ML18086B106
| ML18086B106 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/21/1981 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18086B103 | List: |
| References | |
| NUDOCS 8112080468 | |
| Download: ML18086B106 (5) | |
Text
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'f Frederick W. Schneider Vice President Pub I ic Service Electric and Gas Company 80 Park Plaza Newark, N.J. 07101 201 /430- 7373 Production August 21, 1981 Mr. Boyce H. Grier, Director Off ice of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406 Attention:
Mr. Thomas T. Martin, Acting Director Division of Engineering and Technical Inspection Gentlemen:
NRC COMBINED INSPECTION NOS. 50-272/81-03 AND 50-311/81-04 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FEBRUARY 9-13, 1981 We have reviewed the report of your inspection conducted by Mr.
G. Napuda on February 9-13 and 18, 1981.
The inspection report i:tem:tzes* various problem areas and states that "The pervasiveness of the sum total indicates an area where preventive and improved
'Iltanage*rrient controls can preclude future safety problems".
Due to the va.ried nature of the items, each will be addressed individually.
The managerial steps taken to prevent recurrences in this problem area will be addressed on an item by item basis.
Our response to the item of noncompliance identified.in Appendix A is as follows:
10 CFR 50, Appendix B, Criterion XVI, states in part, "Measures shall be established to assure that conditions adverse to quality, s*uch as*..
- nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
FSAR Amendment 43, Section D.5.16, states in part, "Organizations involved in safety-related activities shall be required to maintain correc'tive action programs commensurate with their scope of activity."
' 8112080468 811 0~9"""""\\
- ~DR ADOCK 05000272 l.j PDR I
Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission 8/21/81 Contrary to the above, the required corrective action programs did not assure that (a) corrective action was accomplished in the specified time frame (i.e., promptly); (b) corrective action was adequate (i.e., all causes of conditions were corrected); and (c) corrective action was effective (i.e., preclude the recurrence of similar conditions) as evidenced by the following examples.
Part (a)
In a response (dated June 3, 1980) to IE Inspection Reports 50-272/80-04 and 50-311/80-01, dated May 6, 1980, the licensee stated that corrective actions would be completed by September 30, 198~ with respect to the following.
Development and issuing of a Unit No. 2 Materials Equipment List (MEL)
Revision and issuing of a station procedure addressing as-built drawings/information and proper use thereof.
The Unit No. 2 MEL was not issued until November 3, 1980.
Procedure AP-3, designated by management as the one to address as-built information and its proper use, was not issued as of February 18, 1981.
Reply to Part (a)
The issuance of preliminary printouts was started on September 29, 1980.
The official issue was held until such time that corrections could be made to the preliminary printouts.
The official copy of the MEL was not issued until November 3, 1980,due to the fact that we had underestimated the scope of this task.
Temporary QA Instruction, TI-1, Rev. O, dated September 24, 1980, was issued as an interim mechanism for obtaining item classi-fication.
EDD-6, "Interim Material Order/Item Classification",
was issued on November 5, 1980.
This procedure provides a mechanism for updating the MEL as necessary.
Procedure AP-3, Rev. 10, was issued February 19, 1981, but the implementation of the intent of the actions formalized in this revision was begun in June 1980.
In March 1981, an individual was designated to review and revise all of the Administrative Procedures.
This step was taken to assure the timely and accurate issuance of procedures requiring revision.
Part (b)
In a response (dated June 3, 1980) to IE Inspection reports 50-272/80-04 and 50-311/80-01, dated May 6, 1980, the licensee
Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission 8/21/81 stated that the program to provide prompt as-built information for station personnel (i.e., Station Technical Document Rooml would be fully implemented by September 30, 1980.
The following latest Design Change Package revisions, issued by site engineering personnel during November-December, 1980, had not been sent to the Station Technical Document Room (TDRl as of February 18, 1981.
lEC-0663, Revision 12 lEC-1034, Revision 2 2EC-0550, Revision 2 (TDR had Revision 8)
(TDR had Revision 0 )_
(TDR had Revision l}
Reply to Part (b}
A review of the system to provide as-built information to the station personnel has been performed.
