ML20199L423
| ML20199L423 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/03/1998 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H Public Service Enterprise Group |
| References | |
| 50-354-97-07, 50-354-97-7, NUDOCS 9802090197 | |
| Download: ML20199L423 (3) | |
See also: IR 05000354/1997007
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February 3,1998
Mr. Harold W. Keiser
Executive Vice President
Nuclear Business Unit
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Public Service Electric & Gas Company
PO Box 236
Hancocks Bridge, NJ 08038
SUBJECT:
Inspection Report 50-354/97-07
Dear Mr.- Keiser:
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This letter refers to your December 12,1997 correspondence (LR N97767),in response to
our November 13,1997 letter regarding the Hope Creek facility.
Thank you for informing us of the corrective and preventive actions for the Notice of
Violation, as documented in your letter. The first violation involved two examples of Hope
Creek maintenance technicians failirT tr. !nplement procedural adherence requirements
during maintenance ectivities. The s90ed violation involves a failure to promptly identify
an inoperable electric motor-driven fire pump supply breaker. Your actions will be
- examined during future inspections at Hope Creek.
. Your cooperation with us is appreciated.
Sincerely,
ORIGINAL SIGNED BY:
-James C. Linville, Chief
Projects Branch 3
Division of Reactor Projects
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Docket No. 50-354
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Mr. Harold W. Keiser
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cc:
L. Stor:, Senior Vice President - Nuclear Operations
E. Simpson, Senior Vice President - Nuclear Engineering
E. Salowitz, Director - Nuclear Business Support
M. Bezilla, General Manager - Hope Creek Operations
J. McMahon, Director - Quality / Nuclear Training / Emergency Preparedness
D. Powell,- Manager - Licensing / Regulation and Fuels
A. O. Tapert, Program Administrator
cc w/cy of Licensee's Letter:
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A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
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J. A. Isabella, Manager, Joint Generation
Atlantic Electric
R. Kankus, Joint Owner Affairs.
Jeffrey J. Keenan, Esquire
M. J. Wetterhahn, Esquire
Consumer Advocate, Office of Consumer Advocate
William Conklin, Public Safety Consultant, Lower Alloways Creek Township
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State of New Jersey
State of Delaware
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' Mr. Harold W. Keiser
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Distribution w/ copy of Licensee's Response Letter:
Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
PUBLIC
D. Screnci, PAO
J. Linville, DRP
S. Barber, DRP
C. O'Daniell, DRP -
. B. McCabe, OEDO
J. Stolz, PD1-2, NRR
B. Mozafari, Project Manager, NRR
inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR '
DOCDESK
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DOCUMENT NAME: G:\\ BRANCH 3\\REPLYLTR\\9707RSP.LTR
Ta receive a copy of this document, Indipate ,n the box: "C" = Cooy without attachment / enclosure "E* = Copy with attachment / enclosure
"N" = No copy
OFFICE'
Rl/DRP
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NAME
JLinville W/
DATE
OM/98// '
01/ /98
01/ /98
01/ /98
01/ /98
M'
OFFICIAL RECORD COPY
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Pubhc Service
Electnc and Gas
Company
Louis F. Stort
Pubhc Sennee Electne and Gas Company
P O. Box 236. Hancocks Bndge, NJ 08038
609-3394 700
% ue e,.w.n . w.., o .-
DEC 121997
LR-N97767
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United States Nuclear Regulatory Commission
Document Contro) Desk
20555
REPLY TO NOTICE OF VIOLATION
INSPECTION REPORT NO. 50-354/97-07
HOPE CREEK GENERATING STATION
FACILITY OPERATING LICENSE NPF-57
DOCKET NO. 50-354
Gentlemen:
Pursuant to the provisions of 10CFR2.201, Public Service Electric
and Gas Company (PSE&G) hereby submits a reply to the Notice of
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Violation (NOV) . issued to the Hope Creek Generating Station in a
letter dated November 13, 1997.
The violations contained in
Appendix A of the November 13th letter concerned: 1) a failure to
promptly identify an inoperable electric motor-driven fire pump,
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as required by 10CFR50, Appendix B,
Criterion XVI; 2) two
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examples of a failure to follow procedures, as required by
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Technical Specification 6.8.1.a,
during maintenance activities;
3) a failure to appropriately perform a 10CFR50.59 safety
evaluation for a design modification; 4) a failure to follow the
requirements of 10CFR50.49 applicable to the environmental
qualification of Struthers-Dunn relays; and 5) a failure to
follow the requirements of 10CFR50, Appendix B,
Criterion III,
Design Control, when extending the service life of the safety-
related Agastat and Telemechanique relays.
As discussed with NRC management on November 18, 1997, the
details of this reply address the first two violutions contained
in the inspection report.
