ML20098E413

Suppls Response to NRC Ltr Re Violations Noted in Insp Repts 50-272/84-15 & 50-311/84-15.Corrective Actions:Review of Work Order History on CD-M-60 Equipment Being Performed

ML20098E413
Person / Time
Site:	Salem
Issue date:	09/21/1984
From:	Liden E Public Service Enterprise Group
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8409280427
Download: ML20098E413 (4)

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~ Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department September 21, 1984 U. S. .~ Nuclear Regulatory Commission Region 1 631 Park Avenue

King of. Prussia, PA 19406

' Attention: _Mr. Richard W. Starostecki, Director Division of Project and Resident Programs

Dear Mr. Starostecki:

-SUPPLEMENTAL RESPONSE NRC COMBINED INSPECTION 50-272/84-15 AND 50-311/84-15 SALEM GENERATING' STATION UNITS.NO.-1 AND 2 DOCKET NOS. 50-272 AND~30-311 During the referenced inspection, a violation was identified for failure to develop a complete and accurate Master

Equipment' List (MEL). As a result of our' response, dated July 13, 198.4l -the original violation ~has been revised to address improper-_ training of appropriate personnel in the use of the MEL. PSE&G hereby provides a supplemental response to the item of violation

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ITEM OF VIOLATION

. . A'. Thh May 6, 1983 Order Modifying the License Effective Immediately~ required that the licensee implement and/or maintain the items specified in the licensee's letter dated April 28, 1983.

.The' licensee's April 28, 1983 letter stated that the following'csrective actions were complete: ,

l.. -Instruct appropriate personnel in purpose and use of

.MEL'(C.1.a.2); and, 8409280427 840921 0500027 h

The Energy People $DRADOCK

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ow G 2; Conduct. a training 1 program to. ensure that work' orders

, are? properly classified-(C.3.a.2)..

< Contraryf to the Above:

, Personnel involved with classifying Work Orders MD946229-

_and)MD946237'were not~ properly trained in the -

icla'ssification logic detailed.in memorandum, CD-M-60 which;is an addendum to the-.MEL, in that the work orders were:not properlyLclassified as-safety-related.

RESPONSE

cIn ourfresponse, dat'e'd: July 13, 19844.the.following corrective

- J. actions .were rproposed:

1. . Develop and present a specific training program for appropriate. personnel to ensure familiarity with the-existence of -certain safety-related components in the turbine area.

2'. Modify the MEL Systems-List to highlight the existence of these components.

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.3. -Provide more'. frequent issuance of MEL revisions.

TheseDcorrective actions:are'now complete.

.The revised notice ~of violation accepted the PSE&G proposed-

. corrective-action in the area of training as being suf ficient

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rto, preclude'recurrencer however, it requested resolution in

. the.following areas of concern:

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.a, ' ass"rance as to the-adequacy of utilizing sponsor eng, leers.to' provide' classifications s

b. assurance that safety-related equipment, such as-that listed in CD-M-60, was maintained so as to enhance _,

safety J", ci . ' the degree to which misclassifications have occurred and. actions necessary~to prove operability of

, - equipment ~ that may have been improperly classified ]

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'Mr. R.'W. Starostecki 9/21/84

.We have examined our method of referring to . sponsor engineers for-proper classifications, and conclude that this remains the best available information source for resolution of apparent

-conflict. The. training program conducted served to reinforce sponsor engineer '(as well as OA. and Station _ personnel) awareness of'CD-M-60 type equipment, and we are confident that future

' errors:of the type identified will not occur.

-In order to ascertain the performance of proper installation and maintenance, and continued operability of CD-M-60 equipment, for.which work orders may have been misclassified, a review of the work order history on this equipment is being performed.

For any equipment which'is found to not have been installed or maintained in accordance with appropriate safety-related type procedures or using appropriate materials, an evaluation as to a need for specific corrective action to assure continued

-operability will be made and such action performed.

As you are aware, PSE&G is developing a formalized preventive maintenance program. During the various reviews that were conducted for that program, a number of inconsistencies in the Master Equipment List were identified and documented. Although a relatively small percentage of the' inconsistencies identified constituted nonconservative classifications of equipment, it is conceivable that they could have resulted in nonconservative

, work order classifications. To provide further assurance that safety-related equipment remains operable, the work order history for this equipment is being reviewed in a manner similar to'that described abowe for the CD-M-60 equipment, and appropriate corructive actions will be taken.

We are-currer.tly approximately 58% through the aforementioned review efforts, which involve approximately 133 work orders. To date, only'23 non-conservatively classified work orders have been found, and these have been evaluated as not requiring corrective action to ensure operability.

In order to assure the operability of any equipment which, in the future, may be identified as having nonconservative classifications, formal procedural requirements will be instituted:to perform a review and resolution of the specification, procurement, installation,_te7% and maintenance of such equipment.

%e anticipate that the above actions will be complete by

) . November 1, 1984, after which time you will be notified of final results.

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, Mr. R. W. .Starostecki 9/21/84 PSE&G is keenly. aware of the vital importance of the correctness

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and completeness of the MEL, as-it is a major source document used in assuring proper procurement, installation, maintenance, and operability of safety-related plant systens, structures, and components. We are currently undertaking a' comprehensive program to enhance many aspects of our operations associated with'the MEL. Some major facets of this program involve:

• enhanced " user friendliness" through on-line computerization and restructuring of data

• enhanced training in understanding and using the MEL development of enhanced guidelines and training for Sponsor Engineers to assist and ensure consistency in classifications

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• review of industry experience in applications of MEL-type documents for ' potential use at PSE&G We feel that the aforementioned specific corrective actions, and our dedication to longer term, overall improvement of MEL associated programs will help assure efficient, safe, and correct conduct of our Nuclear Operations.

If you have any questions, please feel free to contact us.

Sincerely, w

E. A. Liden Manager - Nuclear Licensing and Regulation C Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Sr. P,esident Inspector

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