LR-N970427, Response to NRC Re Violations Noted in Insp Rept 50-354/97-03.Corrective Actions:Severe Disciplinary Actions Have Been Implemented for Personnel Involved in Events Re Procedure Use & Adherence Expectations

Response to NRC Re Violations Noted in Insp Rept 50-354/97-03.Corrective Actions:Severe Disciplinary Actions Have Been Implemented for Personnel Involved in Events Re Procedure Use & Adherence Expectations

ML20196J389
Person / Time
Site:	Hope Creek
Issue date:	07/28/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-354-97-03, 50-354-97-3, LR-N970427, NUDOCS 9708040185
Download: ML20196J389 (7)

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, a Pubhc Service Electre and Gas Cornpany Louis F. Storz Public Service Electric and Gas Cornpany P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Sernor Vice President - Nuclear Operations

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LR-N970427 United States Nuclear Regulatory Commission Document Control Desk l Washington, DC 20555 REPLY .0 NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-03 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 l

l Gentlemen: 1 Pursuant to the provisions of 10CFR2.201, Public Service Electric l 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 l 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.

i l Sincerely,  ;

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JUL 211' 1997 l Document Control Desk i LR-N970427 l

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 Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris USNRC Senior Resident Inspector (X24) l Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 l

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, , At,tachment 1 LR-N970427 I

RESPONSE TO APPENDIX B, CRITERION XVI VIOLATION L

INSPECTION REPORT NO. 50-354/97-03 l HOPE CREEK GENERATING STATION DOCKET NO. 50-354 l 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:

l (1) On May 22, 1997, mechanical maintenance technicians performed e apection of the "C" service water pump discharge ca.c .c valve without referring to the l governing maintenance procedure, HC.MD-GP. ZZ-004 6 (Q) .

Additionally, this procedure did not contain specific n l acceptance criteria for the valve inspection.

(2) On May 28, 1997, following an unsuccessful technical -

l specification required surveillance test of the high  ;

pressure coolant injection system due to the pump's l minimum flow valve failing to close, operators J discovered that the associated differential pressure l transmitter had not been restored to' service following l a May 17, 1997 calibration activity in accordance with maintenance procedure HC. IC-SC.BJ-0002 (Q) " .

l II. REPLY TO VIOLATION j 4

A. PSE&G Position l PSE&G agrees with the violation.

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, , At,tachment 1 LR-N970427 B. Reason for the Violation Examoles Cited in Inspection Report 354/97-03 -

i Hope Creek Inspection Report 354/97-03 identified two I examples of Hope Creek maintenance technicians failing to I 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 procedt.ral adherence. ,

J As a result of these two examples and a previous similar 5 violation, the NRC issued a Notice of Violation for the failure to take effective corrective actions.

Effectiveness of Previous Corrective Actions

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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.

I 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:

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• 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 eva.uations.

• The event specific corrective actions were verified and determined to be appropriate actions to reduce the probability of recurrence of the previously cited i 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  ;

! sessions that reiterated management expectations  ;

! regarding human performance and procedural adherence.

! The personnel involved in thesa events had not yet.  ;

{ attended the Intervention training sessions.  ;

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Attachment 1 LR-N970427 e 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, 1997, l to review and accentuate management expectations involving human performance.

4. The first phase of the Hope Creek Maintenance  !

Department Intervention which includes specific j sessions regarding humaa performance and procedural l adherence, has been completed.

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5. The maintenance procedure for the service water system I check valve inspections, HC.MD-OP.ZZ-0046(Q), has been revised to add acceptance criteria for the inspections, l

l l D. Corrective Steps That Will Be Taken to Avoid Further

! Violations i 1. Senior Union representatives and NBU Senior Management

. will jointly conduct all-hands meetings with union personnel to communicate the expectations for l procedural use and adherence. This communication will l 3 include'the lack of tolerance for'the failure to adhere j to station procedurec as well as a discussion of the  ;

. consequences _for a lack of procedural adherence. These all-hands m;etings will be completed by August 31,

1997.

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2. Management-Action Response Checklist (MARC) refresher )

. training, which stresses the supervisors' l responsibility to enforce employee ownership and '

accountability,:has been' scheduled. Consistent use of the MARC checklist and documentation of disciplinary )

actions willLbe included in the refresher course. '

These training sessions will be completed by October  !

l 31, 1997. '

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L 3. The second phase of the Maintenance Intervention will i validate the retention of cultural traits stressed

during the first phace. The second phase will also l l reinforce procedural adherence and eventless human 1 l performance. These sessions will be completed by March j 31, 1998. -

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l i E. Date When Full Comoliance Will Be Achieved )

l For the first example, full compliance was achieved on May l 23, 1997, when the proper documentation of the check valve i

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 '

valve was restored to an operable status, c

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ATTACHMENT 1 LR-N970427 DPSEG Puolic Service E!ectnc and Gas Company P O. Box 236 Hancccxs Brege New Jersey 08038-0226 Nuclear Business Unit TO: All NBU Employees FROM: NBU Leadership Team / President IBEW Local Union 94

SUBJECT:

PROCEDURE USE AND ADHG4ENCE EXPECTATIONS DATE: July 15,1997 GMHC-9'7 029 1

Procedure use and adherence is a entical attnbute for safe and reliable plant operation and j maintenance. Vr:!d 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 proctidure compliance requirement::. 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:

. Verify your procedure is current

= Review your planned activity and proceoure, to ensure the procedure is adequate for the activity

. Implement STAR (Stop, Think, Act, Review) before, dunng and after each action (step)

. Comoly with prerequisites stipulated in each procedure Document your actions (sign-off each step as you complete the action)

. Stop if you think the procedure is wrong

. Notify your supervisor if you have problems j . Resolve problems before continuing your activity (procedure)

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 l Creek. PSE&G cannot tolerett pocedure noncompliance. Therefore, employees who violate

, procedures and fail to follow w .m procedures will be held accountable for their actions.

O Procedure compliance requires commitment, patience, and attention to detail. Lea us all professionally work together to ensure a procedural compliant work environment lat produces j electric generation in a safe, reliable, cost-competitive man er.

/ MY Gk b] WW Mark Bezilla Chai1es Wolfe# ~ David Garchow

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