ML20235M537
| ML20235M537 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/17/1989 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N89023, NUDOCS 8902280300 | |
| Download: ML20235M537 (4) | |
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Public Service Electric and Gas Company
' St:nley LaBruna Public Service Electne and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038 609-339-4800 Vice President Nuclear Operatons FEB 171989 NLR-N89023 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-354/88-80 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated January 19, 1989, which included a Notice of Violation regarding the design control of certain modified check valves.
Pursuant to the requirements of 10CFR2.201, our response to this violation is provided in the attachment to this letter.
Should you have any questions with regard to this transmittal, please do not hesitate to contact us.
Sincerely, Chnw~
Attachment l
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8902280300 890217 7
PDR ADOCK 05000354 O
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Document Control Desk FEB 17 ggg C
Mr.
C. Y. Shiraki Licensing Project Manager Mr.
G. W. Meyer Senior Resident Inspector Mr. W. T. Russell, Administrator
. Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
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j ATTACHMENT I
PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354 RESPONSE TO NOTICE OF VIOLATION NRC Inspection Report 50-354/88-80 transmitted a Notice of Violation regarding the design control of certain modified check valves.
The violation and our related response are presented i
below.
VIOLATION As a result of the inspection conducted on October 24-28, 1988, and December 1-2, 1988, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
Appendix C (Enforcement Policy), the following violation was identified:
10 CFR 50, Appendix B Criterion 171 requires that design documents such as specifications, drawings, procedures and instructions contain meacures to control the selection of materials and their suitability for use.
It further requires design changes, including field changes, be subject to the same controls as the original design.
20 CFR 50, Appendix B, Criterion V requires instructions and drawings be provided
{
appropriate to the circumstances.
Contrary to the above, on or before December 2, 1988, the field j
design change package for all testable check valves under the
" Modified Check Valve Design" did not contain consideration for i
the suitability of materials, detailed instructions for the important assembly positioning of parts nor final drawings depicting the modified valve.
RESPONSE
PSE&G DOES NOT DISPUTE THE VIOLATION ROOT CAUSE The root cause of this violation was procedural inadequacy in that the design change control procedure used to implement this design change package (SEI 4.2) contained insufficient guidance with regard to the design details to be included.
CORRECTIVE ACTIONS IMPLEMENTED The design change package for the modified check valves has been l
modified to provide more detail in terms of the assembly instructions and the evaluation of materials used.
These changes were completed on February 17, 1989.
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.The remaining part of the violation stated that the valve.
drawings have not been amended to reflect the modification.
The reason ils that this field design change package for all testable check valves has not been completed..The design change package states chat the valve drawings are to be modified to reflect the design change and that the drawings will be updated when the package is completed.
The design change package was completed on February 17, 1989.
' CORRECTIVE ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS The design change control procedure used to implement this modification (SEI 4.2) was established in 1985.
This procedure has been revised to-include more guidance with regard to DCP design detail so as.to preclude recurrence of the concern noted in the violation.
DATE WHEN FULL COMPITANCE WILL BE ACHIEVED
. Modification of the design change package to provide further detail on assembly instructions and the evaluation of materials used was completed on February 17, 1989.
The valve drawing changes will be completed by May 15, 1989.
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