ML20214J941

Responds to NRC Re Violations Noted in Insp Rept 50-354/86-27.Corrective Actions:Practice of Issuing Temporary Procedures as on-the-spot Changes Terminated & Rev 5 to Procedure SA-AP.ZZ-032(Q) Approved

ML20214J941
Person / Time
Site:	Hope Creek
Issue date:	08/08/1986
From:	Corbin McNeil Public Service Enterprise Group
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NLR-N86100, NUDOCS 8608150239
Download: ML20214J941 (5)

Text

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Public Service Electric and Gas Cornpany Corbin A. McNeill, Jr. Pubhc Service Electric and Gas Company P.O. Box 236,Hancocks Bridge NJ 08038 609 339-4800 Wce President -

Nucizar August 8, 1986 NLR-N86100 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Dr. Thomas E. Murley, Administrator Office of Inspection and Enforcement Gentlemen:

NRC INSPECTION REPORT #86-27 DOCKET NO. 50-354 HOPE CREEK GENERATING STATION Public Service Electric and Gas Company (PSE&G) is in receipt of your letter dated July 9, 1986, which transmitted a Notice of Violation concerning a failure to comply with Technical Specification requirements.

Pursuant'to the provisions of 10CFR2.201, our response to the Notice of Violation is provided in Attachment 1.

Inspection Report No. 50-354/86-27 requested that we include, in our reply to the violation, an assessment of those actions taken in response to a Quality Assurance Corrective Action Request (CAR) dated April 25, 1986. This CAR identified essentially the same concerns as the above Notice of Violation. Response to the CAR involved protracted dialogue between OA and the affected department, requiring two time extensions to complete. On June 23, 1986, the Station Quality Assurance Department found the reply to the CAR,. which contained the immediate and long term corrective actions listed in Attachment 1, to be satisfactory.

OA verification of these actions was completed on July 30, 1986.

Additionally, your letter included a request that we describe our efforts to improve the timeliness of our Quality Assurance Corrective Actions. The backJog of unanswered Quality Action Requests, which reached 36 items by the end of April, 1986, developed due to individual station departments tracking their own responses to OA requests. This fragmented approach, compounded by the demands of our startup program, allowed the extent of the backlog to escape the attention of station management. ,

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Dr. Thomas E. Murley 2 8/8/86 To focus specific, increased management attention on Ouality Action Requests, station management, in early May, 1986, began tracking all OA requests on one data base. Any outstanding requests are highlighted at weekly station management meetings.

Presently, there are only three outstanding requests for which -an initial response has not been made. This increased management attention will be continued to ensure timely responses to all Ouality Action Requests.

Sincerely, Attachment C Of fice of Inspection and Enforcement Division of Reactor Construction Inspection Washington, DC 20555 NRC Resident Inspector P.O. Box 241 fiancocks Bridge, NJ 08038

ATTACHMENT 1 o

10 CFR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS HOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOLATION Your letter dated July 9, 1986 identified one Violation of plant Technical Specification 6.8.2. As stated therein, the Violation involved the use of temporary procedures to perform surveillance tests which were not fully approved prior to use. Additionally, since these temporary procedures were handled as ON-THE-SPOT Cha nges (OSC), the Operations Department f ailed to complete the post change review within 14 days as specified in Technical Specification 6.8.3.

1. PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE VIOLATION.

2. THE ROOT CAUSE OF THE VIOLATION STEMMED FROM AN INCORRECT INTERPRETATION BY THE OPERATIONS DEPARTMENT OF REVISION 3 OF PROCEDURE SA-AP.ZZ-032(0), " REVIEW AND APPROVAL OF STATION PROCEDURES".

THE ROOT CAUSE WHICH LED TO EXCEEDING THE 14 DAY PERIOD FOR OSC POST CHANGE REVIEWS WAS THE LACK OF PROPER ADMINISTRATIVE CONTROL IN TRACKING THE INITIATION, REVIEW, AND FINAL APPROVAL OF OSC'S.

3. IMMEDIATE CORRECTIVE ACTIONS:

a) As noted in the inspection report, the practice of issuing temporary procedures as OSC's was immediately terminated. All temporary procedures initiated since 5/21/86 have undergone the complete review and approval process.

b) Since 5/24/86, the Station Qualified Reviewer (SQR) review has been performed on all af fected temporary procedures that were initiated prior to 5/21/86. As a result of this review, no surveillance procedures needed to be redone.

c) The method of tracking OSC's was thoroughly reviewed and improved to ensure any OSC would enter the post change review cycle within several days of initiation. To date, this program revision has been effective.

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,5 ATTACHMENT 1

4. LONG TERM CORRECTIVE ACTIONS:

a) Station procedure SA-AP.ZZ-032(Q) Revision 5 was approved on 7/8/86 and distributed on 7/11/86 clearly defining the usage of temporary procedures and OSC's.

b) On 7/21/86, a memo pertaining to the usage of Temporary Procedures and OSC's in accordance with SA-AP.ZZ-032(Q),

Revision 5, was placed in the Hope Creek Operations Required Readina Book to be read by all licensed operators.

5. FULL COMPLIANCE WAS ACHIEVED ON 7/21/86.

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