ML20083B976
| ML20083B976 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/28/1995 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N95060, NUDOCS 9505150038 | |
| Download: ML20083B976 (14) | |
Text
i PubEc Service Electric and Gas Company Joseph J. Hagan Public Service Electnc and Gas Company P.O. Box 236. Hancocks Bndge, NJ 08038 609-339-1200 APR 2 81995 v -,
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LR-N95060 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO A NOTICE OF VIOLATION RENOTE SHUTDOWN INSTRUNENTATION AND EDGs INSPECTION REPORT NO. 50-354/95-01 HOPE CREEK GENEPATING 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 March 29, 1995.
Should you have any questions or comments on this transmittal, do not hesitate to contact us.
I h
w Attachment 9505150038 950428
{DR ADOCK 05000354 PDR
Document Control Desk APR 2 81995 LR-N950(,0 C
Mr. T. T. Martin,~ Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. David H. Moran Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission l
One White Flint North Mail Stop 14E21 11555 Rockville. Pike Rockville, MD 20852 Mr. R.
Summers USNRC Senior Resident Inspector (SO9)
Mr. K. Tosch, Manager IV i
N.J.
Department of Environmental Protection Division of Enviror. mental Quality Bureau'of Nuclear Engineering CN 415 Trenton, NJ 08625 95 4933
p f-REF: LR-N95060 STATE OF NEW JERSEY
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SS.
COUNTY OF SALEM
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J. J. Hagan, being duly. sworn according to law deposes and says:
I am 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.
I mo - :- -
Subscribed and Sworn to befoze me this f1 day of OtL[,,1995 I
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,hotary Pubic of lie Jersey
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My Commission expires on
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SHERRY L CAGLE NOTARY PUBUC 0F NEW JERSEY My Commission Expires March 5,1997 4
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c ATTACENENT REPLY TO NOTICE OF VIOLATION-REMOTE SNUTDOWN INSTRUNENTATION AND EDGs
~ INSPECTION REPORT NO. 50-354/95-01 NOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57.
DOCENT NO. 50-354 LR-N95060 It INTRODUCTION During an NRC inspection conducted between January 17,.1995 and March 4, 1995,_two violations of NRC requirements were identified.
As a result, the NRC issued a notice'of violation for the two violations in a letter dated March 29, 1995.
The notice of violation contains two violations, each with two parts. - Violation A involves a situation in which an Emergency Diesel Generator (EDG) was inoperable without:
(1) demonstrating the operability of the offsite sources within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and (2) demonstrating the operability of the other 3 EDGs within-24 hours.
Violation B involved inadequate procedures in that:
(1) t' a procedure for performing a channel check of certain remote shutdown instrumentation included a check of only one of two required channels and (2) a procedure for performing.the fuel transfer pump operability test allowed the test _to be performed in conditions other than the required' condition of shutdown.
In accordance with the provisions of'10CFR2.201, Public Service Electric and Gas Company hereby submits a written response'to the notice of violation which includes for each violation: (1) the reason for the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
IIz REPLY TO PART A OF THE NOTICE OF VIOLATION In this response, the missed offsite source check will be referred to as Violation Al and the failure to perform an operability demonstration for the other EDGs will be referred to as Violation A2.
12 Descrintion of Part A of the Notice of Violation
" Technical Specification Limiting Condition for Operation (LCO) 3.8.1.1 Action (b) specifies, in part, that with one diesel Page 1 of 11 l
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Attachment LR-N95060 Reply to Notice of Violation generator of the required A.C.
electrical power sources inoperable, demonstrate the operability of the required A.C.
offsite sources by performing Surveillance Requirement 4.8.1.1.1.(a) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
If the diesel generator became inoperable due to any cause other than preplanned preventive maintenance or testing, demonstrate the operability of the remaining diesel generators within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, at about 6:00 a.m. on February 4,
- 1995, while in Operational Condition 1, a shorted motor for the 1BP-401 fuel oil transfer pump (one of two such pumps for the "A"
emergency diesel generator) was identified, a condition resulting in the "A" diesel generator being inoperable per LCO 3.8.1.1 for a reason other than preventive maintenance or testing; however, the action to demonstrate the operability of the required A.C.
offsite sources by performing Surveillance Requirement 4.8.1.1.1.(a) was not completed within the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> specified; and further, the operability of the remaining diesel generators was not demonstrated by performing Surveillance Requirements 4.8.1.1.2.a.4 and 4.8.1.1.2.a.5 separately for each diesel generator within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> specified.
