ML20086A517
| ML20086A517 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/08/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N91189, NUDOCS 9111190193 | |
| Download: ML20086A517 (12) | |
Text
f:
Pubhc Service Electric and Gas Company Otanley LaBruna Pubhc Service Electric and Gas Company P.O. Box 036. Hancocks Brdge, NJ 08038 609-339-1200
_ V.ce Prmwi-Nudev Operabons NOV C8 M91 NLR-N91189 United States Nuclear Regulatory Commission Document' Control Desk Washington, DC-20555 Gentlemen:
REPLY TO A NOTICE OF VIOLATION AND A NOTICE OF DEVIATION INSPECTION REPORT NO. 50-354/91-80 HOPE CREEX GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO.-50-354-Pursuant to the provisions of 10CFR2.201, this letter submits the response of Public Service Electric and Gas Company to the notice of violation and the notice of deviation issued to the Hope Creek Generating Station on October 10, 1991.. The violations and the
-deviation cited in the October 10,_1991 letter were' identified
-during an inspection conducted between July 15 and 19, 1991.
An enforcement conference was held at the Region I offices in King of-Prussia on September 9, 1991 to discuss the violations and the deviation.
As required by the notice of violation and 10CFR2.201, this response includes the reason =for the violations and deviation, the cotcoctiOe steps that have_been taken and the results achieved,-the-corrective steps that willibe taken to avoid-
- further violations or deviations, the date when full compliance-will be achieved.(violations only), and the date when corrective actions will be complete (deviation only).
This information is provided in-the attachment-to this letter.
Should you-have-any. questions or comments on this transmittal,-do
_'not hesitate to contact us, sincerely,
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Attachment
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311 g961bg 911108 fY gas AnocK0000$4 l
. Document Control Desk 2
NOV 0 8 1991 NLR-N91189 C
Mr. S.
Dembek Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, Administrator
-Region I i
Mr. Kent Tosch, Chief i
New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 I
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i REF: N LR-N91189 STATE OF NEW JERSEY
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SS.
COUNTY OF SALEM
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Stanley LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.
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Subscribed and Sworn to before me this 7
day of Nd%wlk/, 1991 c 6dbmt9
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NotdyPublicofNewbersey SUZANNii V. PHILLIPS NyaN P;Sc of Me s ey My Cctamission expires on
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9 ATTK31MENP REELY 10 A NOTIG OF VIOIA170N INSPECPIM RERRP NO. 50-354/91-80 HOPE GEEK GENERATING STKPICH FANTJYY ORl RATING LIONSE NPF-57 ID3ET 10. 50-354 NIR-N91189 I.
INIPODUCTION Durirg an NRC inspection conductal between July 15 ard Atgust 13, 1991, the NRC evaluated our prtxJram to ensure the reliability of motor operated valves
(}Ols) at the Hope Creek Generating Station ard our response to Generic letter 10 ard its supplements. This letter responds to the two resultirg violations ard the one deviation cited in an October 10, 1991 letter frcan the
- NRC.
II.
REPLY 10 NCrTICE OF VIOIATION In accortlance with the " General' Statement of Policy'and Pmoedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the followirg L..
violations of NRC requirements wtre fdentified:
A.
Tomue Switch Settira Violation (10CFR50.59)
L 1.
Description of Violation "10 CER 50.59(b)(1) requires,_ in part, that the licensee shall maintain records of charges in the facility to the extent that they constitute changes to the facility as described in the safety R
analysis report, incitding a written safety evaluation which provides
~the basis for the determination that the change does not involve'an-unreviewed safety question.
l L
Cbntrary to the above, as of July 19, 1991, the licensee did not maintain a written safety evaluation of certain charges _ to the facility, as described in the. safety analysis report, to confirm that the changes did not involve an unreviewed safety question.
Specifically, the charge involved the torque switches of certain safety-related }OVs being set higher than the setpoints specified by l
-the supplier.
(For exanple, (1) the closing setpoint for the torque -
i switch on RCIC outboard valve FC-V002 (HV-F008) was set at 2 ard 3/8 (indicated on the valve data sheet), which is above the limit of 2 ard 1/4 specified by the manufacturer--(Limitorque); ard (2) the closing set point for the torque switch on RCIC inboard valve FC-V001 l_
(HV-F007) was set at 2 and 3/4, while the maximum specified by the l
manufacturer was 2 aid 1/4.)
