ML18094B308

Responds to NRC 900108 Ltr Re Violations Noted in Insp of Licenses DPR-70 & DPR-75.Corrective Actions:Emergency Operating Procedures Revised & Resubmitted w/10CFR50.59 Safety Evaluation & Program Document to Be Reviewed

ML18094B308
Person / Time
Site:	Salem
Issue date:	02/08/1990
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N90027, NUDOCS 9002260437
Download: ML18094B308 (7)

Text

• Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nuclear Operations FEB O8 ~90 NLR-N90027 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION EMERGENCY OPERATING PROCEDURE CHANGES, TECHNICAL SPECIFICATION 3.0.3 ACTIONS AND POWER RANGE INSTRUMENTATION CHANNEL FAILURE SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Public service Electric and Gas Company (PSE&G) has received the Notice of Violation transmitted in your letter of January 8, 1990. As stated in your letter, two of these violations were discussed in detail at the December 11, 1989 enforcement conference. PSE&G understands the NRC's concerns for these issues and appreciates having had the opportunity to communicate the full details and evaluations of the events at the enforcement conference. Pursuant to 10 CFR 2.201, PSE&G's 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 9002260437 900208 PDR ADOCK 05000272 G PNU

Document Control Desk 2 FEB o 8 'la990 NLR-N90027 C Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. w. T. Russell, 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 TO NLR-N90027 The NRC Notice of Violation dated January 8, 1990, identified three violations. The violations and PSE&G's responses are provided below.

APPENDIX A NOTICE OF VIOLATION 10 CFR 50.59 permits a licensee to make changes to procedures as described in the safety analysis report without prior NRC approval, unless the proposed change involves an unreviewed safety question.

Updated Final Safety Analysis Report (UFSAR) Section 13.5.3 describes the implementation of Emergency Operating Instructions (procedures)to assure that proper actions are taken to combat malfunctions.

UFSAR Section 6.1.1.4 requires the emergency core cooling systems (ECCS) to perform its safety function assuming the most limiting single failure.

Contrary to the above, on November 17, 1989, emergency operating procedure changes were implemented without prior NRC approval; and those changes reestablished a single failure vulnerability in an ECCS. thereby increasing the probability of failure of the ECCS during an accident.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION.

The root cause of this event has been attributed to failure to implement the requirements of Station Administrative Procedure AP-32 pertaining to performance of 10 CFR 50.59 safety evaluations.

CORRECTIVE ACTIONS The Emergency Operating Procedures (EOPs) were revised and resubmitted with a 10 CFR 50.59 safety evaluation completed by the .Technical Department system engineering group.

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CORRECTIVE ACTIONS (Cont.)

The procedure for performing 10 CFR 50.59 safety evaluations has been reviewed. Guidance from NSAC 125 and enhancements identified as a result of PSE&G internal audits have been incorporated. Documentation of UFSAR sections reviewed is now a requirement.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE The EOP program document, Administrative Directive 44, will be reviewed and clarified as follows:

1. All EOP revisions will be reviewed by a station qualified reviewer (SQR) from the Technical Department;

2. If applicable, based on SQR determination, a 10 CFR 50.59 safety evaluation will be performed, and reviewed by SORC.

These clarifications will be incorporated by February 28, 1990.

To address the noncompliance with a station Administrative Procedure AP-32, the following actions will be completed by February 28, 1990:

1. The event will be reviewed with all SORC members;

2. The event will be reviewed with all station personnel who apply AP-32;

3. AP-32 will be revised to clarify the requirement to perform a 10 CFR 50.59 applicability review. This change will provide the necessary enhancement to the SORC process in accordance with commitments mad~ during the December 11, 1989 NRC enforcement conference.

PSE&G is in full compliance.

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• VIOLATION 50-272/89-27-02 Technical Specification (TS) 3.0.3 states, in part; when a limiting condition for operation (LCO) is not met except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above on November 9 and on November 17. 1989. the plant was under TS 3.0.3 for a period of over one hour and actions were not initiated to place the plant in HOT STANDBY.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION.

The root cause of these events has been attributed to procedural inadequacies.

The Technical Specification interpretation contained in OD-12 at the time stated"*** if it is likely that compliance with the Action Statement can be achieved within one hour, load does not have to be reduced." This interpretation led operations personnel to believe that up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> could elapse prior to initiating a plant shutdown. PSE&G recognizes that this interpretation of T/S 3.0.3 is inconsistent with NRC intent regarding initiation of plant shutdown.

CORRECTIVE ACTIONS The Technical Specification interpretation (OD-12) for T/S 3.0.3 was revised and approved by SORC on December 22, 1989. The present interpretation clearly and strongly defines PSE&G policy regarding completion of required actions when T/S 3.0.3 is entered. The revised interpretation states in part,

" .*. immediately begin preparation to place the unit in the next lower mode of operation *** within one hour of entry into 3.0.3, start a load reduction or cooldown ** 11

• This revised interpretation has been issued to all Operation Department Manual (ODM) holders.

Operations management have instructed all licensed operators on the new Technical Specification interpretation for T/S 3.0.3.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE These events will be reviewed by the PSE&G Nuclear Training Center. Lessons learned will be incorporated into the next cycle of Licensed Operator requalification training.

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CORRECTIVE ACTIONS TO PREVENT RECURRENCE (Cont.)

Administrative Directive 45 {AD-45), Technical Specification Interpretation Program, is under development and will require that all Technical Specification interpretations be approved by SORC. This procedure will be issued by April 1990.

PSE&G is in full compliance.

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VIOLATION 50-272/89-27-04 10 CFR Part 50, Appendix B, Criterion XV'I of the Nuclear Quality Assurance Department Manual require that measures shall be established to assure that conditions adverse to quality are promptly identified, corrected and prevented from recurring.

Contrary to the above, as of November 29, 1989. the licensee's measures established to assure that conditions adverse to quality are promptly identified. corrected and prevented from recurring were not adequate, in that; power range instrumentation channel N44 failed to function properly on November 9. 1989, when the channel was tripped in accordance with Technical Specifications and operations procedure IV 10.3.1 and actions were not taken until November 30, 1989 to determine and correct the root cause of the channel's malfunction.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION PSE&G agrees with the NRC's emphasis on timely determination of root cause for safety significant issues. PSE&G believes that the actions taken on November 9, 1989, although timely and appropriate, were directed towards prevention of recurrence and failed to address the full root cause of the condition in a timely fashion. The root cause of this Violation is attributed to insufficient management oversight of the process.

CORRECTIVE ACTIONS Operating procedure IV.10.3.1 was changed and revised on November 9, 1989.

On December 6, 1989, after completion of the bench testing, Technical Department Engineering Memo 89-152 was issued to document the root cause determination for the event.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE station Management will include a discussion of this event as a training tool to further emphasize to station personnel the need to address root cause issues in a timely and complete fashion.

The use of AP-6 as a guidance document will also be stressed during these discussions. These activities will be completed by February 28, 1990.

In addition to the above, PSE&G has an established program for training management personnel in root cause analysis.

Approximately 70 individuals have participated in this program to date. This ongoing program reflects PSE&G managements commitment to proper analysis and root cause determination.

PSE&G is in full compliance.

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