ML18095A907
| ML18095A907 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 05/02/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N91068, NUDOCS 9105090389 | |
| Download: ML18095A907 (6) | |
Text
Public Service Electric and G_as Company Stanley LaBruna Public Service Electric and Gas Company. P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President - Nuclear Operations MAY o 2 1991 -
NLR-N91068 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-272/90-28, 50-311/90-28, 50-354/90-24 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Pursuant to the provisions of 10CFR2.201, this letter submits the response of Public Service Electric and Gas Company (PSE&G) to the notice of violation issued to the Hope Creek Generating Station on March 26, 1991.
The subject notice of violation was included in the transmittal of Inspection Reports*.50-272/90-28, 50-311/90-28, and 50-354/90-24 and cited PSE&G for not implementing measures to provide preservation of a spare core
. spray pump motor ~nd not maintaining the status of ~he-motor
'current on the inventory.
As required by the notice of violation and 10CFR2.201, this response includes the reason tor the violation, the corrective steps that have been taken and the results achieved, the corrective steps that will be taken to avoid further violations, and the date when full compliance will be achieved.
This information is provided in the attachment to this letter.
Should you.have any questions or comments on this transmittal, do not hesitate to contact us.
Attachment Sincerely,
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Document Control Desk NLR-N91068 c
Mr. Stephen Dembek Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 2
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 MAY ci 2 1991~.
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ATTACHMENT.
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-272/90-28, 50-311/90-28, 50-354/90-24 HOPE CREEK GENERATING STATION FACI.LITY OPERATING LICElfSE NPF-57 DOCKET NO~ 50~354 NLR-N91068 I.
DESCRIPTION OF VIOLATION During the period of December 3 -
7, 1990, the NRC conducted an inspection which included the areas of maintenance backlog, spare parts/materials unavailability, and spare parts/materials
- handling and storage.
In accordance with the "General* statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1990), the following violation was identified:
10 CFR 50 Appendix B, Criterion XIII states that measures shall be establishec::l to control the handling and preservation of material and equipment to prevent damage or deterioration.
Criterion V states that activities affecting quality shall be prescribed by procedures and shall be accomplished in accordance with these procedures.
Technical Specification 6.8.1 requires Regulatory Guide 1.33 and Regulatory Guide 1.33 mandates ANS-3.2 ANSI N18.7-1976 of which paragraph 5.2.13.4, states: (1) that.
measures shall be provided to control preservation of *equipment*
- _and (2) that ANSI/ASME N45.2.2-1972 shall be applied.
ANSI/ASME N45.2.2-1972, Paragraph 6.4.2(5) c-states that space heaters enclosed in electrical items shall be e~ergized~ (6) states that rotating electrical equipment shall be given insulation resistance tests on a scheduled basis; and (8) states that other maintenance requirements specified for the item shall be performed.
In addition, the licensee's procedure -NC.VP-PO.ZZ-0003(Q),
- Revision o, paragr~ph 4.2, states that the Material Control process shall provide for storage to afford the maximum protection and preventive maintenance of stored materials; and procedure VPN-PRP-02, Revision o, paragraph 6.4, states that storage Controls includes preventive maintenance as well as measures such as energizing; paragraph 8. 5:. 5,
~.tates i terns placed into stores should be promptly posted to tlie records so that stores inyentory reflects_current_status.
Contrary to the above, on December 6, 1990, measures had not been taken to provide preservation of a safety-related core spray pump motor located in the Salem/Hope Creek Warehouse No. 4 since late August 1990, in that the motor's space heater had not been connected and energized, the insulation resistance tests had not been performed on the scheduled basis, and the preventiv~
maintenance required in the maintenance managerne~t system (MMS)
Page 1 of 4
- Attachment NLR-N91068 Repl~ to Notice of Violation inyentory had not been performed on the scheduled basis.
In addition, the motor was missing from-the MMS inventory, although it* had been stored in the wareho_use greater than 3 months, and the inventory did not reflect.the current status.*
II.
RESPONSE TO VIOLATION PSE&G does not dispute the violation.
A..
Root Cause The root cause of this event has been attributed to inadequate procedures.
(1)
Procedure PM-AP.ZZ-0308(Q), "Preventive Maintenance.of stored Material", did not specify responsibilities for**
notifying Inventory Control or Site Services when Inventory Equipment (including Utility Plant Spare Equipment) is returned to stock after having been sent out for repair.
.* This communication is necessary so.
Inventory _control can update the inventory data base indicating the new storage location and Site Services Maintenance Program.
(2)
Procedure NC.NA-AP.ZZ_.0019(Q) "Procurement of Material and Services", did not require the issuance of a single purchase order for repair services of inventory equipment... As a result, *two repair service purchase orders were processed for the subject Core Spray Pump Motor~
The first purchase order was for the initial
-repair scope and the second purchase order was for additional repair work after the motor has been shipped:
to the repair facility.
Current procedures do require the attachment of a "Repair.and Return" form to the first repair purchase order for the motor, but not to the second, as the item had already been shipped.
Consequently, when the motor was shipped back under. the second purchase order, the receiving*package did not contain the "Repair and Return" form, which would start the notification process discussed in item (1) above.
B~
Corrective Actions Taken and Results Achieved The following corrective actions were initiated at the time of inspection and have subsequently been completed.
)
(1)
The spare core spray pump motor (32UP11) was immediately tagged as being nonconforming in accordance with Procedure PM-AP.ZZ-0300(Q).
Page 2 of 4
__ j
Attachment NLR-N91068 Reply to Notice of Violation (2)
A corrective maintenance work order was issued to perform the Megger Test, energize the motor heaters, check oil levels and add oil as necessary, and cover all openings to prevent dust and moisture intrusion.
All required maintenance functions*were satisfactorily completed and the equipment was determined to be up to specifications and ready for use.
(3)
The preventive maintenance cycle was then reestablished for motor 32UP11 in accordance with the existing preventive maintenance requirements stated in the applicable recurring task.
(4)
The preventive maintenance cycle is now current.
The nonconforming tag has been removed and the motor is available for use.
(5)
A review was conducted of capital spares currently in the Preventive Maintenance Program to ensure that this condition did not exist for other items.
This review identified no additional problems.
- c.
Corrective Actions Taken to Prevent Recurrence The following corrective actions are being initiated. It is felt these actions will prevent the recurrence of this or any similar violation.
(1)
Procedure PM-AP.ZZ-0308(Q), "Preventive Maintenance of Stored Material", will be revi~ed to reflect a standard communication path for.the receipt and set up of retained spare co~ponents and zero stock items and for resetting the clock for recurring preventive maintenance tasks.
(2)
Procedure NC.NA-AP.ZZ-0019(Q) will be revised to ensure the issuance of only one purchase order for service of a component at any given time.
Any additional service orders will require a change order to the original purchase order.
(3)
A computerized tracking system for capital spare equipment has been established and is presently located in a PC data base.
This trackirig system will be further automated by incorporation into the MMIS data base and will identify equipment storage set up as well as Preventive Maintenance Program applicability; (4)
Personnel training will be conducted on the administrative directive, the planned procedure changes, and the core spray pump motor event.
Page 3 of 4
.Attaqhmerit NLR-N91068 Reply to Notice of.Violation
.The above actions will be completed by August 31~ 1991.
In the interim, an administrative directive will be issued by May 15, 1991, which will provide the guidelines that will be formalized in the above procedure revisions.
. D.
Date When Full Compliance Will Be Achieved As a result of the corrective actions* discussed in.Section II.B above, PSE&G is in full compliance with the applicable requirements.
Page 4 of 4*