The reply to the last three violations
contained in Appendix A of the inspection report will be provided
by January 12, 1998.
Should you have any questions or comments on this transmittal, i-
not hesitate to contact us.
Sincerely,
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Attachment (1)
@ Pnotedon
necyew Pap.,
8 % % 20 Off
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- Document Control Desk
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LR-N97767
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Mr. :- T. Martin, Administrator - Region I
U. S.: Nuclear Regulatory Commission
475'Allendale Road-
King of. Prussia,:PA '19406
Ms. B. Mozafari, Licensing Project Manager - HC
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.U.;S. Nuclear' Regulatory Commission
One White Flint North
111555 Rockville Pike
Mail Stop 14E21
Rockville, MD
20852
-Mr. S.-Morris (X24)-
USNRC Senior Resident Inspector - HC
Mr. K.:Tosch, Manager IV
Bureau of Nuclear Engineering
-P.10.
Boa 415
. Trenton,-NJ
08625
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Attachment 1
LR-N97767
RESPONSE TO NOTICE OF VIOLATION
INSPECTION REPORT No. 50-354/97-07
HOPE CREEK GENERATING STATION
DOCKET NO. 50-354
-I.
REPLY TO THE NOTICE OF VIOLATION
A.
Criterion XVI Violation
1.
Description of the Notice of Violation
Criterion XVI, requires in part
that conditions adverse to quality, such as failures,
malfunctions and deficiencies, be promptly identified
and corrected.
Contrary to the above, on September 14, 1997, the
electric motor-driven fire pump supply breaker opened
during an electrical bus swap which rendered the pump
inoperable, a condition adverse to quality.
Despite
several opportunities to detect this condition earlier,
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the inoperable fire pump was not identified and
corrected until September 15, 1997, approximately 34
hours after electrical supply breaker opened."
This is a Severity Level IV violation-(Supplement I) .
2.
Recly to Notice of Violation
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.PSE&G_ agrees with the violation.
3.
Reason for the Violation
PSE&G has attributed the cause of the 10 CFR S0,
Appendix B,
Criterion XVI, violation to personnel error.
During the electrical bus swap,-operators failed to
follow a procedure precaution, which required unloading
of equipment from the bus prior to transferring infeed
pswer.
During=the bis transfer,-the fire pump breaker
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was racked in (which energized a downstream control
panel) ; however, the pump itself was de-energized.
When
the electrical bus was de-energized, the undervoltage
condition caused the fire pump breaker to trip,
rendering the fire pump inoperable.
The operators had
incorrectly concluded that the fire pump breaker would
not trip with the pump in the de-energized condition.
Prior to the bus transfer, fire protection personnel
were notified by the operators of a temporary
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LR-N97767
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interruption of power to the motor driven fire pump.
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When the bus-was de-energized, several alarms
annunciated.
The alarm for the inoperable fire pump was
received and acknowledged, but the operators failed to
recognize that the fire pump breaker had tripped during
the bus de-energization.
Because of the assumption that
thesfire pump breaker would not trip during the bus de-
energization, no follow-up was performed by either
operations or fire _ protection personnel upcn power
restoration to the bus to ensure that the fire pump was
appropriately energized.
Subsequently, one operations'round and two fire
protection rounds were conducted through the fire pump
house while the fire pump was. inoperable.
During these
rounds, the operations and fire protection personnel
failed to notice that an indication light was
extinguished on the fire pump panel, which would have.
alerted them that the fire pump was inoperable.
Inattention to detail.on the-part of these individuals
perpetuated the knoperable condition of the fire pump
for the approxit ately 34 hcur period.
4.
Corrective Steos That Have Been Taken and Results
Achieved
a.
Breaker 52-590-43 was reset.and the electric motor-drive
fire pump was retested satisfactorily on September 15,
1997.
b.
Fire protection and operations personnel involved with
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-the failure _to recognize the inoperability of the fire
pump have been held accountable for their actions in
accordance with PSE&G's disciplinary policy.
The_ lessons learned _from this event have been discussed
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with Operations and Fire Protection Department
personnel.
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5.
Corrective Steos That Will Be Taken to Avoid Further
Violations
The-Training Department will evaluate this event to
a.
determine if additional training is required on breaker
design and performance.
The evalurtion on the need for
training modifications will be completed by January 15,
1998,
b.
Procedure revisions will be made to provide additional
guidance on breaker operation and bus power supply
transfers.
These revisions will be completed by
February 18, 1998.