This is a Severity Level IV violation (Supplement 1)."
Page 1 of 9
Attachmer't NLR-N91189 Reply to Notico of Violation 2a _Bttronse to ViolatigD PSl%G does not dicpute the violation.
p.
Root Cause in the citcd caans, evaluations had been performod khich incitdcd system orgineer apprvval of th darno ard comurrence with the charge frun Limitorque ard the valve mnufacturur; however, neither the evaltution procesa nor the Limitorque or valve mnufacturur concurren:es were adoquately documnted. The imot cat:se of this event has bocn attribated to inadcquate procedures ard poor jtdgemont of the personnel involvcd. The inadequate proordures involved the fact that past prootdural controls failed to adoquately ack1 rem hmntation rcquirencnts.
LUnrrective Actions ard Perults Achievcd 7he follcuiry corrective actioru hav; n canpleted or are in progress.
(1) We have completed a revicM of 11 ope crock post-startup mintenance reconis to identify similar occurrences. This review has identificd 13 valves with limiter pit.tes removou.
(2) The 13 identified occurrerra have boon (Ecunented on Discrepancy D/aluation Forms (DEF) and are beirq evaluated urder the Dyirocring Discrepancy Evaluation proccas. This process includes an initial operability screenirg, prioritization of the DEF hascd on the vupent's safety significarce as it relates to core damago frequency via IBA, ard ovaluation in light of Lhttitorque Maintotunce Update 89-1.
Our initial operability screen W arn prioritization based on safety significanct has bocn capleto:1 for each of the 13 identified occurrences. The initial screenity ard evaluations performed to date have shcun that there is no safety significance for the removal of limiter plates on the st.bjcet valves.
(3l We are in the process of cwpletirg a revics of pre-startup minterance reconis for Mcpe Creek to identify any similar occurrunTs. This revics will be completal by November 15, 1991.
(4) A review of Salem records to identify any similar occurrencca at Salem was recently capletal.
(5) A walkdown will be corducted at Salem to proeide verification for valvas whose status cannot be definitively detenttined based on the reconis review. This walkdcun will be caplettd durirq the next refuelity outage at eads of the units cince the subject valves are imocessible while the plant is at power. If limiter plates are discovend to be missing or if Paae 2 of 9
Attochtent liLR-1191189 Hoply to fiotico of Violation switches are fourd to be set higher thoi the analyzal muimma value, a deficiency repott (01) will bo initiatal an$
pmoecrat as ditmeccd in cormctivo Action c. (1).
(6) All occurrunces idu.cified by Conwtivo Actions (3) ard (4) will receive an initial operability m:reeniin ard prioritization based on safety significanoe by Drn
- r 15, 1991.
(7) A 10CITt50.59 Inview and an engineerirg evaluatical will tu perfonned for each DEF identified by Cbnwtivo Actions (1),
(3), and (4) based cri the priority as detemined by safety significanoo.
It is expected that these reviews ard evaluations for the DElt screened and prioritizcd as of 11ovember 8,1991 (the 25 DEFs notal bolcw) will be canpleted by June 30, 1992. Reviews for all of the subject DEPs will j
be cartpleted prior to startup frun the next ilope Crock refuellig outage.
7ho status of the 10CFR50.59 cvaluations for the DEPs screened ard prioritized as of liovember 8,1991 is as followat o
'Iho Engincering Assesstent Group (FE) has rcrocnod ard prioritized 11 of the DEPs received frm Salcu ard 14 of the DEPs received frm 110p0 Crock, o
The DEFs screened by FM have been prioritized as follows:
Innodiato Action (require resolution within 30 days):
o 1 Salem DEF ard 1 llope Creek DEF 13 car Tem Action (requiro resolution within 90 days):
o 2 Salem DEFs ard 1 llope Creek DEF Iorg Term Action (require recolution by the cxmpletion of the next schedulcd refuelirn outago for the affected unit, khore practicable):
o 8 Salam DEFs ard 12 Ilope Creek DEFs o
7ho o
.a Crock immediato action DEF covers the two valves identi. ' xi by the ICtc in the violaticn) (IN-F007 and IIV-F008, 1ho ergineerirG evaluation ard the 10CFR 50.59 review ha. ' been performtd for these valves, o
'Ihe Salem immt. %to action DEF has been evaluated and has received a 10CFRh, %9 evaluation.
