ML17265A267
| ML17265A267 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/06/1998 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-244-98-02, 50-244-98-2, NUDOCS 9805150021 | |
| Download: ML17265A267 (8) | |
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REGULA ORY INFORMATION DISTRIBUTIO SYSTEM (RIDS) i'CCESSION NBR:9805150021 DOC.DATE: 98/05/06 NOTARIZED: YES DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
05000244 AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rochester Gas
&, Electric Corp.
RECIP.NAME RECIPIENT AFFILIATION VISSING,G.S.
SUBJECT:
Provides response to violations noted in insp rept 50-244/98-02.Corrective actions:plant mgt promptly went to control room
& assessed condition of plant, when notified of event.
DISTRIBUTION CODE: IEOID COPIES RECEIVED: LTR J ENCL J SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
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ROCHESTER GAS ANDE'ELECTRIC CORPORATION ROBERT C. MECREDY V'ce t resic'ent Nvctear Operet oes
~ 89 EASTAVENUE, ROCHESTER, N, Y, Id6d9 0GOI,
-'REA CODE 7I6 5'-2700 May 6, 1998 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy S. Vissing Project Directorate I-1 Washington, D.C. 20555
Subject:
Reply to a Notice of Violation NRC Inspection Report 50-244/98-02 and Notice of Violation, dated March 31, 1998 R.E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Vissing:
Rochester Gas and Electric (RG&E) provides this reply within 30 days of receipt of the letter which transmitted the Notice of Violation. During an NRC Inspection conducted from March 3 - March 12, 1998, a violation of NRC requirements was identified. In accordance with the "General Statement ofPolicy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
"10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
requires in part that activities affecting quality shall be accomplished in accordance with procedures.
The Rochester Gas & Electric (RG&E) Ginna Station Procedure 0-6, Revision 63, "Operations and Process Monitoring," step 5.3.3.1 states that operators "Acknowledge all computer alarms and take appropriate actions."
Additionally, RG&E Ginna Station procedure A-52.11, Revision 8, "Conduct of Activities in the Control Room," step 3.1.4 states that "On-shift operators shall maintain awareness of pertinent plant instrumentation."
Contrary to the above, on March 3, 1998, control room operators failed to acknowledge Plant Process Computer System (PPCS) alarms denoting a high pressure warning for pressurizer pressure which annunciated in response to a pressurizer pressure control system malfunction.
Also, they were not aware of a main control board indication denoting pressurizer backup heaters energized and instrumentation showing pressurizer pressure as it increased from 2235 psig to 2335 psig during the time period of 0808 to 0816.
This resulted in pressurizer pressure increasing unnoticed by the operators until power-operated relief valve 430 opened."
980515002k 980506 PDR ADQCK 05000244 6
Page 2 the reason for the violation, or, ifcontested, the basis for disputing the violation or severity level:
Rochester Gas & Electric Corporation (RG&E) accepts the violation.
This event occurred during performance ofAxial Offset Calibrations and Reactor Protection System Trip Testing, which is normally a three and a half day evolution.
On the second day of the evolution, the appropriate defeats of Channel 3 were performed by Instrument and Control (1&C) technicians, as directed by calibration procedures (Channels 1 &'2 were successfully completed on the previous day).
The defeats were completed at approximately 0802 EST on March 3, 1998.
The on-shift Control Board operators observed proper plant response, and returned pressurizer (PRZR) pressure control (PRZR pressure controller PC-431K) and charging pump speed control to automatic with minimal adjustment.
This return to automatic control indicated to I&C and to the on-shift operators that the defeats were successful, the plant was stable, and it was appropriate for I&Cto proceed with the calibrations.
Based on past experience, problems with establishing this defeat would be expected to occur during or immediately following manipulation of switches.
During this time period, the on-shift operators and I&C technicians exhibited a
heightened sensitivity to the potential for failures.
Once the defeats were completed and control was returned to automatic, without incident
'or unexpected perturbation, the on-shift operators resumed their normal daily activities.
A few minutes later, one of the Control Board operators notified the other operators that he would be going behind the Main Control Board (MCB). The other Control Board operator acknowledged this, and assumed additional monitoring responsibilities normally shared between the two operators.
While the Control Operator was behind the MCB, failure of the pressurizer (PRZR) pressure defeat switch (P/429A) occurred (approximately six minutes after manipulation of the switch) and PRZR backup heaters came full on.
Event reconstruction shows that the only indications of this failure were a momentary alarm on the Plant Process Computer System (PPCS) and change of state of the PRZR backup heater breaker light.
The earlier restoration of PC-431K to automatic provided the operator with reasonable assurance that MCB pressure alarms (both for low and high pressure) were available in the event of a pressure transient.
Licensed Operator training reinforces the expectations that significant transients would be preceded by a MCB annunciator alarm.
- However, due to the failure mechanism, the MCB annunciator alarm for high PRZR pressure was lost.
In the absence of MCB alarms, recognition of a deviation in PRZR pressure from the normal setpoint is limited by the magnitude of the deviation existing at the time of a scan of the MCB indications.
Regardless of the time of scan, indications that the PRZR backup heaters are energized (breaker "on" light) may not be readily recognized unless noted while the light changes state.
