ML18106A801

Responds to NRC 980710 Ltr Re Violations Noted in Insp Repts 50-272/98-06,50-311/98-06 & 50-354/98-06,respectively. Corrective Actions:Personnel Involved in Events Will Be Held Accountable IAW Pse&G Policies & Revised Procedures

ML18106A801
Person / Time
Site:	Salem, Hope Creek
Issue date:	08/03/1998
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-272-98-06, 50-272-98-6, 50-311-98-06, 50-311-98-6, 50-354-98-06, 50-354-98-6, LR-N980367, NUDOCS 9808110027
Download: ML18106A801 (9)

Text

Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company . P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations AUG 03 1998 LR-N980367 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-05, 50-311/98-05 AND 50-354/98-06 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 Combined Inspection Report No. 50-272/98-05 and 50-311/98-05 for Salem Nuclear Generating Station Unit Nos. 1 and 2 was transmitted to Public Service Electric & Gas Company (PSE&G) on July 10, 1998. Within the scope of this report, two violations of NRC requirements were cited. The violations were cited against Technical Specification 6.8.1.a, and involved failures to (1) implement procedures; and (2) establish written procedures to collect drinking water, fish, and invertebrate samples.

Violation Bas stated in Appendix A to Inspection Report 50-272/98-05 and 50-311/98-05 is also described within the body of the Inspection Report as applicable to the Hope Creek Generating Station and identified as VIO 50-354/98-06-01. Therefore the response to violation B is applicable to all three-docket numbers.

In accordance with 10 CFR 2.201, PSE&G is submitting its response to the cited violations in Attachment 2 to this letter. Attachment 1 contains the Notice of Violation as cited by the NRC. Should there be any questions regarding this submittal, please contact us.

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9808110027 980803 PDR ADOCK 05000272 G

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AUG 03 1998 Document Control Desk LR-N980367 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. R. Ennis, Licensing Project Manager - Hope Creek U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris - Salem (X24)

USNRC Senior Resident Inspector Mr. S. Pindale - Hope Creek (X24)

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

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ATTACHMENT 1 LR-N980367 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 between May 24, 1998 and June 21, 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 Technical Specification 6.8.1.a requires in part that written procedures shall be implemented covering the activities described *in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, dated February 1978. RG 1.33 requires procedure review and approval, safety-related equipment control, and measuring and test equipment calibration procedures. The following PSE&G procedures implement.these RG requirements, respectively:

NC.NA-AP.ZZ-0059 (NAP-59), section 5.2 requires that 10 CFR 50.59 applicability reviews be performed for proposed procedure revisions to determine whether a safety evaluation is necessary.

NC.NA-AP.ZZ-0083 (NAP-83), section 5.2 requires that free-standing equipment in safety-related areas be either restrained or evaluated for use under design basis seismic conditions.

• NC.NA-AP.ZZ-0022 (NAP-22), section 3.7 requires that the calibration of measuring and test equipment be current prior to use.

Contrary to the above, on May 4, 1998, NRC inspectors identified examples of failures to implement these procedures, specifically:

Procedure writers failed to perform a 10 CFR 50.59 applicability review and safety evaluation for a revision to procedure SC.MD-CM.ZZ-0024, lnservice Single Cell Battery Charging, as required by NAP-59 .

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ATTACHMENT 1 LR-N980367 Maintenance technicians failed to ensure that a portable battery charger used for a single cell charge on a vital DC battery was properly restrained in or evaluated for use in this safety-related area as required by NAP-83.

Maintenance technicians failed to ensure that voltage and current meters on a portable battery charger used for a single cell charge on a vital DC battery were properly calibrated as required by NAP-22.

This is a Severity Level IV violation (Supplement I).

B. Technical Specification (TS) 6.8.1.i requires in part that written procedures shall be established for Offsite Dose Calculation Manual (ODCM) implementation. Section 4.1 of the ODCM describes the sampling program objectives of the Radiological Environmental Monitoring Program (REMP), and states that the operational phase of the REMP is conducted in accordance with the requirements of TS 3.12. TS 3.12 requires that drinking water, fish, and invertebrate samples be collected.

Contrary to the above, prior to June 12, 1998, PSE&G had not established written procedures to collect drinking water, fish, and invertebrate samples.

This is a Severity Level IV violation (Supplement IV) .

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ATTACHMENT 2 LR-N980367 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-05, 50-311/98-05 AND 50-354/98-06 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 PSE&G RESPONSE TO VIOLATION A PSE&G concurs with the violation.

(1) The reason for the violation.

The reason for the violation is attributed to personnel error, in that personnel involved in these events failed to properly implement and follow the applicable procedures.

A. NC.NA-AP.ZZ-0059 (NAP-59) example.

Personnel failed to perform adequate 10CFR50.59 applicability reviews during past revisions of the maintenance procedure for single cell battery charging. Although the isolation requirements in the original Salem single cell charging procedure may not

• have been adequate, 10CFR50.59 applicability reviews for changes to the isolation requirements during past procedure revisions* did not adequately assess all requirements for connecting a non class-1 E battery charger to an operable class-1 E battery. Although this event is attributed to personnel error, a contributing factor to this violation was a weak 10CFR50.59 program when these revisions took place in 1994.

Since then, improvements have been made to the 10CFR50.59 program B. NC.NA-AP.ZZ-0083 (NAP-83) example.

