ML18096A938
| ML18096A938 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/28/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92131, NUDOCS 9209040041 | |
| Download: ML18096A938 (5) | |
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Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O, Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nyclear Operations AUG 2 8 1992 NLR-N92131 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-272/92-11 & 50-311/92-11 CONTROL OF MEASUREMENT AND TEST EQUIPMENT SALEM GENERATING STATION
. UNITS 1 & 2 DOCKET NOS. 50-272 & 50-311 Public Service Electric and Gas (PSE&G) hereby transmits its response to the Notice of Violation as requested in your transmittal letter dated July 30, 1992. to this letter contains the NRC's Notice of*
Violation, as described in.Appendix A of the subject Inspection Report and PSE&G's response to the violation.
Should you have any questions-in regard to th~s letter, do not hesitate to call.
,_Attachment ( 1) 9209040041 920828 PDR ADOCK 05000272 G
PDR Sincerely,
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Document Control Desk NLR-N92131 c
Mr. J. c. Stone Licensing Project Manager - Salem Mr. T. P. Johnson Senior Resident Inspector Mr. T. T. Martin Administrator -
Region 1 Mr. Kent Tosch AUG 2 8 1992 Chief -
New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
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NLR-N92131 ATTACHMENT 1 During a NRC inspection conducted from July 6-9, 1992, a violation of NRC requirements was identified~
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions", 10CFR Part 2, Appendix C (1992), the following violation is listed below:
Technical Specification 6.8.1 requires written procedures shall pe established, implemented and maintained covering applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33.
Regulatory Guide 1.33, includes administrative procedures *.
Nuclear Department Procedure NC.NA-AP.ZZ-0022(Q), Rev.* 1, Measurement and.Test Equipment (M&TE), and Tool Controi (NAP-22),
- step 5.1.4.a, requires "M&TE shall be returned to the applicable Tool room immediately* after completion of the WO or task for which it was signed out, or after a perioq of seven day(s):
whichever comes first."
Contrary to the above, on July 9, 1992, ten pieces of M&TE were identified which had been signed out for a period in excess of seven days.
Additionally, two of four pieces of M&TE identified as used on specific work orders were not logged out for those work orders.
This is a Severity Level IV violation (Supplement I).
PSE&G'S RESPONSE Nuclear Department Procedure NC.NA-AP.ZZ-0022(Q), Rev. 1, Measurement and Test Equipment (M&TE), and Tool control (NAP-22),
requires in part that "M&TE shall be returned to the applicable Tool room immediately after completion of the WO or task for which it was signed out, or after a period of seven day: whichever comes first.....
M&TE may be signed out for extended periods of time when specifically authorized by the Tool Room Supervisor or M&TE Coordinator".
PSE&G agrees that the procedural requirements concerning the return of M&TE, as specified in st~p 5.1.4.a of NAP-22, were not followed, in that some of the M&TE was not returned within seven days and/or the Tool. Room supervisor was not made aware of the need to issue the M&TE as long term issue.
The seven day requirement to return M&TE was included in NAP-22 solely to improve M&TE availability.
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J NLR-N92131 Although the seven day requirement may be overly restrictive with regard to the control of;M&TE, PSE&G does not accept-procedure non compliance as an alternative or substitute for a poor, inadequate, or overly restrictive procedure.
Given these considerations PSE&G believes that the safety significance of these findings is minimal.
At this time PSE&G would like to clarify some apparent misunderstandings and/or typographical errors in your inspection report.
- 1.
The inspection report cites_ failure to identify, in the M&TE log sheet, the Work Order in which the M&TE was used.
NAP-22 does not require that a piece of M&TE, when issued, be logged out to a specific Work Order.
The mechanism used to link M&TE to specific work activities is the electronic work order system.
NC.NA-AP.ZZ-0009(Q) Rev. 4, "Work Control Process," requires that specific data be recorded to identify the M&TE equipment used to perform a work activity on the electronic work order.
Therefore, the Work Order number was not logged for two pieces of M&TE, as described in the subject inspection report, because it was not required by procedure NAP-22.
Specific data was recorded via the electronic work order system* to link the pieces of M&TE to the work activities on which they were used.
PSE&G believes that this example does not constitute a violation of Technical Specification 6.8.1.
- 2.
Uncontaminated (clean) M&TE is issued from the M&TE Tool Room "col_d sh9p 11 in the Auxiliary Building.
If during the performance of the work it becomes contaminated it will be returned to the contaminated tool room "hot shop" in the RCA.
SA-MNT-0923 was logged out on 6/14/92 as stated in the inspection report, however it was returned to the Hot (contaminated) Shop on 6/15/92, within the procedural time requirement.
- 3.
The inspection report lists SA-SM-0122 as having been issued to WO # 910503173.
SA-SM-0122 is not a valid PSE&G M&TE designator.
SA-STR-0122 is a valid M&TE designator and it was not issued at the time of-the inspection.
SA-STR-0128 was issued from the hot shop to WO # 910503173 on 6/11/92 and returned to the hot shop on 6/12/92, within the procedural time requirement.
CORRECTIVE ACTIONS TAKEN A review was conducted to ensure that any piece of the identified M&TE was not used, if out of calibration, to-perform maintenance or repairs on plant equipment.
No evidence was found to indicate that identified M&TE was used beyond its calibration due date.
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NLR-N92131 All pieces of M&TE discussed in the inspection report were.
verified to have been returned to the tool room or retired from service, if appropriate.
Two micrometers (SA-STR-0171 and SA-STR-0040) could not be located.
Evaluation of their usage, in accordance with NAP-22,* is in progress.
- The personnel involved in this incident were not aware of the requirement to sign M&TE out for extended periods, if it could not be returned in seven days.
The Salem Maintenance* Manager and the Manager - Nuclear Engineering Projects have issued memoranda to all maintenance and engineering project personnel describing this incident, re-emphasizing the importance of procedural compliance, and the employees' responsibilities with respect to usage, storage, and return of M&TE as required by NAP-22.
The M&TE logs at: the "cold shop", "hot shop" and central shop (used by contractor personnel) are being audited to identify any other pieces of M&TE, which may have been issued and not. -returned within seven days.
Any piece of M&TE identified as being out for greater than seven days, will be recalled or reissued as a long term issuance, as appropriate.
This audit is*expected to be completed by October 15,
- 1992.
A procedure revision to NAP-22 has beeri drafted and is being reviewed.
This proposed revision includes general procedural enhancements, as well as a review and assessment of the seven day requirement relative to the control and handling of M&TE.
The procedure revision is expected to be completed and approved by October 15, 1992.
PSE&G has confidence that the administrative and procedural controls on the calibration requirements for M&TE provide significant assurance that the M&TE used on plant equipment is calibrated.
PSE&G will be in full compliance by October 15, 1992.
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