EA-00-018 - Salem 2 (PSEG Nuclear, LLC)

February 14, 2000

EA 2000-018

Mr. Harold W. Keiser
President and Chief Nuclear Officer
PSEG Nuclear LLC
Post Office Box 236
Hancocks Bridge, New Jersey 08038


Dear Mr. Keiser:

On December 7, 1999, the NRC completed an inspection of your Salem 1 & 2 reactor facilities. The enclosed report presents the results of that inspection. Preliminary findings were presented to PSEG Nuclear management led by Mr. D. Garchow in a debrief on November 19, 1999, and by Mr. F. Sullivan in an exit meeting on December 9, 1999. Following review of the preliminary findings by the Significance Determination Process (SDP) panel (January 21, 2000), a re-exit was held by telephone on February 7, 2000, to inform your staff of changes to the preliminary inspection findings.

One inspection finding was assessed using the applicable SDP and was determined to be White, (i.e., an issue with some increased importance to safety, which may require additional NRC inspections). This White finding involved the failure of the Unit 2 4160Vac switchgear room carbon dioxide fire suppression system to achieve the minimum fifty percent concentration when it was originally installed and tested. When using the SDP we determined the finding to be White based on determining that the one hour raceway fire barrier system in the 4160Vac switchgear room was also degraded. The determination is further described in the inspection report in Section 1RO5.2. In a telephone conversation with Mr. W. Ruland of NRC, Region I, on February 11, 2000, Mr. F. Sullivan of your staff indicated that PSEG did not contest the characterization of the risk significance of this finding.

The failure of the carbon dioxide fire suppression system to meet the concentration requirements is a violation of your fire protection license condition, as described in the attached Notice of Violation (Notice). This violation is being cited in accordance with the Interim Enforcement Policy for Use During the NRC Power Reactor Oversight Process Pilot Plant Study, as described in NUREG 1600, because it is associated with a white finding.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

Because plant performance for this issue has been determined to be in the increased regulatory response band, we will use the NRC Action Matrix, as described in SECY-99-007A, "Recommendations for Reactor Oversight Process Improvements," to determine the most appropriate NRC response for this event. We will notify you, by separate correspondence, of that determination.

In addition, we identified several violations of NRC requirements in the protection of alternate shutdown equipment, and fixed suppression systems for the electrical penetration rooms. These findings were evaluated using the applicable SDP and were determined to be Green, (i.e., the risk associated with these issues remains within the acceptable range). These violations are being treated as non-cited violations (NCVs), consistent with the interim Enforcement Policy for pilot plants. These NCVs are described in the subject inspection report and have been entered into your corrective action program. If you contest the nature or severity level of any of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region I, the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and the Salem resident inspectors.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

    Wayne D. Lanning, Director
Division of Reactor Safety

Docket Nos. 05000272; 05000311
License Nos. DPR-70; DPR-75

Enclosures: Notice of Violation

cc w/encl:
L. Storz, Senior Vice President - Nuclear Operations
E. Simpson, Senior Vice President and Chief Administrative Officer
M. Bezilla, Vice President - Nuclear Operations
D. Garchow, Vice President - Technical Support
M. Trum, Vice President - Maintenance
T. O'Connor, Vice President - Plant Support
E. Salowitz, Director - Nuclear Business Support
G. Salamon, Manager - Licensing
A. Kirby, III, External Operations - Nuclear, Connective Energy
J. McMahon, Director - QA/Nuclear Training/Emergency Preparedness
R. Kankus, Joint Owner Affairs
A. Tapert, Program Administrator
J. Keenan, Esquire
Consumer Advocate, Office of Consumer Advocate
W. Conklin, Public Safety Consultant, Lower Alloways Creek Township
M. Wetterhahn, Esquire
State of New Jersey
State of Delaware
J. Guinan, NJPIRG
N. Cohen, Coalition for Peace and Justice
R. Fisher
F. Berryhill
B. August




PSEG Nuclear LLC
Salem Nuclear Generating Station
  Docket No. 05000311
License No. DPR-75

During an NRC inspection conducted on November 15 - 19, 1999, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

License Condition 2.C.10 for Unit 2 requires PSEG to maintain in effect all provisions of the approved fire protection program, as described in the Safety Evaluation Report issued November 20, 1979, and subsequent safety evaluation reports. Section II.C of the November 20, 1979, Safety Evaluation Report states that the carbon dioxide gaseous suppression systems will be designed in accordance with NFPA Standards Numbers 12 and 12A.
National Fire Protection Association Standard on Carbon Dioxide Extinguishing Systems (NFPA 12), Section 2-4, Carbon Dioxide Requirements for Deep-seated Fires, specifies a fifty percent concentration of carbon dioxide for dry electrical wiring insulation hazards in general.
Contrary to the above, when tested in February, 1979, the Unit 2 4160Vac switchgear room total flooding carbon dioxide fire suppression system did not achieve a fifty per cent concentration. This condition had not been corrected as of the date of the inspection in November 1999.

Pursuant to the provisions of 10 CFR 2.201, PSEG Nuclear LLC is hereby required to submit a written statement or explanation 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). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you 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, DC 20555-0001.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), 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. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated at King of Prussia, Pennsylvania
this 14th day of February, 2000

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