ML18096A145

Provides Response to Notice of Violations Re NRC Insp Repts 50-272/91-80 & 50-311/91-80.Corrective Action:Supervisor & Engineer Involved in Incident Counseled on Importance of Attention to Detail & Questioning Attitude

ML18096A145
Person / Time
Site:	Salem
Issue date:	07/12/1991
From:	Crimmins T Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N91117, NUDOCS 9107220152
Download: ML18096A145 (7)

Text

Public Service Electric and Gas Company Thomas M. Crimmins, Jr. Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4700 Vice President - Nuclear Engineering JUL i 2 1991 NLR-N91117 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATIONS NRC INSPECTION REPORT NOS. 50-272/91-80 AND 50-311/91-80 SALEM GENERATING STATION UNITS NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas {PSE&G) has received the Inspection Report dated June 13, 1991. Within the scope of this inspection, two apparent violations of NRC requirements were identified. The first violation involved the issuance of the Emergency Diesel Generator {EOG) Load study without performing any design verification for verifying or checking the adequacy of EDG loading. The second violation involved a failure to follow the procedures established to identify and correct engineering discrepancies.

Pursuant to the requirements of 10 CFR 2.201, PSE&G hereby submits its response to the notice of violations.

Should you have any questions in regard to this transmittal, do not hesitate to call.

Sincerely,

~lu~J Attachment 9107220152 910712 EDR ADOCK 05000272

~ PDR

JUL 1 2 1991 Document Control Desk 2 NLR-N91117 c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 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

REF: NLR-N91117 STATE OF NEW JERSEY SS.

COUNTY OF SALEM T. M. Crimmins, Jr., being duly sworn according to law deposes and says:

I am Vice President - Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated JUL 1 2 1991 , concerning the Salem Generating Station, Unit Nos. 1 and 2, are true to the best

~ of my knowledge, information and belief.

Subscribed and Sworn to before me this day of 1991 EL~BETH J. KIDD Notary Public of New Jersey My Commission Expires April 25, 1995 My Commission expires on ~~t~~~j~=~~~,~/~2~S-=--~~~~~~~-

NLR-N91117 ATTACHMENT As a result of the inspection conducted on April 15-26, 1991, and in accordance with "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C (Enforcement Policy), the following violations were identified:

Violation 1 10 CFR 50,,Appendix B, Criterion III, requires, in part, that design control measures provide for verifying or checking the adequacy of design.

Updated Final Safety Analysis (UFSAR), Section 17.2.3, "Design Control," states that design verification is performed for verifying or checking the adequacy of design.

Public Service Electric and Gas Company, Procedure DE-AP.ZZ-OOlO(Q), "Design Verification," Revision o, requires that the design verification be performed for verifying or checking the adequacy of design.

Contrary to the above, on April 15, 1991, the Salem Units 1 and 2, Emergency Diesel Generator Load Calculation, S-C-4KV-EDC-0650, Revision o, was issued without performing any design verification for verifying or checking the adequacy of emergency diesel generators (EDG) loading. Consequently, the calculation contained several discrepancies such as the failure to consider pump runout conditions, cable losses and equipment kW ratings which were not conservatively factored to determine the worst case loading on the EDG.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOI.ATION.

The root cause for the failure to independently verify the Emergency Diesel Generator Load Calculation is attributed to personnel error in the failure to follow an established procedure. The engineer and supervisor, responsible for issuing the EDG Load Study as a design base calculation, incorrectly assumed that the EDG Load Study had already received independent design verification.

The original EDG load study was performed by a vendor under contract to PSE&G. PSE&G accepted this study in December of 1988, entered it into the document control system and classified it as a Public Service Blue Print (PSBP), vendor document.

Following PSE&G procedures, PSBPs do not require independent verification prior to acceptance from the vendor. In January of 1991, portions of this load study were issued as EDG Load Calculation S-C-4KV-EDC-0650, Revision o, in the form of a design base calculation. This document should have received an' independent design verification prior to issuance as a design

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base calculation, as required by DE-AP.ZZ-OOlO(Q). The engineer who originated the EOG Load Calculation S-C-4KV-EDC-0650 and the supervisor who approved the document had assumed that independent design verification requirements had been met within the original PSBP. Due to the constant supervision by PSE&G Engineering of the vendor's data input and load programs, and peer review of the vendor's documentation before acceptance into the EOG Load study, it was assumed that the requirements of Independent Design Verification had been met.

CORRECTIVE ACTIONS TAKEN The supervisor and engineer involved in this incident have been counseled on the importance of attention to detail and a questioning attitude.

