IR 05000354/1997010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/97-10

ML20216H132
Person / Time
Site:	Hope Creek
Issue date:	04/16/1998
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Keiser H Public Service Enterprise Group
References
50-354-97-10, NUDOCS 9804210060
Download: ML20216H132 (3)

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April 16,1998 Mr. Harold Executive Vice President Nuclear Business Unit Public Service Electric & Gas Company PO Box 236 Hancocks Bridge, NJ 08038 SUBJECT: Inspection Report 50-354/97-10

Dear Mr. Keiser:

This letter refers to your March 4,1998, correspondence (LR-N98074,in response to in our February 3,1998 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 violation included failures to appropriately establish or implement three technical specification required maintenance procedures, a failure to provide sufficient instructions for installing a reactor water cleanup system flow element, and a failure to implement adequate corrective actions to prevent a repeat reactor core isolation cooling system governor valve malfunction. We noted that you have largely completed your corrective actions in response to this Notice of Violation, and have ascribed the cause of many of the noted issues to personnel error. We will review the effectiveness of your actions in a future inspection.

Your cooperation with us is appreciateo.

Sincerely, Original Signed By:

James C. Linville, Chief Projects Branch 3 Division of Reactor Projects

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Docket No. 50-354 l l 9804210060 980416 PDR ADOCK 05000354 s '. hl G PDR lV L_

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Mr. Harold cc:

L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Edear Engineering E. Salowitz, Director - Nuclear Business Support M. Bezilla, General Manager - Hope Creek Operations J. McMahon, Director - QA/ Nuclear Training / Emergency Preparedness D. Powell, Manager - Licensing and Regulation A. C. Tapert, Program Administrator cc w/cy of Licensee's Letter:

A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.

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 q William Conklin, Public Safety Consultant, Lower Alloways Creek Township State of New Jersey State of Delaware i

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Mr. Harold 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 R. Ennis, Project Manager (Acting), NRR R. Correia, NRR F. Talbot, NRR inspection Program Branch, NRR (IPAS)

DOCDESK DOCUMENT NAME: G:\ BRANCH 3\REPLYLTR\9710 RESP.HC Ts receive a copy of this document. Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure *N*=

No copy OFFICE Rl/DRP ,, / /

NAME JLinvi}tt()to g dL DATE 04/15/98 04/ /98 04/ /98 04/ /98 04/ /98 OFFICIAL RECORD COPY

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Public Se'vice Eiocine ano Gas Comneny Louis F. Stor Public Sennce Electnc and Ges Company P.O. Box 236, Mancocks Bridge, NJ 08038 609-339 5700

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United States Nuclear Regulatory Commission l Document Control Desk . i Washington, DC 20555 l

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-10 NOPE CREEK GENERATING STATION 4 FACILITY OPERATING LICENSE NPF-57 I DOCKET NO. 50-354 l l

Gentlemen: l Pursuant to the provisions of 10CFR2.201, Public Service Electric and Gas Company (PSE&G) hereby submits replies to the Notices of violation (NOV) issued to the Hope Creek Generating Station in a

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letter dated February 3, 1998. The violations contained in l Appendix A of the February 3rd letter concerned: 1) three '

examples of a failure to properly establish or implement procedures, as required by Technical Specification 6.8.1.a, 7- s during maintenance activities; 2) a failure to properly establish i

instructions, procedures or drawings for the correct orientation of a reactor water cleanuo system flow measurement orifice plate, as required by 10CFR50, Appendix B, Criterion V; and 3) a failure t'o implement effective corrective actions to preclude recurrence of a Reactor Core Isolation Cooling system governor valve

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malfunction, as required by 10CFR50, Appendix B, Criterion XVI.

The concerns related to personnel performance and supervisory oversight noted in the inspection report will continue to be addressed by PSE&G. In addition to the corrective actions taken/ planned for the specific performance issues and procedure deficiencies, PSE&G is taking measures to comprehensively address human performance in the Maintenance Department. Specifically, PSE&G is planning to implement " lessons learned" roll outs from the Maintenance Department intervention on an approximate quarterly basis. These roll outs will focus on and reinforce management expectations, cultural behaviors, human performance and corrective actions from significant conditions adverse to

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quality. As recaired, personnel performance will continue to be assessed on an individual basis and corrective actions taken when

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appropriate.

