PLA-2389, Forwards Response to Enforcement Action 84-109 Resulting from Violations & Deviation Noted in Insp Rept 50-388/84-34.Corrective Action:Addl Training Conducted Re Proper Procedures for Racking Out Breakers.Fee Paid

Forwards Response to Enforcement Action 84-109 Resulting from Violations & Deviation Noted in Insp Rept 50-388/84-34.Corrective Action:Addl Training Conducted Re Proper Procedures for Racking Out Breakers.Fee Paid

ML20113F863
Person / Time
Site:	Susquehanna
Issue date:	01/17/1985
From:	Kenyon B PENNSYLVANIA POWER & LIGHT CO.
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
EA-84-109, PLA-2389, NUDOCS 8501240157
Download: ML20113F863 (9)

Text

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Dc.5 PP&L Pennsylvania Power & Light Company Two North Ninth Street

• Allentown, PA 18101

• 215 1 770 5151 Bruce D. Kenyon Vice President-Nuclear Operations 215/770-7502 JAN 171985 Mr. James M. Taylor, Deputy Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO ENFORCEMENT ACTION 84-109 ER 100508 FILE 841-04 PLA-2389 Docket No. 50-388/NPF-22

Dear Mr. Taylor:

Pursuant to 10CFR2.201, Pennsylvania Power & Light Company hereby provides the attached response to Enforcement Action 84-109. Payment in the amount of

$50,000 is enclosed.

We trust the Commission will find our response acceptable.

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Very truly yours, N

B. D. Kenyo Vice Presiden -Nuclear Operations Attachments

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Affidavit i

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Dr. Thomas E. Murley Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Mr. R. H. Jacobs - NRC Senior Resident-Inspector Ms. M. J. Campagnone - NRC (NRR)

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3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA) sS

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'I, Bruce D. Kenyon, being duly sworn according to law, state that I am Vice Presideut-Nuclear Operations of Pennsylvania Power & Light Company and that the facts set forth on the attached response to Enforcement Action 84-109 dated December 18, 1984, are true and correct to the best of my knowledge, information and belief.

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-m Bruce D. 1(enyon (-/

Vice President-Nuclear OpMations Sworn to and subspyibed before me this l8lrrl day of January, 1985.

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Notary Public MARTHA C. BARTO, Ncte.7 P:S!!c

- Mentowrs Lehlsh Cor.:y, Pa.

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Attachment to PLA-2389 RESPONSE TO ENFORCEMENT ACTION 84-109 l

Introduction The responses to the individual violations and the deviation'are provided below. However, it should be recognized that these issues are interrelated and -that many of the correctiva actions have been taken in response to the entire event rather.than the individual violations. PP&L has provided

~ detailed corrective action plans to NRC covering many more activities than those which were cited as violations.

(See PLA-2268 dated August 13, 1984, and PLA-2283 dated August 21, 1984.) These were reviewed with NRC at the enforcement conference on October 9, 1984.

A.. Viol'ation (388/84-34-01) 10 CFR Part 50, Appendix B, Criterion XVI requires establishment of measures to assure that the cause of significant conditions adverse to quality-is determined, and corrective action is taken to preclude-repetition.

Contrary to the above, the licensee's corrective action for two previous-t significant operating occurrences adverse to quality on June 4, 1983 (S00R No. IR-2-83-022) and October 6, 1983, (SOOR No. IR-2-83-056),

wherein an operator incorrectly opened a'DC auxiliary relay and bus control power knife switch for a 4.16KV ESS bus, was not adequate in that-the corrective actions did not.. prevent recurrence of the condition.

Specifically, not all of the operators of the subject knife switches were trained in the lessons learned from the previous events as was planned.

As a-result, on July 26, 1984, an operator who had not received the training incorrectly opened four separate DC auxiliary relay-and bus control power knife switches.

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' Response:

(1) PP&L admits that previous corrective actions did not prevent an

_ operator-from opening the incorrect knife. switches.

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- (2) The two precursor: events occurred during construction of Unit 2.

Additional corrective actions were not taken because'the-potential operating. consequences were not fully recognized at that time. The-second incident was placed on the weekly meeting agenda for the

J Supervisor'of Operations to-review with operations personnel.-

However, no system was in place to ensure-that all personnel had attended. '

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Attachment to PLA-2389' Page 2 (3).The following corrective actions have been taken to prevent future knife switch misoperation:

a) New labels have been installed'on all 13.8KV and 4.16KV-Breaker and Bus DC control power. switches. These labels eliminate the ambiguous wording which contributed to the errors.

b) Warning signs have been installed which caution personnel that opening the bus control power knife switches disables _the ESS Bus and.the associated diesel generator.-

c) Additional training has been given to operators _on the proper procedure for racking out breakers.

d). An Operations Instruction has been issued providing procedures for racking out breakers.

