ML20135G487
| ML20135G487 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/12/1985 |
| From: | Martin T Public Service Enterprise Group |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8509190288 | |
| Download: ML20135G487 (4) | |
Text
. _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _
Thomas J. Martin Public Service E ectric and Gas Company 80 Park Plaza Newark, N.J. 07101 201/430-8316 Vice President Engineering and Construction 5%
s.
September 12, 1985 Dr. Thomas E. Murley, Administrator U.
S.
Nuclear Regulatory Commission l
Office of Insnection and Enforcement Region I l
631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Dr. Murley:
NRC INSPECTION REPORT #85-27 NOTICE OF VIOLATION HOPE CREEK GENERATING STATION Your letter dated August 13, 1985, transmitted the above referenced Inspection Report which contained a Notice of Violation citing one (1) item of noncompliance concerning our Preoperational Test Program.
The following response is provided in accordance with your letter dated August 13, 1985, and the Notice of Violation.
Example B:
PTP PG-1, Revision 0, Class lE 480VAC Unit.
Substations, Prerequisite 3.1.3 requires verification that all test packages (TPRs) have been reviewed by the Startup Group.
Startup Administrative Procedure 24, Revision 6, Preoperational Test Procedures, Format, and Instructions states that if a prerequisite cannot be met a test exception will be instituted.
Contrary to the above, on March 11, 1985, Prerequisite 3.1.3 of PG-1 was performed improperly, in that TPR-PGC-153 had neither received the required results review nor been noted as a test exception.
k P
G
'In J
Dr. T.
E. Murley 2
9/12/85 i
j Corrective Steps Taken and Results Achieved Prior to starting PG-1, Startup Deviation Report (SDR) No. PG-0109 documented as test exceptions that six other TPR packages remained open.
TPR-PGC-153 was erroneously not included in SDR-PG-0109 nor identified elsewhere as a test exception.
Another TPR, PGC-0087, performed the required GTP-2 test on the instrument in question, but this test package had been adminis-tratively invalidated as a result of the invalidation of the test procedure.
The listing of the 0087 package as testing the instrument created confusion during the results review of the PTP.
The failure to list TPR-PGC-153 as part of the test exception document by SDR-PG-0109 was an oversight on the part of the Test Engineer.
The failure to detect the open TPR during the results review was due to the listing of the invalidated entry as a completed test for the instrument.
TPR-PGC-153 has since been approved by the Startup Manager on l
June 24, 1985.
Corrective Steps Taken to Preclude Recurrence A report of the required functional test for instruments and equipment has been developed which lists only those TPR's which have not been approved by the Startup Manager or Quality Assurance.
A copy of this report will accompany the copies of the test pro-cedure during the results review / approval cycle.
PORC meeting No. 86 discussed the finding and the PORC Chairman stressed the need for an intensive technical and administrative review of each test procedure.
The effectiveness of this corrective action was demonstrated during the results review / approval cycle for PTP-JE-1, Diesel Fuel Oil Storage and Transfer.
Date of Full Compliance The date of full compliance was June 30, 1985.
Example C:
Startup Administrative Procedure 24 (SAP-24),
Revision 6, Section 7.5.3.2 requires a Change Notice, with QA and Preoperational Review Committee (PORC) approval prior to testing, for procedure modifications that change acceptance criteria.
Section 7.5.3.1 requires for on-The-Spot Changes (OTS), clear marking of the Master Test copy of the procedure step changes and OTS reference j
notation.
i h
-, _ _ _ ~
Dr. T. E. Murley 3
9/12/85 Contrary to the above:
1.
On March 26, 1985, acceptance criteria of PTP PG-1, Revision 0, was changed via OTS without QA and PORC approval.
2.
On March 26, 1985, Part 3 of OTS-1 to Pre-operational Test Procedure PG-1, Revision 0, was not properly implemented, in that the affected test steps in the procedure Master Test Copy were not changed, nor was reference made to the OTS.
Corrective Steps Taken and Results Achieved OTS-5 was reviewed by PORC and QA during the results review of the procedure and changes thereto.
The test approval is sig-nified by the PORC Chairman's signature on the Procedure Test Endorsement Sheet.
During the PORC meeting, the technical aspects of the change were specifically discussed and accepted.
There was no technical problem with the change since the purpose of the change was to ensure that the tert was conducted in accordance with the latest design drawings.
The OTS-1 was entered next to the initial step of the section affected (step a.); but does not appear next to step d.
The second page of the OTS modified the procedure as follows:
" Modify to read using a frequency measuring instrument, measure...."
The original step called out using an oscillo-scope.
The test step was performed using a fluke.
The PSSUG Test Engineers have received reinforced training on the proper method to document an OTS in a PTP.
Corrective Steps Taken to Preclude Recurrence SAP-24 has been revised.
A Change Notice is required when a change in intent or a change in acceptance criteria is involved.
The description of the intent change and examples are now included in the latest revision to SAP-24.
The procedure clearly specifies that any change to acceptance criteria must be accomplished by a Change Notice.
The revised SAP-24 provides additional guidance and clarifica-tion to personnel authorized to approve OTS Changes to PTPs.
The PORC Members have been directed to perform a more detailed review of the procedure's conformity to the administrative requirements as well as the technical nature of the test.
Additional training has been provided for the PSSUG Test Engineers on the proper nethod of documenting changes to the PTP.
Dr. T. E. Murley 4
9/12/85 i
Additional steps taken in response to this Notice of Violation include:
- On July 2, 1985, a letter was issued from the Startup Manager listing the details of the violation and stating the PTP Program requirements.
- On July 8, 1985, an internal memorandum was issued by the Hope Creek QA Startup Engineer requesting that all QA/QC Engineers read and understand SAP-24.
- On July 9, 1985, a training session was conducted with all QC Engineers highlighting the violation and outlining the requirements of SAP-24.
- All new QA/QC employees are given training in the requirements of SAP-24.
Date of Full Compliance The date of full compliance was September 1, 1985.
Very truly yours, C
Office of Inspection and Enforcement Division of Reactor Construction Inspection Washington, D. C. 20555 NRC Resident Inspector P. O.
Box 241 Hancocks Bridge, NJ 08038 4
k e-..
,n.,,
e
,--,,,,v--,.
u-,,