The on-shift operator was not continuously observing the specific indications.
A single audible alarm occurred at the PPCS terminal, but was not heard, and therefore was not identified, acknowledged or announced by the on-shift operator.
Page 3 At approximately 0816 EST, PRZR pressure increased to the liftsetpoint of the PORV, and PORV 430 lifted. The PORV liftcaused several MCB annunciators to alarm, which was the first audible alarm from the MCB for this event.
Operator response to the MCB annunciator alarms was prompt and correct. They observed PC-431K at 0% demand and took manual control of PC-431K to return it to 50% demand position, which de-energized the PRZR backup heaters.
The Control Room operators entered Abnormal Operating Procedure AP-PRZR-1, and restored PRZR pressure to normal.
In accordance with Operations Department Guideline OPG-2, "Conduct of Operations",
section 4.0, the Control Room crew performed a debrief prior to being relieved.
They discussed the chronology of the event, including a missed opportunity for early identification of increasing pressure prior to liftingof the PORV. The operators directly involved provided written summaries of the event, describing operator response.
An Event Investigation was assigned to the Operating Experience group.
The Event Investigation Report has been issued, and identified the following Root Causes:
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Failure of the Control Room operators to monitor, detect, and respond to Main Control Board indication.
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Failure of the Control Room operators to monitor, detect, and respond to PPCS parameters and alarms.
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Failure of the Pressurizer Defeat Switch
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Disabling of the Main Control Board Alarm, F2, "Pressurizer High (2310)" as a result of the Pressurizer Defeat Switch failure.
(2) the corrective steps that have been taken and the results achieved:
When notified of the event, plant management promptly went to the Control Room and assessed the condition of the plant.
The Superintendent, Ginna Production concluded that the plant was in a stable condition, and that the on-shift operators had properly responded to the event.
He evaluated the knowledge and performance of the operators involved in this event and the adequacy of the immediate actions.
He promptly evaluated the continued capability ofthe on-shift operators, and concluded that no immediate actions were warranted, and that lessons learned had already been recognized and internalized by these operators.
As a result of this assessment, the Superintendent, Ginna Production determined that it was appropriate to proceed on a normal time frame for further event investigation.
Therefore, actions such as immediate relief for the on-shift operators was judged not needed, and an accelerated schedule for investigation was also not needed.
An ACTION Report was initiated the day of the event, to determine the cause(s) of the event.
Page 4
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A formal Event Investigation was assigned to the Operating Experience group, and was conducted in an appropriate time frame.
Root causes, contributing
- factors, and corrective actions were. identified in the formal report of this investigation.
(Note that RG8'cE conducted an "Event Investigation" for this event, and not a "Human Performance Enhancement System (HPES) Evaluation"
- However, as part of this investigation, the INPO HPES model was one of the tools used.)
Management expectations, as stated in procedures 0-6 and A-52.11, regarding, monitoring of the MCB and PPCS, were reinforced to the Shift Supervisors.
A requirement to review this guidance at shift turnovers was subsequently added to the Operations Plan of the Day (POD).,
Management expectations for operation with one Control Board operator absent from the "AtThe Controls" area were strengthened to ensure that the remaining Control Board operator assumes the monitoring function with no concurrent administrative duties.
The operators involved in this event reviewed the event prior to the end of their shift on the day of the event.
They discussed both event initiation and concerns for operator monitoring.
Members ofthe shift that experienced this event discussed the potential ofdelayed failure, Control Room vigilance, roles of individual team members, and the importance of the PPCS with all other operating shifts.
The industry was notified of this event using an Industry Operating Experience notification sent out via NUCLEAR NETWORK, (3) the corrective steps that willbe taken to avoid further violations:
A Training Work Request (TWR) has been submitted to develop a Case Study of this event, to ensure optimum benefit from this experience.
Administrative procedures willbe enhanced to formalize management expectations regarding monitoring of the MCB and PPCS, and willbe periodically reinforced.
Formal guidance willbe established relative to expectations following a "Human Performance" event in the Control Room.
4
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Plant management will review, monitor, and evaluate administrative duties and potential process changes that may impact or are currently assigned to the operating shift in the Control Room.
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A Technical Staff Request (TSR) has been initiated.
Under this TSR, MCB annunciator circuitry for PRZR pressure control and alarm circuitry will be evaluated, and modified if appropriate, to ensure that these MCB annunciators remain capable of alarming with one channel out of service.
Page 5
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Replacement of the PRZR pressure defeat switch is currently scheduled for May, 1998.
The removed switch willbe evaluated to determine the root cause of the intermittent failure.
(4) the date when full compliance willbe achieved:
Full compliance was achieved on March 3, 1998, when management assessed the knowledge and performance of the on-shift operators, and concluded that expectations for monitoring the MCB and PPCS were recognized and internalized by the on-shift crew.
Very truly yours, Robert C. Mecredy RCM/jdw Subscribed and sworn to before me on this fifthday of May, 1998, Notary Public DEBORAH A.PlPEgq
~ Pubbc at the State ofN~ y~
ONTARIOCOUNTy CommisQon Extxreg Noy. 23 }9 gg xc:
Mr. Guy S. Vissing (Mail Stop 14B2)
Project Directorate I-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector