ML20086B952
| ML20086B952 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/26/1995 |
| From: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP1L-0956, NMP1L-956, NUDOCS 9507060202 | |
| Download: ML20086B952 (5) | |
Text
.........
I'
? '"
N3"'e#EA u
NIAGARA teOHmhM POWER CORPORATION /NINE MILE POINT. P.O. BOX 63. LYCOMING, NY 13093/ TELEPHONE (315) 349-2882 I
. B. Ralph Sylvia Executive Vice President I
Nuclear June 26,1995 NMPIL 0956 U. S. Nuclear Regulatory Commission Attn: Document Control Desk l
Washington, DC 20555 RE:
Nine Mile Point Unit 1 Docket No. 50-220 DPR-63
Subject:
Response to Notice of Violation - NRC Combined Inspection Report 50-220/95-03 and 50-410/95-03 Gentlemen:
Attached is Niagara Mohawk Power Corporation's response to the Notice of Violation contained in the subject Inspection Report dated May 25,1995. We believe that the corrective actions described in this response have appropriately addressed the cause of this violation. If you have any questions concerning this matter, please contact me.
Very truly yours, h$
h B. Ralph Sylvia Executive Vice President - Nuclear BRS/MGM/ime Attachment xc:
Mr. T. T. Martin, Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. L. B. Marsh, Director, Project Directorate I-1, NRR Mr. G. E. Edison, Senior Project Manager, NRR Records Management 0500LO 9S070602O2 950626 PDR ADDCK 05000220
/y l
i, Q
PDR I
g/
l-NIAGARA MOIIAWK POWER CORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR-63
" RESPONSE TO NOTICE OF VIOLATION," AS CONTAINED IN INSPECTION REPORT 50-220/95-03 AND 50-410/95-03 VIOLATION 50-220/95-03-01 During an NRC inspection conducted from March 12 through April 22,1995, a violation of NRC requirements was identified. In accordance with 10 CFR Part 2, Appendix C,
" General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:
The Nine Mile Point Nuclear Power Station Technical Specifications Section 6.8.1, requires procedures to be established and implemented.
Procedure N1-OP-43B, " Balance of Plant Startup and Shutdown," requires a post transfer check of voltages associated with the control circuits following a transfer of power board 11 from the reserve power source to the normal source.
Procedure N1-SOP-01, " Reactor Scram," requires the mode switch be placed in the " Refuel" position through " Shutdown" (clockwise rotation) following a reactor scram.
Contrary to the above:
On April 7,1995, following a transfer of power board 11 from the reserve power source to the normal source, a post transfer check of voltages associated with the control circuits was not performed in accordance with N1-OP-43B, " Balance of Plant Startup and Shutdown."
e On April 19,1995, the Chief Shift Operator did not rotate the reactor mode switch clockwise to the " Refuel" position after the scram, per N1-SOP-01, "~ Reactor Scram."
Instead, the operator rotated the mode switch counterclockwise, bypassing the shutdown position and therefore the backup scram signal.
In both of the instances, supervisory personnel failed to refer to the appropriate procedures to verify that personnel had implemented the procedures as written.
This is a Severity Level IV violation (Supplement I).
4 L
Tile REASON FOR Tile VIDIATION Niagara Mohawk administrative procedures require the following:
1.
Procedures shall be physically present and implemented as written for extensive, complex, or multi-step activities where reliance on memory is not sufficient.
2.
Procedures shall be implemented as written but need not be physically present while performing frequently repeated, routine activities including:
a.
Skill-of-the-Craft tasks based on personnel training and qualifications and b.
Performing specific actions within SOPS based on qualification and training.
Such actions should be followed up by the use of the appropriate procedure as soon as time permits.
In addition to the above administrative procedure requirements, it has been Operations Management expectations that for item 2.a above follow-up confirmatory action is required to verify procedure compliance as soon as time permits.
The operators considered the power source transfer of Power Board 11 per Procedure N1-OP-43B to be Skill-of-the-Craft tasks. Therefore, ir. accordance with item 2.a above, the operators did not have the operating procedure physically present when performing the transfer of power source for Power Board 11. Due to the operators' misinterpretation of the above Operations Management expectations, the operators did not refer to the operating procedure after taking the above action, and did not remember the procedural requirements.
Therefore, the voltage checks were not performed.
Failure to position the mode switch to refuel through shutdown following the reactor scram as required by Procedure N1-SOP-01 was due to inadequate self-checking in that the intended action was not ensured to be correct prior to taking it. Performance of this task is time critical, consequently, referral to the procedure is not required when peiforming the task.
However, when the operator subsequently reviewed the procedure, he failed to detect the incorrect action previously taken.
Shift Supervision is responsible to ensure adherence to prescribed procedures for operation of the plant during normal, abnormal, and emergency conditions. Procedures shall be implemented as written but need not be physically present for Skill-of-the-Craft tasks, and initial actions of Special Operating Procedures. However, such action should be followed up by use of the appropriate procedure as soon as time permits. In both instances, supervisory failure to refer to the appropriate procedures to verify that personnel had implemented them as written was due to cognitive error.
The plant impact and technical issues regarding the failure to perform a post transfer check of voltages following transfer of Power Board 11 from the reserve power source to the normal source were addressed in LER 95-02, " Reactor Scram Caused by Failure of Generator Protective Relay." In addition, the incorrect rotation of the reactor mode switch will be addressed in response to open item 95-03-02 of the above Inspection Report.
Therefore, this response to the Notice of Violation does not address plant impact and technical issues.
lL CORRECTIVE ACTIONS TAKEN AND RESULTS ACIllEVED Operating crews have been briefed by Operations Management on the following technical as well as management issues:
1.
Procedural requirement to perform contact verification post transfer of Power Board 11 and Power Board 12.
2.
Requirements for the proper rotation of the mode switch.
3.
Expectations for Operations shift personnel on the use and adherence to procedures and self-checking.
4.
Responsibilities for Shift Supervision to ensure procedure use and compliance with associated administrative requirements and management expectations.
5.
Expectations for the shift as a team to provide procedural backup for operators performing tasks on shift.
6.
The Training Department has strengthened monitoring of procedure use in the simulator and is identifying and correcting operators when necessary.
In addition, as part of an already ongoing personnel performance improvement action, the Plant Manger is conducting meetings with all Station Supervisors to reinforce fundamental duties and responsibilities, among which is to ensure the proper use of procedures during work activities.
l]L ACTIONS TAKEN OR BEING TAKEN TO PREVENT RECURRENCE The following long-term preventive actions are being taken to address this event.
1.
Training material was developed and presented to a portion of the operating crews to improve their understanding of the fast transfer function and reason for contact verification. The remaining crews will receive this training by July 15, 1995.
2.
Training and Operations Management personnel will monitor the manner in which the mode switch is manipulated post scram during simulator training, and reinforce the appropriate use of procedures.
3.
A training session which stresses procedure compliance, use, adherence, and oversight will be included in the requalification cycle. Specific expectations will be provided by Operations Management for supervisory oversight. This change will be incorporated into the training program by September,1995.
- 4..
The Operations Manager has issued a written directive discussing management expectations for procedure use, adherence and oversight. This will be incorporated into a new Operations Expectations Manual on this and other topics by September, 1995.
JL DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED We are currently in full procedural compliance. Action associated with the training program and the issuance of a new Operations Expectations Manual, which are being taken to prevent recurrence, will be complete by the end of September,1995.
l-l l-l