The current system allows for the approval of Operational Design Change Notices (ODCN's) by field engineers with verbal concurrence of the Newark sponsor in order to support continued construction.
Prior to issuing these ODCN's to the TDR, these revisions receive a countersignature by the Newark sponsor, confirming the verbal approval.
The system will be revised by September, 1, 1981, to permit direct issue of the field revisions to the TDR, with the countersignature being filed oy Newark but not distributed to the station.
This action w:i'll correct the deficiency and will return the station to full compliance.
Part * (c}
The following describe recurrent or repetitious events:
(ll Multiple examples of missed surveillances as documented by Licensee Event Reports (LER's).
LER 78-14, LER 78-15, LER 78-21, LER 78-25 LER 78-34, LER 79-15, LER 79-17, LER 79-22, LER 79-23, LER 79-25, LER 79-30, 2/25/78, 3/9/78, 3/28/78, 4/19/78, 6/27/78, 2/12/79, 2/19/79, 2/21/79, 3/12/79, 3/15/79, 3/22/79, Missed RCS Fl -
Surveillance Missed suspended solids surveillance Missed RCS Fl - Surveillance Missed breaker surveillance Missed Rl9 Surveillance Missed RCS Inventory surveillance Missed gross activity surveillance Missed rod position surveillance Missed condenser T surveillance Missed chilled water pump surveillance Missed va'1ve lineup surveillance Additionally,the following LER's describe continuing events as those above.
J Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission 8/21/81 80-42/03L, Missed 24 volt Battery surveillance 80-52/03L, Missed inservice inspection of valves 80-66/03L, Missed Fire Detection instruments surveillance (2)
The collapse of a Unit No. 1 CVCS holdup tank (No. 13) in 1976 was followed by a subject IE Circular No. 77-10 issued in 1977, which recommended plant-specific reviews to preclude just such events; however, another eves holdup tank (No. 11) collapsed in October 1979, a recurrent event.
Reply to Part (c)
(1)
The failure to perform surveillance as required has been addressed and corrective action for the identified problem was initiated prior to the inspection period.
In September 1980, an individual was designated to follow all of the surveillances to be performed.
Since that appointment there have been only two instances of missed surveillances. Both cases were on Unit No. 2 where these specific surveillance requirements were new to the personnel responsible due to the recent issuance of the No. 2 Unit license and new Technical Specifications.
(2)
The failure of 13 CVCS holdup tank generated an engineering evalution and a design change was initiated.
The design change provided for the installation of vacuum breakers to all the eves holdup tanks.
The actions necessary to prevent redurrence were initiated but before the material changes could be completed, the second incident had occurred.
It is our opinion that the action taken to correct the eves holdup tank problem is adequate and should not be considered in the violation.
General Comment Overall management attention to corrective action, responsiveness and commitments has greatly increased the effort to improve our performance in these general areas.
PSE&G is in the process of forming a corporate response coordinating team.
This team is comprised of representatives from various departments reporting to a central coordinator and is responsible for assuring the timeliness of commitments.
Specifically, the team will e§tablish responsibility and track the response efforts on such items as bulletins, generic letters, inspection reports and similar items requiring a written response.
Sincerely,
~~
CC Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
STATE OF NEW JERSEY SS:
COUNTY OF ESSEX COUNTY OF ESSEX FREDERICK w. SCHNEIDER, being duly sworn according to law deposes and says:
I am a Vice President of Public Service Electric and Gas Company, and as such, I
~ind the matters set forth in our response dated August 21, 1981 to the NRC's combined inspection report 50-272/81-03 and 50-311/81-04 on various problem areas are true to the best of my knowledge, information and belief.
. ~.vJ~
FREDERICK W. SCHNEIDER Subscribed and sworn to before me this*.r;f Jf 'fA. day of.
- ** vt<;.<J;t, 19-81 New Jersey My Commission expires on f'Pc::t: /; /C/ J a
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