ML18096A303
| ML18096A303 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/01/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N91162, NUDOCS 9110100229 | |
| Download: ML18096A303 (9) | |
Text
Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 080.38 609-339-4800 Vice Pre~ident - Nuclear Operations c
OCT o 1 1991 NLR-N91162 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/91-16 AND 50-311/91-16 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas (PSE&G) has received the Inspection Report dated August 20, 1991.
As a result of delays in PSE&G receiving this report, a September 30, 1991, due date was obtained through the NRC Residents Office.
Within the scope of this report, one apparent violation of NRC requirements was identified.
Pursuant to the requirements of 10 CFR 2.201, PSE&G. hereby submits its response to the notice of violation (Attachment 1).
Additionally in Attachment 2, PSE&G addresses the NRC's concerns as discussed in paragraphs 1.0 and 2.0 of the aforementioned report.
Should you have any questions in regard to this transmittal, do not hesitate to call.
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Sincerely, J L(J 11 I
Document Control Desk NLR-N91162 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 OCT o t 1991
NLR-N91162 ATTACHMENT 1 During an NRC inspection conducted on May 20 - 24, 1991, a violation of NRC requirements was identified.
In_ accordance with the "General Statement of *Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1991), the violation is listed pelow:
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 fpr timely discovery and correction of nonconformances.
Contrary to the above, as of May 21, 1991, watertight doors for the service water valve rooms and the surrounding areas of the auxiliary building had not been adequately maintained i-n that some of the door latching dogs required to be operated to make the door closure watertight were inoperable from their undogged position when reasonable force was applied.
This condition had not been promptly identified and corrected.
The condition further indicates inadequate corrective action in that a similar condition was previously identified during an inspection on April 9, 1990
- PSE&G RESPONSE As a result of the previous NRC findings (April 9, 1990) PSE&G took adequate immediate corrective action to bring the watertight doors to an acceptable condition.
However, in May 1991, the NRC identi_fied that some watertight door latching dogs required unreasonable force to operate.
Although Operations Department procedure required the service water valve room watertight doors to be closed with two latching dogs engaged, no justification for this requirement could be identified. In light of the established
- requirements, plant personnel failed to identify or document that some of the latching dogs were difficult to operate. It is PSE&G's expectation that all its employees and contractors promptly identify conditions adverse to quality so that prompt corrective actions can be taken.
Since these doors are used ori a daily basis by plant personnel, unreasonable force should not have been needed to properly operate them.
The Nuclear Department Administrative Procedure, NC.NA-AP.ZZ-OQ09(Q), Work Control Process, clearly defines the responsibilities and requirements of station personnel in the identification of deficient conditions via the work order system.
PSE&G agrees that a violation of 10 CFR 50, Appendix B, Criterion XVI occurred in that the deficient condition, of some of the watertight door latching dogs, was not properly identified and corrected
- ROOT CAUSE The root cause of the violation has been attributed to inadequate procedural guidance of watertight door latching requirements to plant personnel.
CORRECTIVE ACTIONS TAKEN When notified by the inspector that unreasonable force was required to operate the watertight door latching dogs, the dogs were loosened and tested to verify proper operation.
The General Manager - Salem Operations has issued a letter to all station personnel emphasizing: a) The need to promptly identify to management deficient conditions using existing-procedures, and b) The need to have the service water valve room watertight doors closed at all times, with all the dogs latched.
Exception to this rule will only be allowed when the doors are being used for entry/exit, or when personnel are working inside the valve room area.
The Operations Department primary equipment operator log sheet (OD-26) will be revised to require that the service water valve room watertight doors be verified closed with all latching dogs engaged.
A system engineer, recently added to the* Technical Department, has been assigned responsibility and ownership of the watertight doors and hatch~s.
Operations Department will label the service water valve room watertight doors as being required to be maintained closed with
- all latching dogs engaged.
This labeling will be controlled in
_accordance with NC.NA-AP.ZZ-0044(Q), Operating Guides.
This labeling will be completed by October 31, 1991.
In October of 1990, the Reliability Centered Maintenance (RCM) established a PM inspection for watertight doors to be performed at an _18 month frequency.
This frequency will be revised to 12 months.
The result of PM inspections will be used to determine the most effective PM frequency.
The recurring task will be issued in October 1991 after the PM procedure (SC.MD-PM.ZZ-0036) is completed.
