ML20203H675
| ML20203H675 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/12/1997 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-354-97-07, 50-354-97-7, LR-N97767, NUDOCS 9712190020 | |
| Download: ML20203H675 (7) | |
Text
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9 Pubhc Servse Dectric and Gas cornpany 1,culs F. Stor Pubhc Servco E'octnc and Gas Company P.O. E ax 236. Hancocks Bxigo. NJ 08038 00E}339-5700 wev<.e, -. %
DEC 121997 LR-H97767 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-07 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKE't NO. 50-354 Gentlemen:
Pursuant to the provisions of 10CFR2.201, Public Service Electric and Gas Company (P9E&G) hereby submits a reply to the Notice of Violation (NOV) issued to the Hope Creek Generating Jtaticn 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, as required by 10CFR50, Appendix B, Criterion XVI; 2) two exa'aples of a f ailure 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 cf 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 safet'y-related Agastat and Telemechanique relays.
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As discussed with NRC management on November 18, 1997, the
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details of this reply address the first two violations contained
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in the inspection report.
The reply to the last three violations contained in Appendix A of the inspection report will be provided e
by January 12, 1998.
p Should you have any quections or comments on thia transmittal, do not hesitate to contact us.
Sincerely, kr Attachment (1) 9712190020 971212
PDR ADOCK 05000354 G
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DEC! 21997 '
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- Document.Contr'ol-LDesk-
'-2-~
i-LR-N97767
- -- C Mr.1T. Martin,1 Administrator-~,-REglon I.
U. S. Nuclear--Regulatory; Commission.
475 Allendale-Road King of-Prussia,rPA -194066
- Ms. B.'Mozafari," Licensing Project' Manager --HC U..S.-Nuclear Regulatory Commission"
. One White Flint 'srth 11555'Rockville Fike
- Mail Stop 14E?1.
Rockville, MD 20852-i Mr. S. J' orris '. (X24 )
___USNRC Senior Resider.t Inspector - HC Mr. K._Tosch, Manager IV-Bureau,of Nuclear Engineering P. 0. Box 415 4
Trenton, NJ-.08625 0
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' 95-4933
LR-N97767 A
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-07 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 I.
REPLY TO THE NQIICE OF VIOLATI_QH A.
10 CFR 50, Appendix B, Criterion KVI Viclatien 1.
Description of the Notice of Violati.QD "10 CFR 50 Appendix B, Criterion XVI, requires in part that conditions adverse to quality, such as failures, malfunctions and deficiencies, be promptly identified and corrected.
Cont 2ary 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 r-idition adverse to quality.
Despite several opporti;1 ties to detect this condition earlier, the inoperable fire pump was not identified and corrected until September 15, 1997, approximately 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> after electrical supply breaker opened."
This is a Severity Level I'.
violation (supplement I).
2.
Reolv to Notice of Violation PS2&G agrees with the violation.
3.
Reason for the Violation PSE&G has attributed the cause of the 10 CFR 50, 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 power.
During the bus-transfer, the fire pump breaker 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 puup in the de-energized condition.
Prior to the bus transfer, fire protection personnel were notified by the operators of a temporary Page 1 of 5 I
LR-H97767 interruption of power to the motor driven fire pump.
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 the fire pump breaker would not trip during the bus de-energization, no follow-up was performed by either operations or fire protection personnel upon 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.as inopernble.
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 inoperable condition of the fire pump for the approximately 34 hour3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> period.
4.
Corrective Steos That Have Been Taken and Resulta Achieved a.
Breaker 52-590-43 was reset i.nd the electric motor-drive fire pump was retested satisfactorily on September 15,
- 1997, b.
Fire protection and operations personnel involved with 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, c.
The lessons learned from this event have been discussed with Operations and Fire Protection Department personnel.
5.
Corrective Stens That Will Be Taken to Avoid Further Violations a.
The Training Department will evaluate this event to determine if additional training is required on breaker design and performance.
The evaluation on the need for training modifications will be completed by January 15, 1998.
b.
Procedure revisions will be made co provide additional guidance on breaker operation and bus power supply transfers.
These revisions will be completed by February 18, 1998.
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x. s-Attochment 1-LR-N97767 6 '.
Date_When Full Comoliance-Will Be Achieved
-Fullicompliance-was achieved on September 15, 1997.-when the tire pump breaker was closed and the fire pump was declared-operable.
B.
Technical-Specification 6.8.1.a Violation 1.
Descriotion of the Notice of Violation.
" Hope Creek technical _speciUication 6.8.1.a requires in part that written procedures shall be established and implemented for the applicable activities specified in
(. G) 1.33 Revision 2.
RG-Appendix A of Regulatory Guide R
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 usr.ge requirements, including Category I (in-hand with verbatim step-by-step compliance)-and Category II (available at work site and 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 maintenance procedure, HC.MD-ST-PB-0010(Q), in order to complete a 4160 VAC vital bus relay test.
(2)
On October 4, 1997, technicians completed feed water system flow transmitter calibration checks and-adjustments without completing the applicable sections of the governing Category II maintenance procedure, HC.IC-DC.ZZ-0030(Q)."
This is a Severity Level IV violation (Supplement I).
2.
Reolv 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 testing.
This failure-to adhere to the Category I procedure requirements, o
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A,ttashment 1 LR-N97767 which does not permit " skill of the' craft" to perform steps out of sequence, was the result of a lack of understanding concerning this aspect of compliance with Category I procedures.
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 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 involved in the 4160 VAC vital bus relay tests were held accountable for their actions in accordance with PSE&G's disciplinary policy, b.
The contractor technicians involved in the feed water system flow transmitter calibration ch?cks and adjustments were terminated.
The cont,.act 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" uso needs to be incorporated in procedure evisions.
d.
The procedure for the 4160 VAC vital bus relay tests was enhanced to address the condition 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.
e.
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 thin event and reinforce procedure compliance requirements.
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l AttOchment 1 LR-N9'767 I
In addition, a field verification was performed to ensure that the appropriate procedure steps had been actually completed during the flow transmitter calibration checks and adjustments.
f.
A review of selected work packages completed by the contract group performing the feed water system flow transmitter calibrations was conducted and only one other similar case of an inadequately filled out procedule 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 this care as well.
5.
Corrective Steos That Will Be Taken to Avoid Further Violations No additional corrective actions are planned.
6.
Date When Full Compliance Will Be Achieved Hope Creek is in full compliance.
The two examples of procedure non-compliance were determined to have no adverse impact on equipment operability.
Corrective actions have been implemented to address the cause of the procedure non-compliance.
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