ML18095A495
| ML18095A495 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 09/21/1990 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N90185, NUDOCS 9010030214 | |
| Download: ML18095A495 (8) | |
Text
Public Service Electric and Gas
- Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nuciear Operations s=p L -1 1990 NLR-N90185 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE.OF VIOLATION NRC INSPECTION REPORT NO 50-272/90-200 AND 50-311/90-200 DOCKET NOS~ 50-272 AND 50-311 Public Service Electric and Gas {PSE&G) has _received the Notice of Violation dated August 21, 1990.
During the period April 9 - 13 and April 23 - 27, 1990, a maintenance team inspection identified apparent violations of NRC requirements involving failure to maintain design features of the facility required to mitigate the consequences of flooding, including modifications to a design feature.of the facility without performance of a 10 CFR 50.59 safety evaluation, and multiple examples of failure to follow written procedures for various plant activities.
Pursuant to the requirements of 10 CFR 2.201, our response-to this Notice of Violation is.provided in the attachment to this letter.
Should you have any questions in regard to this transmittal,_ do no_t hesitate to call.
Attachment 9010030214 900921 PDR ADOCK 05000272 Q
PNU
Document Control Desk NLR-N90185 C
Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 2
Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 s._-,,
~ 1 1990
ATTACHMENT SEP 2 1 1990 During the period April 9 -
13 and April 23 -
27, 1990, a maintenance team inspection identified apparent violations of NRC requirements involving failure to maintain design features of the facility required to mitigate the.consequences of flooding, including modifications to a design feature of the facility without performance of a 10 CFR 50.59 safety evaluation, and multiple examples of failure to follow written proc::edures for various plant activities.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2-, Appendix C (1990), the following are identified as violations.
- 1.
10 CFR 50.59, Changes, Tests, and Experiments, states that the holder of a license authorizing operation of a production or utilization facility may make changes in the fadility as described in the safety analysis report without prior Commission approval, unless the proposed change.
involves a change in the Technical Specifications incorporateq in the license or an unreviewed safety question.
Further, 10 CFR 50.59(b) states that the licensee shall maintain records of changes in the facil-ity made pursuant to s.ection 50. 59, to _the extent that such changes constitute changes to the facility as described in the safety analysis report.
These records must include a written safety evaluation which provides the basis for the determ.ination that the change does not involve an unreviewed.
safety question as defined in 10 CFR 50_. 59.
Salem Updated FSAR, Section 3. 4,."Water level* (Flood)
Design," states that the_ auxiliary building is watertight up to elevation 115 feet.
All doors in the outer auxiliary building walls below elevation 120.4 feet are watertight.
Contrary to the above, as of April 9, 1990, modified hatch covers were installed in the service water rooms of both
.units that did not meet the water tightness specified by the Updated Final Safety Analysis Report, Section 3.4 (delineated by design documents drawing 201044 and Cambell Foundry Co. Figure# 1866227, Type 2).
-No written safety evaluation was available for this modification pursuant to 10 CFR 50.59.
PSE&G does not dispute the violation.
ROOT CAUSE The root cause of this,event has been attributed to lack of knowledge by plant personnel as to the requirements of these hatches as described in the FSAR.
While it is apparent that the modified hatches installed at the time of the inspection, were designed with security requirements in mind, the requirement for water tight capability was not considered.
Page 1 of 6
PSE&G has not been able to determine when these hatches were SEP 2 1 199'!
modified, nor whether a 10 CFR 50.59 safety evaluation was performed at the time.
However, it had been common practice to
~tilize these hatches during maintenance periods for the purpose of draining the service water headers.
CORRECTIVE ACTIONS TAKEN Following the identification of this discrepancy (nonconformance), Deficiency Reports (DR) were initiated in accordance with PSE&G's Nonconformance program.
Temporary water tight hatch covers were fabricated and installed in accordance with the Temporary Modification Program(AP-13).
As part of this installation, a 10 CFR 50.59 safety evaluation was performed.
The safety evaluation identified no Unreviewed Safety Question (USQ).
Subsequent to this temporary installation, original design hatches were ordered and have now been installed.
Additionally, these hatches have been stenciled to identify them as having to be maintained water tight and to contact the Shift
. Supervisor prior to opening.
