ML20138H303
| ML20138H303 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/29/1996 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20138G636 | List:
|
| References | |
| FOIA-96-351 50-272-95-81, 50-311-95-81, LR-N96030, NUDOCS 9701030224 | |
| Download: ML20138H303 (10) | |
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I Document Control Desk i
LR-N96030 ATTACEMENT 1 NOTICE OF VIOLATION Public Service Electric and Gas Company Docket Nos: 50-272 Salen Nuclear Generating Station Units 1 and 2 50-311 License Nos: DPR-70 DPR-75 During an NRC inspection conducted on October 5 through November 13, 1995, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,.!'
violations'are listed belowf ~('*60 FR.34381; June 30, 1995), the
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10 CFR 50.54 (g) requires, in part, "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part."
The Emergency Classification Guide (ECG), Section 10, " Loss of Instrumentation / Annunciation / Communications," requires an alert declaration if " Loss of most or all (>75%) Overhead Annunciators, (excluding a scheduled test or maintenance activity for which pre-planned compensatory measures have been impl~emented) and 15 minutes have elapsed since the loss of annunciators."
The ECG, " Introduction and References" section, Step V.A.
requires, in part, that "If the Emergency Coordinator, using his best judgement, determines an Initiating Condition has been satisfied but the specific EAL is in question, he/she should promptly classify the event in accordance with the Initiating Condition.
In any event, if the plant conditions are equivalent to one of the four emergency classes...,
that classification should be declared."
Contrary to the above, an alert for a loss of annunciator event was not promptly declared as required by the ECG,
" Introduction and References" section, Step V.A.,
on October 4-5, 1995.
The operating crew recognized that the initiating condition had been satisfied by about 11:12 p.m.,
on October 4.
The alert was declared at 1:38 a.m.,
on October 5.
This is a Severity Level IV violation (Supplement VIII).
PSE&G concurs with the violation.
9701030224 961226 PDR FOIA O'NEILL96-351 PDR
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LR-N96030 (1)
The reason for the violation.
i The root cause of this event was personnel error.
The SNSS i
failed to declare an ALERT in accordance with Emergency Classification Guide after recognizing the entire OHA system i
was inoperable for >15 minutes.
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A contributing factor associated with this inappropriate action is as follows:
The SNSS reviewed the ECG description of an ALERT and j
dotarmined there was not an actual or potential substantial
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degradation of the plant safety level.
Therefore, he
.;, c.:.; concluded. that..because the. plant was in, a,defueled, condition an ALERT was not warranted.
The ECG' required declaring an i
j ALERT independent of operational mode.
(2)
The corrective steps that have been taken.
l 1.
The Senior Nuclear Shift Supervisor who failed to declare the ALERT was counseled for his actions, in accordance with j
the PSEGG disciplinary process.
The individual has since chosen to leave PSE&G.
i l-2.
This event was discussed with Salem senior Nuclear Shift i
Supervisors.
During the discussions, the proper use of the Salem Emergency Classification Guide was stressed.
These expectations were also reinforced at the February'1, 1996, Senior Nuclear Shift Supervisor meeting.
i (3)
The corrective steps that will be taken to avoid further j
violations, i
1.
Proper use of the Salem Emergency Classification Guides and lessons learned from this event and selected previous events d
will be reviewed and emphasized during the operator training l
sessions that are scheduled to support restart of the units.
2.
The Zaergency Preparedness continuing training program for i
operations Department shift personnel will be evaluated, and l
improvements,will be implemented as necessary.
Identified l
improvements will be in place by December 31, 1996.
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(4)
The Date when full compliance will be achieved.
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PSEGG achieved full compliance when the alert was declared
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on October 5 at 01:38.
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1 II.
10 CFR 50.54 (q) requires, in part "A licensee authorized to maintain in effect emergency plans which meet the s i
in 50.47(b) j part."
and the requirements in appendix E of this The licensee's NRC-approved Emergency Plan, 5setjon 3,
" organization," Part 10.0, 3
commitment for minimum staffing in accor8ance with" Staffing Com t
Supplement 1 of NUREG-0737, Table 2.
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Emstgency Plan, Section 3, details licensee'staffingTables 3.1 and 3.2 i
commitments by position.
Specifically, these tables denote
.u.;..e ;by.at least one electrical' engineer and one mechanic i
engineer within about i hour.
i October 5, 1995 Contrary to the above, on positions were n,ot staffed within about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.some emergency respon electrical engineer and mechanical enginuer emergency The response organization positions were not filled in the i
technical support center by fully qualified emergency response organization the alert declaration. personnel until about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> af ter This is a severity Level IV violation (supplement VIII).
PSEEG concurs with the violation.
(1)
The reason for the violation.
l The root cause of this event was inadequate management oversight.of the emergency preparedness function.
i Causal factors identified which contributed to this violation are:
1, Management's expectations to staff the Technical Support Center (TSC) within approximately one hour after notification were not well communicated or i
understood by all emergency response personnel.
2.
Emergency Planning drills were not structured to test the responsiveness of emergency response personnel to callout situations.
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3.
There was no selection criterion for personnel on the emergency response teams to assure the ability to
- aff the TSC in a timely fashion.
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LR-N96030 (2)
The corrective steps that have been taken.
1.
On October 26, 1995, the Senior Vice President - Nuclear Operations issued a letter delineating the roles, responsibilities and expectations to the entire emergency response organization.
This letter has been included in the handgut packa 2.
provided to new emergency response pagar nolders..geIncreased management support has significantly reinforced expectations of roles and responsibilities to emergency responders.
3.
The quarterly peger test methodology has been revised and tests.are being conducted on a more frequent basis of'at 2,
least once a month.
4.
A response callout accountability form has been developed and will continue to be sent to the managers or supervisors of emergency response personnel who do not respond l
appropriately to a pagsr test.
This action will hold the individual and his manager /su f ailure to n'est expectations.pervisor accountable for 5.
Unannounced off-hours mustering drills are currently being conducted quarterly.
These drills reinforced *.he expectation of timely response and are also used to test and evaluate individual responses and call-out system.
operations.
(3)
The corrective steps that will be taken to avoid further violations.
1.
Emergency Preparedness is developing a self assessment program which will include evaluating and measuring the ability of the Emergency Response Organization (ERO) to activate facilities in a timely manner.
This self assessment program will be completed by May 10, 1996.
2.
A Duty Roster System for essential ERO members is being implemented.
It will define expected actions concerning assignments, duty expectations and response times for both essential and non-essential members of the Emergency Responsa Organization.
This Duty Roster system will assure the ability to staff the TSC in a timely fashion as described in the PSEEG Emergency Plan.
The Duty Rosser system will be completed by March 31, 1996.
i 3.
Ongoing off-hours mustering drills will be utilized to assess the effectiveness of the ERO response and to refine the process as needed.
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Document Control Desk 5
LR-N96030 (4)
The Date when full compliance will be achieved.
PSE&G achieved full compliance when the TSC was fully staffed at 04:00 on October 5, 1995.
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l LR-N96030 l
III.10 CPR 50.54 (g) re, quires, in part, "A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in appendix E of this l
part."
r 10 CFR 50, Appendix E,Section IV, content of Emergency
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Plans, Subpart B, Assersment Actions requires, in part, i
"These emergency action levels shall be discussed and agreed j
en by the applicant and state and local governmental i
authorities and approved by the NRC."
Contrary to the above, the licensee failed to discuss and i
seek agreement with the State of New Jersey prior to l
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implementing a revision to their emergency action level scheme on October 7, 1995.
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This is a Severity Level IV violation (supplement VIII).
PSE&G concurs with the violation.
1 (1)
The reason for the violation, j
The root cause of this violation was a misinterpretation of i
10 CFR 50.54 (q) and 10 CFR 50 Appendix E.
believed that the annual training and reviews associatedPSE&G mistakenly with the preparation and submittel of the NUMARC Energency Action Levels (EALs) were adequate to allow for the revision of the EAL associated with the Loss of Annunciation.
(2)
The corrective steps that have been taken.
1.
PSEEG conducted NUMARC EAL training with the BNE staff.
This training was conducted on November 29, 1995.
2.
PSEEG is conducting team building sessions with BNE management and staff in order to improve communications.
3.
PSEEG, in coo Engineering (peration with the New Jersey Bureau of Nuclear BNE), has developed an EAL Review Form to be used for submittal of EAL changes and to document agreement / disagreement with proposed revision.
j (3)
The corrective steps that will be taken to avoid further violations.
