ML20212L032

Responds to NRC Re Nonviolation Issues Noted in Insp Rept 50-354/86-52.Corrective Actions:Number of Unnecessary Overhead Annunciator Alarms Reduced & All Spare Breaker Safety Tags in Power Block Removed

ML20212L032
Person / Time
Site:	Hope Creek
Issue date:	03/02/1987
From:	Corbin McNeil Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N87029, NUDOCS 8703100136
Download: ML20212L032 (5)

Text

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Public Service Electric and Gas Company Corbin A. McNeill, Jr. Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609339-4800 Vice President -

Nuctsar W02 W NLR-N87029.

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

-Gentlemen:

SUPPLEMENTAL RESPONSE NRC INSPECTION REPORT #86-52 DOCKET NO. 50-354 HOPE CREEK GENERATING STATION On February 2, 1987 Public Service Electric and Gas Company (PSE&G) responded to your letter dated January 5, 1987, which transmitted a Notice of Violation. Our response did not address several additional non-violation issues that were identified in your letter.

Our. responses to these items of concern are provided in Attachment 1.

Sincerely, w ~

Attachment C Dr. Thomas E. Murley, Administrator USNRC Region I 631 Park Avenue King of Prussia, PA 19406 USNRC Resident Inspector P.O. Box 241 Hancock's Bridge, NJ 08038 8703100136 PDR 870302- I ADOCK 05000354 f PDR

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-l ATTACHMENT 1 '

1 PUBLIC SERVICE ELECTRIC AND. GAS COMPANY

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_ HOPE CREEK _ GENERATING STATION. ,

RESPONSE TO ITEMS OF CONCERN INSPECTION REPORT NUMBER 50-35'4/86-52 Your. letter dated January.5, 1987 identifiad several_ issues that were: considered to warrant ouricontinued management attention.

These concerns.were raised during an' October 20-31, 1986-

' inspection by an operational assessment inspection team led by 1Mr. L. Norrholm' of your staf f.

Char responses, including corrective actions which have been taken and those yet to be implemented, are provided-below:

. CONTROL ROOM OVERHEAD ANNUNCIATORS Initial efforts to reduce the. number of unnecessary overhead annunciator alarms were directed by the Control- Room Complex group'of system engineers who reduced the number of invalid alarms from well over 100 to the present level of roughly fifty rema'ining alarms.

Additionally, a review of all alarming overhead annunciators in the control room was conducted to identify which should be-1 included in a corrective program. Using the data from this review, design changes are being prepared to 1) permanently eliminate unnecessary alarms, 2) revise alarm logic, where feasible, to achieve a " dark board" at power,.- and 3) relocate sensors to eliminate spurious or transient-induced alarms.

Presently, an evaluation is in progress to determine any

" nuisance" alarms that can be eliminated, on an interim

' basis, by any of several techniques such as alarm setpoint changes or lifted leads until one of the previously mentioned permanent design changes can be implemented. These efforts are espected to substantially reduce, and ultimately eliminate, unnecessary control room overhead annunciator alarms...thereby enhancing control room operations.

SHIFT TURNOVER AND LOG ENTRIES Section 3.1 of the detailed discussion of the inspection report identified an apparent inconsistency in operating staff responses to Limiting Conditions for Operation (LCOs).

In one case, the operating staff, upon being notified by the maintenance staf f that a main steam line radiation monitor had failed a channel check due to a typographical error in a surveillance test procedure, " ... declared the instrument inoperable and were preparing to shutdown the reactor."

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,The operating; staff responded properly to.the input._from the maintenance staff.by declaring the. instrument inoperable. ~

-While:the action of preparing.to shutdown the reactor was not the required Technical fipecifications action for the affected

. instrument, stat' ion management review would have ensured that the' proper actions were taken before any actual shutdown was initiated. In any case, the operating staff actions were conservative' with regard to plant safety.

.The second example. cited in.the inspection report-(to demonstrate. inconsistency) described a situation wherein the operating staff did not enter a Limiting Condition for

' Operation (LCO) for a primary containment isolation failure.

The actual conditions involved-an unexplained rise in suppression pool' water level. The operating staff, in an attempt to_ locate the source of in-leakage to-the torus, selected _the "A" Core Spray check valve as a likely cause for the in-leakage since a HPCI surveillance ~had been recently completed that could have_left_that valve improperly seated.

The-check for_ proper seating of the valve demonstrated that.

the.. valve actually was improperly seated; but, since;the valve did seat properly during the process of ver!ying its closure, it became operable at the same time that it was determined to have been inoperable. Hence, no LCO was entered.

We_do.not consider these examples demonstrative of any '

significant inconsistency in our operating staff's response. .