To increase awareness of the FSAR requirements in this area the General Manager -
Salem Operations has issued a letter to all station personnel detailing this violation and the importance of Water Tight Doors and Hatches to the physical plant.
CORRECTIVE ACTIONS TAKEN*TO PREVENT REcuRRENCE In addition to the corrective actions indicated above, PSE&G has recently strengthened its Temporary Modifications Program.
The revised Temporary Modification Program procedure was approved in August 1990.
The revised Temporary Modification Program in conjunction with the increased awareness regarding the importance of this equipment, assures PSE&G that this type of modification will no lo.nger occur* without the proper evaluation and approval.
A procedure re~i~ion has been initiated to indorporate these water tight hatches into Abnormal Operating Procedure (AOP)
Wind 1.
This revision will be completed by October 1990.
This event will be forwarded to the Nuclear Training Center for inclusion in the Continuing/Operating Experience.Training Program PSE&G is in full compliance~
Page 2 of 6*
Sf P 2 1 1990
- 2.
10.CFR 50, Appendix B Criterion XVI requires that.conditions adverse to quality, such as defective material and equipment, be promptly identified and corrected.
Updated UFSAR Section 17. 2*. 16 states that the station general manager is responsible for assuring that conditions
. adverse to quality are identified and corrected for all activities involving station-operations, maintenance, testing, refueling, and modification.
Administrative Procedures that govern station activities covered by the QA program provide for timely discovery and correction of nonconformances.
Contrary to the above, as of April 9, 1990, water tight doors between the service water valve rooms and *the surrounding areas of the auxiliary building had not been adequately maintained in that the door la_tching dogs required to be operated to make the door closure water tight were unmovable.. from their undogged position when reasonable force was applied.
This condition had not been promptly identified and corrected.
PSE&G does not dispute the violation.
ROOT CAUSE The root cause of his event has been attributed to lack of knowledge by plant personnel regarding the FSAR requirements of the watertight doors.
This lack of knowledge is exemplified by the fact that there were neither corrective maintenance work orders identified nor preventive maintenance tasks specified for maintenance of this equipment.
CORRECTIVE ACTIONS TAKEN All water tight doors specified in the FSAR, including those required by Abnormal Operating Procedures (AOP), were inspected, adjusted and re-gasketed to bring _them to an acceptable condition.
In addition, to increase awareness of the FSAR requirements in this area the General Manager -
S~lem Operations has issued a letter to all station personnel detailing this violation and the importance of Water Tight Doors and Hatches to the physical plant.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE PSE&G has initiated recurring tasks to perform_periodic maintenance inspections of these doors (PM Task Form #9063).
PSE&G Maintenance Department has initiated a request for new PM procedures.
These procedures will be in place prior to the performance of the inspections.
These inspections will.be performed in accordance with the frequency established by the Reliability Centered Maintenance (RCM) program.
Page 3 of 6
iJ S£p 2 1 1**
This event will be forwarded to the Nuclear Training Center for inclusion in the Continuing/Operating Experience Training Program
- PSE&G is in full compliance.*
- 3.
Salem Nuclear. Generating Station Unit 2 Technical Specifications, Section* 6.8.1, requires that written procedures be established, implemented, and maintained for various plant activities, including those recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
As of April 27, 1990, the following examples of failure to follow written procedures were identified:
- a.
-Administrative Procedure AP-9, "Work Control Process,"
Revision 1, Section 5.1.5.b, requires that, when.
performing a task which requires a written procedure, the prc;icedure shall be present and followed step-by-step (unless deviation is permitted in the body of the procedure) while the task is* being performed.
Further the licensee's "Written Instruction Use Standard" part of the Salem Handbook of Standards, dated August 14, 1989, requires step-by-step and sign-off of procedures categorized as "Category 1" instructions.
Contrary to the above, work on valve 22BF19 performed using procedure IC14.1.058, "BF-19 Maintenance procedure," Revision o, which was* categorized as a "Category 1 11 instruction was completed without step-by-step sign-offs having been performed.
- b.
Procedure M14A-2, "General Instructions for Bolted Globe, Stop, and Stopcheck, Plug and Piston Valve Maintenance," Revision 2, Step 7.3 requires that thread engagement for bolted fasteners be a minimum of one thread past the nut.