This is a Severity Level IV violation (Supplement 1)"
12 Response to Part A of Notice of Violation h2 Response to Part Al PSE&G does not dispute the violation.
11 Description of Event Following a scheduled preventive maintenance system outage and a satisfactory retest, the "A" EDG was declared operable l
at 0215 on February 5, 1995.
At about 0230, an equipment operator discovered the overloads for the "B"
fuel oil transfer pump tripped.
The overloads were reset and the pump was verified to run satisfactorily.
The overloads tripped again during subsequent investigative activities.
At this point, a tracking LCO was entered, but the EDG was not declared inoperable because the operators did not recognize that LCO 3.8.1.1 specifies that a separate fuel transfer pump is required for each storage tank.
At 0700, an active LCO was entered and the EDG was declared inoperable when the next shift discovered the error.
The l
Page 2 of 11 l
3 Attachment LR-N95060 Reply to Notice of Violation required offsite power distribution line-up verification was
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. completed at 0730.
The EDG fuel oil transfer system is designed to support transfer of fuel oil from any of the EDG fuel oil storage tanks to any EDG fuel' oil day tank or other fuel oil storage tank.
Additionally, the transfer system can be used to transfer oil to the auxiliary boiler storage tank in the event the EDG storage tanks require draining to support cleaning or inspection.
The system consists of two redundant four inch headers that interconnect the fuel oil transfer pumps discharge piping through normally locked closed valves.
This system, which is not required for EDG operation and is normally isolated, is required to be tested on an 18 month frequency during shutdown.
Periodically, the system has been used to transfer fuel oil between storage tanks to accommodate sampling and fuel receipt.
It Reason for Violation The missed offsite power distribution line up verification was caused by a personnel error in that the operators did not recognize that the EDG was inoperable and that the offsite source verification was required.
The causes of the personnel error included the following:
a.
An inadequate review of the EDG Technical Specification (TS) Limiting Condition for Operation (LCO) by the particular crew on duty at the time.
The crew did review the TS actions and bases and the FSAR, but failed to read the specifics of the LCO.
This is believed to be isolated to the particular crew and the subject TS as evidenced by the oncoming crew recognizing the error.
b.
Inattention to detail.
f Page 3 of 11
ru Attachment LR-N95060 Reply to Notice of Violation 22 Corrective Steos that Have Been Taken and Results Achieved a.
The appropriate personnel were counseled relative to their lack of sufficient review of the EDG TS LCO, and their lack of attention to detail, b.
The details of this event were communicated to each of the remaining operating shifts through night orders.
c.
Reiteration of our expectations relative to familiarity with the TSs has been communicated to all licensed operators.
d.
Information on this event was made available to the entire organization via an FYI.
At Corrective Steos that Will Be Taken to Avoid Further Violations a.
A review of incident reports for the last three years will be conducted to determine if any similar problems were identified involving TS review weaknesses in order to provide confidence that the identified problems were isolated incidents and that no generic TS review problems exist.
This corrective action also applies to Violations B1 and B2.
22 Date When Full Comoliance Will Be Achieved Full compliance has been achieved.
Rz Resoonse to Part A2 PSE&G does not dispute the violation.
12
\\escriotion of Event Dutfig the incident described in Section A.1 above, the opercb:'ity of the remaining EDGs was not demonstrated l
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/ Attachment LR-N95060 Reply to Notice of Violation j
-within!24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.in accordance with the action statement;-
k. Reason'for' Violation 1
The other EDGs were'not-run as required by'the action _,
statement because a TS interpretation was in place which i
allowed >the operability demonstration for the other EDGs to l
be avoided in the subject' situation.
The inappropriate-j interpretation'was written in 1988 and was not consistent f,
with our current philosophy or standards associated with.TS j
interpretations.
Im Corrective Stoos that Have Been Taken and Results Achieved a.
The inappropriate TS interpretation was voided.
j b.
An amendment to the Hope Creek TSs has been
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approved by the NRC to avoid' running the other EDGs.for an inoperable support system.
j c.
A review of all other TS interpretations was conducted by the Operations Department.
No additional inappropriate interpretations were l
found.
I im Corrective Steos that Will Be Taken to Avoid Further Violations I
a.
An independent review of all other TS interpretations will be conducted by the Licensing Department / Hope Creek Safety Review Group.
~i 52 Date When Full Comoliance Will Be Achieved 1
l Full compliance has been achieved.
j i
III. REPLY TO PART B OF THE NOTICE OF VIOLhTION
'l In this response, the inadequate procedure for the remote j
shutdown instrumentation will be referred to as Violation B1 and the inadequate procedure which allowed performing the fuel transfer surveillance in a' condition other than shutdown will be j
referred to as Violation B2.
