ML20115C355
| ML20115C355 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 07/05/1996 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N96180, NUDOCS 9607110301 | |
| Download: ML20115C355 (11) | |
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I' Public Service Electnc and Gas Company Louis F. Storz Public Service Electric and as Com any P.O. Box 236, Hancocks Bridge. NJ 08038 609-339-5700 Senor Vce President. Nuclear Operabons WVb W
LR-N96180 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Gentlemen:
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/96-04 HOPE CREEK 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 (PSE&G) to 4
the notice of violation (NOV) issued to the Hope Creek Generating Station in Inspection Report 354/96-04 dated June 7, 1996.
The details of the reply to the NOV are contained in Attachment 1.
In addition, pursuant to the request in the cover letter for Inspection Report 354/96-04, this letter submits PSE&G's response to cr.e identified UFSAR discrepancies described in the subject inspection report.
The response and plan are included as.
Should you have any questions or comments on this transmittal, do not hesitate to contact us.
Sincerely, J
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Attachment 4
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9607110301 960705 PDR ADOCK 05000354 G
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i JUL 051996 l
Document Control Desk l l
LR-N96180 C
Mr. T. T. Martin, Administrator - Region I U.
S.
Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - Hope Creek U. S.
Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21
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l Rockville, MD 20852 l
Mr. R.
Summers USNRC Senior Re6.4. dent Inspector (X24) l Mr. K. Tosch, Manager IV Bureau of-Nuclear Engineering 33 Arctic Parkway CN 415 l
Trenton, NJ 08625 i
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UUL 051996 l
Document Control Desk LR-N96180 CEM BC Senior Vice President - Nuclear Engineering (N19)
General Manager - Hope Creek Operations (H07)
Director - QA/NSR (X01)
Director - Nuclear Design Engineering and Projects (N25)
Director - Nuclear System Engineering (XO7)
Operations Manager - Hope Creek (H01)
Maintenance Manager - Hope Creek (H03)
Manager - System Engineering - HC (H18)
Manager - Quality Assessment - HC (H09)
Manager - Nuclear Safety Review (N38)
Manager - Joint Owncrs/ External Affairs Interface (N28)
Onsite Safety Revieb Engineer - Hope Creek (Hil)
Station Licensing Engineer - Salem (XO9)
Station Licensing Engineer - Hope Creek (XO9)
General Solicitor, R.
Fryling, Jr. (Newark, SG)
Mark J. Wetterhahn, Esq.
Records Management (N21)
Microfilm Copy File Nos.
1.2.1, 3.1 (HC IR 354/96-04)
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ATTACEMENT 1 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/96-04 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 LR-N96180 I.
INTRODUCTION During an NRC inspection conducted between April 15, 1996 and April 19, 1996, a violation of NRC requirements was identified.
As a result, the NRC issued a notice of violation (NOV) in a letter dated June 7, 1996.
In accordance with the provisions of 10CFR2.201, Public Service Electric and Gas Company (PSE&G) hereby submits a written response to the NOV that includes:
(1) the reason for the violatio~; (2) the corrective steps that have been caken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved.
II.
REPLY TO THE NOTICE OF VIOLATION A.
Description of the Notice of Violation
" License Condition 2.C.5 requires that, "PSE&G shall continue, for the life of the plant, a reliability program to monitor the performance of the Bailey 862 SSLMs installed at Hope Creek Generating Station.
This program should obtain reliability data, failure characteristics, and root cause of failure of both safety-related and nonsafety-related Bailey 862 CSLMs.
PSE&G Procedure HC.IC-DD.ZZ-0017(Z), Revision 4,
" Bailey Module Reliability Program," which implements the above license condition, requires in part, that: (1) work sheets are required to be completed with as much detail as possible for all rework, repair, replacement and/or testing of any type Bailey module; (2) detail sheets are required to be completed with as much detail as possible for any Bailey Logic Module failure; and, (3) a copy of the completed and signed work sheets and detail sheets shall be sent to the System Engineering Group for review and failure characteristic analysis.
Contrary to the above, during 1994, 1995, and 1996, reliability data was not obtained for Bailey 862 SSLMs, in that, all work sheets and detail sheets were not sent to System Engineering for review and failure characteristic analysis.
This is a Severity Level IV vfolation (Supplement I)."
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1 i-LR-N96180 Reply to Bailey Notice of Violation
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B.
Response to Notice of violation i
l PSE&G concurs with the facts cited in the NOV and agrees that adherence was not maintained with the procedures used to implement License Condition 2.C.5.
1.
Backaround Information/ Event Description / Event Review l
BACKGROUND INFORMATION l
The Bailey solid state logic module (SSLM) automatic tester is normally used to perform testing of Bailey logic cards.
Testing performed with this device is governed by Procedure HC.IC-GP.ZZ-0075(Q) (GP-75).
