ML20070V125
| ML20070V125 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/03/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N91052, NUDOCS 9104110003 | |
| Download: ML20070V125 (3) | |
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Stanley LaBruna Pubhc SeMce Dectoc and Gos Company P.O Don 236. Hancocks DNdge NJ 08030 609 330-1200 a
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1 United States Nuclear Regulatory Commission Document Control Desk 3
Washington, DC 20555 t
Gentlement RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-354/90-23 I
DOCKET NO. 50-354 HOPE CREEK GENERATING STATION 2
Public Service Electric and Gas Company (PSE&G) is in receipt of
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your letter, dated March 5, 1991, which transmitted a Hotice of Violation citing a failure to comply with requirements of 10 CRT 50, Appendix B, criterion XVI.
Pursuant to the provisions of 10 Cr3 2.201, our response to the Notice of Violation is provided in 4.ttachment 1.
Sincerely,
,dbh
/1%v Attachment 3
C Mr. S. Dembek USNRC Licensing Project Manager-I Mr. T. P. Johnson USNRC Senior Resident Inspector i
Mr. T. T. Martin, Administrator USNRC Region I Mr. K. Tosch, Chief Bureau of Nuclear Engineering New Jersey Department of Environmental Protection i
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9104110003 910403 1/\\\\\\.
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NLR-91052 ATTAQiMENT 1 10 CFR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/90-23 DESCRIPTION OF VIOLATION 334/90-23-01 10 CFR 50, Appendix B, criterion XVI states, in part, that:
" Measures shall be established to assure that conditions adverse to quality, such.as... defective material... are promptly identified and corrected... and corrective actions taken to preclude recurrence."
Contrary to the above, on October 3, 1990, Hope Creek identified the existence of non-EQ components for the source range monitors and intermediate range monitors (SRM/IRM) detector electrical connectors.
Non-EQ components for the SRM/IRM detector electrical connectors had been idontified by the NRC in an inspection performed on August 9, 1985.
Failure to document this data at that time resulted in the installation of the non-EQ components.
This was documented in LER-90-021-00.
PSE4G'S RESPONSE Although all SRM/IRM connectors were changed to the correct EQ matorial subsequent to the NRC inspection in 1985, all supporting documentation was not corrected.
Therefore, PSEtG does not dispute Violation 354/90-23-01 and.has taken the following corrective actions to correct the discrepancy:
A.
CORRECTIVE ACTIONS:
The Operations Engineer briefed all licensed operators on the inoperability of the SRMs and IRMs, and directed all licensed operators to immediately shutdown the reactor (manual scram) in the event an operating scenario (ie. power reduction to less than 4% reactor power) arose that would have required use of the SRMs or IRMs.
A Justification for Continued Operation, including safety evaluation, was prepared and approved which allowed Hope Creek to remain in operation with-the inoperable SRMs and IRMs.
Workorders were initiated for the inspection of all SRM/IFut connectors and scheduled for completion during the first forced or planned outage.
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i NLR-H91052 ATTACHMENT 1 On November 4, 1990, Hope Creek entered a forced outage during which, all SRM/IRN connectors were restored to proper EQ status.
This work was performed in accordance with PSE&G's Design Change Package (DCP) program.
B.
CORRECTIVE ACTIONS TO PREVENT RECURRENCE All conflicting documentation associated with the SRM/IRM connectors was identified and corrected through implementation of the DCP process.
During the. interim prior to DCP close out, field personnel.were instructed to confirm all part numbers on components associated with GE supplied instrumentation through System Engineering.
The controls supervisor responsible for maintenance of the SRM/IRM dersctors received counselling which stressed the need for early identification and resolution of engineering discrepancias and the need for strict adherence to procedures.
The Mainte'ance Manager reviewed this incident with all maintenance department supervisors, and communicated his expectations with regards to identification and resolution of problems such as those related to this issue.
Since the time-that the non-EQ parts were installed in the SRMs and IRMs, an Engineering. representative within the station has been assigned a full time position with the express purpose of EQ Program implementation. - This position is responsible for performing detailed research and providing direction pertaining to parts identification and qualification.
PSE&G is now in compliance on this issue.
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