(4) The following actions have.been.takeneto prevent recurrence of events:

a)- A comprehensive operator training tracking. system has been implemeured to ensure that all licensed and non-licensed operatora t-eview designated non-routine events, b). Training for event evaluators has been. conducted to improve evaluation and investigation activities associated with review of-operating occurrences...

c).The INPO Human Performance Evaluation' System has been implemented.

'The last two activities should-improve our. assessment. capabilities

regarding personnel error related occurrences so that effective -

corrective actions.can be recognized and implemented.

(5)~ PP&L is now in full compliance.

B., Violation'(388/84-34-02)

10 CFR Part 50, Appendix B,' Criterion II requires indoctrination and training of personnel performing activities.affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Contrary to the above.

'(1). operator training for the' process to.be followed to rack out a 4.16KV' circuit breaker on an ESS~ bus cubicle containing two knife switches was not sufficient in that.an operator incorrectly opened each of-E four separate DC' auxiliary relay and bus conttol-knife switches on July 26, 1984; e - -

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7 Attachment to PLA-2389

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Page 3 (2) operator training in the reset of emergency diesel generator i

protective devices that can prevent the diesels from being started

~ was not sufficient in that, on July 26 1984, operators initially were unable to reset priority alarms, and required approximately thirty-five. minutes to determine that the protective relay seal-in must be reset before system reset of the "B" and "D" emergency-diesel generator "Hi Priority" alarms could be accomplished, allowing the 3

diesels to be started; (3) operator training in recognizing the 4.16KV-ESS breaker light indications on the front control panels of 4.16KV ESS bus cubicles was not sufficient in that, on-July 26, 1984, several plant operators who operate this equipment were not knowledgeable of the meaning of 4

1the light indications, and were therefore unable to ascertain the incorrect manipulation of the DC auxiliary. relay and bus control power knife switch when it was opened; and, (4) operator training in the restoration of the suppression pool temperature monitoring instrumentation following the loss and restoration of power was inadequate in that, on July-26, 1984, Loperators were not knowledgeable in the resetting procedure and were therefore unable to' restore suppression pool temperature monitoring

.for approximately one hour.

Response

- (1) PP&L admits-that several of the personnel involved in this event did not display suitable proficiency in the activities they performed.

(2) The reasons for the violation were:

a) -For item B(1), a lack' of thoroughness in the methods used to ensure that all individuals were properly trained, b) For items B(2) through (4), incomplete; training in that the specific tasks had not been identified and incorporated into the training program.

.(3).The following. corrective actions have been taken:

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_a)

Additional training covering the event was given to Operations-

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personnel prior to Unit 2 restart. ' The start-up test was

. reperformed successfully on August 7, 1984.

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~ Numerous operating procedures including those~ associated with the four specific instances cited have been revised to provide' additional guidance and information to facilitate improved y.

operator response.

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Attachment to PLA-2389 Page 4 c) A comprehensive operator training tracking system has been implemented to ensure that all licensed and non-licensed operators review designated non-routine events, d) A self-evaluation program was conducted-involving non-licensed operator activities. This program consisted of training instructors monitoring non-licensed operators.during their routine activities. 'The goal of.the program was to identify what

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additional information and training would be necessary or useful to improve non-licensed operator proficiency.

e)

A' job. analysis of operator positions has been completed including

'the generation of a listing of tasks performed. By comparing the existing training program.to this task list, training deficiencies were identified. High impact deficiencies-have been incorporated into the training programs.- The remaining deficiencies will be incorporated as training material is-y revised.

(4) The following corrective actions are in progress:

a) An " operating practices" training program is being implemented.

4 This program includes topics aimed at improving communications, maintaining awareness of plant conditions, and enhancing the

. effectiveness of operator rounds. The training will be completed-I by December 1985 in accordance with the retraining: schedule.

b) The results of the self-evaluation program discussed in 3d above have been incorporated into the initial training program for-non-licensed. operators. These results are also being used to

. enhance retraining for non-licensed operators during their' periodic requalification training. The training will be completed'by December 1985 in accordance with the retraining schedule.

1 (5) PP&L'is now in full compliance.

C.

Violation (388/84-34-29)'

10 CFR Part 50, Appendix B, Criterion V requires that activities affecting

. uality be prescribed by documented instructions, procedures or drawings q

of a type appropriate to the circunstances. Further, the SSES Operational Quality Assurance.NMnual (0QAM), Operational Policy Statement (OPS)-12, Administrative ' Control of Plant rperation, Revision 1. states (paragraph 5.1.4), "The procedures shall be of sufficient detail to allow a qualified individual to perform the prescribed activity without direct i

supe rvision.... " The licensee procedure for controlling the breaker.

alignments for thefstartup test was ST-31.1 " Loss of Turbine Generator and Loss of Offsite Power," Revision 3, dated July 24, 1984.