o Two of the throo near tenn action DEFs (ono Salem DEF and one !!opo Crock DEF) will have been evaluated and received Page 3 of 9
Attoch30nt NLR-N91189 Reply to Notice of Violation 10Cm50.59 evaluations by Novemeber 15, 1991.
o The runining Salem near tarn action EP was just ruoently identified. This DEF will be evaluated and a 10CIR50.59 evalaution will be perforund by Novester 30, 1991.
p.
Corrective ActiargLtg Prevent Recurrence
'Iho following corrective action has been ompleted.
It is felt that this action will prevent the recurrence of this or any similar violation.
(1) llope Cmek Maintenance Procedum IIC.MD GP.ZZ 031(Q),
"Limitorque Valve Operator Limit Switd1 Adjustments", ard Salem Maintenance Procedure SC.MD-EU.ZZ-0009(Q), " Motor Operated Valve Analysis and 7bst Systan (ItWATS) Daeeline 7bstirg", have been zwvised to reouire that a deficiency Itport (IR) be initiated and proc.> Ad to allow setting torque switdies above analyzed muman values..The DR process requires that 10CFR50.59 reviews and evaluatlerts be prepared in accortlance with Nuclear Department procedures and will ensure that those evaluations are prtperly hW.
LDate When Full Omoliance Will Be Achieved Full empliance will be achieved een our docunentation reviews described in Corrective Actions b.(3) and b.(4) are emplete and all of the resultirq DEFs, includirq the original 13 DErs identified in carrective Acd 'on b. (2), have been evaluated and have received 10Cm50.59 eva.tuations.
It is expec. ed that this t
will bo acomplinhed by June 30, 1992 for those NFs screened and prioritized as of November 8,1991. For those DEFs not screened and prioritized as of November 8,1991, an irdtial screening for operability and safety significanoe will be performed as irdicated in Corrective Action b.(6). 7he required 10Cm50.59 evaluations will be scheduled based on safety significance. All of the DEFs identified by Corrective Actions b. (1), b. (3), and
- b. (4) are e.xpected to have received a 10Cm50.59 evaluation prior to startup frcan the next Hope Creek refueling outage.
.B. Ven: lor Doctment Proctram Violation 1.
Doocription of Violation "1bchnical Specification 6.8.1.a ruquires, in part, that written procedures be established, inplemented, and maintainod coverirg the activities referenced in Appendix A of 1kgulatory Guide 1.33, Pavision 2, Febntary 1978.
Page 4 of 9 u
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Attcch=nt NLR-N91189 Reply to Notice of Violation Section 1.h of Arperdix A of Rogulatory Guido 2.33 requires, in part, administrative procodures for the tuview of pitcodures.
Alministrative Proceduru NC.NA-AP ZZ-0054(Q), Revision 0, states, in part, in Soction 1.0, that tM purpace of the procodure is to assure that 1ccoons loamod frun the ruview preocos of both intermi and exterml operating expericrue informtion are effectively utilized to inprovo plant safety ard reliability. Section 5.2.1.a of the proocduru requirus that the sp;nsor departnant shall review external ruports and scrTen the informtion to detemino the significarro ard applicability to the stations ant /or the support departments, as well as the patential impact on procedures. Section 5.2.5 requires that the responsible department evaluation results rhall be hentcd ard includo corrective actions, such as charges to prucodures.
Contrary to the above, as of July 19, 1991, spccific external operating technical information pruvided in Limitorque Raintemnoo Updates 89-01, "Riximum 'Ibrque Switch Settims," ard 90-01, "ltydraulic Lock," conoemi g itNs, had not been adequately evaluated to determino the potential inpact on mintenanos procedures, ard to assure appropriate corrective actions were talra to irrorporate that technical informtion into the procodures. Spocifically, maintemnoa procedures had not boon updated tor (1) ensure that MN torque switches aru not set above the analyzed mxinum valuo, ard (2) provido ingoct.lon nothods ard corrective actions to detect ard corruct the potential prublems discunstd in the todinical information.
'Ihis is a Severity level IV violation (Supplement 1)."
