ML18093A303

Ack Receipt of Informing NRC of Corrective & Preventive Actions Taken in Response to Violations Noted in NRC

ML18093A303
Person / Time
Site:	Salem
Issue date:	08/06/1987
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil Public Service Enterprise Group
References
NUDOCS 8708140219
Download: ML18093A303 (6)

Text

Docket Nos.

50-272 50-311 Public Service Electric and Gas Company ATTN:

Mr. Corbin A. McNeill, Jr.

Vice President - Nuclear P.O. Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen:

AUG 0 6 1987

Subject:

Inspection Nos. 50-272/87-02 and 50-311/87-02 This refers to your letter dated March 30, 1987, in response to our letter dated February 25, 1987.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

• Original Si&ned By:

<:iut!?.SkA~

~illiam V. Johnston, Acting Director cc:

Public Document Room (PDR)

Nuclear Safety Information Center (NSIC)

State of New Jersey bee:

Region I Docket Room (w/concurrences)

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• ** ;...' ***..) ** :-... "l;i MAR 3 0 1987 NLR-N87051 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/87-02; 50-311/87-02 SALEM GEN2RATING STATION DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the three violations noted in the Notice of Violation dated February 25, 1987 regarding design interface, procedural adequacy and document control in the area of piping and pipe supports.

Our respons~ to the Notice of Violation is provided in the attachment to this letter.

In addition, the cover letter of Inspection Report Nos.

50-272/87-02 and 50-311/87-02 requested our assessment of apparent weaknesses in design interface and plant configuration control in the mechanical/structural and electrical areas and of the detail of our review of contractor technical reports.

The requirements for design interface and configuration control are addressed in PSE&G Engineering Methods Procedures.

One of the violations noted in the subject Notice of Violation was the result of inadequate application of these procedural guidelines.

In order to augment our efforts to comply with stated design interface and configuration control requirements, an engineering analysis checklist and an engineering interface checklist will be issued which will address the program requirements for each discipline.

Th~se measures will b~ monitored formally on an interim basis to determine their effectiveness in assuring that design interface and configuration control considerations are adequately addressed.

With regard to the detail of review of contractor technical reports, PSE&G has traditionally selected contractors based upon their expertise and has relied upon the experience and qualifications of the contractor to provide assurance that

MAR 3 0 1987 Document Control Desk 2

specified work has been performed accurately and in accordance with appropriate standards and regulations.

This is particularly pertinent to work done in technical specialty areas in which PSE&G does not retain internal expertise.

Contract reports have been reviewed for acceptability by a manager or engineer within the department which has been assigned sponsorship of the project for which the contract work is being performed.

This review has not normally,involved a recheck of calculations but has consisted of an overall review of the quality of the contractor document based on the sponsor engineer's level of knowledge of the technical area and the specification to which the work was performed.

Also, this review function has not been documented in the past.

In response to the stated concern, an Engineering Methods Procedure is to be developed by July 31, 1987 to dictate internal review and documentation requirements for consultant reports and other vendor documents.

Attachment C

Mr. D. C. Fischer Licensing Project Manager Mr. T. J. Kenny Senior Resident Inspector Dr. T. E. Murley Regional Administrator NRC Region I Sincerely,

ATTACHMENT PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION UNIT NOS. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION A.

Contrary to Criterion III of 10 CFR 50, Appendix B, PSE&G Quality Assurance Manual Procedure QAI 3-1, and Section 7.3 of PSE&G Procedure VPN-QAP-01, "Operational Quality Assurance Program," procedures for implementing design interface measures for two piping an9 support system modifications completed during the 1986 Salem Unit 2 refueling outage were either non-existent or inadequately specified.

This resulted in the failure to update affected safety related structural as-built configuration records and to evaluate the effects of increased mechanical component support loads on the applicable structures.

RESPONSE

PSE&G does not dispute the violation.

The apparent inadequacy in addressing design interface considerations for the two piping and support system modifications in question was due to the lack of clear definition in existing Engineering Methods Procedures of the design interface review and do8umentation requirements for this particular inte~disciplinary interface.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The structural impact of the pipe support modifications documented in Design Change Requests (OCR) 2EC-01691, 2EC-01692 and 2EC-02236 has been reviewed and it has been confirmed that affected structures are capable of supporting the increased mechanical component loads with an adequate margin of safety.

The Engineering Methods Procedure which addresses pipe supports is being revised to identify the interfaces which must be addressed with piping and support system modifications.

Thi~ procedure will be issued by July 31, 1987.

B.

Contrary to Criterion V of 10 CFR 50, Appendix B and Section 7.5 of PSE&G Procedure VPN-QAP-01 "Operational Quality Assurance Program," piping and pipe support design activities were not documented and approved criteria for the performance of piping stress analysis were not established.

Also, PSE&G Specification S-C-MBOO-MDS-043 for ""Design of r

~.

Pipe Supports" required the checking of pipe support displacements and rotations under applied loads without providing acceptance criteria for the evaluation of these parameters.

RESPONSE

PSE&G does not dispute the violation.

This violation was the result of two conditions:

(1) the fact that Engineering Methods Procedures did not provide quantitative acceptance criteria with regard to pipe support displacements and rotations under applied loads and (2) that although a procedure governing the conduct of piping stress analysis was in preparation, it had not yet been formally issued.

PSE&G has traditionally regarded stress analysis as a technical specialty to.be conducted by professionals with appropriate qualifications and proven experience in this area.

Recent industry trends have pointed to more rigorous internal documentation of methods used.

At the time of the inspection, our procedure to address this documentation of pipe stress analysi~ methodologies was under development.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A controlled piping stress analysis procedure will be finalized and issued which will formally document currently used pipe stress analysis methodologies.

Also, the existing pipe support design procedure is being revised to include quantitative acceptance criteria.

Acceptance criteria for pipe support displacements and rotations under applied loads

• will be included in this procedure.

Both procedures will be issued for use by July 31, 1987.

C.

Contrary to Criterion VI of 10 CFR 50, Appendix 8 and Section 7.6 of PSE&G Procedure VPN-QAP-01, "Operational Quality Assurance Program," instructions governing the mechanical standard for determining load capacities of U-bolts was uncontrolled.

Also, the evaluation of local stresses in piping walls at locations of integral attachments was described in Sectiori 10.4 of the criteria for design of pipe supports (Specification S-C-MBOO-MDS-043) using ASME code cases No. N-392 and N-318-1.

However, the evaluation of local stresses in piping at locations of U-bolt components was described in, and performed, using another document which was uncontrolled.

RESPONSE

PSE&G does not dispute the violation.

This violation was a result of the inadvertent referencing of a non-controlled document in a controlled procedure (Notice of Violation C.l) and the inadvertent omission of design criteria applicable to U-bolt induced local stresses in the procedure nominally governing pipe support local stress calculations (Notice of Violation C.2).

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A directive has been issued to the Stress Group of the PSE&G Engineering department to control the use of the mechanical standard and pipe local stress evaluation for U-bolts.

The controlled pipe support design procedure is being revised to include (1) the mechanical standard for load capacities of U-bolts and straps and (2) the pipe local stress evaluation criteria for U-bolts.

This procedure will be issued for use by July 31, 1987.