ML20113G223
| ML20113G223 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/25/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N91184, NUDOCS 9111050075 | |
| Download: ML20113G223 (6) | |
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- 1. ' o OCT 2 5 1931 11LR-119118 4 United Staten liuclear Regulatory Commission Document Control Denk Washington, DC 20555 Gentlement RESPO11SE TO 110TICE OF V101ATIO14 IIRC 111SPECTIO!! REPORT 50-354/91-16 DOCKET 110. 50-354 llOFE CREEK GE!1ERATI!1G STATIO!1 Pub 1'c Service Electric and Gas Company (PSE&G) la in roccipt of yout lotter, dated September 26, 1991, which transmitted a 110tice of Violation citing inadet uate maintenance and control of the Pont Accident Sampling System.
Purndant to the provisions of 10 CPR 2.201, our response to the 110ti co o f: Violation in provided in Attachment 1.
Sincerely,
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11LR-1191184 Attachment C
Mr. S.
Dombok USliRC Licensing Project Manager l
Mr. T. P. Johnson US!lRC Senior Resident Inspector Mr. T. T. Hartin, Administrator USilRC Region 1 Mr. K. Tosch, chief Bureau of liuclear Engincorina flow Jersey Department of F ronmental Protection i
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I ATTACHMENT _1 10 CFR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY llOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOIATION INSPECTION REPORT NO. 50-354/91-16 IAI ' -.
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NIR-N91184 VIDIATION RESKtlSE DMCRIPTION OF VIOIRION 35.4/J1-16-01 A.
Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained I
covering the activities referenced in (1) Appendix A of Regulatory Guide 1.33, Revision 2, February 1978; and in (2)
NUREG 0737, Clarification of TM1 Action Plan Requirements.
A.1 Regulatory Guide 1.33, Appendix A requires administrative 3
procedures for the control of maintenance.
Nuclear administrative procedure, NC.NA-AP.ZZ-0009(Q), " Work Control Process", Revision 2, sections 3.1 and 5.2 require personnel to initiate work requests and recommend hanging an Equipment Malfunction Informatien System (EMIS) tag for malfunctioning components or systems.
"ontrary to the above, training and chemistry personnel observed low flow indications during liquid post accident sampling system (PASS) operation betwoon May 16 to July 9, 1991, such that a reactor coolant rample could not be acquired and no work request was initiated nor were any EMIS tags posted on the system.
A.2 NUREG 0737 item II.B.3, Post Accident Sampling, requires procedures for PASS sample collection, transport a.M analysis.
Procedure llc.Cil-EO.Sil-0001(q), Reviulon
.3,
" Post Accident Sample Panel Operation", section 2.9 requires the PASS sample team to inform chemistry supervision when any problems are encountered during uampling in order to effect resolution.
Contrary to the above, on March 15, 1991, during an emergency drill involvino PASS operations, chemistry, 5
training and emergency preparedness personnel noted that there was no detectable sample flow such that a reactor coolant saniple could not be acquired, and this information was not formally communicated to chemistry supervisien until May 17, 1991.
PME 1 OF 3 ATTAOME2Tf 1
InR-N91164 VIOIATION RESIOfEE EEEkGIS.RESEQHSE The llope Creek Chemistry Department performed a detailed root cause analysis of the PASS inoperability issue.
The events leading to this violation were caused by the failure of personnel to properly notify supervision of equipment prcblems as
" Work Control Process".
delineated in procedure NC.UA-AP.ZZ-0009(Q),
Based on the results of that analysis, PSE&G does not dispute Violation 354/91-16-01 and has taken the following corrective actions to correct the discrepancy:
A.
CORRECTIVE ACTIONS:
1.
All Chemistry Department personnel were briefed on procedure NC.NA-AP.ZZ-0009(Q), " Work Control Process".
The briefings stressed the identification of problems to supervision and the requirements for initiating work requests and, when appropriate, hanging Equipment Malfunction Information System (EMIS) tags.
This action was completed on September 15, 1991.
Chemistry instructors in the Nuclear Training Department 7.
received formal training on the requirements of NC.NA-AP.ZZ-0009(Q) and the use of EMIS tags.
This was completed in September, 1991.
3.
Chemistry Department supervision reinforced the requirements of Category 1 procedural compliance through on-chift information sessions.
The focus of these sessions were to eliminate procedural noncompliance.
If a stop is discovered in a Category 1 procedure that cannot be performed as written, the activity shall be stopped and supervisory personnel contacted.
This will prevent a situation such as continued PASS operation with no detectable sample flow.
4.
All Emergency Preparedness personnel were briefed on NC.NA-AP.ZZ-0009(Q).
The briefings stressed the requirements for initiating work requests and, when appropriate, hanging EMIS tags if problems are identified during drills or exercises.
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p/CE 2 OF 3 ATTACIME27T 1
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NIR-N91184 VIO!ATION RESIWSE B.
CORRECTIVE ACTIONS TO PREVENT RECURRENCE:
1.
The Chemistry Dopartmont has initiated four now recurring tasks based on recommendations of the root cause analysis.
Those proventative maintenance tasks consist of the performance of operability verification of all samplo points for power and refueling operations.
2.
Malfunctions of PASS components are now dispositioned as at Icast "B" priority requiring "... correctivo action to start as soon as possible but normally by the next scheduled work day."
Such PASS component malfunctions are highlighted in the daily management planning package.
Operation of PASS continues to be monitored by plant management on a wookly basis.
3.
The revision of IIC.CH-EO.Sil-0001(Q), " Post Accident Sample Panel Operation", in use at the time of the violation directed Chemistry personnel to contact an Emergency Plan titled supervisor; this n'uld have misicad technicians as to the applicability of certain requirements.
In order to avoid confus.on, this procedure has boon revised to direct i
the requisjte supervisory contact be made to the normal supervisory titles to report "...any problems encountered
...whenover the system is used (routine oporation, training,-post accident, etc.)."
Additionally, the procedure now stressos the importance of problem identification and subsequent notification.
4.
Inservico Inspection Proceduro M9-ILP-03H, used for local leak rate testing, was modified to provido caution for application of pipe scalant to provent inadvertant introduction of scalant into small bore pipes.
PSE&G is now in compliance on this issuo.
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