Maintenance technicians and supervisors failed to properly implement the requirements of NAP-83, in that the battery charger was not properly restrained, or evaluated for its impact on the safety related battery. A contributing factor to this violation was weak knowledge of the requirements of NAP-83 by maintenance personnel, including supervision.

C. NC.NA-AP.ZZ-0022 (NAP-22), example.

Maintenance technicians failed to properly implement the requirements of NAP-22, in that they did not ensure that the installed instrumentation was properly calibrated prior to its use. A contributing factor to this violation was the lack of clarity in the requirements of procedure SC.MD-CM.ZZ-0024(0), "lnservice Single Cell Battery Charging." Specifically, the procedure did not clearly identify the Measuring and Test Equipment (M&TE) instrumentation requirements for voltage and current readings.

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ATTACHMENT 2 LR-N980367 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-05, 50-311/98-05 AND 50-354/98-06 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 The maintenance technicians properly recorded the voltage reading using the proper M&TE instrumentation called for by the maintenance procedure, which is the reading taken to determine proper charging of the battery cell. However, the current readings, which are taken in accordance with Attachment 4 of the procedure, and are taken for trending purposes only (and not part of the acceptance criteria), were taken utilizing the installed amp meter without verifying proper calibration.

(2) The corrective steps that have been taken.

Personnel involved in all examples and still employed by PSE&G have been held or will be held accountable in accordance with PSE&G policies.

Example A - NC.NA-AP.ZZ-0059 (NAP-59)

1. A self-assessment of the 50.59 process was performed in early 1996 to address concerns relative to the quality and overall condition of the 50.59 program. As result of the self-assessment, and other continuing improvements to the program a number of corrective actions have been implemented. These actions improved the quality of the process. Some of these actions are listed below:

The administrative procedure was revised to eliminate misleading examples and to include good practices from other facilities, and 10CFR50.59 process has been improved by establishing formal training and

. requalification requirements for 10CFR50.59 preparers, peer reviewers, and approvers.

2. The failure to perform an adequate 50.59 review was included in the June 1998 50.59 Newsletter for general communication purposes.

Example B - NC.NA-AP.ZZ-0083 (NAP-83)

The battery charger was promptly removed from the battery room on May 4, 1998.

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ATTACHMENT 2 LR-N980367 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-05, 50-311/98-05 AND 50-354/98-06 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 Example C - NC.NA-AP.ZZ-0022 (NAP-22)

• Procedure SC.MD-CM.ZZ-0024 (Q) was placed on administrative hold on May 11, 1998, to prevent use of the procedure. This procedure will remain inactive until satisfactory resolution *Of the proper isolation of the single cell battery charger from the Class -1 E battery.

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

Example A- NC.NA-AP.ZZ-0059 (NAP-59)

1. This issue will be included* in the next two-year cycle of 10CFR50.59 refresher training starting in July 1998.

2. The "10CFR50.59 Program Guidance" procedure, NC.NA-AS.ZZ-0059, will be revised to include examples concerning the connection of temporary equipment to operable systems as added guidance, when performing 10CFR50.59 reviews. The procedure will be revised by August 31., 1998.

3. A review of maintenance procedures is being performed to determine if other procedures allow temporary equipment to be installed on operable systems. If maintenance procedures exist that connect temporary equipment to operable systems, a review will be performed to determine if the effect of the temporary equipment on system operation has been properly evaluated. This review will be completed by August 7, 1998.

Example B - NC.NA-AP.ZZ-0083 (NAP-83)

The requirements of NAP-83 will be reviewed in the in-service training of maintenance personnel. This training will be completed by S~ptember 30, 1998.

Example C - NC.NA-AP.ZZ-0022 (NAP-22)

Procedure SC.MD-CM.ZZ-0024 (Q) will be revised to clarify the M&TE requirements for voltage and current readings. This revision will be in place prior to SC.MD-CM.ZZ-0024 (Q) being re-activated.

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ATTACHMENT 2 LR-N980367 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-05, 50-311/98-05 AND 50-354/98-06 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 (4) The date when full compliance will be achieved.

PSE&G achieved compliance on May 4, when the battery charger was removed from the battery room and achieved full compliance on May 11, 1998, when procedure SC.MD-CM.ZZ-0024 (Q) was placed in an inactive status.

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ATTACHMENT 2 LR-N980367 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT 50-272/98-05, 50-311/98-05 AND 50-354/98-06 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311 AND 50-354 PSE&G RESPONSE TO VIOLATION B PSE&G concurs with the violation (1) The reason for the violation.

The apparent cause for the violation is attributed to an organizational deficiency in the implementation of the Offsite Dose Calculation Manual/Rad.iological Effluent Monitoring Program (ODCM/REMP). The organizations responsible for the implementation of the ODCM did not ensure that the Technical Specification required procedures for compliance with the sampling program objectives of the REMP were in place for the portions of the ODCM that were implemented by vendors Although written procedures had not been established to collect drinking water, fish, and invertebrate samples, none of these samples were missed.

(2) The corrective steps that have been taken.

1. The ODCM has been reviewed, and procedures exist to implement the remainder of the ODCM.

2. The organizational deficiency has been addressed via our Corrective Action Program, clear program oversight and ownership has been established.

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

A procedure will be developed to provide direction to vendors for use in collecting drinking water, fish, and invertebrate samples. This procedure will be issued by September 30, 1998 prior to the next scheduled sample collection.

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

PSE&G will achieve full compliance by September 30, 1998, when the procedure to provide direction to vendors for use in collecting drinking water, fish, and invertebrate samples will be issued prior to the next scheduled sample collection.

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