The Maintenance Department has labeled all watertight doors with component ID numbers and their inspection will begin upon issuance of the PM procedure.
The inspection of those doors required for watertight integrity will be completed by December 31, 1991.
CORRECTIVE AcTIONS TAKEN TO PREVENT RECURRENCE P~E&G believes that the corrective actions discussed above will ensure that the watertight closure requirements are clearly understood by plant personnel, and when coupled with present administrative procedures and the established PM inspection, will provide sufficient monitoring to adequately prevent the possibility of recurrence.
PSE&G IS IN FULL COMPLIANCE
NLR-N91162 ATTACHMENT 2 In April 1990, a Maintenance Team Inspection (MTI) was conducted.
PSE&G responded to the MTI findings via letters dated September
- 21; 1990 and October 10, 1990 (reference NLR-N90185 and
- NLR-N90203 respectively).
During the MTI follow up inspection, the NRC identified some apparent discrepancies and concerns with respect to PSE&G's response.
PSE&G appreciates having the opportunity to clarify some of the NRC's concerns as stated in paragraph 1.0 and 2.0 of Inspection Report Nos. 272/91-16 and 311/91-16.
NRC Concern Regarding the Watertight Hatches In the September 21, 1990 Notice of Violation response, PSE&G provided the following corrective actions relative to the water tight hatch discrepancies:
- 1. The watertight hatches were replaced,
- 2. A 10 CFR 50.59 review was completed,
- 3. Stenciled signs were placed on the hatches, and
- 4. Procedure AOP Wind 1 would be revised by October 1990 During this inspection the NRC found items 1 and 2 to have been completed satisfactorily.
However, some concerns were raised regarding items 3 and 4.
Regarding item 3, the inspector did not find stenciled signs on the hatches of either unit, instead he discovered a portion of an engraved pl&stic sign on Unit 2 and no sign at all on unit 1.
Regarding item 4, the procedure had not been revised, as committed to in the Notice of Violation response, and in addition the inspector questioned the overall management of commitments.
PSE&G Response To Item 3 Concern During the Salem Unit 1 Ninth Refueling Outage, a substantial amount of work was conducted in the service water valve room with the service water pipe replacement.
To facilitate the handling and installation of the new piping, the hatch covers and watertight hatches were removed.
Upon completion of this work and re-installation of the watertight hatches and hatch covers, the signs were inadvertently omitted from the new hatch covers.
On Salem Unit 2, a portion of the the sign became detached and lost; the remaining portion could be seen attached to the hatch cover.
The hatches were not stenciled as committed but rather were labeled with engraved plastic signs.
At the time, it was believed that the plastic signs met the intent of the commitment made to stencil the hatches.
New signs have since been stencilled around the hatch covers and a memorandum from the Maintenance Manager has been issued to all maintenance personnel reemphasizing the importance of component labeling and the need to ensure that labels be maintained and or returned to a legible condition after any maintenance activity.
The Maintenance Department will inspect these lab.els as part* of the PM to ensure that they remain legible.
PSE&G Response To Item 4 concern PSE&G committed to rev.ise procedure AOP Wind 1 in the Notice of
- Violation Response.
This commitment was not entered into PSE&G's Action Tracking System (ATS) and therefore was not tracked to ensure that it was completed as committed.
During this inspection, when it became apparent that the AOP*wind 1 procedure revision had not been entered into ATS, a search of the tracking system was performed.
With the'NRC Inspector present, all Salem violation response commitments (since the MTI) were verified to be properly tracked in ATS.
An ATS item was opened to revis~ procedure AOP Wind 1, and the procedure revision was completed and approved on May 23, 1991.
The Action Tracking System has been in use for approximately four (4) years.
The ATS is controlled by a Nuclear Department Procedure, NC.NA-AP.ZZ-0057(Q).. This procedure defines the responsibilities for the establishment and implementation of the automated tracking system for both internal and external commitments.
There are a number of mechanisms by which management is kept aware of commitments and their due dates.
The Nuclear Licensing and Regulation Department distributes a monthly report to management identifying all open docketed regulatory commitments (NRC) and their due dates.
Station management generates a similar ~eport on a monthly basis, which is.discussed at the Management Accountability Meetings.
