IR 05000354/1997003
| ML20217Q085 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/15/1997 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| References | |
| 50-354-97-03, 50-354-97-3, NUDOCS 9708290142 | |
| Download: ML20217Q085 (2) | |
Text
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50 354/97-03
Dear Mr.Eliason:
This letter refers to your July 28,1997 correspondence (LR-N970427), in response to our June 12,1997 letter.
Thank you for informing us of the corrective and preventive actions for the Notice of Violation, as documented in your letter. The violation involved two examples of Hope
Creek maintenance technicians failing to adhere to established procedural guidance for safety-related work activities. Your response to the violation indicates that ycu have implemented measures to prevent recurrence, including the cor. duct of a department-wide maintenance intervention and issuance of clear guidance regarding procedural adherence to all your employees. We will reviev the effectiveness of these actions in a future inspection.
Your cooperation with us is appreciated.
Sincerely, i
Original Signed By:
James C. Linville, Chief Projects Branch 3 Division of Reactor Projects Docket No. 50-354 fh
{l
.
9708290142 970815 PDR ADOCK 05000354 G
.
.
.
.
-
.
.
Mr. Leon R. Eliason
cc:
L. Storr, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President Nuclear Engineering E. Salowitz, Director 14aclear Business Support D. Powell, Manager Licensing and Regulation A. C. Tapert, Program Administrator J. McMahon, Director - Quality Assurance & Nuclear Safety Review M. Berilla, General Manager Hope Creek Operations cc w/cy of Licensee's Letter:
A. F. Kirby, Ill, External Operations Nuclear, Delmarva Power & Light Co.
Jeffrey J. Keenan, Esquire J. A. IsabeKa, Manager, Joint Generation Atlantic Electric Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township R. Kankus, Joint Owner Affairs State of New Jersey State of Delaware Distribution w/ copy of Licensee) Responso Letter:
Region l Docket Room (with concurrences)
Nuclear Safety information Center (NSIC)
NRC Resident inspector PUBLIC L. Olshan, Project Manager, NRR D. Jaffe, Project Manager, NRR W. Dean, OEDO J. Stolz, PD12, NRR J. Linville, DRP S. Barter, DRP C. O'Doniell, DRP DOCUMENT NAME: g:\\ branch 3\\hc9703.rpy n.
...pv.: ihi. e. cum.nt, ino6c.i. in th. no.: c - copy without.ti. chm.ni/.ncio.ur.
. - Copy with.tt. chm.nt/.netosure N* - No copy
_
OFFICE Rl/DRP,3 g (klg
/
/
l NAME JLinv447 DATE 08/15/97 08/ /97 08/ /97 08/ /97 08/ /97 OFFICIAL RECORD COPY
_.
.. -
,
-
.
.
,
ew.c service Escuic and Gas
'
Company
' Louis F. Stor Pubhc Servce Electre and Gas Company P O Box 236 Hancocks Brcge. NJ 08038 009-339 5700 l
'JUL 2 81997 s.no vc. s ww.., ow.-
LR-N970427 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-03 HOPE CREEK GENERATING STATION
.
FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:
Pursuant to the provisions of 10CFR2.201, Public Service Electric and Gas Company (PSE&G) hereby submits a reply to the Notice of Violation (NOV) issued to the Hope Creek Generating Station in a letter dated June 12, 1997.
This violation involved two examples of the failure of the Hope Creek Maintenance Department to adhere
'
to established procedures and was cited as a violation of 10CFR50, Appendix B, Criterion XVI.
The details of the reply are contained in the-attachment to this letter.
Should you have any questions or comments on this transmittal, do not hesitate to contact us.
Sincerely,
,-
Attachment (1)
-O Pmwdon Recycled Paper CY T O~ 1hCrj C I
,
.
..
.....
_ -
.
.- -....... ~..
.... _..
-. -. -. -.. -
-
l
'
m.,.
a
-.
h!
JUL 2 8 897 Documenticontrdl~ Desk-2-
-LR-N970427;
..
C r. H.fJ.. Miller,JAdministrator - Region I
'
.
-
U. S. Nuclear Regulatory Commission-475'Allendale Road King of Prussia,~PA 19406-
-Mr.:D.!Jaffe,- 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 USNRC-Senior Resident Inspector (X24)
Mr. K.LTosch,-Manager IV
+
Bureau of Nuclear Engineering
'
33 Arctic-Parkway-
,CN 415
!
