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)

Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and G~s 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 Commiss~on 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.

Sincerely, Attachment 9007170193 900710 PDR ADOCK 05000272 Q PDC

Document Control Desk 2 JUL l o 1991 NLR-N90145 c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 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

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 _ye~r 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 Manag~ment 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 Page 4 of 4