LR-N980485, Responds to NRC Re Violations Noted in Insp Repts 50-272/98-08 & 50-311/98-08.Corrective Actions:Completed TS Surveillance,Performed Comparison of Mmis Data to Design Calculation & Personnel Involved Were Held Accountable

Responds to NRC Re Violations Noted in Insp Repts 50-272/98-08 & 50-311/98-08.Corrective Actions:Completed TS Surveillance,Performed Comparison of Mmis Data to Design Calculation & Personnel Involved Were Held Accountable

ML20195B255
Person / Time
Site:	Salem
Issue date:	11/04/1998
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-272-98-08, 50-272-98-8, 50-311-98-08, 50-311-98-8, LR-N980485, NUDOCS 9811160075
Download: ML20195B255 (10)

Text

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Pubhc Service Electnc and Gas

. . Company Louis F. Storz Public service Electric and Gas Company P.o. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 ssnu Vice Pres. dent . Nuclear Operatons NOV 041998 LR-N980485 United States Nuclear Regulatory Commission Document Control Der',

Washington, DC 20F' Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-08 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Combined Inspection Report No. 50-272/98-08 and 50-311/98-08 for Salem Nuclear Generating Station Unit Nos.1 and 2 was transmitted to Public Service Electric & Gas ,

Company (PSE&G) on October S,1998. Within the scope of this report, two violations i of NRC requirements were cited. One of the violations was cited against 10 CFR 50, l I

Appendix B, Criterion XVI, requiring that conditions adverse to quality be promptly identified, with corrective actions implemented to prevent recurrence. The second violation was cited against Technical Specification 6.8.1.a, involving failures to implement written procedures covering the activities described in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, dated February 1978 including the radiation monitoring system and the service water system.

In accordance with 10 CFR 2.201, PSE&G is submitting its response to the cited violations in Attachment 2 to this letter. Attachment 1 contains the Notice of Violation as cited by the NRC. Should there be any questions regarding this submittal, please contact us.

Sincerely, l J .

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/$ddd/J Attachments (2) .

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9811160075 981104

[ PDR ADOCK 05000272 I O PM

@ Printedon Recycled Paper

NOV 041998 i

! Document Control Desk LR-N980485 * '

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l l C Mr. Hubert J. Miller, Administrator - Region l l

U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North '

11555 Rockville Pike j Mail Stop 14E21

- Rockville, MD 20852 Mr. S. Morris - Salem (X24) l USNRC Senior Resident inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection I

, Division of Environmental Quality  ;

l Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 1

95 4933

!" ATTACHMENT 1 l

LR-N980485 ,

APPENDIX A NOTICE OF VIOLATION

, ' Public Service Electric and Gas Company Docket Nos: 50-272 Salem Nuclear Generating Station 50-311 Units 1 and 2 l License Nos: DPR-70 DPR-75 During an NRC inspection conducted between August 2,1998 and September 12, 1998, violations of NRC requirements were identified. In accordance with the " General

' Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the i violations are listed below:

A'. 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires in part that significant conditions adverse to quality be promptly identified, with corrective actions implemented to prevent recurrence.

Contrary to the above, on August 20,1998 it was identified that PSE&G failed to i complete required containment penetration breaker functional testing within the time period mandated by Unit 2 technical specification 4.8.3.1.a.2, a significant

!- condition adverse to quality. PSE&G failed to promptly identify this issue following several previous similar discoveries, and failed to implement sufficient corrective actions to prevent the most recent recurrence.

This is a Severity Level IV Violation (Supplement 1).

B. Salem Unit 1 technical specification 6.8.1.a requires, in part, that written procedures shall be implemented covering the activities described in Appendix A l of Regulatory Guide (RG) 1.33, Revision 2, dated February 1978. RG 1.33 requires procedures for maintenance on safety-related systems, including the  ;

radiation monitoring system and the service water system. Two examples of a l

! failure to satisfy this requirement are listed below:

1. Salem Unit 1 maintenance procedure S1.lC-CC.RM-0028(Q),1R18 Liquid Waste Disposal Process Radiation Monitor, Step 5.3.36 requires that troubleshooting of the 1R18 radioactive liquid effluent monitor be initiated if as-found calibration data is determined to be outside of the specified acceptance criteria.