To address repetitive personnel performance issues, including inadequate Technical Specification procedure revisions, PSE&G l '/ will continue to utilize the corrective action program to:

resolve specific conditions adverse te quality; 2) identify 1)

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significant trends in departmental and station performance; and 3) implement corrective measures to improve overall station operatien. This process was used to resolve the conditions adverse to quality identified in the inspection report's Notice of Violation as described in PSE&G's associated response i (Attachment 1) . l Shouldyouhaveanyquestionsorcommentsont$listransmittal,do l l

not hesitate to contact us. i l

Sincerely, V -

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Attachment (1)

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.g gpR 0 41998 Document Control Desk -3-LR-N98074 I

C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Ms. B. Mozafari, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. D. Jaffe, Licensing Project Manager - HC (Acting)

U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike i Mail Stop 14E21 Rockville, MD 20852

Mr. S. Morris (X24)

USNRC Senior Resident Inspector - HC b Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625

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/ Attachment 1 LR-N98074 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-07 HOPE CREEK GENERATING STATION DOCKET NO. 50-354

!. REPLY TO THE NOTICE OF VIOLATION A. Technical Specification 6.8.1 Violation *

1. DescriDtion of the Notice of Violation

" Hope Creek technical specification (TS) 6.8.1 requires, in

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part, that written procedures shall be established, implemented and maintained for applicable activities specified in Appendix A of Regulatory Guide (RG) 1.33, Revision 2. TS 6.8.1 also requires that written procedures shall be established for surveillance and test activities of safety-related equipment.

Appendix A of RG 1.33 requires that procedures be established for startup, operation, and' shutdown of the Reactor Core Isolation Cooling (RCIC) system, as well as for the cca. trol of maintenance, repair or replacement of components tu_. can

,_, affect the performance of safety-related equipment.

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Contrary to the above, three examples of failures to either establish or implement the above required procedures were identified:

a. On November 24, 1997, maintenance technicians failed to follow Hope Creek procedure HC. IC-DC.ZZ-0140 (Q) ,

Revision 3, " Device / Equipment Calibration Masoneilan Pressure and Temperature Controllers," in that they did not restore a gain adjustment in the "B" control room ventilation system chiller pressure control valve circuitry to the proper value following an instrument calibration. This led to two subsequent trips of the safety-related chiller due to high back pressure.

b. On December 30, 1997, it was identified that procedure HC.OP-SO.BD-0001(Q), Revision 16, " Operation of the Reactor Core Isolation Cooling System," failed to provide adequate guidance for resetting the turbine mechanical overspeed trip device. As a result, the RCIC turbine trip throttle valve could not be re-opened for several hours following system maintenance, c. On January 3, 1998, it was identified that maintenance s department procedure HC.MD-ST.SB-0006 (Q) , Revision 0, Page 1 of 7 i

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mar-% ear upes FM l',, * Attachment 1 LR-N98074

• g e's "18 Month Electrical Protection Assembly Channel l Calibration," established in part to implement the surveillance test requirements of TS 4.8.4.6.b, did not incorporate the appropriate acceptance criteria for

under-frequency channel calibrations. Specifically, step 5.9.8 of the noted procedure lists the acceptance criteria as "57 Hertz," while the associated TS specifies the criteria as "57 Hertz, -0% + 2%."

l These are Severity Level IV violations (Supplement I).

2. Reply to Notice of Violation PSE&G agrees with the above three violations.

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3. Reason for the Violation v'iolation a. f PSE&G has attributed the cause of procedure non-compliance to personnel error. Due to an inadequate review of personnel qualification, a maintenance supervisor inappropriately assigned a non-qualified technician to perform pneumatic controller adjustments, and as a result, the procedure was l not properly completed. Contributing to the procedure non- l compliance was the lack of a questioning attitude and failure

/" of the technician to notify supervision of procedure steps that he could not complete as required.

Violation b.

