ML18102A704
| ML18102A704 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/26/1996 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N96427, NUDOCS 9701020131 | |
| Download: ML18102A704 (11) | |
Text
Public Service Electric and Gas Company Louis F. Storz Public Service Electric an~te~mSa19gB P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N96427 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NRC NOTICE OF VIOLATION INTEGRATED INSPECTION REPORTS 50-272/96-13 1 50-311/96-13 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Inspection Report Nos. 50-272/96-13 and 50-311/96-13 for Salem Nuclear Generating Station Units Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G) on December 3, 1996..
Within the scope of this report, two violations of NRC requirements were cited.
PSE&G management has recognized problems associated with procedure usage.
These problems have manifested themselves as inconsistent identification of conditions adverse to quality through the corrective action program, and procedure adherence.
PSE&G developed a plan and put forward initiatives to combat these issues.
The plan to address these issues was for management to set and communicate expectations, to provide the necessary training and to effect the cultural change needed to be successful.
Expectations have been set and communicated, and managers and supervisors have been trained in the positive discipline process to uroperly enforce these expectations.
The issue fundamentally remains as one of personal accountability.
These initiatives remain valid; however, effecting cultural change is a methodical process, and PSE&G remains committed to the successful implementation of its plan.
In accordance with 10CFR2.201, PSE&G is submitting its response to these violations. contains the violations as cited by NRC, and Attachment 2 contains PSE&G's response to the violations.
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Document Control Desk LR-N96427 2 -
Should there be any questions regarding this submittal, please contact us.
Sincerely,
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Attachment (2) 95-4933
Document Control Desk LR-N96427 3 -
I 1.
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c Mr. Hubert J. Miller, Administrator -
Region I U. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 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 (S09)
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-N96427 EHV/
DEC 2 6 1996 3 -
BC CNO & President - Nuclear Business Unit (N09)
Senior Vice President - Nuclear Engineering (N19)
Senior Vice President - Nuclear Operations (X04)
Director - Nuclear Business Support (NlO)
Director - QA/Nuclear Safety Review (XOl)
Director - Nuclear System Engineering (X07)
General Manager - Nuclear Operations Services (XlO)
General Manager - Salem Operations (S05)
General Manager - Hope Creek Operations (H07)
Manager - Nuclear Safety Review (N38)
Manager - External Affairs (N28)
Manager - Licensing & Regulation (X09)
Onsite Safety Review Engineer - Salem (X15)
Onsite Safety Review Engineer - Hope Creek (Hll)
General Solicitor, E. J. Selover (Newark, 5G)
Perry Robinson, Esq.
Records Management (N21)
Microfilm Copy File Nos. 1.2.1, 3.1 (Comb Jnsp Report 50-272/96-13; 50-311/96-13)
LR-N96427 Attachment I APPENDIX A
NOTICE OF VIOLATION Public Service Electric and Gas Company Salem Nuclear Generating Station Units 1 and 2 Docket Nos: 50-272 50-311 License Nos: DPR-70 DPR-75 During an NRC inspection conducted on August 12, 1996, to September 20,1996, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR so, Appendix B, criterion v, requires, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
Contrary to the above, on or before September 20, 1996, the NRC identified the following two examples where activities affecting quality were not accomplished in accordance with the applicable plant procedure.
- 1.
Nuclear Procedure NC.NA-AP.ZZ-0006(Q), Revision 13, Corrective Action Program, Step 4.3, and Nuclear Procedure NC.NA-AP.ZZ-OOOO(Q), Revision o, Action Request Process, Step 4.1 require that conditions adverse to quality be identified and documented on an Action Request.
During the installation of the boron injection tank discharge pressure transmitter (2PT912) sensing line, an unqualified cable termination, discovered in an application requiring a qualified termination, was corrected but not documented on an Action Request in accordance with the plant procedure.
1
LR-N96427 Attachment I
- 2.
Nuclear Procedure NC.NA-AP.ZZ-0059(Q), Revision 4, 10 CFR 50.59 Applicability Reviews and Safety Evaluations, Section 5.4, Revisions, requires review and approval of changes made to a safety evaluation, unless the change is typographical or editorial.
Changes that were neither typographical or editorial in nature, were made to Safety Evaluation S96-037 without review and approval in accordance with plant procedure.
This is a Severity Level IV violation (Supplement I).
B.
Technical Specification Section 4.0.5 requires that in-service inspection of ASME Code Class 1,2 and 3 be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.
ASME Section XI, 1974 throughout the 1975 Summer Addenda Table IWB-2500, Examination Category B-D,
- requires that all nozzles be ~xamined during the first inspection interval.
Contrary to the above, the in-service inspections were not performed in accordance with ASME Section XI in that the in-service inspection of the Unit 2 pressurizer spray nozzle was not completed during the first inspection interval that ended May 1992.
This is a Severity Level IV violation (Supplement I).
2
LR-N96427 Attachment II
- 1.
Nuclear Procedure NC.NA-AP.ZZ-0006(Q), Revision 13, Corrective Action Program, Step 4.3, and Nuclear Procedure NC.NA-AP.ZZ-OOOO(Q), Revision o, Action Request Process, Step 4.1 require that conditions adverse to quality be identified and documented on an Action Request.
During the installation of the boron injection tank discharge pressure transmitter (2PT942) sensing line, an unqualified cable termination, discovered in an application requiring a qualified termination, was corrected but not documented on an Action Request in accordance with the plant procedure.