The Engineering Department is performing a complete line by line peer review of EOG Load Calculation, S-C-4KV-EDC-0650, Revision

o. Following this peer review, a complete design verification of the calculation will be independently performed by the Engineering Department. This independent design verification, which includes confirmation and/or reassessment of assumptions, sequencing, and load bases, will be complete by December 31, 1991.

It should be noted that in July of 1989, PSE&G internally questioned the use of Brake Horse Power versus Pump Runout Conditions, in the EDG Load Study, and the assumptions used to form the basis for the calculations. Discrepancy Evaluation DES-90-01489 was issued, in accordance with PSE&G procedure DE-AP.ZZ-0018(Q), to address these concerns. Immediate analysis of the DEF addressing worst case assumptions concluded that neither a safety nor operability concern existed. The Engineering Department determined in October of 1990, that a detailed calculation revision was necessary to resolve this discrepancy. PSE&G was in the process of performing the calculation revision when the NRC conducted this inspection.

During the interim, PSE&G has complete confidence, through preliminary operability and safety reviews built into the evaluation cycle of the discrepancy process, that the diesel generators are configured within the ratings specified by the manufacturer.

CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE This incident of an issuance of a design calculation without proper Independent Design Verification is an isolated case.

Verification that all other electrical calculations were properly issued using Procedure DE-AP.ZZ-OOlO(Q) has been confirmed by our Electrical Engineering Department's review, as of June 28, 1991.

The Engineering Department will be conducting further counseling of the entire functional engineering staff, emphasizing the requirements for design verification, and will review this incident during these counseling sessions.

PSE&G will be in full compliance on De.cember 31, 1991.

Violation 2 10 CFR 50, Appendix B, Criterion XVI, requires in part that measures be established to assure that conditions adverse to quality, such as deficiencies, deviations, and nonconformances are promptly.identified and corrected.

UFSAR, Section 17.2.16, "Corrective Action," states that administrative procedures provide for the timely discovery and correction of nonconformances.

Public Service Electric and Gas Company, Procedure DE-AP.ZZ-0018(Q), "Engineering Discrepancy Control" requires that potential engineering discrepancies be identified on an Discrepancy Evaluation Form to make an initial safety assessment.

Contrary to the above, a known design discrepancy of underrated fuse applications in the 125 Vdc system was not formally identified and corrected in accordance with the established procedures for correcting engineering discrepancies.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION.

Failure to initiate a proper Discrepancy Evaluation Form (DEF)' in accordance with PSE&G procedure DE-AP.ZZ-0018(Q) is attributed to personnel error.

As a result of the Salem Unit 2 Trip in August of 1986, PSE&G initiated various engineering calculations to address electrical distribution system adequacy concerns identified during the review of this event. In response to one specific draft calculation for Appendix R breaker coordination issues and NRC comments relative to this calculation. PSE&G performed Safety Evaluation S-C-M200-NSE-0709-1 in October of 1987. This Safety Evaluation verified that no nuclear safety or operability concerns existed requiring immediate action. The engineering calculation, whose draft version initiated the previously discussed Safety Evaluation, was not completed and issued until January 4, 1989. In the process of performing this calculation the underrated fuse concern was identified. This concern was tracked, by PSE&G Engineering, and addressed through the performance of an Engineering Evaluation in November of 1988, prior to the completion and issuance of the calculation discussed above. PSE&G's procedure DE-AP.ZZ-0018(Q), "Engineering

Discrepancy Control," was initially developed and implemented during this time frame. A Deficiency Report should have been written when the calculation identified the underrated fuse concern. Although the Deficiency Report was not generated the underrrated fuse concern was tracked and properly evaluated.

As a result of the calculations and evaluations performed, the fuses were slated for replacement in the Salem Unit 2 6th refueling and the Salem Unit 1 10th refueling outage.

CORRECTIVE ACTIONS TAKEN Further analysis, discussions and correspondence with Bussmann, the vendor supplying the fuses, has concluded that the interrupting rating for the subject fuses is actually 50,000 amps. This is acceptable for the application of the fuses, since the maximum possible short circuit current is slightly lower than 25,000 amps. A determination will be made for the replacement of the fuses upon revision of the engineering calculation. PSE&G is in the process of updating the necessary documentation and will complete this task by October 31, 1991.

CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE All Functional Engineering personnel will be counseled on the discrepancy evaluation procedure with an emphasis placed on non-conformances. This counselling will also include a review of the above incident.

PSE&G will be in full compliance on October 31, 1991.