As part of the GP-75 testing requirements for in-service or repaired modules, Procedure Step 5.2.9 requires performing Procedure HC. IC-DD. ZZ-0017 (Z)
(DD17) if the as four.d test results were unsatisfactory.
In addition, as part of the requirements for returning the logic module to service, Step 5.4.2 of the procedure revision in l
I effect during the period when the violation occurred directed the technician to complete Procedure DD17 and to forward a copy of the associated information to the responsible Maintenance Engineer in the System Engineering Department (referred to throughout the remainder of this document as the Bailey Engineer).
1 If the manual tester is used, the testing is governed by Procedure HC.IC-GP.ZZ-0031(Q) (GP-31).
As part of the requirements for returning the logic module to service, Step 5.5.2 of the revision of GP-31 in effect during the period when the violation occurred directed the technician to complete Procedure DD17 and to forward a copy of the
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associated information to the Bailey Engineer.
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l In accordance with Procedure HC.SE-PR.RL-0001(Q), the Dailey Engineer obtains failure information from the Maintenance l
Department and prepares-a quarterly report that provides reliability data.
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EVENT DESCRIPTION On April 2, 1996, the Bailey Engineer determined that he had i
not received all of the copies of Procedure DD-17 for Bailey SSLMs that had been replaced in the first quarter of 1996.
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Specifically, he identified three work orders which appeared i
to have replaced a Bailey card without the DD-17 information being properly processed.
The Bailey Engineer documented this finding in the corrective action program.
Upon further i
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l LR-N96180 Reply to Bailey Notice of Violation investigation, it was discovered that ten cards had been replaced during the first quarter of 1996 with the requisite forms properly processed in only two of those occasions.
Subsequent to the first quarter 1996 review, a review of 1994 and 1995 information was also performed.
l EVENT REVIEW The reviews of 1994, 1995, and the first quarter of 1996 produced the following results:
1Q 1996 1995 1994 Numbe_ Procesced Properly 2
14 18 Procedure DD-17 Not Completed 4
2 2
Procedure DD-17 Completed But 4
3 1
Information Not Received by Engineer Total 10 19 21 l
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2.
Reason for Violation l
The causes of the violation were failure to follow procedures, procedure inadequacy, and lack of continuing training.
The identified occasions in which the Bailey Engineer failed to receive the required information fall into two categories.
The first category includes those occasions in which Procedure DD-17 was completed but the associated information was not received by the Bailey Engineer.
The second category includes those occasions when Procedure DD-17 was apparently not completed.
A subset of this second category are cases in i
which the test results for the removed card were satisfactory.
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Procedure HC.IC-DD.ZZ-0017(Z) is required to be completed anytime a card is replaced.
Even if the test results were satisfactory, the Bailey Engineer needs the DD-17 information to maintain the Bailey solid state logic module database.
Procedures GP-31 and GP-75 included a procedure step that j
directed the technician to complete Procedure DD-17 and to 1
transmit a copy of the associated data sheets to the Bailey i
Engineer.
The DD-17 data sheets had supervisor signature lines, and the normal flow path for any procedure that has a sign off step for a supervisor, would be for the technician to 3 of 6 4,
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LR-N96180 Reply to Bailey Notice of Violation give the entire work order package to the supervisor for his review.
The forms included nothing that would indicate to the supervisor that a copy of the DD-17 forms was required to be sent to the Bailey Engineer, or that it had been sent.
As a result, the supervisor reviewed the work order package and signed it, but did not always deliver the DD-17 information to l
the Bailey Engineer.
The cause for the first category of events includes the following:
l a.
The procedures were inadequate in the following respects:
The forms and associated signature lines included no indication to the supervisor that Procedure DD-17 was required to be completed or tnat the information had been properly transmitted.
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- The forms did not require signatures to acknowledge 1
transmittal and receipt of the information.
b.
Information gathered during interviews indicates that the technicians and the supervisors were unclear j
concerning the proper steps to take with the completed j
i DD-17 information.
This was indicative of a lack of l
training describing which procedures were required to l
be used and why they were required to be completed.
The causes for the second category of events include the following:
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- a. There was a failure to properly follow Procedures GP-31 l
and GP-75, which direct the technician to complete l
Procedure DD-17.
- b. Procedures GP-31, GP-75, and DD-17 were vague regarding expectations for informing the Bailey Engineer of card replacements for cases in which the test results for the removed card were satisfactory.
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- c. There was a lack of training describing which l
l procedures were required to be used and why they were i
required to be completed.
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3.
Corr.ective steps That Have Been Taken and Results Achieved Corrective actions that have been taken include the following:
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Reply to Bailey Notice of Violation a.
An action' request was written and a root cause analysis was performed.
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b.
The quarterly failure reports include graphs of the l
number of failures and the failure rate in each quarter i
L during the last three years.
The first quarter 1996 failure report has been updated to reflect the missing information from 1994, 1995, and the first quarter 1996.
c.