Contrary to the above, feedwater control valve actuator diaphragms for valves.21BF19 and 23BF19 incorporated several bolts that did not extend past the ~ut.
- c.
Administrative Procedure AP-15, "Station Tagging Program," Revision 5, Section 6.1 requires that red
.blocking tags be removed only by authorized Operations Department personnel.
AP-15, in Section 6. 8,. *further prohibits operation of equipment tagged with a red biocking tag until the tag has been properly released and removed.
Contrary to the above, valve *21MS81 *had been cut from the associated piping system while red tagged by blocking clearance #057385 without being properly released
- a_nd removed.
- Page 4 of 6
- i 41J
- d.
Piping Specification No. S-C-MPOO-MGS-001 for Piping Schedule SPS27, "Service, Fresh and Salt Water,"
Revision 2, requires that copper alloy-to-steel dissimilar metal flange joints be installed with Maloney Standard Flange insulation style E-N-D-W 1/8 inch thick or appro~ed equal.
SEP 2 1 \\1!0 Contrary to the above, Maloney isolating washers kits were not_ installed in several.bolt holes in dissimilar metal flange joints in the service water system during reassembly of the joints under DCP No. 2SC2018 and work orders 890914164, 891026108, 90030911, 89102611 arid 900319121.
PSE&G does not dispute the violation.
ROOT CAUSE*
The root cause of these events, has been attributed to lack of attention of detail by contractor individuals performing these activities.
CORRECTIVE ACTIONS TAKEN
- a.
During the performance of procedure IC14.1.058 on valve 22BF19, contract technician did not complete step-by-step sign-offs.during the progress of the job as required by the "Written Instructions Use Guidelines" and AP-9.
Maintenance and Contractor supervision reviewed the Handbook of Standards and the use of category 1 procedures with all the I&C contractor personnel emphasizing the need for compliance with procedures and standards.
b..
Inadequate thread engagement on the 21BF19 and 23BF19 feedwater control valve actuator diaphragms was caused by poor work practices in the past.
PSE&G was unable to determine when those studs were installed.
The condition was corrected when identified.
PSE&G will continue to monitor work practices and enforce the established work standards.
- c.
The red tag for valve 21MS81 was found on the floor in the Unit 2 North Penetration area.
The valve in question had been removed from the system.
Subsequent investigation could not determine whether the tag was in place during demolition or if it had fallen off sometime prior.
PSE&G supervision personnel responsible for the demolition performed a walk-down of the affected system prior to start of work and did not observe the tag in place.
- However, personnel involved in the demolition work were counseled and-reminded of the importan9e of red blocking tags.
Page 5 of 6
SEP 2 1 1RJ-
- d.
During the time of the Maintenance Team Inspection, work was in progress on DCP 2SC-2018.
It is a common practice to temporarily install piping for fit-up and measuring of the other pieces of pipe.
The insulation washer kits may not be
- installed until the final installation of the piping.
All insulating washers were in place when the work order was completed and signed off on May 18, 1990.
PSE&G's Work standards familiarization training is provided to -
all contractor personnel before they are allowed to work on site~
The training emphasizes PSE&G policy of procedure compliance.
PSE&G views these events as isolated cases where contractor personnel failed to adhere to PSE&G's work standards of attention to detail and procedure compliance.
During the course of the follow-up investigation of these events, the importance of strict procedure compliance was stressed to all supervision and specifically to those contractors involved. -
All personnel,including contractor personnel, receive training on the significance of red blocking tags in General Employee Training '(GET).
Contractor supervisors and foremen are trained in AP-15, "Station Tagging Program".
The Salem Maintenance Administrative Procedure (SC.MD-AP.ZZ-0005), "Control of Contractor Work" and E&PB procedure (DE-CS.ZZ-0031) "E&PB Contractor Site Qualification and Training" have recently been revised to clarify and strengthen-the required training on Salem Work Standards and Station Tagging Program.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE PSE&G will continue, as it has done in the past, to enforce procedure compliance with contractor personnel as well as PSE&G employees.
PSE&G is confident that adequate administrative procedures are in place to provide assurance that the contractors are trained and knowledgeable about station procedures and standards.
PSE&G is in full-compliance.
Page 6 of 6