ML20080C920
| ML20080C920 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/08/1994 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N94214, NUDOCS 9412220058 | |
| Download: ML20080C920 (10) | |
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e Pubic Service Dectre and Gas Company Stanley LaBruna Public Service Electric and Gas Cornpany P.0, Box 236. Hancocks Bridge, NJ 08038 609-339 1700 w n ne.we.,e m DEC 0 81994 NLR-N94214 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/94-09 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 to the notice of violation issued to the Hope Creek Generating Station in a letter dated October 31, 1994.
Per discussion between John White (NRC) and Dave Smith (PSE&G) on November 30, 1994, agreement was reached that this reply could be submitted within 30 days of receipt of the transmitting letter (November 8, 1994).
Should you have any questions or comments on this transmittal, do not hesitate to contact us.
Sincerely, r g/f &
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I DE0 0 81994 Document Control' Desk 2
-NLR-N94214-C 'Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of. Prussia, PA 19406 Mr.
D. Moran, Licensing Project Manager - Hope Creek U.
S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852
' l Mr. R. Summers (SO9)
USNRC Senior Resident Inspector Mr. K. Tasch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 4
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NLR-N94214 STATE OF NEW JERSEY
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COUNTY OF SALEM
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LaBruna, being duly sworn according to law deposes and says:
I am Vice President - Nuclear Engineering 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.
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Subscribed and Sworn o before me this d
of%I O A01T)/21/L.,1994 An'1')30I
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KlMBERLY JO BROWN NOTARY PUBLIC Of NEW JERSEY My Commission expires on My Commission Espires April 21,1998
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ATTACHMENT REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/94-09 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET No. 50-354 NLR-N94214 It INTRODUCTION During inspection activities conducted between March 27 and April 30, 1994, the NRC identified three potential violations of NRC requirements.
These potential violations were eubsequently documented in Inspection Report 354/94-09 dated June 15, 1994 and responded to by PSE&G in NLR-N94116 dated July 18, 1994.
In the response, two of the violations were disputed and a subsequent meeting was held on August 8, 1994 to further discuss the issues.
In a letter dated October 31, 1994, the NRC re-issued the violations.
Our response to the re-issued violations is provided below.
112 REPLY TO NOTICE OF VIOLATION FOR CONTAINMENT INTEGRATED LEAK RATE TESTING 12 Description of Violation "10 CFR 50, Appendix B, Criterion XI requires, in part, that all testing required to demonstrate that structures, systems and components will perform satisfactorily in service is identified and performed.
10 CFR 50, Appendix J, section II.A.1.b requires closure of containment isolation valves for the Type A test by normal operation and without any preliminary exercising or adjustments.
Contrary to the above, prior to Containment Integrated Leak Rate (Type A) Testing on April 11 and 12, 1994, the control rod drive directional control valves, listed as containment isolation valves in the FSAR, were exercised prior to the Type A test.
This is a Severity Level IV violation (Supplement I)."
22 Response to Violation PSE&G does not dispute this violation.
Page 1 of 7
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' Attachment NIR-N94214 Reply to Notice of Violation A.
Reason for Violation For a number of days prior to the Type A test, the control red drive (CRD) system was in an operational coMition other than that which would exist during nomal power operation (the pumps were out of service with no flow through the directional control valves). With the CRD syst s out of service, it is believed that sediment collects in the CRD lines.
As a result of the above noted conditions, it was suspected that some sediment had accumulated on the seats of the directional control valves.
In an attempt to flush away the r@nt, certain directional control valves were cycled with flow through the system. 'Ihis is considered by PSE&G to be a maintenance activity. 'Ihe cmbined leakage through all the directional control valves was measured before and after flushing.
In addition, the amount of leakage was again measurM with the containment at Type A test pressure prior to isolating the penetrations.
Although the violation was cited against Section II.A.1.b of Appendix J, it is believed that the intent was to cito Section III.A.1.b.
Section III.A.1.b of Appendix J allows repairs and maintenance of valves as long as the as-found leakage is determined and properly incltried in the report of test results required by Section V.B of Appendix J.
Specifically,Section III.A.1.b states the following:
"Clocure of containment isolation valves for the Type A test shall be accomplished by normal operation and without any preliminary exercising or adjustments (e.g., no tightening of valve after closure by valve motor). Repairs of maloperating or leaking valves shall be made as newry. Information on any valve closure malfunction or valve leakage that requires corrective action before the test, shall be included in the report subnitted to the Commission as specified in V.B."
