ML14328A598
| ML14328A598 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/24/2014 |
| From: | Ho Nieh NRC Region 1 |
| To: | Joyce T Public Service Enterprise Group |
| References | |
| EA 14-145 IR 2014003 | |
| Download: ML14328A598 (5) | |
See also: IR 05000354/2014003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
November 24, 2014
EA 14-145
Mr. Thomas P. Joyce
President and Chief Nuclear Officer
P. O. Box 236
Hancocks Bridge, NJ 08038
SUBJECT:
NRC INSPECTION REPORT NO. 05000354/2014003 AND NON-CITED
VIOLATION, HOPE CREEK AND YOUR LETTER DATED AUGUST 27, 2014
Dear Mr. Joyce:
This responds to your August 27, 2014 letter to the U.S. Nuclear Regulatory Commission
(NRC), LR-N14-0197, (ML14239A4221) regarding non-cited violation (NCV)05000354/2014003-01, Inadequate Procedural Guidance for Responding to an Internal
Flooding Event in the HPCI and RCIV Rooms. The Green NCV documented a violation of
Technical Specification 6.8.1.a, Procedures, because PSEG procedures HC.OP-AR.ZZ-0006
and HC.OP-AR.ZZ-0022 did not direct operators to enter these rooms using a door other than
the watertight door between the two rooms. Using that door during a flooding event may result
in floodwater from one room entering the other, and potentially render two safety-significant
single train systems inoperable. In your letter, you denied that a performance deficiency existed
and contended that the NCV should not have been issued. You also asserted that the NRCs
characterization of a performance deficiency, that is more than minor, cannot be substantiated.
Finally, you stated that the basis for the cross-cutting aspect of Human Performance, Training
[H.9] was not clear.
Our letter dated September 25, 2014 (ML14268A350) indicated that the NRC was evaluating
the merits of your dispute of the violation and the characterization of the performance
deficiency. Based on the NRC staffs review, the Green NCV was determined to remain valid,
as described in the enclosure. We are, however, seeking additional input from you on the
assigned cross-cutting aspect.
1 Designation in parentheses refers to an Agency-wide Documents Access and Management System
(ADAMS) accession number. Documents referenced in this letter are publicly-available using the
accession number in ADAMS.
T. Joyce
2
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter will be
made available electronically for public inspection in the NRC Public Document Room or from
the NRC document system (ADAMS), accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html.
Please contact Raymond Powell at (610) 337-6967 if you have any questions regarding this
matter. Your cooperation with us is appreciated.
Sincerely,
/RA/
Ho K. Nieh
Director
Division of Reactor Projects
Docket No.: 05-354
License No.: NPF-57
cc: Distribution via ListServ
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RI/DRP
RI/ORA
RI/DRP
NAME
LCline/RJP for
BBickett/MM for
RPowell
LCasey
DATE
11/24/14
11/24/14
11/24/14
11/21/14
OFFICE
RI/DRP
NAME
GGulla
HNieh
DATE
11/21/14
11/24/14
1
Enclosure
Issue 1
You stated that PSEG alarm response procedures comply with Regulatory Guide 1.33 contrary
to the assertion in the Enforcement discussion of the NCV. You also stated that there is no
industry guidance or regulation that requires the level of detail being added via the
enhancement.
Response
The NRC agrees that Regulatory Guide 1.33 does not contain a discussion on the specific level
of detail that is required in an alarm response procedure. However, Regulatory Guide 1.33
does state that such procedures should normally contain the immediate operator actions.
Inherent in this is the expectation that operator actions will not complicate the event. In general,
the level of detail in alarm response procedures will vary depending on a variety of factors,
including the initiating condition and the facility design. As such, the lack of guidance in the
Regulatory Guide is not a sufficient basis for denial of a violation.