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Attachment ' l -
LR-N97767
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Date When Full Comoliance Will Be Achieved
-Full' compliance was achieved on September 15, 1997, when the
fire pump breaker was closed and the fire pump was declared
B.-
! Technical Specification 6.8.1.a Violation
1.-
Descriotion of the Notice of Violation
" Hope Creek technical specification 6.8.1.a requires in
part that written procedures'shall be established and
implemented for the applicable activities specified in
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Appendix A of Regulatory Guide (RG) 1.33 Revision 2.
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1.33 requires administrative procedures be implemented'
which prescribe procedure adherence practices.
PSE&G
Nuclear Administrative Procedure NC.NA-AP.ZZ-0001 (NAP-
1) ,- specifies procedure usage requiren ents, including
Category I (in-hand with verbatim step-by-step
compliance) and Category II (available at work site and
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completed as applicable)..
Contrary to the above, two examples of failures by
maintenance technicians to implement the procedure
adherence requirements of NAP-1 were identified as
follows:
(1)- On September 18,-1997,. technicians deviated from.
the sequence of steps specified in a Category.I
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maintenance procedure, HC.MD-ST-PB-0010 (Q) , in order to
complete a 4160 VAC vital bus relay test.
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On October 4,
1997, technicians completed feed
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water system flow transmitter calibration checks and
adjustments without-completing-the applicable sections
of the governing CategoryfII maintenance procedure,
HC.IC-DC.ZZ-0030(Q)."
This is a Severity Level-IV violation (Supplement I).
2.
Recly to Notice of Violation
PSE&G agrees with the violation.
3.
Reason for the Violation
PSE&G has attributed the cause of both of the examples
cited in the Technical Specification 6.8.1.a violation
to personnel error.
During the 4160 VAC vital bus relay
test, the relay technicians inappropriately implemented
" skill of the craft" to compensate for unexpected
conditions encountered during the teeting.
This failure
to adhere to the Category I procedure requirements,
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Attachment 1
LR-N97767
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which does not permit " skill of the craft" to perform
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steps out of sequencu, was the result of a lack of
understanding concerning this aspect of-compliance with
category I p.oceduros.
_During the feed water system flow transmitter
calibration checks and adjustments, the contractor
- technicians did not appropriately sign-off steps-in
applicable sections of the procedure.
The calibration
procedure for the feed water flow transmitter was_used
by the technicians as a guide and not followed step-by-
step as is required.
In this particular case, the
calibration was performed and the procedure initials
completed later. . There were three other transmitter
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calibrations completed at the same time by the same
technicians.
When the procedures were filled out, all
four were done the same way; however, one of the
transmitters did require adjustments, which was not
documented properly by the technicians when the
-procedure was completed.
The technician's inattention
to detail was the cause of the procedure non-compliance.
4.
Corrective Steos That Have Been Taken and Results
Achieved
a .- The relay technicians f avolved in the 4160 VAC vital 'aus
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relay tests were hald accountable for their actions in
acccrdance with PSE&G's disciplinary policy.
.b.
The contractor technicians involved in the feed water
system flow transmitter calibration checks and
adjustments were terminated.
The contract supervisor of
those technicians was also removed from his. position,
c._
Following the 4160 VAC vital bus relay test procedure
non-compliance, a work stand <down was conducted for
Relay Department personnel to review this event and
reinforce procedure compliance requirements.
Following
this stand down, Relay Department personnel have been
identifying cases where " skill,of the craft" use needs
to be incorporated in procedure revisions,
d.
The procedure for-the 4160 /AC vital bus relay tests wa.,
enhanced to address the c+ .ition where " skill of the
craft
was implemented.
Additional procedural guidance
has also been established to address " skill of the
craft" and compliance with written procedures.
3.
Following the feed water system flow transmitter
calibration checks and adjustments procedure non-
compliance, a work stand-down was conducted with the
contract group involved with the event to review this
event and reinforce procedure compliance requirements.
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Attachment 1
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LR-N97767
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In addition, a field verification was performed to
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ensure that the appropriate procedure steps had been
actually completed during the ficw transmitter
calibration checks and adjustments.
f.
A review of selected work packages completed by the
contract grouo performing the feed water system flow
transmitter calibrations was conducted and only one
other similar case of an inadequately filled out
procedure was identified.
However, the cause of this
issue was attributed to an ambiguously worded procedure
step and not technician inattention to detail as in the
violation example.
A field verification was also
performed to ensure that the appropriate procedure steps
had been actually completed in thic case as well.
5.
Corrective Steos That Will Be Taken to Avoid Fu*thgg
Violations
No additional corrective actions are planned.
6.
Date When Full Comoliance Will Be Achieved
Hope Creek is in full compliance.
The two examples of
procedure non-compliance were determined to ha.ve no adverse
impact on equipment operability.
Corrects"e actions have
been implemented to adfress the cause of the procedure non-
compliance.
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