ML18101B129
| ML18101B129 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/06/1995 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N95214, NUDOCS 9512130173 | |
| Download: ML18101B129 (9) | |
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- Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N95214 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/95-17, 50-311/95-17 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 DEC 0 6 1995 NRC Safety Inspection Report Nos. 50-272/95-17 and 50-311/95-17 for Salem Nuclear Generating Station Unit Nos. 1 and 2 were transmitted to Public Service Electric & Gas Company (PSE&G) on November 6, 1995.
Within the scope of this report, a violation of NRC requirements was cited.
Pursuant to the provisions of 10CFR2.201, PSE&G submits its response to the aforementioned violation in Attachment 1 to this letter.
Should there be any questions regarding this submittal, please do not hesitate to contact us.
Sincerely, Attachment
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9512130173 951206 PDR ADDCK 05000272 g
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- Document Control Desk LR-N95214 C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 DEC 0 6 1995 Mr. L. N. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall - Salem (X24)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
Document Control Desk LR-N95214 NOTICE OF VIOLATION During an NRC inspection conducted on August 13, 1995 to October 14, 1995 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, the violation is listed below:
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1. 33 requires that ma*intenance that can affect the performance of safety related equipment be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
- 1.
- 2.
- 3.
Nuclea_r Administrative Procedure NC.NA-AP. ZZ-0015 (Q), Safety Tagging Program, step 5.3.2.D requires that, when reinstalling a draw-out type breaker into a cubicle, maintenance personnel should reinstall the red blocking tag on the racking device handle.
Contrary to the above, on September 25, 1995, maintenance personnel reinstalled a draw-out type breaker into a cubicle, but failed to reinstall the red blocking tags on the racking device handle.
Salem and Hope Creek procedure NC.NA-AP.ZZ-0009, Work Control Process, step 5.7.1.d requires that individuals perform work in accordance with the work package.
Contrary to the above, on August 14, 1995, maintenance contractors performed service water pipe installation that was not in accordance with lEC-3323, No. 11 Service Water Header Piping Replacement.
On September 14, 1995, site services performed service water pump installation activities that were not in accordance with SC.MD-EU.SW-0002, Johnston Service Water Pump Removal and Installation.
Salem maintenance procedure SC.MD-PM.SW-0007, Disassembly, Inspection and Reassembly of C&S Butterfly Valve, step 5.1.1 requires verification of all prerequisites prior to starting the job.
Contrary to the above, on August 17, 1995, maintenance started the disassembly of a service water butterfly valve without completing the required prerequisites.
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- Document Control Desk LR-N95214 NOTICE OF VIOLATION (cont'd)
- 4.
Salem procedure NC.NA-AP.ZZ-0023, Scaffolding and Transient Loads Control, requires that scaffolding in safety related areas have adequate clearances, cross-braces, restraints, and variance approval.
Contrary to the above, on August 17, 1995, scaffolding erected in the vicinity of an operable service water nuclear header did not have the required clearance, cross-braces, restraints, or variance approval.
This is a Severity Level IV violation (Supplement I).
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- Document Control Desk LR-N95214 REASON FOR THE VIOLATION PSE&G does not dispute the violation.
When the conditions adverse to quality described in the Notice of Violation (NOV) were identified, Salem station management acted promptly to reinforce their work control expectations and to establish better control of the activities.
These actions included work stoppage until it could be assured that these activities would be carried out safely and in accordance with PSE&G programs.
Salem management affected stand downs and took several outage days to reinforce safety work standards, procedure compliance, and scaffold and rigging requirements before it allowed work to proceed.
PSE&G management recognizes that, in the past, it has taken similar actions with limited short-lived results.
What is different this time is that some of the stop-work actions were not initiated by management but by first line supervision, including the Senior Nuclear Shift Supervisor (SNSS).
These stop-work actions indicate that Operations is taking ownership for "their" plant and raising the standards of performance for Salem workers.
These actions are fully supported by the Nuclear Business Unit (NBU) management team.
The "apparent" root cause of the conditions adverse to quality are repetitive failures of personnel not following approved procedures.
PSE&G recognizes that this apparent root cause is only a symptom of a programmatic deficiency within our work control process.
In accordance with the NBU Corrective Action Program (CAP), a root cause analysis was performed to identify the programmatic root cause(s), contributing causal factors, and corrective actions.
The root causes of this violation have been attributed to:
- 1.
Less-than-adequate communication of management expectations relative to procedure compliance.
- 2.
Less-than-adequate management oversight of maintenance activities.
Significant contributing causal factors identified were:
a)
Inadequate contractor training and qualification.
b)
Inadequate performance standards.
Document Control Desk LR-N95214 DESCRIPTION OF EVENTS -
CORRECTIVE ACTIONS TAKEN Example 1 On September 25, 1995, during the restoration of the lE 460V bus following completion of the preventive maintenance of the 460V switchgear breaker cubicle, the red blocking tag for one of the breakers was found in the wrong location.
The electricians performing this activity mistakingly switched tags after returning the breaker to its cubicle. This is contrary to the requirements of Nuclear Administrative Procedure NC.NA-AP.ZZ-0015 (Q), Safety Tagging Program.
Specifically, step 5.3.2.D requires that, when reinstalling a draw-out type breaker into a cubicle, maintenance personnel should reinstall the red blocking tag on the racking device handle.