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Attachment LR-N95060 l
Reply to Notice of Violation 11 Description of Part B of Notice of Violation
" Technical Specification 6.8.1 requires, in part, that written l
procedures be established, implemented, and maintained for surveillance and test activities of safety-related equipment.
Contrary to the above, on February 15, and February 17, 1995, it was determined that certain Hope Creek surveillance procedures were not properly established or maintained for the following two examples, respectively: (i) Procedure HC.OP-ST.SV-0001(Q), Remote Shutdown Instrumentation Channel Check, did not include a check of all suppression pool water level instruments listed in Technical Specification Table 3.3.7.4-1; and, (ii) Procedure HC.OP-ST.KJ-0011(Q), Diesel Fuel Oil Transfer Pump Operability, did not reflect that the surveillance activity was to be conducted in a shutdown condition as specified in Technical Specification Surveillance Requirement 4.8.1.1.2(h).
This is a Severity Level IV violation (Supplement I)."
It Response to Part B of Notice of Violation The events associated with this violation are addressed in Hope Creek Licensee Event Reports (LERs) 95-002-01 dated March 31, 1995 and 95-003-00 dated March 20, 1995.
These documents may be used to obtain additional details concerning the events.
Am Response to Part B1 PSE&G does not dispute the violation.
It Description of Event on February 15, 1995, a training instructor notified the on duty Senior Nuclear Shift Supervisor (SNSS), that the surveillance test (ST) used to verify operability of the remote shutdown system (RSS) instrumentation did not satisfy the surveillance requirements specified in the TSs.
TS 3.3.7.4 requires a monthly channel check of both the primary and alternate suppression pool level instruments that satisfy the minimum channels operable under the RSS TS.
A review of the ST procedure determined that only the primary suppression pool level instrument was included in the ST.
A historical review of past procedure revisions was performed for the ST.
The procedure is structured to include the main body of the procedure and an attachment for Page 6 of 11
Attachment LR-N95060 Reply to Notice of Violation data collection.
The procedure was originally drafted and approved in 1985 based on a draft of the Hope Creek TSs which required one suppression pool level instrument under the RSS limiting condition for operation (LCO).
When the final low power TSs were issued in April 1986, the RSS LCO required two suppression pool level instruments.
The original version of the RSS surveillance procedure compared the indicated level on the RSS Indicator, LR-4805-2, to the level indication on control Room Indicator LI-4801.
In 1986, the procedure was revised to address the need for two level instruments by including a new instrument (LR-4805-01) in the attachment section; however, the step in the main section of the procedure was not similarly revised.
It is noted that the attachment was normally used by the operators so that the correct channel checks were usually performed.
In 1993, Revision 13 was completed to conform to a new standard.
At this time, several other minor changes were implemented, including a revision request identifying a typographic error involving the instrument identification number for the alternate suppression pool level instrument in the attachment section.
The revision request identified the "-1" on the Instrument Number LI-4801-1 as a typographical error and requested it be removed to provide conformity between the sections.
The writer incorporated this change by removing the
"-1".
As a result, the attachment, which had been correct, was modified to agree with the incorrect main section of the procedure.
lx Reason for Violation The 1986 procedure change was reviewed by a station qualified reviewer (SQR).
The SQR review checklist required a check to ensure that instrument identification numbers were correct and that the user coulu locate and identify all equipment referred to in the procedure.
Apparently, the reviewer did not adequately address these two checklist items since either step should have identified the deficiency.
Review of the 1993 procedure change indicated that individuals at each stage of the review exhibited less than adequate work practices while implementing their particular phase of the process.
All the individuals assumed that the identified error was merely editorial and that the identified resolution correctly resolved the problem.
This event was therefore attributed to the following:
Page 7 of 11
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.e Attachment -.
LR-N95060 Reply to Notice of Violation-A less than adequate test procedure in that'the-a.
procedure did not specify all.of the instruments-required to be tested.
b.
The 1986 failure to modify'the main section of.the=
procedure was attributed to less than adequate work practices ontthe part of the individuals who had-prepared and reviewed the revision.
c.
13Ha root cause of the incorrect revision in'1993'has been attributed to:less than adequate work practices in that the intended verifications required by the change and-review process were not adequately performed.
In addition, confusing instrument numbers contributed to the belief that a typographical error existed.
1.
Corrective Stoos that Have Been Taken and Results Achieved The.following corrective actions were taken:
a.
The SNSS immediately entered the action statement for less than the minimum number of channels operable and the alternate level instrument was verified to be within the acceptable limits by-performance of a channel check.-
b.
The surveillance test procedure was revised via an on-the-spot-change and performed satisfactorily later the same day.
c.
