, AND NRC
EVALUATION OF THAT RESPONSE
With respect to Example 1 of Violation A, involving a lack of separation
and suppression capability for charging pumps, the licensee indicated that
it had identified to the NRC, in letters dated December 28, 1983, and
January 13, 1984, that the separation of charging pumps did not conform to
the NRC inte.pretation of Appendix R contained in Generic Letter No.
83-33, and requested an exemption request prior to the 1984 inspection.
However, the exemption request was not submitted until after the
inspection began on December 5, 1983.
Further, the licensee also
indicated that, in accordance with Generic Letter No. 86-10, complete
area-wide suppression is not required to ensure compliance with
Appendix R.
Although the NRC agrees with the licensee regarding this
contention, the NRC notes that this Generic Letter also stipulates that
when suppression (and detection) features are not installed over the
entire area, licensees must perform an evaluation to assess the adequacy
of partial suppression (and detection) to protect against the hazards in
the area.
Such an evaluation was not performed by the licensee until
after the st.rt of the inspection on December 5,1983, and that subsequent
evaluation formed the basis for the exemption request.
Since the
licensee was unable to demonstrate an ability to achieve safe shutdown at
the time of the inspection, an adequate basis was not prov',ded for
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withdrawal of Example 1 of Violation A.
With respect to Example 2 af Violation A, involving inadequate fire
protection features for the 460 VAC/230 VAC switchgear, including only a
partial height one hour barrier at Unit 1, the licensee indicated that a
similar partial height one hour barrier was approved for Salem Unit 2 by
the NRC during the licensing review.
Since Appendix R, which became
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effective on February 17, 1981, is applicable to plants licensed to operate
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prior to January 1,1979, and Salem Unit I was licensed on August 13, 1976,
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whereas Salem, Unit 2 was licensed on April 18, 1980, the compliance
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Appendix
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requirements for the two units are different.
The approval of the partial
height on a one hour barrier for Unit 2 is not suf ficient justification for
not complying with the requirements of Appendix R at Unit 1, unless a
specific exemption was requested and approved.
Since the exemption for
the incomplete one hour fire barrier at Unit I was not requested until
after the start of inspection on December 5, 1933, specifically, by letters
dated December 28, 1983, January 31, 1985, and January II,1986, which also
proposed upgrading of the CO2 system with an automatic total flooding fire
suppression system as a long term corrective act:Jn, the licensee has not
provided an adequate basis for withdrawal of Example 2 of Violation A.
With regard to Example 3 of Violation A, involving a door on a fire wall
not being rated to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the licensee indicated that Generic letter No.
86-10 states that the fire area boundaries need not be completely wall to
wall and ficor-to-ceiling. Although the NRC agrees with the licensee, the
NRC notes that Generic Letter No. 86-10 also requires a licensee evalu-
ation in such cases where the boundaries are not completely rated to
determine if the boundaries will withstand the hazards associated with the
area.
Such an evaluation did not exist prior to the start of the inspec-
tion on Dece.mber 5, 1983.
Therefore, the licensee did not provide an
adequate basis for withdrawal of Example 3 of Violation A.
After the
start of the inspection, the licensee requested an exemption, by letter
dated January 31, 1984, which was withdrawn by letter dated
January 17, 1986, due to the licensee's commitment to provide a rated fire
barrier between redundant equipment.
II.
SUMMARY OF LICENSEE'S RESPONSE REGARDING VIOLATION B, AND NRC EVALUATION
OF THAT RESPONSE.
With regard to Violation B, involving the lack of planning, procedures
and materials to implement fire damage repairs of RHR pumps, the' licensee
indicated that the Salem shutdown model does not utilize repairs to the
RHR system for safe shutdown.
If such repairs are not utilized, the
redundant pumps should be provided with the fire protection separation
features in accordance with 10 CFR 50, Appendix R. Such features were not
provided.
Further, the licensee references Generic Letter No. 86-10
concerning not needing a complete fire barrier between redundant pumps.
In such cases, the Generic Letter requires performance of an adequate
evaluation of the barrier. At the time of the inspection, such an evalua-
tion had not been performed.
Therefore, the licensee did not provide an
adequate basis for withdrawal of the violation.
The NRC recognizes that
subsequent to the inspection, the licensee requested an exemption, by
letters dated January 31, 1984, April 5, 1984, and January 17, 1986.
The
January 17, 1986 letter also proposed a modification consisting of enhanced
penetration seals and fire detection in the area.
Although the corrective
actions were initiated af ter the inspection, the RHR pump area was not in
compliance at the time of the inspection,
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Appendix
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III. SUMMARY OF LICENSEE'S RESPONSE REGARDING VIOLATION C, AND NRC EVALUATION
OF THAT RESPONSE
With regard to violation C, involving the failure to provide adequate fire
protection features for Pressurizer Heater Cabinet And Pressurizer
Pressure and Level Instrumentation Cabinet 355 inside non-inerted contain-
ment, the licensee states that the 10 USSG steel plates in Panel 335 and
the steel conduit inside cantainment were adequate "non-conbustible
radiant energy shields" (alternative III.G.2.t).
However, neither of
these shields qualify as an acceptable radiant energy shield, nor were
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they similar to the licensee's design used in containment NW quadrant for
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the electrical cable penetrations (see Inspection Report No. 50-272/83-37,
Section 7.1.4).
An exemption request, on January 31, 1985, and
January 17, 1986, and your proposal to have sprinkler coverage of the
Panel 335 in your January 17, 1986 letter, were not submitted untti af ter
the inspection.
Therefore, the licensee did not provide an adequate basis
for withdrawal of the violation.
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IV.
SUMMARY OF LICENSEE'S RE0 VEST FOR A REOUCTION IN SEVERITY LEVEL OF THE
VIOLATION, AND NRC EVALUATION OF THAT RESPONSE.
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The licensee requests a reduction in the Severity Level of the violation,
if the violations stand.
The licensee did not provide a basis for this
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request. Although the safety significance of the individual violations
was considered low, the violations were nonetheless classified in the
aggregate as a Severity level III problem because they demonstrated, at
the time of the inspection, a lack of adequate analysis of, and attention
to, assuring adherence to the separation, suppression, and detection
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requirements set forth in 10 CFR 50, Appendix R.
In light of these
program.matic deficiencies, the violations were appropriately classified
in the aggregate as Severity Level !!I.
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V.
NRC CONCLUSICN
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The violations occured as stated in the Notice of Violation and were
approprately categorized in the aggregate at Severity level III.
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