On September 25, 1995, the Operations Manager stopped tagging evolutions at Salem, and on September 27, a team of Salem personnel and a contractor with expertise in root cause analysis evaluated the tagging problems and recommended changes to the tagging program.
NC.NA-AP.ZZ-0015(Q), Safety Tagging Program, was revised to clarify tagging requirements for breakers and to restrict authorized movements of red blocking tags to Operations personnel only.
Appropriate personnel involved in this incident were counseled about procedure compliance.
Example 2 On August 14, 1995, personnel were installing new replacement piping on the No. 11 Service Water (SW) header under Section 8~5.5 of DCP lEC-3323, Large Bore SW Pipe Replacement Program.
This DCP section contained a NOTE prohibiting the start of pipe installation prior to the return of the valves from refurbishment.
The NOTE was followed by an Engineering hold point to ensure that the valves would not be fit-up or installed without the proper verification that the valves were refurbished and inspected.
On September 14, 1995, site services personnel were installing No. 26 SW pump.
During the installation personnel performed a step out of sequence, did not sign-off a completed step, and installed a pump coupling for which the serial numbers did not match.
Subsequently workers replaced it with the right coupling without a work order activity.
Document Control Desk LR-N95214 Procedure SC.MD-EU.SW-0002, Johnston Service Water Pump Removal and Installation, is a category two procedure.
Category two procedures need to be at the job site and frequently consulted to ensure that activities are performed in accordance with procedures.
Although these errors were not detrimental to the pump maintenance activity, the procedure use was not in accordance with PSE&G expectations.
On August 14, 1995, DCP lEC-3323 work activities relative to pipe installation were suspended until an appropriate modification change request (MCR) could be issued.
On August 15, 1995, an MCR to lEC-3323 was approved and issued.
The current Johnston pump installation procedure is being reviewed to determine its adequacy and appropriate changes will be implemented on completion of review.
Appropriate personnel involved in this incident were counseled about procedure compliance.
Example 3 On August 17, 1995, personnel were removing the spool piece between service water valves 1SW457 and 1SW458 to support the removal of these valves for refurbishment.
Upon review of the package it was noted that the pre-requisites of Salem maintenance procedure SC.MD-PM.SW-0007, Disassembly, Inspection and Reassembly of C&S Butterfly Valve, had not been completed.
Step 5.1.1 requires verification of all prerequisites.prior to starting the job.
On August 17, 1995, a stop-work order relative to the NRC Generic Letter (GL) 89-13 work scope was issued.
An assessment was conducted and appropriate corrective actions taken to address procedure compliance.
Additional supervision was assigned to the GL 89-13 project.
Contractor personnel received training on all appropriate procedures, including maintenance procedures applicable to the GL 89-13 work scope.
Workers reinstalled the spool piece and installed a blank flange in the No. 1 Service Water to preclude flooding of multiple bays.
Appropriate personnel involved in this incident were counseled about procedure compliance.
Document Control Desk LR-N95214 Example 4 On August 8, 1995, scaffold had been constructed to support the removal and refurbishment of the service water valves. The scaffold was built with less than 4 inches clearance from a service water cross-tie header without an engineering variance.
This is contrary to the requirements of Salem procedure NC.NA-AP.ZZ-0023, Scaffolding and Transient Loads Control.
A scaffold variation request was initiated and approved by Engineering on August 17, 1995.
On August 21, 1995 a station wide stand down was implemented by management and key programmatic elements and expectations were reviewed with all Salem assigned contractor and PSE&G personnel.
Safety meetings were conducted with the contractor personnel regarding procedural compliance, pre-job briefs and rigging requirements.
Appropriate personnel involved in this incident were counseled about procedure compliance.
On October 31, 1995, the Chief Nuclear Officer Team issued a letter detailing Senior Management's expectations of strict procedure adherence by all NBU employees, including the consequences of not following these approved procedures.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE As part of the Salem Restart Plan, the NBU will conduct a series of assessments to affirm the readiness of the plant, people and processes to support a successful restart and safe and reliable operation.
Each department will affirm restart readiness in accordance with the Operational Readiness Self Assessment Program.
This will be presented to the Management Review Committee (MRC).
The MRC will perform a collegiate review of these assessments and, if appropriate, will recommend approval of the plan to NBU Senior Management.
In support of this plan, the Salem Maintenance Department has developed a Restart Action Plan.
Some of the needed actions identified to support the successful restart of the Salem Units are:
- 1.
Establish standards and expectations for the conduct of maintenance and establish accountability for adherence to those standards and expectations.
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- Document Control Desk LR-N95214 2.
Establish clear lines of authority and accountability to assist with the development of maintenance personnel and communicate internal and external to the department. *
- 3.
Review and revise, as appropriate, maintenance department program and procedures for control of contractors and non-station personnel.
- 4.
Establish accountable maintenance oversight and coverage of non-station personal performing maintenance activities.
- 5.
Establish objectives for continuing maintenance self-assessment in accordance with station assessment programs.
These actions will be completed prior to unit restart.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PSE&G was in full compliance with the requirements of Technical Specification 6.8.1 at the time these conditions were identified and corrected as stated in the Description of Events - Corrective Actions Taken section.