The procedure has been revised to include a channel check of the redundant-suppression pool' level instrument.
L d.
The individuals involved in the 1993 incident have l
been counseled with regard to proper work practices.
12 Corrective Steos that Will Be Taken to Avoid-Further Violations a.
This event will be reviewed with all station procedure' writers and reviewers regarding the r
implementation and review criteria for procedure changes that are considered typographical.
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- LR-N95060 LReply to Notice of Violation-b.-
LTraining personnel'will' review this eventifor appropriate upgrades to the lesson plan regarding roles and responsibilities'of'the individuals performing the procedure reviews.
The operations; Department is reviewing it's
-c.-
L procedure change and review process to enhance efficiency,: operational' work assignments,_and clarity of standards, d.
A review of incident reports for the'last three years will be conducted to determine if any similar problems were identified _ involving procedure review weaknesses in. order _to' provide confidence'that the identified problems were isolated incidents and that no generic procedure review problems' exist.
At Date When Full Comoliance Will Be' Achieved Full compliance has been achieved.
Em Response to Part B2 PSE&G does not dispute this violation.
lx DescriDtion of Event on February 17, 1995, while in operational Condition 1, a surveillance test was being performed to ensure the operability of the diesel generator fuel oil transfer system.
While performing this test, a review of the associated TSs determined that theitest.is required to be performed on an 18 month frequency during shutdown.
A review of the previous performances of.this test revealed that it had always been performed during power operation.
Investigation into this event has revealed the following:
When the work order computer initiated a work request for performance of_the 18 month surveillance, the operations planner reviewed the procedure to ensure all equipment or issues that would have to be pre-staged, or addressed in advance were completed.
The planner referred to the technical specifications and discovered the statement "during shutdown".
Based upon a review of past test performances and an absence of any operational condition Page 9 of 11
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Attachment LR-N95060' Reply;to Notice of Violation.
limitations in'the procedure,-the planner concluded that' the surveillance test could be scheduled as originally planned.
(during power; operation).
1 Nun work package was. prepared and testing began' on 2/15/95. -
A problem:with one of the fuel' oil transfer system check D,
valves that occurred.during testing resulted in'an investigation that again raised the question: relative to the.
. operational condition in which the test was to be performed.~
The shift.immediately contacted-the planner.
Based.on the planner's research which had been performed several weeks-1 before, the shift concluded that the test could continue as
- r scheduled.
{
i Transfer of-fuel oil.between storage tanks to accommodate sampling, fuelE receipt, and the past practice of five performances of the is month test.at power reinforced the conclusion reached by.the planner and the shift personnel (habit intrusion).
The recurring. task scheduling this l
4 activity had-never been coded as an outage activity because 1
the procedure permitted performance in any operating i
condition.
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t 11 Reason for Violation f
I The root cause of these. events is an inadequate test procedure in that the procedure permitted performance of the i
test in any operational condition.
This inadequacy also 1
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resulted in the work order computer being coded. incorrectly.
l The' inadequacies resulted from personnel involved in the preparation and review of the' procedure not having a clear understanding.of the impact of this test-on diesel I
operability.
A contributing factor to the latest event was that personnel involved did not properly address the deficiency when it became apparent that the specification required test performance only during shutdown.
l 22 Corrective Steos that Have Been Taken and Results Achieved i
i Corrective actions include:
i I
a.
A review was performed for all other tests required j
under T.S.
4.8.1.1.2.h.
for compliance with the shutdown requirement.
The EDG sequencer 18 month test l
was also found to be coded for performance under any operating condition, rather than during shutdown.
In Page 10 of 11 i
.';; 3 Attachment
- LR-N95060 Reply to Notice of Violr/dion addition, two:otJ0sr in:Atsness where the shutdown condition modifieriva, notl incorporated into the
- t surveillance test or the schaduling computer were
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identified in the"LER.
At Corrective Steos that W{ll Be 'faken to Avoid Further
?
Violations a.
.The procedure and scheduling computer database are being revised to specify the proper rporating condition for performing the fuel oil transfer test and the tests identified in 3.a above.
b.
This event will be reviewed with licensed. operators and equipment operators with specific emphasis on maintaining a questioning. attitude,-making = conservative decisions and considering the impact of component manipulations on the operability of equipment'.
c.
Review of surveillance test' procedures against technical specification surveillance requirements with regard to operational condition and frequency will be completed.. - The review will~ include a verification for consistent frequency coding in'the work order system.
d.
Appropriate. personnel involved in this event will be.
disciplined as required.
52 Date When Full Comoliance Will Be Achieved Full compliance has been' achieved.
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