- Trenton, NJ 086,25 l
J (
!
!
._
--
-
+
@.
,, _
-. ~.
n.
_
._
___ _ ____ _ - _
l'
P
.
.
Attachmtnt 1 LR-N970427
,
..
RESPONSE TO APPENDIX B, CRITERION XVI VIOLATION INSPECTION REPORT NO. 50-354/97-03 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 I. DESCRIPTION OF VIOLATION The description of the violation contained in the Notice of Violation received in the June 12, 1997, letter is as follows:
A. Violation
"10CFR50, Appendix B, Criterion XVI, requires in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, these measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition.
Contrary to the above, two examples of Hope Creek maintenance technicians failing to adhere to established procedural guidance for safety-related activities were identified, a significant condition adverse to quality.
These examples were repetitive in nature in service water system work during the Restart Assessment Team Inspection conducted in February 1996.
Specifically (1)
On May 22, 1997, mechanical maintenance technicians performed an inspection of the "C" service water pump discharge check valve without referring to the governing maintenance procedure, HC.MD-GP.ZZ-0046(Q).
Additionally, this procedure did not contain specific acceptance criteria for the valve inspection.
(2)
On May 28, 1997, following an unsuccessful technical specification required surveillance test of the high pressure coolant injection system due to the pump's minimum flow valve failing to close, operators discovered that the associated differential pressure transmitter had not been restored to service following a May 17, 1997 calibration activity in accordance with maintenance. procedure HC. IC-SC.BJ-0002 (Q)".
II.
REPLY TO VIOLATION A. PSE&G Position PSE&G agrees with the violation.
.
_
__.
__
____.-____._.___-______.__A___
.-
..
'-
.-
."
Attachmsnt 1~
LR-N970427
,
3.Raamon for-the Violation Examoles Cited in Insoection Reoort 354/97-03 Hope Creek Inspection Report 354/97-03 identified two examples;of Hope Creek maintenance technicians failing-to.
adhere to established procedural-guidance for safety-related activities.
The cause of both of these examples was personnel error.
The individuals involved in these two examples did not follow the PSE&G procedural adherence
- requirements or the previously disseminated management expectations regarding procedural adherence.
As a result of these two examples and a previous similar violation,-the NRC issued a Notice of Violation for the failure to take effective corrective actions, Effectiveness of Previous Corrective Actions The previous similar violation referenced in this notice from the February 1996 Restart Assessment Team Inspection, is contained in Inspection Report 50-354/96-80.
A review of the status of corrective actions contained in the PSE&G response to the above violation was conducted in response to this Notice of Violation.
The following conclusions were reached as a result of this review:
I The Corrective Action program appropriately includes
follow up reviews to assess corrective action effectiveness-and an independent Corrective Action Review Board review for significant root cause-evaluations.
The event specific corrective actions were verified and
determined to be appropriate actions to reduce the probability of recurrence of the previously cited-examples.
Station management recognized the need for additional
comprehensive-actions'regarding Maintenance Department performance and initiated a Maintenance Intervention that
' commenced on April 21, 1997.
This Intervention included sessionsLthat reiterated management expectations
regarding human performance and procedural adherence.
>
The personnel involved:in these. events had not yet
-
attended ~the Intervention training-sessions.
,
-
_ _- - - - _
_
_ _ _. - _ __ - -.. -. - -
....
.
..
o.
i.
Attachmont.1-LR-N970427 ht Although the. consequences _of human performance events
such as those cited were communicated to the maintenance shops prior to these events- (Inspection Report 354/97-03), the individuals involved did not internalize the communication and did not follow the PSE&G procedural adherence requirements or the previously disseminated management expectations regarding procedural adherence.
C.
Corrective Stoos That Have Been Taken and Results Achieved 1.
Severe disciplinary actions have been implemented for the personnel involved in these events.
2.
Senior Union representatives have joined with NBU Senior Management to communicate the expectations for procedural use and adherence.
This communication included the lack of tolerance for the failure to adhere to station procedures as well as a discussion of the consequences for a lack of procedural adherence.
This message was communicated in the attached letter co-signed by Senior Union representatives and NBU Senior Management.
3.
As a result of the May 28, 1997, event, all hands meetings were conducted at Hope Creek on May 30, 1397, to review and accentuate management expectations involving human performance.
