ML20125C906
| ML20125C906 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/07/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92175, NUDOCS 9212140145 | |
| Download: ML20125C906 (4) | |
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Public Service Electric and Gas Comp any Stanley LaBruna Pabi:c service Elecinc and Gas Company P.O. Box 236, Hancocks Budge. HJ 06038 609-339 1200 40Perusteri 14-awa* Ocsts;vs DEC 0 71992 NLR-N92175 s
United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-354/92-13 DOCKET NO. 50-354 HOPE CREEK GENERATING STATION Public Service Electric and Gas Company (PSE&G) is in receipt of your letter, dated November 10, 1992, which transmitted a Notice of Violation citing failure to comply with requirements of 10CFR50, Appendix B,. Criterion-XV, "Non-conforming Materials, Parts, or Components".
Pursuant to the provisions of 10 CFR 2.201, our response to the Notice of Violation is provided in Attachment 1.
Sincerely, Gp 4
- QQ & Yf
!cWMc%
Attachment C
Ms. A.
Keller USNRC Licensing Project Manager (Acting)
Mr. T. P. Johnson USHRC Senior Resident Inspector
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Mr. T. T. Martin, Administrator USNRC Region I Mr.
K. Tosch, Chief Bureau of Nuclear Engineering
-New Jersey Department of Environmental Protection 140067 3
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- 2g2q0gg?y g4 O
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4 ATTACHMENT 1 10 CFR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT No. 50-354/92-13 10CFR50, Appendix B, Criterion XV, "Non-conforming Materials, Parts, or Components," requires that, in part,... " measures be established to control components which do not conform to requirements in order to prevent their inadvertent use.. These measures shall include, procedures for identification, documentation, disposition, and notification to affected organizations.
Non-conforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
Contrary to the above, during maintenance activities (work order 911126153) between September 26-28, 1992, a Wiring error was introduced in Residual Heat Removal (RHR) motor operated valve (MOV) 1BC-HV-F024A.
Subsequent MOV testing and troubleshooting activities during the period September 29-30, 1992, noted the existence of a wiring error in this;RHR MOV; however, the error was not completely identified or documented, nor dispositioned, nor were appropriate notifications made to management and/or quality assurance personnel.
Although a jumper wire was installed in the 1BC-HV-F024A wiring circuits, the nonconforming condition was not repaired.
As'a result, on October 2, 1992, an unplanned loss of the reactor cavity water occurred, partly due to this MOV 1BC-HV-F024A wiring error.
I.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THAT A VIOLATION OCCURRED.
A clarification and explanation of the event follows.
Our investigation into the event has determined that an initial wiring error was introduced into the subject valve during implementation of work order 911126153.
This work order required that maintenance personnel remove power and control leads from
, 1BC-HV-F024A (RHR full flow tust return l valve) for trouble -
shooting and preparation of v0TES testing being-performed-per Generic Letter 89-10.
=The terminal block for the subject valve is inverted and close to the floor so that. technicians must manipulate leads from under and up into the unit.
The work order and procedure require documenting each lead
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removed on a lifted lead sheet.
This ensures that lifted leads are returned to their proper terminal upon restoration.
L
'A Between September 26 and Septembc 1992, tt'a technicians were assigned to remove approximately eads frou -he subject valve a
actuator.
Two affected terminals uN pertinent to this event.
5 The term _nal labeled 15C includes two leads, one of t'hich was 9,,
required to be removed.
Terminal 14C also required a lead to be
' ~ t lifted.
It is hypothesized that from the position being worked,
.se second lead on teiminal 15C dropped off and was hanging freely while removing the required lead.
This was not detected by the technicians. Subsequently while removing the 1eLJ on 14C, the fr<a lead, which is an internal jumper, was probably detected and landed on 14C.
The lifted lead sheet only records leads that are req..;ed to be left disconnected and thus the internal jumper wcs not required to be documented.
On September 29 - 30, 1992, valve test technicians worki) 4nder the same work order noted that valve position indication i not e3i provided to the Control Room.
It was determined by them t.at the power to provide indication was supplied from terminal 15C.