2.
Recronse to ViolatiQD IEE&G does not dispute the violation.
a.
Root Causg
'Ihe root cause of this event has been attributed to the following:
(1) Inadoquate training was a major contributirg factor as evidereed by the unfamiliarity on the part of some ISE&G personnel with " elements" of the Verdor Document contrul Iwgram. Specifically, personnel not normlly in the " mainstream" of the Verdor Document l:
Control Prograla did not urderstard their responsibility l
reganiing the in-processiry of docurrents received directly i
from vendors.
(2) Lack of clear understardirg by Limitorque ard MOVATS of the PSE&G Vendor rment Control Program ard their rusponsibilities regardirg points-of-contact for correspondence.
Page 5 of 9
Attcchm:nt NLR-N91189 Reply to Notice of Violation b.
Oormctive Actions Taken ard Results Achiev14 The followirg correctivo actions have boon ocupleted or are in progress.
(1) All documents ruquestal by the lac durire the ingxction which were not retrievable thrush our systan have since been obtainod ard in-processed to our Verdor Lbcument Cbntml Systan ard are currently urdorgoirg detailed evaluation, our evaluations will be canpleted by rw,,Wr 15, 1991.
(2) Limitorque ard ICVA75, as directed by IGl%G, have modified their mailing list to conform with our Vendor Contact Program.
(3) Actions have been taken or are in progress to ad.i'ess the infomation contained in the subject Limitorgm. a:::uments.
These actioi.s include the following:
(1) liopo Crook Maintenanoo Proceduru HC.MD-GP.ZZ-031(Q),
"Limitorquo Valve operator Limit Switch Adjustments",
ard Salem thintemnoo Proceduru SC.MD-111.ZZ-0009(Q),
" Motor Opeated Valve Amlysis ard Test System (! OVA 7S)
Baselino Testirg", have been revised to reqJtitu that a deficiency report (CR) be initiated aM processed to allow settiry torque switches above analyzed maximum values. Should such a situation arise, theco IEs will be evaluated in light of Lbnitorque Maintenanoo Update 89-1 ard other technical considerations.
(ii) Revision of applicable llopo Creek maintemnce procedures have been initiattd to provide inspoction methods ard corrective actions to detect ard correct potential problens diccussed in Limitorque Maintenance Updates 89-1 and 90-1.
These revisions will be cxmpleted by D % r 31, 1991.
(iii) Revision of applicablo Salem maintemroe procedures, if required, will bo initiated to adiruss the rumendations resultity frm our evaluation of Linitorque Maintenance Updates 89-1 and 90-1.
These revisions, if required, will be canpleted by Dacamber 31, 1991.
c.
Corrective Actions to Prevent Recurrengg The followiry corrective actions have bocn completed or are in progress.
It is felt that these actions will prevent the recurrence of this or any similar violation.
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I Attcch=nt NLR-N91189 Reply to Notico of Violation (1) A samlirg of other verdors to assuru receipt of all thwats issued to IEl%G Ins bocn ca@leted. We contactal 10% of our verdors ard requestal thorn to identify docuents provided to us durisy the last two ycars. We were able to retrievo 100% of the identified documents thrugh our verdor docunent control system.
(2) A letter ins bocn issued, under Vice Presidential signature, to all PSE&G Nuclear Department Personnel reiteratirg the imortarce of and their resporwibility to the Vendor tecument control Policy, Program ard Procodurus.
(3) All Vendor Docunent Control Program Procedures will be reviewod to ensure clarity ard determine acklitional areas for potential improvanent. As part of this review, PSE&G will address procedural conristency ard identification of prtp2r responsibilitics, authoritics arxi interfaces. m is action will be capleted by November 29, 1991.
(4) 20 process for validatirg ard reconcilirn vendor-supplicd document distribution lists will be fonnalized; this will provido confirmation upon receipt of documents t.ransmitted by verdors. mis action will be oorpleted by November 29, 1991.
(5) An evaluation will bo conducted to conpare PSE&G's programs to those of other utilities that have been recognized by I!HO as having excellent Verdor Infonnation Control Programs.
mis action will be ampleted by Novanter 29, 1991.
Enhanoaments, if reglred, wiu be incorporated.
