ML20199L423

Ack Receipt of 971212 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/97-07 on 971113.C/As Will Be Examined During Future Insp at Hope Creek

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

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Nuclear Business Unit

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 ,.

Docket No. 50-354 I

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Mr. Harold W. Keiser 2

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:

I 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 .

State of New Jersey

State of Delaware

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' Mr. Harold W. Keiser -3

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 ///] / / l l

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 ,

United States Nuclear Regulatory Commission

Document Contro) 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

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

' 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

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promptly identify an inoperable electric motor-driven fire pump,

l as required by 10CFR50, Appendix B, Criterion XVI; 2) two

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examples of a failure to follow procedures, as required by

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)

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Document Control Desk -2-

LR-N97767

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C 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

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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. 10 CFR 50, Appendix B, Criterion XVI Violation

1. Description of the Notice of Violation

"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.

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,

l 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.

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 toenergized.

appropriately the bus to ensure that the fire pump was

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

Achieved Steos That Have Been Taken and Results

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 '

-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.

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5.

Corrective

Violations Steos That Will Be Taken to Avoid Further

a. The-Training Department will evaluate this event to

determine if additional training is required on breaker

design and performance. The evalurtion on the need for

training

1998, modifications will be completed by January 15,

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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26. 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

operable.

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 .

Appendix A of Regulatory Guide (RG) 1.33 Revision 2. RG  ?

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 ,

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.

~(2) On October 4, 1997, technicians completed feed

j 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

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

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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LR-N97767

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In addition, a field verification was performed to

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 andexample.

violation not technician inattention to detail as in the

A field verification was also

performed to ensure that the appropriate procedure steps

had been actually completed in thic case as well.

5.

Corrective

Violations Steos That Will Be Taken to Avoid Fu*thgg

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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