ML20238D805
| ML20238D805 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/03/1987 |
| From: | Miltenberger S Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N87165, NUDOCS 8709110405 | |
| Download: ML20238D805 (3) | |
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l Puvic Service Electric and Gas Cornpany Steven E. Miltenberger Public Service Electric and Gas Company P.O. Box 23S, Hancocks Bridge, NJ 08038 609 339-4199 Vice President -
Nudear Owakons 4
SEP 0 3 E6?
NLR-N87165 U. S.4, Nuclear Regulatory Commission Attentiont Document Control Desk
{
Washington, DC 20555 Gentleman:
NRG INSPECTION REPORT 50-354/87-16 DOCKET NG. 50-354 DOPE CREEK GENERATING STATION Public Service Electric and Gas Company (PSe&G) is in receipt of your letter dated July 7, 1987, which transmitted a Notice of Violation concerning a f ailure to comply vith requiremer.ts of Technical Specification 3.'8.4.2.
Pursuant to the proVicions of 10 CFR 2.201, our response to the Notice of Violation is provided in Attachmont 1.
Sincerely, kh !Mj54 J
.1 e'~"
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Attachment C
Mr.
W.
T.
Russell, Administrator USNRC Region I Mrt G.
W.
Rivenbark USNRC Licensing Prcject Manager Mr.
R.
W. Borchardt USNRC Senic?r R6sident InGpector Mr.
D. M. Scotte Chief
(([h0l[
Bureau of Nucletr Engineering Department of Environmental Protection 380 Scotch Road Trenton, NJ 08628 i
isI\\
T ATTACHMENT 1 10 CFR 2.201 INFORMATION PUBLIC SERVICE BLECTRIC AND GAS COMPANY I
HOPE CREEK GENERATING STATION l
RESPGNSE TO NOTICE OF VIOLATION INSPECTION REPCRT NUMBER 50-354/87-16 Your letter. dated August 5, 1987 identified a violation of the requirements of Technical Specification 3.8.4.2 wherein certain motor operated valve thermal overload protection bypass circuits which were required to "9 operable were in fact, found to be not r
j installed.
Your letter a;lso Tequired an explanation of how the 1
above discrepancy between Technical Spe'cifications and the as-built plant could remain undetected from April 1986 through j
June 1987 end what assurances we nave that other similar problems do not exist.
1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE i
VIOLATION.
fj 2.
THE ROOT CAUSE OF THE VIOLATION WAS,PEFSONNEL ERROR.
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i The MOV Tables 3.8.4.2-1 AND 3.8.4.3-1 contained in the fic.al i
Technical Specifications issued with the Operating License (i.n April 1986) were recited from the Tables contained in the Draft TS used to perform the Surveillance Requirements (prior i
to April 1986) for the affected MOVs.
The affected MOVs were mGved f rco Table 3.8.4.3-1, which only required t:asting of 1
overload protection to Table 3.8.4.2-1, which recyired both I
thermal overload protection and thermal overloed bypase capability testing.
J The impact of this change in the specifications did not re ce j vd an adequate review by Design Engineering against as-built wiring diaorams for the MOVs...resulting in the j
absehce of the thermal overload bypass circaitry from four
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Service Water Screen Wash Isolatlan velves.
I The thermal overlo&d bypass feature for four other valves, l
Turbine Auxiliary Coolina System-to-; Safety Auxiliary Cooling Fystem Return Isolation Valves, were improperly disabled by a Bechtel design change which was implemented to address an unrelated valve timing concern during the startup program.
The ifo pac t ot this change was also masked by the ebove change
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I in rechnical specifications.
Finally, because both overload and overload bypass testing are contoined in the same maintenance test procedure, Maintenance pepartment personnel failed to recognize that a
portion of the test procedure ased for the MOVs woul.d have to be re-perfcraed to s&tifactorily address the bypass testing j
de f f. ned in TS 3.8.4.2.
The review of the change in Technical Specification Tables resulted in correction of the referenced
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surveillance requirements in the procedures and inspection order schedulina system but, since the required testing is an IP month surveillance, the need for overload bypass testing for the valves in question was not discovered until the first timo the velve surveillance became due in June 1987.
~m f-y..-
. _i ATTACHMENT 1 (CONT'D)
-3.- 'IMMEDIATE CORRECTIVE: ACTIONS:
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Temporary modifications were immediately made.to the valves to' provide' thermal overload bypass capability and all other valvesithat were" moved from Technical Specifications TablW'
'3;8.4.3-1 to Table 3.8.4.2-1 were retested and ensured toc e3, b
5 hi sex A review of all Technical Specification revisions that todk [2
. place.between receipt of-the draft TS (which were used'to oL Ci
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' develop.TS surveillance test p ocedures) and the issuancebdfaa the ' Revision OTS with.the coerating License in April 1746 was completedLagainst all-I&C~and Maintenance procedures. JNo L
other discrepancies between r rveillance procedures and TS surveillance requirements were identified.
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All station departments reviewed tabular-type TS surveillance requirements against their surveillance testing procedures for consistency to preclude recurrence of this type of event.
4.
LONG TERM CORRECTIVE ACTIONS:
The temporary modifications to the overload circuits were replaced.with permanent engineered design changes which added
'the required bypass functions.
An evaluation of this incident will be used to determine any necessary corrective measures to our desian change process.
The evaluation will be completed by September 15, 1987.
Additionally, all station departnients are reconfirming
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procedures and scheduling programs against all TS surveillance requirements.
This process is aJso expected to be complete by September 15, 1987.
5.
WE ARE NOW IN FULL COMPLIANCE.
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