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l ATTACHMENT 1 l LR-N980485 Contrary to the above, on August 19,1998, it was identified that, during a calibration of the 1R18 radiation monitor on August 7,1997, maintenance technicians failed to troubleshoot the 1R18 radiation monitor after documenting the as-found calibration data as being outside of the l acceptance criteria established by procedure S1.lC-CC.RM-0028(Q) for over one year.

2. Salem Unit 1 surveillance test procedure S1.OP-ST.SW-0010, inservice Testing of Containment Fan Cooler Unit Service Water and Control Air i Valves, Step 5.4.4 requires that a test device be properly connected to l service water accumulator discharge valve control circuitry in order to test the valve for proper operation Contrary to the above, on September 7,1998, it was identified that maintenance technicians connected a test device to the improper service l water valve control circuit terminals. This error caused a redundant service water accumulator discharge valve to open, resulting in the simultaneous inoperability of two independent accumulators.

This is a Severity Level IV violation (Supplement 1).

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L ATTACHMENT 2 LR-N980485 RESPONSE TO NRC NOTICE OF VIOLATION I INSPECTION REPORT 50-272/98-08 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 PSE&G RESPONSE TO VIOLATION A PSE&G concurs with the violation.

(1) The reason for the violation.

The reason for this violation was human error.

The PSE&G Quality Assessment (QA) department performed a detailed review of the surveillance requirements of Technical Specifications (TS) 3.8.3.1. This review assessed the effectiveness of the controls and programs to ensure compliance with TS 3.8.3.1 " Containment Penetration Conductor Overcurrent Protection Devices." The QA assessment determined that a type of low voltage circuit breaker (categorized as TEC type by planning and scheduling) had exceeded the requirement of TS 4.8.3.1.a. 2 which requires that10% of each l type of breaker be tested every 18 months. Specifically, the TEC type breakers (6 breakers are contained in this type) were identified as not having been properly tested within the 18 months frequency (plus the 25% grace period)

! required by TS surveillance 4.8.3.1.a.2. As a result of this event, and other similar events, PSE&G management established a level-1 root cause investigation team.

Inattention to detail caused the missed surveillance of the TEC type breaker.

The initial creation of the recurring tasks (RTs) in the 1988-1991 timeframe should have created two separate RTs, with one created to track the 10%

sampling. As the system was created and modified in the 1988-1991 timeframe, the system depended on individual recognition of the testing requirement by planning and scheduling personnel (since no 18 month RT was created) to ensure the 10% sampling was performed.

The following apparent contributing factors played an instrumental role in the human errors; 1) an ineffective implementation of the requirements of Technical Specification 4.8.3.1.a.2 with regard to the scheduling of a 10% sampling of each type of low voltage breaker every 18 months,2) inadequate training and lack of knowledge of personnel associated with the surveillance program, and 3) ineffective corrective actions from events occurring in the last three years.

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ATTACHMENT 2 LR-N980485 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-08 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 The scope of the Technical Specification Surveillance improvement Program (TSSIP) was reviewed to determine whether this project should have identified the surveillance deficiency when the particular Technical Specification was examined during the 1996 - 1997 time frame. As reported to the NRC in LER 95-008, the scope of the TSSIP project specifically excluded the ISI/IST programs, snubbers, and those specifications that would be removed as a result of the improved Technical Specification project. The Containment Penetration breaker fell under the improved Technical Specification category and as such did not receive a detailed review of the recurring tasks and method of implementation. However, during the TSSIP Phase I overview effort an opportunity was missed to identify that the method of the surveillance implementation for the Containment Penetration breakers was ,

less than adequate.

(2) The corrective steps that have been taken.

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1) Operations entered Technical Specification Action Statement (TSAS) 3.8.3.1 at 0940 on August 20,1998, and exited the TSAS at 1528 on the same day, following completion of the TS surveillance. l

2) A comparison of the MMIS database to the design engineering calculation was  !

performed to ensure that the MMIS database contained all the required overcurrent protection devices. The comparison showed that the breakers in i the design calculation were included in the MMIS database.