Additionally, we are confident that continued accumulation of operating experience will continue to enhance the operators' capabilities with regard to determinations of operability. -

An additional concern under section 3.1 involved improper use of the Technical Specifications Action Statement Log by l ' operating personnel. Revisions have been made to Operating L Department procedure, OP-AP.ZZ-108(O) which require periodic L audits of the Action Statement Log vs. the Log index and-the

. entry into the Action Statement Log of all out of service l

equipment actions whether in the applicable operating i condition or not. These corrections have improved our l administrative control of control room records vs. plant conditions.

SAFETY TAGGING As discussed in section 3.5 of the detailed discussion, a large number (15 of 27) of Tagging Request Inquiry System l (TRIS) generated computer pages which identify blocked or tagged components were attributed to spare breakers.

Following a review of the need for continued tagging, all spare breaker safety tags in the power block have been

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ATTA'CHMENT - ~ 3 --

removed'.-(withithe exception of .120V; AC in Rad Waste .which' is

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in; progress).- This; action alone has significantly~ reduced;

the potential.for biasing of. TRIS audits towards:

non-functional components.-

All spare breaker: safety ' tags will ultimately. be removed in the plant and anLongoing process of review and: upgrade.will

, contitiue to: improve our control of the- tagging process.

4 EQUIPMENT MALFUNCTION IDENTIFICATION TAGGING-(EMIT) SYSTEM Se'ction'4.2.3 of-the. detailed discussion identified an EMIT System deficiency where tags were found on.non-deficient

! eq'uipment. Our own review of the plant with regard to out- .

l' dated- EMITS tags and other vistages of construction and start-up tagging resulted in an in-progress purge ~ of all-EMITS and construction /s tartup related tags. The station will no longer use the EMIT system and will rely,.instead, on the Managed Maintenance Information System (MMIS) when it is

implemented during 1987.

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OBSERVATIONS: INPECTION ORDER SYSTEM The comments regarding the Inspection Order (IO) System in ~

Section 5.3,. while valid, have not had an adverse impact on the ef fectiveness of the system or on plant operation. While ,

some surve'illances are carried as overdue when they have not i exceeded their required frequency, this is a conservatism that;has, to date, not detracted from management's oversight of, and concern for, timely conduct of all surveillances.

Additionally, there was a concern expressed by the inspectors over the IO system's generating only one work order for any surveillance item at a time. After approximately one year of

. operation of the system, there have-been no surveillances missed because of the IO system's not issuing a work order on time.

It is worthy of note that the Hope Creek IO system is identical to Salem's system which has been cited by INPO as a

" good practice" and recommended to several nuclear utilities as an ef fective management tool for control of surveillances.

When the MMIS is implemented for Hope Creek, it will incorporate the functions of the present IO system.

TEMPORARY MODIFICATIONS The three " personnel error" administrative deficiencies identified in Section 7.4, when viewed in perspective against the scope of our otherwise comprehensive and successful temporary modification program, are not indicative of a lack of management oversight and review.

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OPERATOR ACCESSIBILITY.TO PLANT AREAS

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At_the. time.of~the= operational assessment team visit,~the~

station.was.in. transition from an "all doors locked, limited

-access" philosophy to the present plant conditions 1where only high radiation areas :(controlled by the Radiation ' Protection

.: Department) .and access card security doors 1are not open.

Additionally, the Operating-Department has sets of master keys for use, by shif t personnel in the event.of an inoperable security card- reader or other unusual situation.

UPGRADE OF SAFETY. EVALUATIONS r

L Prior to issuance of the Hope Creek. Operating License, all 10CFR50.59 Safety Evaluations were done by our. Nuclear Site Engineering (Nuclear Systems Engineering Department) .

During th'e power ascension ~ program _it was recognized that there was a need to upgrade the quality and completeness of

. safety _ evaluations being performed by the Startup Group in in the station for-FSAR and Startup Program changes. At the same time, the station Technical Department systems engineers were charged with performing safety evaluations for-minor design changes. .Since there was no formal station procedural guidance for performing safety evaluations at that juncture, our Nuclear Safety Review Department assisted the. station

-Technical Department in the development of an administrative procedure, SE-AP.ZZ-100(O), which was in place within two weeks of the team visit, and the Nuclear Department promulgated an upper tier administrative procedure, VPN-LEP-04. Both procedures address proper preparation of 10CFR50.59 Safety Evaluations.

Additionally, the Nuclear Safety Review Department conducted a'special training program for station system engineers which focused on the importance of complete, high quality safety evaluations and provided guidance in proper research and preparation techniques.

We are (through audits, reviews, plant walk-downs, training and the-occasional discovery and resolution of problems) fine-tuning all of our procedures and programs...resulting in continual growth of our management ef fectiveness in all endeavors of plant operation. l

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