ML18092B366
| ML18092B366 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/24/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-82-02, IEB-82-2, NLR-N86177, NUDOCS 8612080541 | |
| Download: ML18092B366 (4) | |
Text
Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Vice President -
Public Service Electric and Gas Company P.O. Box236, Han cocks Bridge, NJ 08038 609 339-4800 Nuclear November 24, 1986 NLR-N86177 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Stewart D. Ebneter, Director Division of Reactor Safety Gentlemen:
NRC INSPECTION 50-272/86-25 AND 50-311/86-25 SALEM GENERATING STATION UNITS NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company is in receipt of the subject inspection report dated October 21, 1986, which transmitted a Notice of Deviation concerning the inadequacy of quality assurance measures taken in response to Action Item 1 of IE Bulletin 82-02, Degradation of Threaded Fasteners in the Reactor Coolant Pressure Boundary of PWR Plants, to ensure proper selection, procurement, and application of fastener lubricants.
Also identified was the absence of a formal response to NRC Region I with regard to Action Item 4 of IE Bulletin 82-02.
As this inspection report was received only several days prior to the due date for response to the identified Deviations, PSE&G requested an extension for the response to November 24, 1986.
This extension was granted verbally by Mr. Leif Norrholm of your staff.
Our response to the Notice of Deviation is provided in the attachment to this letter.
The cover letter of the inspection report also requested a discussion of actions taken by PSE&G with regard to the tracking of NRC Bulletin commitments.
In response to this concern, a review of NRC Bulletin responses provided by PSE&G prior to IE Bulletin 82-02 was performed.
The results of this review indicated that all Bulletin action items were responded to within the specified time frame, including those action items requesting additional actions to be performed after subsequent milestones had been reached; i.e. action items similar to IE Bulletin 82-02, Action Item
- 4.
Beginning with the IE Bulletin 82-03, tracking of Bulletin commitments and associated implementation schedules has been accomplished through a computerized tracking
\\
I
Stewart D. Ebneter, Director 2
11-24-86 system.
This tracking system has been used effectively since its inception and has more than adequately provided for the recording and assignment of actions required by NRC Bulletins.
For these reasons, we feel that the oversight related to Action Item 4 of IE Bulletin 82-02 is an isolated occurrence.
The review of the previous responses to NRC Bulletins also indicated that appropriate corrective actions were proposed to properly address long range or continuing commitments.
As such, we feel that those NRC Bulletin required actions which go beyond a one time response are being implemented.
We are currently examining our capabilities to ensure that implementation of those commitments is being accomplished.
Attachment C
Mr. Donald C. Fischer Licensing Project Manager Mr. Thomas J. Kenny Senior Resident Inspector Sincerely,
ATTACHMENT PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION RESPONSE TO NOTICE OF DEVIATION NRC Inspection 50-272/86-25 and 50-311/86-25 identified two deviations concerning actions requested by IE Bulletin 82-02, Degradation of Threaded Fasteners in the Reactor Coolant Pressure Boundary of PWR Plants.
DEVIATION 50-272/86-25-01; 50-311/86-25-01
RESPONSE
Contrary to Action Item 1 of IE Bulletin 82-02, quality controls committed to by PSE&G for the designation, purchase, receipt inspection, verification and documentation of two lubricants, Neolube and Fel-Pro N5000, used on Reactor Coolant Pressure Boundary threaded fasteners were inadequate.
PSE&G does not dispute the deviation.
The cause of the deviation was a failure to appropriately designate the use and attributes of the two lubricants both in storage and in the procedure which provides for their use.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED These corrective actions are intended to resolve the deviation and implement actions to prevent any future recurrence of the deviation.
Previous procurements of these materials were not within the QA program.
The QA program has been revised to include these materials in the quality procurement process.
A comprehensive review of purchase requirements was conducted to assess that proper quality requirements would be achieved.
Previous procurements of these materials were not within the QA program.
Purchasing requirements for Neolube 1 and 2 and Fel-Pro N-5000 have been changed to clearly designate the specific product, type, and QA provisions.
The Salem Maintenance Procedure M8C-3 along with additional maintenance procedures, where applicable, will be revised to incorporate proper application of Neolube and Fel-Pro.
This activity is scheduled to be completed on December 15, 1986.
Neolube 2 materials designated by the NSSS supplier for use on Reactor Pressure Vessel stud holes is now certificable by the manufacturer with respect to halogens and sulfides and will be purchased accordingly.
Preliminary analysis by PSE&G of materials used onsite indicate halogen content is well below PSE&G allowable limits identified in Administrative Procedure AP-38.
Additional analysis of materials are being completed offsite.
A review of work activities and material such as Reactor Vessel Studs (ASTM-A 540 6RB24 and Reactor Vessel Flange A-533) has not identified that the lubricants used would cause sec.
Physical verification of station storeroom and warehouse facilities was conducted to assure that only certified materials are available for use within the station.
DEVIATION 50-272/86-25-02; 50-311/86-25-02
RESPONSE
Contrary to Action Item 4 of IE Bulletin 82-02, a written report signed under oath was not submitted to the Regional Administrator within 60 days following completion of the outage during which the activities specified by Action Item 2 of IE Bulletin 82-02 were to be performed.
PSE&G does not dispute the deviation.
As described in the cover letter to this attachment, PSE&G feels that the oversight of the reporting requirement specified in this action item was an isolated occurrence and is not indicative of a problem in our ability to assign and implement actions related to NRC Bulletins.
The formal response to Action Item 4 of IE Bulletin 82-02 was provided to NRC Region I in a letter dated November 21, 1986, to Dr. T. E. Murley from c. A. McNeil!, Jr., Vice President -
Nuclear.
A signed affidavit accompanied this submittal.
Since the inspection activities directed by Action Item 4 were scheduled, performed and incorporated into future maintenance and ISI activities in the appropriate time frame, submittal of the aforementioned letter is all that is required for closure of this deviation *