ML20147E887
| ML20147E887 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/15/1988 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N88008, NUDOCS 8801210235 | |
| Download: ML20147E887 (5) | |
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Pubhc Service Electoc and Gas Company Corbin A. McNeill, Jr.
Puohc Service Electnc and Gas Company P.O Box 236.HancockS Bndge.NJ 08038 609 339-4800 sew v c. Prescem -
PNC eaf January 15, 1988 NLR-N88008 U.
S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 Gentleman:
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-354/87-17 DOCKET NO. 50-354 HOPE CREEK GENERATING STATION Public Service Electric and Gas Company (PSE&G) is in receipt of your letter, dated December 18, 1987, which transmitted a Notice Violation identifying two violations.
The first violation involved a failure to comply with a Technical Specification limiting condition for operation.
The second violation concerned a failure to comply with the requirements of an approved station procedure for equipment control.
Pursuant to the provisions of 10 CFR 2.201, our response to the Notice of Violation is provided in Attachment 1.
Sincerely, Attachment C
Mr.
W.
T.
Russell, Administrator USNRC Region I Mr.
G.
W.
Rivenbark USNRC Licensing Project Manager Mr.
R.
W.
Borchardt USNRC Senior Resident Inspector Mr.
D.
M.
Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 8801210235 800115 PDR ADOCK 05000354 o
PDR fl)
ATTACHMENT 1 10 CPR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NUMBER 50-354/87-17 ITEM A One of the violations identified in your letter dated December 18, 1987 involved the failure to comply with a Limiting Condition for Operation (LCO) in Technical Specification 3.3.3 and Table 3.3.3-1.
As described in the Notice of Violation, the LCO for the Automatic Depressurization System (ADS) requires that whenever the reactor is in Operational Condition 1,2 or 3, two residual heat removal (RHR) pump discharge pressure instruments per pump shall be operable to satisfy the ADS actuation permissive logic.
With less than two pressure instruments per pump operable, the affected pump must be declared inoperable...
and, pursuant to the requirements of LCO Action Statement
- 3. 5.b.1, with one RHR pump inoperable, operation of the reactor may continue for not more than 30 days, provided that at least one core spray system is operable.
Contrary to the above requirements, for some period of time after April 10, 1987 until July 11, 1987, while the reactor was in Operational Condition 1, the two discharae pressure instruments for the "C" RHR pump were inoperable because the isolation valve for transmitters PTN055H and PTN056D was closed and the "C"
RHR pump was not declared inoperable. Since the transmitter isolation valve was last verified open on April 10, 1987, the "C" RHR pump is considered to have been inoperable for more than 30 days.
ITEM B The second violation described in Appendix A of your December 18, 1987 letter involved a failure to comply with an approved station procedure in that, Operations Department Administrative Procedure OP-AP.22-108(0), "Removal and Return of Equipment to Service" requires that applicable Technical Specifications LCOs be reviewed to determine if equipment status requires entry into an action statement.
Contrary to the above, two instances were cited in the Notice of Violation where the review of the LCOs was not adequate...
resulting in the station not entering required action statements for Technical Specifications Sections 3.3.3 and 3.5.1.
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t ATTACHMENT 1 (CONT'D) i I
1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THESE TWO VIOLATIONS.
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2.
THE ROOT CAUSE OF BOTH VIOLATIONS HAS BEEN DETERMINED TO BE I
INSUFFICIENT MANAGEMENT CONTROL OF EQUIPMENT ALIGNMENT.
AN ADDITIONAL IMPORTANT OBSERVATION WAS A NEED TO IMPROVE THE r
OUALITY OF ROOT CAUSE EVALUATIONS AND CORRECTIVE ACTIONS.
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i 3.
IMMEDIATE CORRECTIVE ACTIONS:
The Operations Manager issued a letter to all operators and I
held small group meetings to review the recent valving and
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switchino errors.
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Quarterly shift meetinas, conducted by the General Manager -
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Hope Creek Operations, were implemented to discuss the l
concerns of licensed and non-licensed operators and to l
identify issues needino management support.
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I The General Manager - Hope Creek Operations issued a letter
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to all personnel clarifyina responsibilities for plant
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operations.
Department managers held small group meetings to l
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review responsibility for equipment operations.
i The Operations Manager revised procedure OP-AP.22-109(0),
"Equipment Operational Control" to address partial system l
restorations prior to returning equipment to service.
This I
change will ensure that valves that require repositioning during equipment repair or surveillance testing are either controlled by safety tagging (TRIS) or procedurally addressed l
for proper allonment after the equipment is released for return to service.
g Retraining, during requalification training for licensed and non-licensed operators, on recent valve and control problems throughout the industry was commenced and will be completed by February 1, 1988.
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0 ATTACHMENT 1 (CONT'D) l l
3.
IMMEDIATE CORRECTIVE ACTIONS (Cont'd)
A Nuclear Department Incident Assessment / Human Performance Evaluation / Scram Response Task Force, chaired by the General Manager - Hope Creek Operations, has been instituted.
The Task Force's stated objectives include:
Upgrade and standardization of Nuclear Department procedures regarding Licensee Event Report (LER) and Incident Report (IR) preparation.
Standardization of root cause analysis techniques.
i Enhaticement of corrective action programs.
Development of a uniform trending program for LERs and irs for our nuclear plants.
Formation of a Scram /Significant Event Response Team that will rapidly mobilize, following any event, for analysis and remedial recommendation formulation using techniques and program developments described above.
In addition to the above, the Task Force has:
Sponsored a presentation of the INPO Human Performance Evaluation System (HPES) to station management.
Evaluated HPES program applications for 1988.
Dispatched several team members to attend the INPO course at other utility locations.
To complement the above effort, the Maintenance Manager -
Hope Creek is chairing a Scram Elimination and Procedures Compliance Task Team.
This team will draw on the knowledge and experience of both management and bargaining unit personnel.
Additionally, station management has participated in BWR Owners Group workshops on scram reduction, root cause analysis, and LER reduction. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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ATTACHMENT 1 (CONT'D) 4.
LONG TERM CORRECTIVE ACTIONS:
By June 30, 1988, the following programmatic enhancements will be implemented:
Conduct a Taqqina Request Inquiry System (TRIS) audit of instrument root valves on a continuing basis as P& ids are revised to complete our update program.
Complete intermediate valve numbering and lockina program for instrument sensing lines.
Reanalyze the need for O/non-O boundary valves in those pressure indication lines that require periodic use.
An annual review will be conducted in 1988 and 1989 by the Nuclear Safety Review organization to determine the effectiveness of the above actions.
5.
WE ARE NOW IN PULL COMPLIANCE.
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