ML18106A678

Responds to NRC 980522 Ltr Re Violations Noted in Insp Repts 50-272/98-03 & 50-311/98-03 on 980210-20.Corrective Actions: Personnel Involved Held Accountable IAW Pse&G Procedures & Policies

ML18106A678
Person / Time
Site:	Salem
Issue date:	06/22/1998
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-272-98-03, 50-272-98-3, 50-311-98-03, 50-311-98-3, LR-N980308, NUDOCS 9806290356
Download: ML18106A678 (7)

Text

Public Service Electric and Gas Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations LR-N980308 JUN 2 2 1998 United States Nuclear Regulatory Commission Document Control Desk

• washington, DC 20555 Gentlemen:*

RESPONSE TO NR,C NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-01 AND 50-311/98-03 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Combined Inspection Report No. 50-272/98-03 and 50-311/98-03 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G) on May 22, 1998. Within the scope of this report, two violations of NRG requirements were cited. The violations were cited against 10 CFR 50, Appendix B, Criterion V, and involved; (1) Failure to evaluate the impact of unsatisfactory results on January 19, 1998 for an emergency control air compressor (ECAC) test; and (2)

Inadequate oversight of PSE&G's Corrective Action Program resulted in level 3 condition reports not being monitored for trends.

In accordance with 10 CFR 2.201, PSE&G is submitting its response to the cited violations in Attachment II to this letter. Attachment I contains the Notice of Violation as Jft./

cited by the NRG. Should there be any questions regarding this submittal, please contact us.

Attachments (2) 9806290356 980622 PDR ADOCK 05000272 G PDR 11:19. Printed on W Recycled Paper

Document Control Desk JUN '.- 2 1999 LR-N980308, C Mr. Hubert J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 .

Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris - Salem (S09)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 95-4933

ATTACHMENT 1 APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Docket Nos:50-272 Salem Nuclear Generating Station 50-311 Units 1 and 2 License Nos: DPR-70 DPR-75 During an NRC inspection conducted February 10-20, 1998, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50 Appendix B, Criterion V, requires in part that activities affecting quality be accomplished in accordance with established procedures.

1. PSE&G administrative procedure NC.NA-AP.ZZ-OOOO(Q), Revision 3, "Action Request Process," step 5.3.5.D requires in part that condition resolution for performance test acceptance criteria failures be conducted and documented.

Contrary to the above, as of February 16, 1998, NRC inspectors determined that PSE&G personnel did not perform a condition resolution to evaluate the impact of unsatisfactory results on January 19, 1998 for an emergency control air compressor (ECAC) test. Specifically, unsatisfactory starting pressure and load time test data indicated degradation of the No.1 ECAC, but no root cause or corrective actions were developed to preclude recurrence. *

2. PSE&G procedure NC.NA-AP.ZZ-0006, Revision 15, "Corrective Action Program," requires in part that level 1, 2, and 3 condition report issues and corrective actions be monitored for adverse trends.

Contrary to the above, inadequate oversight of PSE&G's Corrective Action Program resulted in level 3 condition reports not being monitored for trends since program inception in July 1995. Additionally, this issue was

. identified in two consecutive annual Quality Assurance corrective action program audits.

These are Severity Level IV violations (Supplement I).

1

Attachment 2 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-03 AND 50-311/98-03 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980308 PSE&G RESPONSE TO VIOLATION A 1 PSE&G concurs with the violation.

(1) The reason for the violation.

The reason for the violation is attributed to inadequate communication between the corrective action coordinator and the operation department personnel.

On January 19, 1998, the No. 1 Emergency Control Air Compressor (ECAC) failed the acceptance criteria for starting pressure and load time requirements as stated in procedure S1 .OP-PT.CA-0001 "Emergency Control Air Compressor Operability."

Procedure S1 .OP-PT.CA-0001 had been recently revised to add section 5.2 addressing ECAC performance, such that the procedure now contained two sections; (1) Section 5.1 which validates the ECAC start on low header air pressure is a 31 day surveillance, and (2) Section 5.2 which addresses compressor performance is a 92 day surveillance.

Both sections were performed on January 19, 1998, and neither section met its acceptance criteria. Section 5.1 was satisfactorily re-performed. Section 5.2 was not re-performed, but the ECAC was judged operable with justification provided in the procedure comments section.,

Two Action Requests (AR) were generated to document the problems. AR/CM 80119217 identified that the ECAC may not start as required and that the pressure switch may *need to be re-calibrated. AR/CR 980119263 identified that the acceptance criteria for percentage of time loaded had been exceeded. Although the AR/CR indicates this second issue was to be formally evaluated by System Engineering, the corrective action review team administratively canceled the AR/CR with a reference to AR/CM 980119217. However since the test (section 5.1) was re-performed satisfactorily, the CR was inappropriately cancelled believing the procedure was satisfactorily completed.