As part of the agencys review of the dispute, information contained in your letter dated
August 27, 2014, and in NRC inspection report 05000354/2014003, were independently
reviewed by an NRC staff member who had not been previously involved with the finding. In
addition, this reviewer also directly observed the physical characteristics of the affected areas
and reviewed other PSEG alarm response and fire response procedures for comparison. The
reviewer also considered as documented by the inspection: (1) there was no apparent training
provided by PSEG to operators regarding HPCI/RCIC room access during flood conditions,
(2) equipment operators interviewed indicated that in a flood condition, they would still access
the HPCI room via the RCIC room door, (3) a senior reactor operator interviewed did not
indicate that he would direct operators which door they should use to access the HPCI room in
a flood event, and (4) that other PSEG response procedures appeared to contain a higher level
of detail than HC.OP-AR.ZZ-0006(Q) regarding area access.
In consideration of all of the above, the NRC has concluded that, absent specific direction in the
procedure, it was reasonable that an equipment operator could enter the HPCI room through
the door connecting the HPCI and RCIC rooms which may complicate the internal flooding
event. As such, a non-cited violation of Technical Specification 6.8.1.a, Procedures was valid.
Issue 2
You stated Based on the results of the technical evaluation, PSEG does not agree that Hope
Creek procedures could potentially complicate an internal flooding event and adversely affect
assumptions in Hope Creeks flood design. You also stated In this case, the technical
evaluation concludes there is no impact to the operability of RCIC when the HPCI room is
flooded, and vice versa; therefore, there is no reasonable doubt of the operability of the system
affected by opening the adjoining door. In summary you stated The technical evaluation
concluded that there was no safety significance to flooding an adjacent room (i.e., no failure of
RCIC due to a HPCI room flood and vice versa).
Response
In NRC Inspection Report No. 05000354/2014003, the inspectors had concluded that the issue
was more than minor because it was associated with the procedure quality attribute of the
Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the
2
Enclosure
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences (i.e., core damage). Specifically, the inspectors concluded that not
preventing operators from entering the HPCI room through the RCIC room door during an
internal flood event (and vice-versa) could potentially complicate the event and adversely affect
assumptions in Hope Creeks flood design, since the procedures did not ensure operator
response would not communicate the HPCI and RCIC watertight rooms and potentially render
multiple trains of safety-related systems inoperable.
The NRC independent reviewer considered PSEGs technical evaluation and acknowledges its
conclusion that communication between the HPCI and RCIC rooms during an internal flood
event would not impact the operability of the other system. However, as noted in Inspection
Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, The intent behind
examples 3.j and 3.k is to illustrate that equipment inoperability is not a prerequisite to an issue
being more than minor. Rather, these examples illustrate the more-than-minor criterion in IMC 0612, Appendix B, Issue Screening, for an issue that, if left uncorrected would have the
potential to lead to a more significant safety concern. As such, the fact that a subsequent
technical evaluation, which required multiple iterations, determined RCIC (or HPCI) would not
be rendered inoperable during a postulated flooding event is not, in and of itself, a sufficient
basis to determine the issue is of minor significance.
Accordingly, using MC 0612 guidance, the reviewer also considered whether the underlying
issue of concern, if not addressed, could have the potential to lead to a more significant safety
concern. The reviewer determined that inappropriately accessing RCIC (or HPCI) via the water
tight door during a flooding event may complicate operator response to the event. EOP HC.OP-
EO.ZZ-103/4, Reactor Building and Radioactive Release Control, directs significantly different
operator actions, if multiple areas of the plant (defined in the EOP as 2 or more areas) are
affected by the flooding event at levels below the flood levels used in your technical evaluation.
As such, we have determined that this is appropriately characterized as a green non-cited
violation.
Issue 3
You stated The basis for the cross-cutting aspect of Human Performance - Training [H.9] is not
clear. Training is provided for alarm response procedures and EOPs to ensure the plant is
operated within the bounds of the design and licensing basis.
Response
PSEGs August 27, 2014, correspondence stated the performance deficiency would not be
more than minor and, therefore, would not have an associated cross-cutting aspect. As we
have confirmed that the performance deficiency is more than minor, we will provide you an
additional 30 days to provide your assessment of the most significant contributing cause, if you
should choose to.