LR-N970368, Responds to NRC Re Violations Noted in Insp Rept 50-354/97-02.Corrective Actions:Removed Equipment Operator Involved in Violation from Auxiliary Bldg Watch Qualification List

Responds to NRC Re Violations Noted in Insp Rept 50-354/97-02.Corrective Actions:Removed Equipment Operator Involved in Violation from Auxiliary Bldg Watch Qualification List

ML20141D161
Person / Time
Site:	Hope Creek
Issue date:	06/20/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-354-97-02, 50-354-97-2, LR-N970368, NUDOCS 9706260333
Download: ML20141D161 (6)

Text

__ _ _ _ m .

. l* -

4 i

Public Service Electne and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236. Hancocks Bridge, NJ 08038 609-339-5700 Senior Vce President - Nuclear Operatms

@N 201997 LR-N970368 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 4

REPLY TO NOTICE OF VIOLATION l 4

INSPECTION REPORT NO. 50-354/97-02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354

)

Ladies &'3entlemen:

Pursuant to the provisions of 10CFR2.201, Public Service l 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 May 23, 1997. The details of the reply are contained in the attachments to l this letter.

Should you have any questions or comments on this transmittal, do not hesitate to contact us. .  ;

Sincerely,

> l

,pga-,w,/< >

b ,

1 Attachments (2)

X[O 11111.111.111.1lll.111ll11ll.!!i11.11 9706260333 970626 PDR ADOCK 05000354 G PDR Printed a Recycled Paper

JUD0sy

,LR-N970368 .

C Mr. H. J. Miller, Administrator - 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 i Mail Stop 14E21 l Rockville, MD 20852 l l

Mr. S. Morris l USNRC Senior Resident Inspector (X24)

Mr. K. Tosch, Manager IV l Bureau of Nuclear Engineering 33 Arctic Parkway i CN 415 Trenton, NJ 08625 l

l l

l i

I i

l 95-4933

t REF: LR-N970368 STATE OF NEW JERSEY }

SS.

COUNTY OF SALEM }

Louis F. Storz, being duly sworn according to law deposes and says:

I am Sr. Vice President Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Hope Creek Generating Station, are true to the best of my knowledge, information and belief.

f(EMc '

O and Swo be re me Subscribe t h i s <-f, /) f-@A -

day o Ix.gtA_ , 1997 JAv1 YL W.

tdryPt4blic/ftfWJersey KIMBERLY JO BROWN NOTARY PUBUC 0F NEW JERSEY My commission expires on uy commission 0pires Anni 21,1998

- ~ . . . - .. -- .~. . . - . _ -. . .. -----_ .

+

. ATTACHMENT 2 l RESPONSE TO PROCEDURE ADHERENCE VIOLATION INSPECTION REPORT NO. 50-354/97-02 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 LR-N970368 I. DESCRIPTION OF VIOLATION i

The description of the violation contained in the notice of

, violation received in the May 23, 1997 letter is as follows:

A. Eiolation

" Technical Specification 6.8.1.d requires in part that written procedures shall be established and implemented for surveillance and test activities of safety-related equipment.

Hope Creek operations department surveillance test procedure HC. OP-ST. KJ-0003 (Q) , revision 34, requires that emergency

, diesel generators be " barred-over with air..." in accordance with the system operating procedure.

Hope Creek emergency diesel system operating procedure, HC . OP-SO . KJ- 0 0 01 (Q) , revision 26, step 5.9.3.I directs operators to " shut all cylinder test cocks" following completion of the barring over process.

Contrary to the above, on April 23, 1997, operators failed to shut six of the twelve cylinder indicator test cocks j

following completion of "C" emergency diesel generator pre- ,

start checks. This failure led to emergency diesel engine operation at full load with the cylinder test cocks open.

1 This is a Severity Level IV Violation (Supplement I)." l II. REPLY TO VIOLATION '

A. Ef,E&G Position PSE&G agrees with the violation. l L. Reason for the violation The cause of this procedure adherence violation was human error.

I

., Attachm2nt 2 LR-N970368 i

Procedure Adherence Violation The Equipment Operator (E01) responsible for closing the I cylinder test cocks had been qualified less than two months prior to this occurrence. This was only the second time that the E01 had performed this task. E01 was assigned to participate in the surveillance test to gain experience in the EDG evolution, while a more experienced Equipment Operator (EO2) was the lead Equipment Operator for the surveillance test. Just prior to opening the cylinder test cocks, E01 was briefed by EO2 regarding the unusual aspects of task. The cylinder test cocks are 90-degree right angle manually operated valves. To open the cylinder test cocks, the stem must be turned in the counter clockwise direction, which is the standard direction for opening a valve.

However, the stem screws toward the cylinder test cack when opening. To close the cylinder test cock, the stem must be turned in the clockwise direction, which is the standard  :

direction for closing a valve. However, the stem screws away from the cylinder test cock. EO2 reiterated that the direction of the stem movement could be confusing, and EOl's focus needed to be on the direction that the stem is being turned. E02 observed, as closely as possible given the location of the valves, E01 performing the task for the first two cylinder test cocks until confident that the task was being performed correctly. However, E01 failed to fully close the 6 cylinder test cocks for which he was responsible.

Previous Similar Occurrence and Effectiveness of Corrective Actions On February 13, 1996, operators, working in accordance with an approved operations procedure, found 6 cylinder test cocks in the incorrect position following maintenance performed on the 'C' EDG. The cause was determined to be inadequate maintenance procedures and training to perform the work. The maintenance procedure was revised and the training was enhanced, which have been effective in preventing inadequate turnover of the EDGs to the operations department following maintenance. PSE&G believes that the February 13, 1996 occurrence was the result of programmatic issues, whereas the April 23, 1997 occurrence was the result of human performance issues. Therefore, the corrective actions from February 13, 1996 occurrence would not have been expected to prevent the April 23, 1997 violation.

2

4

,. . Attachmsnt 2 LR-N970368 Procedure Adherence Violation C. Corrective Steps That Have Been Taken for Are Ongoing) and Results Achieved

1. ~There has been increased management focus on Hope Creek

Operations Department personnel human error reduction.

Since December 1996, the Hope Creek Operations Department personnel performance has improved, indicating the effectiveness of management's focus and resultant actions.

2. The Equipment Operator involved in this procedure ,

adherence violation was removed from the Auxiliary l Building Watch Qualification List until Operations management was satisfied that remediation had been effective and would prevent recurrence.  !

D. Date When Full Compliance Will Be Achieved Full ' compliance was achieved on April 23, 1997 when the cylinder test cocks were closed in accordance with the p acedure.

1 l

1 3

_- -. - _ - -