ML18095A346

Responds to NRC 900608 Ltr Re Violations Noted in Insp Repts 50-272/90-12 & 50-311/90-12.Corrective Actions:Assessment of ECCS & Component Performance Undertaken & ECCS Flow Testing Procedure Upgraded to Address Human Factors

ML18095A346
Person / Time
Site:	Salem
Issue date:	07/10/1990
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N90145, NUDOCS 9007170193
Download: ML18095A346 (6)

See also: IR 05000272/1990012

Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Cor11par:iy

?P. _Box 236, Hancocks-Bridge. -NJ 08038 609--339-4800

1 Fce Pi-8s1der:t

-Nuc18ar Ooera11ons

• JUL l 0 iSSG NLR-N90145

United States Nuclear Regulatory

Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION

REPORT NO 50-272/90-12

AND 50-311/90-12

DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas (PSE&G) has received the Notice of Violation

dated June 8, 1990, regarding

(1) Plant operations

outside of the Technical

Specification

Limiting Condition

for * Operation

of the ECCS, and (2) Ineffective

corrective

action for a recent similar event. Pursuant to the requirements

of 10 CFR 2.201, our response to this Notice of Violation

is provided in the attachment

to this letter. Should you have any questions

in regard to this transmittal, do not hesitate to call. Attachment

9007170193

900710 PDR ADOCK 05000272 Q PDC Sincerely,

• * Document Control Desk NLR-N90145

c Mr. J. c. Stone Licensing

Project Manager Mr. T. Johnson Senior Resident Inspector

2 Mr. T. Martin, Administrator

Region I Mr. Kent Tosch, Chief New Jersey Department

of Environmental

Protection

Division of Environmental

Quality Bureau of Nuclear Engineering

CN 415 Trenton, NJ 08625 JUL l o 1991

ATTACHMENT

As a result of the inspection

conducted

on April 11-18, 1990, and in accordance

with "Gene+aL statement

of Policy and Procedure

for --NRC-Enforceirient -Actions", 10 CFR 2, Appendix c (Enforcement

Policy 1989), the following

violations

were identified:

1. APPENDIX A NOTICE OF VIOLATION

Technical

Specification

3.5.2 and 4.5.2.h require two independent

emergency

core cooling subsystems (ECCSs) to be operable during plant operation

in Modes 1, 2 and 3, including

two operable safety injection

pumps with a total flow rate less than or equal to 650 gallons per minute (gpm) per pump. Contrary to the above, on April 11. 1990, the licensee identified

that two ECCSs were not operable during plant operation

in Modes l, 2 and 3 for Unit 1 since December 17. 1987 and for Unit 2 since October 22. 1988. During these periods one of the two safety injection

pumps (12 and 21) for each Unit exceeded the 650 gpm maximum flow requirement

by about 0.5 to 3.0 percent. RESPONSE PSE&G DOES NOT DISPUTE THE VIOLATION.

The root cause of this event has been attributed

to inadequate

procedure, personnel

error, and inconsistent

trending of safety injection

pump data. Contributing

factors that played an important

role in this event were an inadequate

original writer's guide (for operations

department

procedures)

and ari ineffective

two year review of this procedure.

-CORRECTIVE

ACTIONS TAKEN The following

corrective

actions have been taken: 1) A complete assessment

of the ECCS and component

performance

was undertaken.

2) The ECCS flow testing procedure

was upgraded to address human factors and to add responsibilities

for independent

verification

of calculations.

3) A verification

that similar miscalculations

do not exist in other Technical

Specification

pump surveillances

was conducted.

4) The event was reviewed with applicable

operations

personnel

stressing

attention

to detail. 5) An independent

review of completed

18 month Technical

Specification

surveillances

involving

calculations, for Unit 2, was completed

prior to the restart of Unit 2. 6) The Inservice

testing (IST) program is being upgraded to include design basis as well as ASME section XI requirements.

7) All measuring

orifices NLR-N90145

Page 1 of 4

• were replaced.

8) The two year procedure

review process was strengthened

as detailed below. The strengthening

of the two

review-process-consi-sted

of -the--follbwing;

1r Tlie two year review requirements

were clarified

as detailed in the current revision of AP-32. _ 2) All revision requests were reviewed for significance.

3) Maintenance

procedures

which have not yet received a two year review will be reviewed prior to being performed.

A full review of the Maintenance

procedures

will be completed

by October 31, 1990. 4) Operations

procedures

are undergoing

a two year review on an expedited

basis. A full review of the Operations

procedures

will be completed

by July 31, 1990. CORRECTIVE

ACTIONS TAKEN TO PREVENT RECURRENCE

The following

additional

corrective

actions will be completed

to prevent recurrence

of the event. 1) The present Nuclear Department

procedure

writer's guide will be reviewed for potential

human factors enhancements

and lessons learned (such as data sheet presentation

and format). 2) All procedure

writers will be trained on the revised writer's guide. 3) Charging and Safety Injection

• pump curve -fit tests data will be trended. 4) Technical

Specification

surveillance

calculations

for the charging and safety injection

pumps will be independently

verified.

5) A line by line reverification

of Technical

Specifications

requirements

vs surveillance

procedures

requirements

will be completed

by December 31, 1990. PSE&G IS IN FULL COMPLIANCE.

NLR-N90145

Page 2 of 4

• 2. 10 CFR 50. APPENDIX B VIOLATION

10 CFR Part 50, Appendix B, Criterion

XVI and the Nuclear Quality Assu:i;-a_nce

Department-Manual -require*

that-ineasures

• shall be established

to assure that conditions

adverse to quality are promptly identified, corrected

and prevented

from recurring.

Contrary to the above, as of April 11. 1990, the licensee's

measures established

to assure that conditions

adverse to guality are promptly identified.

corrected

and prevented

from recurring

were not effective.

in that; corrective

actions regarding

the licensee's

identification

of flow rate test miscalculation

which rendered the Unit 2 charging pumps inoperable

on January 4. 1990 did not prevent the recurrence

of a similar event on April 11. 1990 regarding

an inoperable

safety injection

pump at both Units 1 and 2. RESPONSE PSE&G DOES NOT DISPUTE THE VIOLATION.

The root cause of this event has been attributed

to lack of management's

definition

of the requirements

of the review necessary

to prevent duplication

of the error in a timely manner. CORRECTIVE

ACTIONS This event has been reviewed by Station

for the following;

1) The importance

to clearly define expectations

during performance

of reviews. 2) The importance

of heightening

awareness

of conditions

potentially

affecting

safety significant

issues and the importance

of the independence

of the reviewers.

CORRECTIVE

ACTIONS TO PREVENT RECURRENCE

Station management

will issue written guidance to clearly specify the requirements

for conducting

applicability

review of safety significant

issues. This guidance will include such things as; purpose, objective

and scope of review and resource requirements (including

independent

assessment).

This guidance will be issued by July 31, 1990 * NLR-N90145

Page 3 of 4

• PSE&G management

will continue its emphasis on timely corrective

actions and thorough reviews. As indicated

earlier at the meeting between PSE&G and the NRC, these events were self identified

and actions were taken to place the plant in a safe configuration.

PSE&G believes that the conservative

course of action taken clearly demonstrate

management's

commitment

to a safety culture. PSE&G IS IN FULL COMPLIANCE . NLR-N90145

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