They failed to detect the mislanded lead u
'4C.
The technicians installed a temporary jumper an'. comp. toned testing satisfactorily.
This ary jumper was do-atec on the work order and the e n Systr n32neer in charge of the system was notified.
The System Engino.. directed the valve testing crew to restore the wiring in accordance with the drawings.
The temporary jumper was then made perma ^ent.
Unknown to the persons involved, the combination c.f
- mislanded lead and the new jumper created an interaction between the control circuits of 1DC-HV-F02^ ana HOV 1BC-HV-F000A (RHR pump shutdown cooling suction valve).
EV-F006A was tagged closed and out of service Lt the time.
With HV-F006A tagged out of service, cu. trol power from HV-F024A picked up the HV-F006A open coil and attempted to drive the valve open through the' control power transformer.
This resulted in a blown control power fuse for HV-F006A.
This was undetected because the valve was out of service.
On October 2, 1992, while restoring the system, power was restored to HV-FC06A.
Power failure, indicacion was then received in the Control Room due to the blown fuse.
After troubleshooting had identified t'ie blown fuse, a work order for replacement was initiated.
'When pciser was restored to HV-F024A, control power from this valve picked up the open coil of HV-F006A.
However this time HV-F006A was energized, and the motor d ove the valve open without an open command from the Control Rm %.
With 1BC-HV-F008 and FOO9 (shutdown cooling ccmmon suction ie:lation valves) and 1BC-HV-F004A (RHR tarus suction valve) open drain path was ectM
'ted between the reactor cavity to '
orus.
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The" event-was terminated in approximately 5 minutes when operators isolated 1BC-HV-F004A and 1BC-HV-F008 and F009, closing the drain path.
A decrease in cavity water level of approximately 20 inches and an increase of torus water level of approximately'7 inches occurred during this time.
Water level was re-established utilizing the control rod drive system with suction frem the condensate storage tank.
Fuel Pool cooling pumps which tripped by design, were rastored in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 22 minutes.
corrective Steps which Have Been Taken and The Results Achievedi 1)
Public Service Electric and Gas Company- (PSE&G) har had an in-depth, detailed, independent root cause analysis performed by the Or.-Site Safety Review Group (SRG).
This report is currently drafted and awaiting final approval.
2)
As discussed above, water lavel and fuel pool cooling were quickly re-established.
No radiological consequences resulted from this event.
3)
Troubleshooting on the valve (HV-F024A) included a complete wiring check and corrected all wiring errors.
4)
A discussion was held with all maintenance and valve rest supervisory personnel about the event.
5)
Interface meetings were held between the valve testing. group supervisors, system engineern, and mnintenance ma.tagement to strengthen the lines of communication between the groups and to clarify management expectations on resolution of retest" problems.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
1)
Although all wiring work discussed.bove included verification, this was not. effective in detecting the mislanded lead.
This was due to requiring only leads being' worked to be documented and verified.:
3 To preclude this from occurring again, the lifted lead and troubleshooting procedure is going to be revised to require accounting of all wires on affected terminals.
2)
Work performed on the subject valve was in accordance'with a-proper. work order (Corrective Action Document)'per NC.NA-AP.ZZ-0009(Q)L" Work Control Process".
However,.there was less than adequate follow-up-(identification,
. documentation or notification) by the yalve testing personnel to the originally discovered missing lead.
E.
A discussion of this event including procedural expectations and lessons learned will be incorporated into appropriate continuing training programs.
3)
A contributing factor to this event, was that the valve testing did not provide a-thorough pcst maintenance re-test.
The valve testing-tid not comp 1.
91y check installed interlocks dua to the-electrica.
agging involvcd, Future post maintenance testing of the shutdown cooling valvos will be expanded to include testing of valve interlocks.
PSE&G agrees that thn event should not have occurred and believe that.the corrective steps detailed above and additional actions under consideration from the SRG report will preclude a similar event from occurring.
The Date When Full Compliance Will Be Achieved; PSE&G'is 3n full compliance.
Additional preventative actions detailed above will be completed by July 1, 1993.
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