The Quality Assurance (QA) Department is performing a verification that NRC commitments, docketed over the past two years, are properly being tracked in ATS.
This verification is expected to be completed 'by December 1991.
Additionally, by December 31, 1991, Station QA will verify, by sample, that corrective actions which closed NRC commitments, in the past two*
years, are still in place.
PSE&G believes that an adequate program exists to assure that management is kept aware of outstanding commitments.
NRC Concern Regarding the Watertight Doors In the September 21, 1990 response to the Notice of Violation, PSE&G provided the following corrective actions relative to the watertight doors:
- 1. As prompt corrective actions the watertight doors were inspected and regasketed to bring them to acceptable conditions, and
- 2. As long term corrective actions, PSE&G committed to implement a Preventive Maintenance (PM) program to maintain the watertight doors.at a frequency to be determined by the Reliability Centered Maintenance (RCM) program.
The inspector determined that either the corrective actions taken in 1990 had not corrected (in total) the conditions cited in the original violation or if the corrective actions taken in 1990 had fixed the deficient watertight door condition, then the condition that existed in May 21, 1991 was not promptly identified.and corrected.
The inspector further questioned why no interim PM program had been initiated to ensure watertight door operability, including an engineering evaluation that would permit less than all the latching dogs to be operable.
The inspection report further stated that the only PM action taken to date, was the task to develop the PM procedure.*
PSE&G's Response to NRC's Concern As stated in the violation response (Attachment 1 of this letter), PSE&G believes that the immediate corrective actions, taken in 1990 to correct the deficient condition of the watertight doors, were adequate.
The violation response further amplifies PSE&G's assessment of why the deficient condition of the latching dogs existed on May 21, 1991.
Concerning the watertight door PM, the Reliability Centered Maintenance Group established a PM frequency of 18 months for the watertight doors on October 8, 1990.
The work instruction, describing the inspection to be performed as part of this PM, was approved on April 8, 1991.
The next required PM, as established by the RCM group, would be scheduled in early 1992 or 18 months from the time that watertight doors were originally regasketed and inspected.
As discussed in the violatiori response (Attachment 1 of this letter) the PM frequency will be revised to 12 months.
In addition to establishing the inspection frequency, an inspection procedure was also to be developed.
At the time of the follow-up inspection (May 1991), PSE&G informed the inspector that this inspection procedure would be issued in September 1991.
Presently, this procedure will not be issued until October 1991.
Waiting until October 1991, to complete the inspection procedure, would not have delayed the original PM schedule nor will it delay the new schedule.
PSE&G believes that the establishment of an interim PM program to inspe_ct these doors, as -discussed in the subject Inspection Report, is not warranted in light of the established program for corrective maintenance as described in NC.NA-AP.ZZ-0009(Q), Work Control Process.
Presently PSE&G does not have an evaluation determining the minimum number of latching dogs needed to secure the service water valve room watertight doors.
Until such an evaluation is completed, PSE&G will require that all latching dogs be engaged to secure the service water valve room watertight doors.
NRC Concern Regarding the Reliability Centered Maintenance As stated in our response of October 10, 1990, reference NLR-N90203, PSE&G stated that the Reliability Centered Maintenance (RCM) had completed the review of 12 systems and that data bases existed for them.
This statements appears to be in contradiction with the NRC finding as stated in Inspection Report 272/91-16, ".. only 10 systems were completed as of May 13, 1991.. 11
- PSE&G Response to NRC's Concern PSE&G believes that this apparent contradiction resides in the defini.tion and or interpretation of "system".
When the RCM reviews systems to identify critical components, it freqriently combines like plant systems into one RCM analysis system.
For example, when the review of the steam generator feed and condensate was completed in 1989, it was classified as one (1)
"RCM _system analysis" although four (4) plant systems were reviewed (2 system per unit).
A review of the RCM system analysis status report from the August 16, 1991, Preventive Maintenance Improvement Project Monthly Report, indicates that as of today nine (9) RCM system analyses have been completed.
However, if the same report is reviewed for the number of plant systems, then seventeen (17) plant systems would have been counted.
Therefore, as of the end of 1990, 12 plant systems (8 RCM system analyses) were completed.
Within the context of the October 10, 1990 response, PSE&G was accurate, however, PSE&G realizes that it should have differentiated between "plant" systems and "RCM analysis" system.