PSE&G concurs with the violation.
(1)
The reason for the violation.
The root cause of failing to initiate a condition report was attributed to personnel error.
During development of DCP 2EC-3560 it was noted that the termination of 2PT942 transmitter intq panel 215-2 was not environmentally qualified for HELB conditions.
The discrepancy was discovered by drawing review and confirmed by.performing a field walkdown.
This condition was outside the original DCP scope.
Engineering expanded the DCP scope and corrected the condition during DCP development.
However, they did not generate an Action Request (AR) as required by NC.NA-AP.ZZ-0006(Q)
"Corrective Action Program."
(2)
The corrective steps that have been taken.
- 1.
The termination of 2PT942 transmitter into panel 215-2 was corrected to be environmentally qualified for HELB conditions.
Additionally, a corrective action was added to the original AR (960507302} to describe and document the actions taken to resolve the termination of 2PT942.
- 2.
AR 960820102 was generated to address similar condition in Salem Unit 1 and to review for other.transmitter circuitry, for both units, that could be exposed to effects of HELB conditions.
1
LR-N96427 Attachment II
- 3.
The instrumentation in the inner mechanical penetration area susceptible to the effects of a HELB will be capable of performing their safety function when required.
- 4.
A review of the.Managed Maintenance Information System (MMIS) database sort by location and component showed that there* were no other transmitters or instrument panel located in this room.
- 5.
Personnel involved with the occurrence were held accountable for their actions in accordance with PSE&G disciplinary policy.
(3)
The corrective steps that will be taken to avoid further violations.
- 1.
The corrective actions associated with AR 960820102 for Salem Unit 1 will be completed prior to Unit 1 entering Mode 4.
See response to number 2 below.
(4)
The date when full compliance will be achieved.
See response to number 2 below
- 2
LR-N96427 Attachment II
- 2.
Nuclear Procedure NC.NA-AP.ZZ-0059(Q), Revision 4, 10 CFR 50.59 Applicability Reviews and Safety Evaluations, Section 5.4, Revisions, requires review and approval of changes made to a safety evaluation, unless the change is typographical or editorial.
Changes that were neither typographical or editorial in nature, were made to Safety Evaluation S96-037 without review and approval in accordance with the plant procedure.
PSE&G concurs with the violation.
(1)
The reason for the violation.
The root cause of this violation was attributed to inadequate knowledge.
Safety evaluation S96-037 was written to support a modification to the Fuel Handling Area Ventilation System.
During the closeout review of the modification it was noted that the YES box was checked when answering whether or not a Technical Specif.ication change was required.
However, the explanation provided to justify the YES answer clearly stated that the Technical Specification Bases were being changed.
As the evaluation was not being changed, it was thought that the revision was made within the requirements of NC.NA~AP.ZZ-0059{Q)
"10CFR50.59 Applicability Reviews and Safety Evaluations."
(2)
The corrective steps that have been taken.
- 1.
The safety evaluation was brought back to the Station Operating Review Commitment for their acknowledgement.
(3)
The corrective steps that will be taken to avoid further violations.
- 1.
Lesson learned from these events will be incorporated in the operating experience feedback program, and evaluated for inclusion in the Engineering Support Personnel training program.
No further corrective actions are required.
(4)
The date when full compliance will be achieved.
PSE&G achieved full compliance when AR 960820102 was initiated, and the change to safety evaluation S96-037 was represented to SORC.
3 I!I,I.
I I'
LR-N96427 Attachment II B.
Technical Specification Section 4.0.5 requires that in-service inspection of ASME Code Class 1,2 and 3 be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda.
ASME Section XI, 1974 throughout the 1975 Summer Addenda Table IWB-2500, Examination category B-D, requires that all nozzles be examined during the first inspection interval.
Contrary to the above, the in-service inspections were not performed in accordance with ASME Section XI in that the in-service inspection of the Unit 2 pressuri~er spray nozzle was not completed during the first inspection interval that ended May 1992.
This is a Severity Level IV violation {Supplement I).
PSE&G concurs with the violation.
(1)
The reason for the violation.
The root cause was of the missed technical specification violation was attributed to insufficient administrative controls of the previous PC (personal computer) data input, and review.
In August 19, 1996, it was determined that the first interval Inservice Inspection {!SI) for the Pressurizer Spray Nozzle inner radius had not been performed.
Although the computer database indicated satisfactory completion of the surveillance, the data could not be located.
The weld inspection portion of the !SI 10 year interval was maintained by an outside contractor.
(2)
The corrective steps that have been taken.
- 1.
PSE&G conducted a satisfactory visual inspection of the spray nozzle, and completed the required Technical Specification surveillance.
- 2.
The Salem Unit 2 10 year IS! required welds were satisfactory reviewed to ensure no other welds were missed.
- 3.
The missed technical specification surveillance was reported to NRC via Licensee Event Report 311/96-010 on September 18, 1996.
4
LR-N96427 Attachment II (3)
The corrective steps that will be taken to avoid further violations.
- 1.
PSE&G now has in-house control all 10 year ISI program information, including updates of the ISI long term plan.
Additionally, the current PC database has inherent program controls linking completed NOE examinations with exam schedule updates and final reports.
(4]
The date when full compliance will be achieved.
PSE&G achieved full compliance on October 2, 1996, when the required technical specification surveillance was completed.
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