Although our activities associated with the directional control valves were permitted by the regulations, procedures were not adequate to ensure that the applicable requirements would be met, and for this ruason, we do not disptte the violation.
B.
Corrective Actions Taken and Results Achieved 1.
'Ihe CIIRT test was ruviewed to ensure that the activities associated with the directional control valve did not invalidate the test. It was determined that the test remained valid.
2.
'Ihe Containment Integrated Icak Rate Test (CIIRT) procedure was revised as follows:
a.
a step in the procedure was revised to state:
" Containment Isolation Valves shall be positioned by normal, remote operation (10CFR50 Appendix J SIII.A.1.b).
Containment Isolation Valves may be cycled one time to ensure normal closure."
Page 2 of 7
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' Attachment NIR-N94214
' Reply to Notice of Violation b.
a step was aMari to state:
" Exercising Containment Isolation Valves for the purpose of inproving leakage performance is not permitted (ANS-56.8-1987 53.2.1.4)."
c.
a table in the procedure was revised to clearly identify the.
directional control valves as Containment Isolation Valves.
C.
Curtactive Actions to Be Taken to Prevent Recutra s 1.
Procedures will be reviewed and revised as narmanary to clarify the requirements associated with obtaining and reporting as-found test results prior to the next CIIRP.
2.
'Ihis event and the associated pro dure changes will be d%===3 with appropriate personnel prior to the next CIIRP.
D.
Date When Full Octroliance Will Be Achieved Full cmpliance has been achieved.
III. PAfuelina Bridae Mis-Oceration Violation 1.
Descriotion of Violation "10 CFR 50, Appendix B, Criterion XVI requires, in part, that licensees establish measures to assure that significant corxlitions adverse to quality are prmptly identified, corrected, the cause is determined, and corrective action is taken to preclude repetition.
Contrary to the above, corrective actions inplemented for a previous occurrence involving mis-operation on the refueling brick e on W217, J
1993 (in which the causal factors were identified as failure to self-check and adhere to procedures) were not effective, in that on March 9,1993, the refuelirxJ bridge was again' mis-operated (i.e., operators inadvertently moved the refueling bridge while the mast was still extended and grappled to a dumy fuel load) due to failure to self-check and adhere to procedures.
'Ihis is a Severity Invel IV violation (Suppleent I)."
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'1 Attachment NIR-N94214 Reply to Notice ~of Violation 2.
Resoonse to Violation PSE&G does not dispute the violation.
A.
Description of Events 1.
First Mis-Oceration Incident On C+: 2+r 17, 1993, a refuelity platform bridge operator repositioned the refueling mast without properly verifyiry release of a grappled new fuel===hly.
%e operator moved a new a==hly frun the fuel preparation machine to its spent fuel pool location. %e operator verified the location, lowered the mast and released the grapple. %e operator lifted the mast to the full up position and prmaadai to move the mast back toward the fuel preparation machine to transport the next fuel assembly. A GE fuel inspector noticed that the fuel anaanbly, whid1 was initially lowered into its spent fuel pool location, was still attached to the grapple. %e operator was not aware that the naaanbly was still grappled. Personnel frm the Reactor Engineering Department acted irrmediately to halt the fuel movement and placed the fuel aaaanbly into the correct location. It was determined that the mast and grapple functioned as required. % e cause of the mis-operation was that the operator apparently did not properly verify that the load was removed frm the grapple.
%e causal factors identified for this incident were:
a.
inattention to detail on the part of the operator and b.
lack of clearly defined requirements relative to the duties of the spotter (independent verifier) which resulted in the spotter being distracted by other duties.
Cbrrective actions taken included the following:
a.
We responsible operator was counseled.
b.
A procedure change was initiated to enhance the requirements for spotters during movement of fuel.
c.
A night order was issued which ensured that, prior to operating the bridge, all applicable personnel were re-familiarized with the bridge controls arxl the relevant procedure and were required to review documents describing additional spotter requirements and the Susquehanna refuel brickje incidents.
d.
% e Operations Manager instructed the Senior Nuclear Shift Supervisors to ensure that all operators were thoroughly familiar with bridge controls and operation prior to operating the bridge.
