ML20137K586
| ML20137K586 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/14/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8601240139 | |
| Download: ML20137K586 (3) | |
Text
,
e Pubhc Service Electric and Gas Company Cerbin A. McNeill, Jr.
Pubhc Service Elecinc and Gas Company P.O. Box 236. Hancocks Bndge, NJ 08038 609 339-4800
%ce President -
Nac; ear
.Tanuary 14, 1986 W-SS'l i
l Dr. Thomas E. Murley, Administrator
~
U.
S.
Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Dr. Murley:
NRC INSPECTION REPORT #85-51 NOTICE OF VIOLATION HOPE CREEK GENERATING STATION l
Your letter dated December 13, 1985, transmitting the subject report contained a Notice of Violation citing two (2) items of noncompliance.
The following is provided in response to the Notice of Violation.
A.
The Licensee's Nonconformance Reports (NCRs) No. 7967 and j-channel instruments PDT-N086A, B,
C, D; N087A, B, C, D; 7968 identified inadequate separation between redundant
- N088A, B,
C, D and N089A, B,
C, D.
These NCRs were dispositioned "use as is" based on the Project Engineer-ing and Field Engineering conclusion that the instruments serve unrelated and non-redundant functions.
Contrary to the above, the Licensee did not exercise adequate design control in their disposition of these NCRs as "use as is" in that the Inspector determined 1
that the instruments serve related and redundant functions.
Corrective Steps Taken and Results Achieved We have established that although the "use as is" dispositions to NCRs No. 7967 and 7968 are appropriate for the installations concerned, the justifications i
i 8601240 54 Pun A
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Dr.
T.
E.
Murley 2
given were incorrect.
The "use as is" dispositions were based on a seismic II/I walkdown and a hazards review which determined that the instruments identified would not become " targets" in a seismic event.
To document the proper justification for the dispositions assigned, Bechtel Project Engineering initiated a memo to the file which has been filed with the closed Noncon-formance Reports.
Corrective Steps Taken To Preclude Recurrence Thirty-three additional NCRs with "use as is" dispositions were reviewed to verify the adequacy of the justifications provided.
No discrepancies were noted and we conclude that the problem noted with NCRs No. 7967 and 7968 is an isolated instance.
Bechtel Site Resident (Project) Engineering supervisors have instructed their personnel to be more rigorous in documenting the basis for "use as is" NCR dispositions.
The Date of Full Compliance The date of full compliance was January 9, 1986.
B.
We have investigated the reversed wire incident addressed in the subject report and it appears that this concern is based on an incomplete understanding of our startup program.
The following information is provided to clarify the apparent misunderstanding of the NRC Inspector:
1.
The reversed wire problem was identified by the I&C Startup Test Engineer during a functional loop test performed prior to preoperational testing of that portion of the system.
2.
The purpose of loop testing is to identify problems prior to preoperational testing and ensure that work activities performed do not invalidate previous test results.
The reversed wires were corrected and documented in full compliance with the startup program requirements.
Q Dr.
T.
E. Murley 3
3.
In compliance with Startup Administrative Procedure No. 20, the installed condicion was brought into conformance with the latest design drawing by correctly reterminating the wires at GE Panel HllP618.
This was done as a matter of course and recorded on the test package exception sheet on October 24, 1985, the same day the discrepancy was noted.
4.
As a further clarification, no Startup Deviation Report (SDR) was generated.
The program requirements for initiating a Change Authorization Document (CAD) were explained to the NRC Inspector during his inspection.
These distinctions, however, were not reflected in the report.
Very truly yours, h
'['
/
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 l
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