PSE&G has attributed the cause of the failure to provide appropriate guidance for resetting the turbine mechanical overspeed trip device to over reliance on the " skill of the craft" to reset a RCIC overspeed trip. Successful resetting of RCIC overspeed trips during previous 18 month surveillances did not provide an opportunity to identify a need to provide additional procedural guidance on ensuring proper seating of the RCIC trip tappet assembly. In addition, PSE&G notes that the time to reset the RCIC overspeed trip was the result of planning controlled investigations of the overspeed trip.

Violation c.

PSE&G has attributed the cause of the improper development of the electrical protection assembly calibration procedure to personnel error. Although the new calibration procedure provided appropriate guidance for setting the frequency trJp setpoint, a less than adequate review of TS requirements by the procedure writer and subsequent reviewers resulted in es-l ( left and as-found ac:eptance criteria in the calibration procedure that did not correspond to the TS acceptance criteria.

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4. Corrective Steos That Have Been Taken and Results Achieved Violation a.

a. The ventilation train chiller pneumatic controller was properly reset and the chiller was successfully placed in service on November 24, 1997.

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b. The Maintenance personnel involved were held accountable for their actions in accordance with PSE&G's disciplinary policy.

Violation b.

a. The RCIC operating procedure was revised to add steps that ensure the trip tappet assembly is properly seated during a reset of an overspeed trip.

Violation c.

l a. The Maintenance personnel involved were held accountable for his actions in accordance with PSE&G's disciplinary policy.

b. Similar procedure sections covering undervoltage and

/"% overvoltage testing (ir procedures HC.MD-ST.SB-0004 & -

0006) were reviewed to ensure that TS acceptance criteria were properly implemented. No other deficiencies were identified.

c. Maintenance procedure HC.MD-ST.SB-0006 was revis'ed to provide acceptance criteria that appropriately reflects the TS requirements. l 5. Corrective S_ tees That Will Be_Taken to Avoid Further !

Violations I violation a.

No additional corrective actions are planned.

Violation b.

No additional corrective actions are planned.

Violation c.

a. A review of other recently revised or created maintenance surveillance procedures will take place to

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' ensure thet TS acceptance criteria are being appropriately implemented. These activities will be completed by May 30, 1998.

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,, * Attachment 1 LR-N98074 6. Date When Full Comoliance Will Be Achieved Violation a.

Full compliance was achieved on November 24, 1997, when qualified personnel properly set the pneumatic controller for the. ventilation train and the associated chiller unit was placed successfully in service.

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Violation b.

Full compliance was achieved on December 31, 1997, when the RCIC operating procedure was revised to provide additional guidance on resetting of an overspeed trip.

Violation c.

Full compliance was achieved February 25, 1998, when maintenance procedure HC.MD-ST.SB-0006 was revised to reflect the appropriate 18 month TS surveillance teot requirements.

B. 10 CFR 50, Appendix B, Criterion V Violation 1. Descriotion of the Notice of Violation g- s "10 CFR 50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,and shall be accomplished in accordance with these instructions, procedure or drawings.

Contrary to the above, on November 29, 1997, it was identified that no instruction, procedure, or drawing was provided to workers regarding the correct orientation of a reactor water cleanup system LRWCU) flow measurement orifice during system maintenance. Specifically, while restoring from a corrective maintenance activity to repair an associated RWCU piping flange leak, technicians installed the noted orifice plate backwards in part because no specific guidance for proper reassembly was provided. The orifice plate provides a flow signal to primary containment isolation logic."

This is a Severity Level IV violation (supplement I).

2. Reolv to Notice of Violation PSE&G ngrees with the violation.

3. Reason for the violation O

PSE&G has attributed the cause of the failure to provide i

appropriate guidance for the re-installation of the RWCU flow Page 4 of 7

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LR-N98074 l l

yr s orifice to reliance on the " skill of the craft" of the '

! maintenance personnel. Flow orifice elements are normally marked to provide indication to maintenance personnel on their proper orientation during reassembly. However, the RWCU flow orifice, installed during plant construction, was not marked to indicate its proper orientation. Due to this lack of orientation indication and a lack of a questioning attitude on the part of a maintenance worker performing this task, the RWCU flow orifice was not installed in the correct orientation. .