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Attachment NIR-N94214 Reply to Notice of Violation e.
W e Operations Manager personally interviewed the responsible operator; the operator indicated that his training had been adequate ard attributed the error to lack of attention to detail.
2.
Second Mis-Operation Incident On March 9, 1994, an operator had been performing retest activities following DCP work when Reactor Dgineering Department and General Electric Ccrapany personnel arrived to set the frame uninted auxiliary hoist upper limits for control red moves. During activities to set the limits, General Electric personnel requested the bridge be moved for easier passage to the fuel prep / channel area. We operator inadvertently moved the refueling bridge approximately two feet in a horizontal direction while the mast was still extended and grappled to a "dumtrf' fuel bundle. Se mast flexed as the bridge began to nove forward. %e operator immediately recognized the problem ard returned the bridge to its original, unflexed position.
We causal factors for this incident were identified as follows:
a.
inattention to detail and failure to adhere to procedural requiremnts for proper verification of load status by the responsible operator due to distraction of the operator by personnel performing other activities.
Corrective actions taken for this incident included the following:
a.
We responsible operator was counseled relative to self verification and maintaining focus on the task at harxi.
b.
Although not taken to specifically address this incident, the General Manager - IIope Creek Operations communicated management expectations and re-emphasized the importance of procedure adherence in a letter addressed individually to each member of the llope Creek organization.
Mditional corrective actions planned include the following:
a.
A new presentation on STAR (stop, think, act, and ruview) will be incorporated into the continuing operator trainity program.
%is presentation will re-emphasize self verification and maintaining focus on the task at hand and will alert operators to areas of increased vulnerability (e.g., times when distractions / interruptions occur durity performance of a task, etc.) when a heightened focus and awareness is required.
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Atta & ment
-NIR-N94214 Reply to Notice'of Violation b.,
%e Hope Creek Technical Department is reviewing the " grapple engaged / hoist loaded" interlock logic for possible enhancements. mis will be ccmpleted prior to the next use of the refuel bridge, c.
%e Hope Creek Technical Departanent is evaluating a design change which would provide protection against mast bending.
mis will be ocmpleted prior to the next use of the refuel bridge.
B.
Root Cause
% e cause of the failure to prevent occurrence of the second incident is attributed to the root cause evaluation of the first incident being too narrowly focused and the associated corrective actions not being sufficiently effective or c w ehensive. S e root cause evaluation did not adequately address incidents which might occur during activities which do not involve movement of fuel ard the corrective actions were not sufficiently thorough to strengthen the first barrier in place for avoiding mis-operation events (the bridge operator). Although training which covered the STAR concept had been provided, the training was not specific enough and did not provide guidance on times when a heightened awareness is required.
C.
COnective Actions Taken and Results Achieved
% e following corrective actions have been coupleted.
1.
We tm incidents were re-evaluated and ack11tional corrective actic a were identified as noted previously in Section III.A.2.
2.
A new t~xt cause analysis guideline was recently issued. mis guideilne provides additional direction for identifying specific causal factors, root causes, and contributing factors to andment and human performance problems. It discusses several root cause analysis methods and provides ruv=*1rlations as to when each method should be enployed. It provides guidance to assist in developing corrective actions that will prevent recurrence and yield systematic benefits.
3.
A root cause analysis survey was sent to all Hope Creek enplayees.
We objective of the survey is to find ways to inprove the effectiveness of root cause and corrective action efforts, identifying precursors to large events arrl resolving issues while they are small, and corxtucting a thorough analysis in a timely manner.
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L Attad1 ment 3
NIR-N94214 Reply to Notice of Violation
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D.
Cutructive Actions to Prevent Rectutarer.wi
'Ihe following corrective actions' are in prgrass. It is felt that these actions will prevent the recurrence of this or any similar violation.
1.
Training on the new root cause analysis guideline will be provided to nuclear depatLisit personnel involved in root cause evaluations.
'Ihe training will provide a ocanon understanding of the root cause process and mansgwwit's expectations concernirg that prmaan. 'Ihis will contribute to a more consistent application of thorough root.
cause analysis.
2.
. A team will be a=aambled to evaluate the results of the root cause analysis survey and to r.=
....ard appropriate enhancements to our root cause program.
E.
Date When Full Corneliance Will Be Achieved Fbil empliance has been achieved, i
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