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Attachment to PLA-2389 Page 5 s

Contrary.to the above, ST-31.1 did not provide sufficient instruction to the operator for the rack out of the Unit I supply feeder breakers to the four Unit 2.4.16KV ESS busses in that the procedure directed that the appropriate breakers be racked out, but did not detail the process to be followed, and did not identify which one of two knife' switches in each

cubicle should be manipulated.

Response

. (1) PP&L admits that ST-31.1 did not include specific instructions on how to properly-rack out the supply feeder breakers.

-(2)- The reason for the violation was that the procedure relied on

" standard practices" and did not specifically detail the process for racking out a breaker. The breakers involved have two knife switches as opposed to a single knife switch in other similar breakers.

Presence of the second knife switch and confusing labelling of the switches contributed-to the error.

(3), The following corrective actions have been taken in addition to those provided in response to Violations A & B:

a) ST 31.1 was revised to specifically indicate the_ proper knife switches to be operated.

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I b) All of-the remaining Startup Test procedures were reviewed.

Where appropriate, these have been revised-to incorporate sufficient additional information to preclude misoparation of equipment.

<(4) No additional corrective action is necessary.

(5)- PP&L is now in full compliance.

-D.

. Violation - (388/84-34-30)'

l'0 CFR Part 50, Appendix B, Criterion X requires a program be executed to independently verify activities affecting quality for conformance with the documented instructions, procedures and. drawings for accomplishing the activity. Further, the SSES OQAM, OPS-14, Control of Inspection'and:

. Testing, Revision 1, states (paragraph 5.1.2), " Inspections shall be performed to verify that activities are being or have been performed in accordance with'the applicable instructions, procedures, or drawings."

Contrary to the above, on July 26, 1984', a startup engineer assigned to1 independently verify that test procedure ST-31.1 was followed for operation of_the knife' switches did not detect the improper opening of the DC auxiliary relay and bus control power. knife switch in each of the four 4.16KV ESS breaker cubicles.

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1 Page 6

Response

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. (1) ~ PP&L admits that independent _ verification of the knife switch

" positions in the 4.16KV ESS breaker cubicles during ST 31.1 did not identify the error.

(2) The reason for the violation was an improper verification performed by the' assigned' individual.

(3) The following corrective action has been taken:

A station policy has been issued which provides additional guidance on verification requirements. This policy establishes a hierarchy of verification levels as well as identifying activities which require verification. For the.most part, activities which require verification include operations, maintenance, surveillance testing, equipment control measures and temporary modifications. An independent verification is required for activities which simultaneously affect equipment from both divisions.

4 (4) The following corrective action is in progress:

As plant procedures are reviewed and revised, additional signoffs g

will be incorporated where necessary to ensure adequate verification of actions, data, and observations.

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, 5) PP&L is now in full compliance.

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E.

Deviation (388/84-34-03)-

Final Safety Analysis Report (FSAR), Section.3.13.3 references other sections in the FSAR which describe the licensee's commitment to Regulatory Guide 1.47.

Regulatory Guide 1.47' indicates that automatic

' indication should be provided in the control room for deliberately induced

' inoperable status when any redundant portion of the safety systems or their supporting systems is not capable of performing its safety-related

. function and this activity occurs more frequently.than once per year.

Contrary to the above, implementation of monthly surveillance procedure SM-204-009 results in opening test links which disable automatic transfer to alternative power sources for ESS bus on loss of power, but no

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automatic indication of this situation is provided in the control room.

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Response:.

l (1) The corrective action to bring the design into conformance with Regulatory Guide 1.47 has been initiated.

Plant Modification Requests (PMR) 84-3113 for Unit 1 and 84-3114 for Unit.2 will include i

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Attachment to PLA-2389 Page 7 design changes which are intended to permit surveillance testing of the degraded grid voltage protection relaying without disabling the automatic 4KV bus transfer to alternate power sources on loss of power. Therefore automatic indication in the control room will not be required. Upon completion of the design changes, the surveillance procedures will be revised.

(2) ENo further corrective action will be necessary to prevent recurrence.

(3) Full compliance will be achieved upon completion of the corrective action in (1) above. A firm schedule cannot be provided since it is not known at this time if the design change will require outages or other special conditions. Upon completion of engineering and evaluation of installation constraints, PP&L will provide a schedule for installation.

In the interim, the surveillance procedures have been revised to require a continuity-check be made after restoring the test links to the closed position.

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