ML18093B056
| ML18093B056 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/02/1988 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N88141, NUDOCS 8809080073 | |
| Download: ML18093B056 (5) | |
Text
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I-Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer September 2, 1988 N:i,R-N88141 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION NRC COMBINED INSPECTION REPORT 50-272/88-14 AND 50-311/88-14 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated July 27, 1988, which included a Notice of Violation.
A one week extension to the response time was requested and granted per phone correspondence with NRC Region I Reactor Projects Section Chief Paul Swetland on August 25, 1988.
Pursuant to the requirements of 10CFR2.20i, PSE&G's response to this Notice of Violation is provided in the attachment to this letter.
Should you have any questions, please do not hesitate to contact us.
Attachment c
Mr. J. c. Stone Licensing Project Manager Mr. R. w. Borchardt Senior Resident Inspector Sincerely, Mr. W. T. Russell, Administrator Region I Mr. D. M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 8809080073 80~868~7~
PDR ADOCK PNU~
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ATTACHMENT Your letter dated July 27, 1988, transmitted a Notice of Violation concerning a failure to perform a surveillance within the required time (272/88-14-01) and a failure to declare 2B SEC inoperable and enter the applicable action statement (311/88-14-02).
The written response requested in the Notice of Violation is presented below.
NOTICE OF VIOLATION, ITEM A Technical Specification (TS) Surveillance 4.0.5 states that surveillance requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:
Inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10CFR50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10CFR50, Section 50.55a(g) (6) (i).
In addition, ASME Section XI states that when a valve surveillance stroke time increases by more than 25% from the last surveillance stroke time, the surveillance frequency is required to be increased from quarterly to monthly.
During March 1988, the surveillance stroke time for valve 12SW39 increased by more than 25% from the previous surveillance.
Contrary to the above, on May 17, 1988 it was determined that valve 12SW39 had not been tested on a monthly basis following the March 1988 stroke time test which increased more than 25% of the previous value.
DISCUSSION Although this violation specifically involves only the 12SW39 valve, the inspection report clearly delineates an increased concern as to the scheduling and proper completion of surveillance tests and action.statements.
This concern stems from recurring problems with missed or overdue surveillance tests.
The following section not only provides PSE&G's response to the specific violation, but should also provide the corrective actions necessary to prevent recurrence of missed or overdue surveillances.
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RESPONSE
- 1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE VIOLATION.
- 2.
THE ROOT CAUSE OF THE MISSED 12SW39 SURVEILLANCE WAS PERSONNEL ERROR IN MISFILING THE SURVEILLANCE CHECK-OFF SHEETS.
- 3.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
- a.
The 12SW39 surveillance was performed and valve stroke time was within ASME Section XI requirements.
- b.
A complete review of the Operations Department "current copy" procedures file was performed to ensure all surveillance files are in order.
This review verified that no other files were out of order and that no additional surveillances were overdue.
- c.
A letter stressing the need for attention to detail was distributed to all management and professional employees.
- 4.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS:
- a.
The Quality Assurance Department will audit Operations Department surveillance files on a monthly basis to ensure that these files are in order and surveillance requirements are met.
If no deficiencies are identified within a 4 month period, the frequency of these audits will be reduced to a quarterly basis.
These audits will continue until management is assured that control is being adequately maintained.
- b.
A review of the Work Control Process as it applies to this specific instance has been performed and the following recommendations will be implemented:
- 1.
- 2.
A program will be established to implement the actions necessary to preclude recurrence of the problem using the INPO Good Practice TS-410, Surveillance and Periodic Test Scheduling Program, as a guide.
This program will be implemented by January 1989.
A surveillance coordinator has been assigned in the Technical Department to develop this program, determine scope of responsibilities, and oversee program implementation *
- 3.
A Technical Specification Surveillance Data Base has been established based on a review of Technical Specification, ASME Section XI and plant operating procedures to assist the surveillance coordinator in implementing and maintaining the surveillance scheduling program.
- 4.
A revision to AP-9, Work Control Program, will be performed to incorporate the recommended changes to the Work Control Process.
- 5.
FULL COMPLIANCE HAS BEEN ACHIEVED NOTICE OF VIOLATION, ITEM B Technical Specification 3.9.2 requires that three channels of the Safeguard Equipment Control System be operable in Mode 1 (power operation).
With less than three operable channels the unit is required to be placed in hot standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, on June 16, 1988, the unit was operated in Mode 1 for greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> with less than three operable channels of the Safeguard.Equipment Control System in an operable status.
RESPONSE
- 1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THIS VIOLATION.
- 2.
THE ROOT CAUSE OF THE VIOLATION WAS INADEQUATE PROCEDURAL GUIDANCE.
- 3.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
- a.
The 2B SEC chassis had a failure circuit card which was replaced, and 2B SEC was returned to OPERABLE status.
- b.
Operations Department management has reviewed the event and clarified to Operations personnel the conditions by which SEC inoperability determination will be made.
- 4.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
- a.
The "SEC Trouble Alarm" Alarm Response Procedure has been revised requiring the SEC cabinet to be declared inoperable upon determining that the alarm can not be reset.
All applicable personnel have been informed of this change.
- b.
As part of the on-going Operating Experience Review Program, the Nuclear Training Center will review this violation with all Licensed Operators during Segment 2 of the Licensed Operator Requalif ication Cycle for 1988-1989.
This review will be completed by March 1989.
- 5.
FULL COMPLIANCE HAS BEEN ACHIEVED.