ML18093B504

Responds to NRC 890208 Ltr Re Violations Noted in Insp Repts 50-272/88-24 & 50-311/88-27.Corrective Actions:Spilled Fuel Oil Cleaned,Emergency Diesel Generator Returned to Svc & Individuals Involved Counseled

ML18093B504
Person / Time
Site:	Salem
Issue date:	03/10/1989
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89044, NUDOCS 8903210138
Download: ML18093B504 (5)

Text

Public Service Electric and Gas

• ~ley La~runa Company Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-:339-4800 Vice President - Nuclear Operations MAR 1 O 1989 NLR-N89044 United States Nuclear Regulatory Commission Document Control Desk Washington D.C. 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC COMBINED INSPECTION REPORT NO. 50-272/88-24 AND 50-311/88-27 SALEM GENERATING STATION - UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311

• Public Service Electric and Gas Company (PSE&G) has reviewed the subject NRC Inspection Report dated February 8, 1989 and the Notice of Violation forwarded therein regarding a failure to properly implement procedures for performing corrective maintenance on the emergency diesel generator day tank level monitoring system. Our response to this violation and a discussion ~i the appropriate corrective actions to prevent future Violations is provided in the Attachment to this letter.

If you have any questions regarding this transmittal, feel free to contact me directly.

Sincerely Attachment

• 8903210138 890310 PDR G

ADOCK 05000272 PNU

Document Control Desk 2 MAR 10 1W9 NLR-N89044 C Mr. J. C. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. W. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

_I

• -=*

ATTACHMENT TO NLR-N89044 PUBLIC SERVICE ELECTRIC AND GAS SALEM GENERATING STATION UNIT NOS. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION Your letter dated February 8, 1989 transmitted combined NRC Inspection Report 50-272/88-24 and 50-311/88-27 for Salem Units 1 and 2 which included a Notice of Violation pertaining to Salem Unit 1 only. The specific item identified in the notice and our response is discussed in the following paragraphs.

VIOLATION 272/88-24-01 Technical Specification 6.8.1 requires that procedures be established, implemented and maintained covering surveillance and test activities of safety related equipment.

Contrary to the above, on December 12, 1988, a procedure was not established and implemented for the calibration of the lC emergency diesel generator (EDG) day tank level instrument.

Consequently, a day tank was overfilled and the resultant fuel

• oil spill caused an EDG to be out of service until the fuel oil was cleaned up.

RESPONSE

1. ROOT CAUSE Contrary to the Statement of Violation, established procedures were being used at the time the day tank overfill occurred.

Maintenance procedure M3I, "Auxiliary Control Switches Calibration" and Surveillance Procedure SP(0)4.8.1.1.3A, "Electric Power Systems - Diesel Fuel Oil" were implemented and in use during the corrective maintenance activity. Station personnel were attempting to use these procedures in combination to trouble-shoot and calibrate a faulty tank level indicator.

Neither of the procedures provided specific instructions for the activity.

The root cause of the event was the use of inadequate procedures to perform corrective maintenance on a safety related system.

This is attributed to the following factors; 1) a lack of proper management oversight in the planning of the activity, and 2) a lack of supervisory awareness of the need for specific instructions when performing maintenance on safety related equipment .

• 1

ATTACHMENT TO NLR-N89044

2. CORRECTIVE ACTIONS IMPLEMENTED A discussion of the immediate actions taken by PSE&G in response to the overfill of the EDG day tank was presented in NRC Combined Inspection Report 50-272/88-22 and 50-311/88-24. Those actions consisted of; 1) cleaning up the spilled fuel oil and returning the affected EDG to service, 2) a detailed review by the Operations Department of the events leading to the day tank overfill, and 3) subsequent counseling of individuals responsible for the evolution on the need for proper procedures prior to performing maintenance on safety-related equipment.

Additionally, the EDG day tank level control system calibration procedure will be reviewed and upgraded to provide adequate guidance for the full calibration of the system.

3. LONG TERM ACTIONS TO AVOID FUTURE VIOLATIONS Presently, two programs exist which were initiated by PSE&G to address the issue of procedural use, compliance with procedures, and procedural adequacy.

The first of these programs is the Salem Work Practices Improvement Program which was discussed in our transmittal dated December 27, 1988. This program was developed in response to concerns raised in NRC Combined Inspection Report 50-272/88-19 and 50-311/88-20, regarding the use of procedures and procedural compliance at Salem Station. The program includes improving awareness on the part of personnel as to when procedures are required and the need for strict adherence to procedural requirements. PSE&G is now in the process of implementing the program.

The second program was initiated in August 1988 and consists of an effort to evaluate all maintenance related activities within the Station and to upgrade procedures controlling these activities where necessary. A key element of this program is to evaluate generic procedures and identify where more specific guidance is required.

2

ATTACHMENT TO NLR-N89044

4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The upgrade to the EDG day tank calibration procedure will be completed prior to the performance of any additional calibrations or April 30, 1989, whichever comes first.

Implementation of the Salem Work Practices Improvement Program is underway and will be complete by June 30, 1989.

The procedure upgrade program is projected to be complete by December 31, 1992 .

• 3