(6) Oversight will be pruvided to the Verdor Contact Program via periodic QA Audits ard Surveillances of the vendors. mis will ensuro that: 1) verdors participating in our program are maintaining naility arxl document distribution lists as requested, ard 2) verdorn not participatirg in our program are spot-checked for downts which have been transntitted.
(7) Periodic effectiveness reviews of our Verdor Ibcument Control Programs will in corducted.
(8) Trainirg needs will be evaluated and additloral trainirg programs implemented as required, no evaluation will be emplettd by January 31, 1992, ard any trainity programs identified as boiry required will be initiated by April 15, 1992.
(9) Prior to the inspection, on turch 8,1991 ard June 12, 1991, PSE&G issued letters to vendors for the purpose of clarifyirq document transalttal requirenents ard PSE&G contacts.
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i Attcchnent 141J1-1191189 I
Iloply to !{otico of Violation d2_ D214LMlWLD111_gmpliance Will no Adilevid Ib11 ompliarra will be adtievcd Men ruvisions to pruoodures are emplete as noted in Corrective Actions b. (3)(ii) ard b. (3)(111).
'Ihose proceduru rwisicns will be ampletal and full conplianco will therefore be adtieved by Dcomber 31, 1991.
IIJdgl'LY 'IO IUI' ICE OF DDljAT32 In accordance with the "conoral statement of Iblicy and Proceduru for lac Enforument Actions," 10 ClR Part 2, Appealix C (1991), the followirg devit ; ion was identificxt:
A.
lW ProcinNL(Vaitnent DevintlOD L_._DJNrlI2t1911_Qi_IETiat19D "Public service Electric ard Gas campany (1Y;E&G) letter (li!R-1190179) dated August 31, 1990, in tusponso to filC Generic Intter (GL) 89-10,
" Safety-Italatrd Motor-operatal Valve 'Ibstirg ard Surveillanoo,"
statal:
"A notu detailed CL 89-10 program description will be available on sito January 1,1991 in acconlance with Supplomont 2 to GL 89-10. "
Contrary to the above, as of July 19,1991, the GL 89-10 program deceription was not fonnally entablirdal as ocanittal to in the abwe licennoo letter.
'Ihis in a deviation."
24__.EWP2IreQ_t9_.IXNiati2D IM&G does not dicpute the deviation.
Ih _ ECot Caugg
'Iho ruot cause of this avont has been attrilxital to the followirg:
(1) One ruot cause of the deviation was a failure to recognize ard address the over-ocmnitrents on our valvo engincorirq Insourocs in a tinely mnnor. Tim over-comitments resulted in a ten nonth slip in schedulo primrily due to turnover of
):cy paroonnel ard allocation of rcratrces to other significant issues.
Page 8 of 9
,9 Attcch=nt NLR-N91189 Reply to Notice of Violation i
I (2) A second root cause was failure to utilize our monitoring Nx1 l
oantrol process for tracking Generic letter 09-10 program i
description ocmaitments. Had this ocessitment been properly tracked, an alternative means of alertiry managem nt to the
- approaciting canonitment would have existed and am v iate action would have been initiated.
1 I
b.
Corrective Actions Taken and Results Actileved The follcwing corrective action has been canpleted.
1 (1) A motor operated valve program description which meets the intent of Generic Ictter 89-10 was develcped and approval as Progranstntic Standarti NC.IE-AP.ZZ-0033(Q) on October 28, 1991.
c.
conuctive Actions to Prevent Ikutrrence The folicwing corrective actions have been aanpleted or are in progress.
It is felt these actions will prevent the recurrence of this or any similar violation.
. (1) The Vice President - Nuclear Engineering has counseled all management perconnel directly involved.
(2) A letter has been sent frun the Vloe President - Nuclear Engineering to all Nuclear Ergineering Department personnel comunicating his expectations-relative to control of ocannitments, schedule adherence, and timely reconciliation of resca.t ce issues and requesting managers to review all Irgulatory programs to ensure similar problems do not exist in other areas.
(3) An independent ruview will be conducted to assess the -
effectiveness of our regulatory ocoraitment tracking process.
This review will be cmpleted by Doocmber 31, 1991.
d.
Ibte When Corrective Ictions Will Be Ocstoleted All corrective actions associated with this deviation will be conpleted by %r 31, 1991.
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