PSE&G is revising its procedure to require Stater and Local 1.
officials to review and agree on any EAL changes prior to d
implementation.
This procedure will be revised by March 31, 1996.
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i LR-N96030 i
o (4)
The Date when full compliance will be achieved.
PSEEG will achieve full compliance when the State of New l
Jersey (BNE) agrees with the proposed EAL changes.
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LR-N96030 IV.
10 CFR 50.47(b) (8) requires that " Adequate emergency facilities and equipment to support the emergency response
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are provided and maintained.
The Emergency Classification Guide '(ECG), Section 10,
" Loss of Instrumentation / Annunciation / communications," requires an alert declaration if " Loss of most or all (>75%) overhead l
. Annunciators, (excluding a scheduled test or maintenance
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activity for which pre-planned compensatdty measures have been implemented) and 15 minutes have elapsed since the loss 4
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of annunciators."
contrary to the above, on october 4-5, 1995, the control
.croom emergency response.cfacility equipment provided was not m n..
adequate to support the emergency response, in that design deficiegies existed in the overhead annunciator system equipnet.t that resulted in inadequate support of the emergency classification and action level scheme.
Additionally, the design deficiencies were not detected and or indicated by the overhead annunciator equipment tests in such a manner that the loss of most or all (>75%) overhead annunciators could be determined by the operators and therefore support'an alert declaration.
This violation applies to both Salem Unit i and Unit 2, since the overhead annunciator equipment is identical for both units.
This is a Severity Level IV violation (supplement vIII).
PSEEG concurs with the violation.
(1)
The reason for the violation.
The root causes of this violation are:
1)
An initiating event occurred which caused a critical task to abort.
This failure caused the system not to process new alarms.
2)
Inadequate mana action process.gement oversight of the corrective V
(2)
The corrective steps that have been taken.
1.
The OHA system operating and abnormal procedures were revised.
The revised procedures provides better technical guidance to the operator to rapidly test the annunciator system to determine operability.
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LR-N96030 2.
In accordance with the operability Determination procedure, i
a manual test, to s'imulate an incoming alarm, tests the I
system's primary function to annunciate and process incoming j
change-of-state alarms, thus verifying continued operability l
of the system.
j 3.
The 18-month system functional test (preventive maintenance 4
procedure) was completed.
Three sequence of Event Recorder (SER) power supplies (+5 4.
VDC) were replaced.
5.
The SER main chassis BETA 4100R backplane was replaced with
,,.a newly purchased and tested printed circuit board (PCB).'
The PCB was purchased with augmented Quality Assurance.
6.
A new corrective Action Program (CAP) has been i.aplemented to communicate NBU management expectations on timely problem identification and resolution.
The cap also provides clear definition of roles and responsibilities.
The current CAP establishes a low threshold for reporting problems, provides aggressive problem assessment / root cause determination expectations and places management in charge of root cause and corrective action completion times.
Results to-date indicate that personnel are not hesitant to raise issues through the process.
7.
A new element incorporated under the CAP imprr,vement area, is the Operational Experience Feedback (OEF) Program.
Improvements to the OEF process itself included the establishment of well defined roles and responsibilities, and standards of performance for implementing organizations.
Performance measures have been be established to allow NBU management to monitor program effectiveness and assign accountability if performance standards are not satisfied.
These changes were made in order to better integrate the OEF program into the operation of the mEations.
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(3) he corrective steps that will be taken to avoid further violations.
1.
The OHA system software /firmware will be replaced prior to the respective Unit's restart.
Quality will be assured through a modified critical Digital Review of task structure, data structure, hardware and code.
A factory acceptance test will be performed at the vendor facility.
2.
A permanent modification will install an auto tester on the OHA system that will simulate an alarm and verify that the OHA system continues to process the alarm.
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LR-N96g This modification will take the place of the control room operator manually p'erforming the test periodically on both Salem plants.
This modification will be completed prior to
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the Unit's restart.
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A design change will be pursued to replace the present OHA 3.
system with a new system following the Unit's restart.
(4)
The Date when full compliance will be achieved.
PSEGG will achieve full compliance prior to the restart of the units, when the autotester modification will be installed.
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