3) Personnel involved in the event identified in this violation have been held accountable, in accordance with PSE&G policies.

(3)

The corrective steps that will be taken to avoid further violations.

1) A review and appropriate revision of recurring tasks associated with l Containment Breakers will be made to ensure multiple barriers are in place to i preclude scheduling errors with Technical Specification Surveillances.

2) A walk down will be conducted of 10 % of the containment circuit breakers (molded case only) to verify that model numbers are correct and labels are in place.

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ATTACHMENT 2 LR-N980485 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-08 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311

3) Training and qualification sessions will be conducted for key individuals involved in Technical Specification surveillance administration.

The corrective actions noted above will be completed by January 29,1999.

Additional corrective actions may be identified during the review and assessment ,

activities noted above. Appropriate proactive completion schedules will be established, as necessary.

(4) The date when full compliance will be achieved.

PSE&G achieved compliance for the TEC circuit breakers when Operations entered Technical Specification Action Statement (TSAS) 3.8.3.1 at 0940 on August 20, 1998, and exited the TSAS at 1528 on the same day, following satisfactory completion of the TS surveillance.

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ATTACHMENT 2 i

LR-N980485 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-08 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 L

PSE&G RESPONSE TO VIOLATION B 1

l PSE&G concurs with the violation item 1 1 (1) The reason for the violation.

The reason for this violation is human error.

l The apparent cause of this occurrence was a lack of attention to detail and a failure to self-check on the part of the technicians that performed the calibration of the 1R18 on July 25,1997. In addition, the job supervisor failed to adequately review the completed channel calibration documentation to verify that the calibration had been properly performed and that the recorded data was correct.

(2) The corrective steps that have been taken. .

1)'A channel calibration was satisfactorily performed on the 1R18 on August 21, 1998.

j 2) The personnel involved in this event have been held accountable in accordance with PSE&G policies and procedures.

3) An independent assessment has been performed of the latest channel calibration performed for each of the radioactive liquid effluent monitoring instruments that support the requirements of Technical Specification 3.3.3.8. to verify that no additional calibration errors exist and that no liquid release data was identified which exceeded the limits of Tech Specs.

4) Discussions were held with the qualified technicians to review this incident and

! to stress procedural adherence and the need to review precautions and limitation.

(3)

The corrective steps that will be taken to avoid further violations.

No further actions are planned in response to this event.

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ATTACHMENT 2 LR-N980485 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-08 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50 272 AND 50-311 l

l (4) The date when full compliance will be achieved.  ;

Full compliance was achieved on August 21,1998 with the satisfactory performance of the channel calibration.

i item 2 l

(1) The reason for the violation.

, The reason for this violation was human error.

The event investigation determined that the test device was connected improperly. Additionally, the review determined that the governing test procedure did not clearly identify the intended connection points for the test device. The maintenance technicians incorrectly assumed which set of terminals were to be used for test equipment connection (failure to self check).

(2) The corrective steps that have been taken.

1) A root cause evaluation of the event has been performed.

2) A departmental stand-down was conducted to reinforce the lessons learned from this and several other recent human performance problems.

3) A revision to procedure 81.OP-ST.SW-0010(Q)" INSERVICE TESTING CONTAINMENT FAN COOLER UNITS (CFCU) SERVICE WATER AND CONTROL AIR VALVES" has been completed in order to clarify the proper test device connection points and to add caution statements.

4) The personnel involved in this event have been held accountable in accordance with PSE&G policies and procedures.

5) Information has been provided to all 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts via a Maintenance Flash regarding this event and the human performance issues of self-checking and stopping work when the expected results are not obtained has been reinforced.

This activity was completed on October 22,1998.

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ATTACHMENT 2 LR-N980485 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-03 AND 50-311/98-08 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 (3) The corrective steps that will be taken to avoid further violations.

No other corrective actions are planned.

i (4) The date when full compliance will be achieved.

Full compliance was achieved, on September 7,1998, when the equipment was returned to operable status upon refilling of the 11 Service Water Accumulator, d i 6

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