4.
The first phase of the Hope Creek Maintenance Department Intervention, which includes specific sessions.regarding human performance and procedural adherence, has been completed.
L 5.
The maintenance procedure for the service water system check valve -inspections, HC.MD-GP.ZZ-0046 (Q), has been revised to add acceptance criteria for the inspections.
D.
Corrective Stoos That Will Be Taken to Avoid Further Violations 1.
Senior Union representatives and NBU Senior Management will jointly conduct all-hands meetings with union personnel to communicate the expectations for procedural use and adherence.
This communication will include the lack of tolerance for the failure.to adhere tofstation procedures as well as a discussion of the consequences for a lack of procedural adherence.
These all-hands meetings will be completed by August 31, 1997.
_ _. _ - - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ - _ - - _ _ _ _ - _ _ - _. - - _ _ _ _ _ _ _,
__-
.d k :,,
..:
Attcchmant.1-LR-N970427 p
2.
Management Action Response Checklist (MARC). refresher training, which stresses the supervisors'
responsibility to enforce employee ownership and accountability, has been: scheduled.
Consistent use of
,
the MARCichecklist and-documentation of disciplinary
.
actions will be included-in the refresher course.
These training sessions will be completed by October 31,'1997.
3.
The second phase of the, Maintenance Intervention will validate the retention of cultural traits stressed during the first phase.
The second phase wtll also.
' reinforce procedural-adherence and eventless human performance.
These sessions will be completed by March 31, 1998.
E. Date When Pull Ca=aliance~ Will Be Achieved For the first example, full compliance was achieved on May 23, 1997, when the proper documentation of the check valve inspection was completed.
For_the HPCI flow transmitter example, full compliance was achieved on May 28, 1997, when the transmitter was restored and the affected minimum flow 1 valve was restored to an operable status.
.
__
_
~
)
.
...
..
_ _-_ - - - ~ -
- - - - - - - - ~ - - - - - - -
-
' ^ ^ - - -
^
.,
..
(
-ATTACHMENT 1 LR-N970427
'
O PSEG 5, cue Serece Eectr,c anc Gas % meany * 0. Sex 206 -ancccas Snege New.,ersey :sc;e.;236
'
Nuclear Business Unit TO:
All NBU Employees M CM:
NBU Leadership Team / President IBEW Local Union 94 SUBJECT:
PROCEDURE USE AND ADHERENCE EXPECTATIONS DATE:
July 15,1997,
GMHC 97 029 Procedure use and adherence is a entical attnbute for safe and reliable plant operation and maintenance. Valid procedures and the discipline to follow them constitute a vital part of eventless operations.
The Company and the Union jointly recognize the need to emphasize procedure comoliance requirements, As such, the parties have agreed to collectively reinforce the stnct procedural compliance standards established under NBU Administrative Procedure NC.NA AP.ZZ-001,
' Nuclear Procedure System,* which establishes the NBU's procedure use and adherence expectations.
.
Simply stated, these expectations are:
Venfv your procedure is current
.
Review your planned activity and proceoure, to ensure the procedure is acecuate
.
for the activity Imolement STAR (Stop, Think, Act, Review) before, cunng and after eacn action
.
(step)
. Comolv with prerequisites stipulated in each prc:edure
.
Document your actions (sign off each step as you complete the action)
.
$Jgp if you think the procedure is wrong
.
Notify your supervisor if you have problems
.
Resolve problems before continuing your activity (procecure)
.
Violations of procedures and failure to follow or use procedures have resulted in plant events, equipment damage, and violation of govemment regulations (fines) at both Salem and Hope Creek, PSE&G cannot tolerate procedure noncompliance. Therefore, employees who violate procedures and fail to follow or use procedures will be held accountable for their actions.
Procedure compliance requires commitment, patience, and attention to detail. ;
us all professionally work together to ensure a procedural compliant work environment 1at produces electnc generation in a safe, reliable, cost competitive man r.
j
[
Cd[2 On W/M
/
-
Mark Bezilla Chaies Wolfe#
~ david Garchov0
/
A
' ChipG'emty CJ Marty Trum
'
iThepwrisinyourhands-
u...o
.
_. _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _. _ _ _ _ _ _ _ _ _ _. _
__
-. _ _ ~
d