Procedures GP-31, GP-75, and DD-17 have been revised.
The revisions include the following:
1.
A signature requirement was added to Procedures GP-31, GP-75, and DD-17 for the technician to l
document transmittal and for the Bailey Engineer i
to acknowledge receipt of the DD-17 data.
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The single step in GP-31 and GP-75 that required
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completion of Procedure DD-17 and transmittal of the associated information to the Bailey Engineer has been made into'two separate steps.
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3.
Prior to the step in GP-31 and GP-75 that requires forwarding of the information, e note has been added that states:
"The RL System Manager is informed of all Logic Module replacements to ensure that all applicable tracking and trending documentation is completed."
d.
A single point of contact for Bailey issues has been established in the Maintenance Department.
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Corrective Steps that Will Be Taken to Avoid Further Violations Additional corrective actions that will be taken include the following:
a.
Assessments will be performed by the Bailey Engineer to verify proper processing of DD-17 information for the second and third quarter of 1996 to determine l
corrective action effectiveness (October 15, 1996).
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Quality Assurance will perform an assessment of the j
Bailey trending program to verify proper processing of 4
DD-17 information to determine corrective action j
effectiveness (February 1, 1997).
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LR-N96180 j
Reply to Bailey Notice of Violation c.
The findings and corrective actions associated with this violation will be discussed with Maintenance Department technicians and supervisors at tailgate meetings with emphasis placed on procedure compliance (July 15, 1996).
1 d.
Positive discipline will be taken as appropriate. (July 15, 1996).
e.
A continuing training module will be developed that includes information on the Bailey tester, the Bailey trending program and the purpose of the DD-17 icrms (November 15, 1996).
I' 5.
Date When Full Compliance Will Be Achieved i
The missing information for 1994, 1995, and the first quarter l
of 1996 has been located and provided to the Bailey Engineer.
The failure report has been updated to reflect the missing information.
Based upon the above, full compliance has been achieved.
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e ATTACKMENT 2 RESPONSE TO UFSAR INCONSISTENCIES INSPECTION REPORT NO. 50-354/96-04 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 LR-N96180 I.
Introduction The NRC noted several UFSAR inconsistencies during'the Bailey inspection and requested that PSE&G provide a plan to address the inconsistencies.
Each of the three inconsistencies is identified 1
below along with PSE&G's response, u
IIz Response to Issue A response to each of the three UFSAR issues is provided below.
12 Issue and Response to UFSAR Section 7.1.2.9.2 ISSUE E
"UFSAR Section 7.1.2.9.2 states,
... testing of a system circuit from its control switch through the output (s) of the associated i
logic modules is made possible by a switch on the fuse module which, when operated, disables the output drive relayu."
This statement is misleading because the licensee does not perform i
testing as described."
RESPONSE
As noted above, the statement in UFSAR Section 7.1.2.9.2 relative to testing made possible by use of a switch to disable the output i
drive relays was considered misleading by the NRC.
The subject test feature has been used for troubleshooting and retesting of Bailey circuits at Hope Creek, but the statement is not meant to imply any specific methodology or frequency for testing.
UFSAR Section 7.1.2.9.2 will be changed to better represent the intent of the statement in question.
2 Issue and Response on UFSAR Sections 7.3.1.1.9 and t
21.3.1.1.10 ISSUE "UFSAR Sections 7.3.1.1.9 and 7.3.1.1.10 indicate that the Filtration Recirculation and Ventilation System and Reactor Building Ventilation Isolation Systems are fully testable during 1 of 2
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.4 LR-N96180 Response to UFSAR Inconsistencies normal power operation.
These systems are not normally tested at power."
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RESPONSE
As stated above, the NRC noted that statements in UFSAR Sections 7.3.1.1.9, and'7.3.1.1.10 indicate that the specified systems are l
fully testable at power but are not normally tested in that i
condition.
The subject UFSAR sections will be revised to better describe system testing.
lx Issue and Tatyponse on UFSAR Tables 7.1-2 and 7.1-3 ISSUE "UFSAR Tables 7.1-2 and 7.1-3 indicate that plant systems conform to the at-power testability requirements of Regulatory Guide (RG) 1.22.
The licensee does not perform at power testing for all engineered safety feature systems.
This is an exemption from RG 1.22."
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RESPONSE
PSE&G has further reviewed the NRC comments associated with UFSAR Tables 7.1-2 and 7.1-3 and has concluded that the applicable l
systems are in compliance with RG 1.22.
Specifically, Hope Creek complies with Regulatory Positions D.4 a, b,
and c of RG 1.22 for I
the systems not tested at power.
Compliance with this regulatory l
position is documented in Section 7.3.2.5 of Supplement 6 to the Hope Creek Safety Evaluation Report (NUREG-1048).
Since the applicable systems comply with RG 1.22 and are not exempt from it, no changes to the UFSAR are considered necessary.
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