Less than adequate communication resulted in the corrective action review team believing that both sections of the procedure were re-performed satisfactorily, when in fact only one section (5.1) had been re:-performed.

The ECAC performance test (section 5.2) of the procedure and its acceptance criteria were created to provide trending indication of compressor performance. The results 1

Attachment 2 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-03 AND 50-311/98-03 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980308 were not intended to be used to prove compressor capacity since the test is nof conducted at the required minimum pressure.

(2) The corrective steps that have been taken.

1. Personnel involved in this event will be held accountable in accordance with PSE&G's

. procedures and policies.

2. On February 16, 1998, AR/CR 980216085 was initiated documenting the failure to initiate a CR and to evaluate the acceptance criteria.

3. A preventive maintenance change request form has been initiated to create a separate recurring task for section 5.2 of procedure S1 .OP-PT.CA-0001 "Emergency Control Air Compressor Ope.rability."

(3) ThE:**corrective steps that will be taken to avoid further violations.

1. The acceptance criteria for section 5.2 of the procedure will be revised to clearly indicate that the stated value(s) are to be used for trending purposes only. This revision will be in place prior to the next scheduled performance of the test.

2. The corrective action group will share this event with the work management center for lessons learned. This action will be complete by July 30, 1998.

(4) The date when full compliance will be achieved.

PSE&G achieved full compliance on February 16, 1998, when the condition report 980216085 was issued and the test results were evaluated.

2

Attachment 2

. RESP()f\)f.X::: TO NOTICE OF VIOLATION

• IN-S:-'~c**nor-3 R~;rok:'r 50-272/98-03 AND 50-311/98-03

!'..".. *-~~-iiGENfRATING STATION UNI"!' NOS. 1 AND 2 LR-N980308 PSE&G RESPONSt:: 'fC Vh.J:i..AflON A 2 PSE&G concurs with the violation (1) The reason for the violation.

The reason for the violation is attributed to ineffective management oversight of the Corrective Action Program (CAP).

In November 1997, PSE&G management had recognized the apparent shortcomings in its oversight of the CAP and had taken steps to identify root causes and corrective actions. Additionally during this time frame, PSE&G management created a team to conduct an organizational review of selected groups, including the corrective action group. The team mission was to fundamentally rethink and redesign the Nuclear Business Unit processes to achieve sustainable improvements in problem solving, speed, and communication.

In addition to the efforts stated above, the Senior Man~gement Team developed a level 1 Action Plan to continue performance improvement and strengthen the value of information collected in the corrective action program. The plan was issued on February 18, 1998 and includes, in part; (1) Improving the overall effectiveness of trend reports; and (2) Improving line management's ownership and oversight of the corrective action program for their respective departments. Some of the corrective actions developed within the plan are identified below.

(2) The corrective steps that have been taken.

1. The Action Plan has been incorporated into the Nuclear Business Unit's overall

• 1998-business plan.

2. Action Plan updates are provided directly to the Chief Nuclear Officer and President of the Nuclear Business Unit on a monthly basis.

3. The 1997 fourth quarter trend report, which was issued on February 1998, included an evaluation of low-level condition resolution reports (significance level 3) to identify trends across all departments.

3

Attachment 2 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-03.AND 50-311/98-03 SALEM GENERATING STATION UNIT NOS. 1 AND 2 LR-N980308

4. The first quarter 1998 trend report was issued on May 1998, and included a more detailed trend evaluation of significance level 3 condition reports.

5. Self-assessment schedules have been developed to review the effectiveness of root cause investigations and trend report effectiveness for the corrective action program. The results of the self-:assessments will be used to revise the Action Plan as appropriate.

(3) The corrective steps that will be taken to avoid further violations.

1. The design and philosophy of the correction action program has been discussed and agreed to by the Senior Management Team. A training schedule has been developed for managers and other appropriate management personnel on corrective action program requirements and its use as a tool to improve plant and personnel performance. This training will take place during the third and fourth quarter of 1998.

2. Procedure NC.NA-AP.ZZ-0006(Q) "Corrective Action Program," will be revised to clarify the responsibility requirements for trending of significance level 3 condition reports. This revision .will be in place by December 1, 1998.

(4) The date when full compliance will be achieved.

PSE&G achieved full compliance on February 1998, when PSE&G re-established management oversight of the CAP and the issuance of the 1997 fourth quarter trerid report including the evaluation of low-level condition resolution reports (significance level 3).

4