4. Corrective Steos That Have Been Taken and Results Achieved a. An evaluation has been completed to confirm the i'

operability of the flow orifice in the installed orientation.

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5. Corrective Steos That Will_Be_Taken to Avoid Further Violations a. A work order will be created to ensure that orientation indication is provided on the RWCU flow orifice element during the next RWCU flow orifice removal and re-installation. The work order will be created by

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September 30, 1998. 1 O b. Lessons learned from this event with respect to questioning proper component configuration will be

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I rolled out to Maintenance Department personnel. This will be completed by May 5, 1998.

6. Date When Full Compliance Will Be Achieved With the completed evaluation confirming the operability of the flow orifice in the installed orientation on November 29, 1997, full compliance was achieved.

C. 10 CFR 50, Appendix B, Criterion XVI Violation l 1. pgscriotion of the Notice _of Violation

"10 CPR 50, Appendix B, Criterion XVI, requires in part that for significant conditions adverse to quality such as failures, malfunctions, and deficiencies, measures shall be established to assure that the cause of the condition is determined and corrective actions are taken to preclude repetition.

Contrary to the above, prior to December 5, 1997, corrective measures implemented subsequent to a December 28, 1996

[' failure of the RCIC turbine governor valve assembly were insufficient to preclude recurrence. Specifically, the

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governor valve stem was replaced following the 1996 event with a material design that exhibits an increased thermal expansion rate as material temperature increases. The engineering analysis which supported the stem material change did not account for this factor, and led to governor valve stem binding and a RCIC system failure on December 5, 1997.'

This is a Severity Level IV violation (Supplement I) . }

2. Reply to Notice of Violation ,

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i PSE&G agrees with the violation.

3. Reason for..the violation j

PSE&G has attributed the cause for the December 5, 1997 RCIC system failure to personnel error. In March 1997, as a I result of increasing occurrences of governor control valve stem binding due to galvanic corrosion, the Nitrided 410 Stainless Steel stem was replaced with a stem manufactured from Inconel 718. Although the Engineering personnel involved in the equivalent replacement part evaluation of the Inconel stem reviewed the material suitability to address the industry concerns with corrosion induced binding, the evaluation failed to appropriately address the difference in thermal exptnsion coefficients between the original nitrided stainless steel shaft and the Inconel shaft. In addition, the evaluation failed to identify that the replacement shaft had a wider manufacturing tolerance (0.4985" to 0.499" for the original, 0.498" to 0.500" for the replacement) since the proprietary shaft dimensions for the original shaft were not available. Since the replacement Inconel stem was purchased to a BW/IP drawing with dimensional specifications consistent to those successfully tested and placed in sertice at other utilities, the Engineering personnel did not fully evaluate the effects of thermal expansion. As a result, the change in dimension coupled with the greater thermal expansion coefficient caused binding of the shaft at elevated RCIC operating temperatures.

4. Corrective Steps That Have Been Taken and Results Achieved a. An appropriate carbon spacer inner diameter was calculated to account for thermal expansion of the replacement Inconel stem. The carbon spacers were re-sized prior to reassembly of the RCIC turbine governor valve and the RCIC system was successfully tested and placed into service.

b. Hope Creek Maintenance Procedure HC.MD-CM.FC-0002 (Q),

/"5 " Reactor Core Isolation Cooling (RCIC) Turbine Steam Stop and Governor Valve Overhaul", was revised to clarify the requirements associated with assuring Page 6 of 7 l

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adequate clearance between the valve stem and carbon fs spacers.

5. Corrective Steps That Will Be Taken to Avoid Further violatieng a. Lessons learned from this event will be rolled out to Engineering personnel conducting equivalent replacement evaluations by April 30, 1998, b. Purchase specifications / drawings for the RCIC governor valve stem will be revised to accommodate increased thermal expansion of Inconel 718 versus 410 Stainless Steel by April 30, 1998.

6. Date When Full Comoliance Will Be Achieved Hope Creek is in full compliance. With the successful implementation of corrective actions to resolve the RCIC

, governor valve stem binding, the RCIC system has been restored to an operable condition.

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