ML20236T205

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/98-05

ML20236T205
Person / Time
Site:	Hope Creek
Issue date:	07/21/1998
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Keiser H Public Service Enterprise Group
References
50-354-98-05, 50-354-98-5, NUDOCS 9807280032
Download: ML20236T205 (3)

See also: IR 05000354/1998005

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July 21,1998

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Mr. Harold W. Keiser

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Executive Vice President

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Nuclear Business Unit

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Public Service Electric & Gas Company

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PO Box 236

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Hancocks Bridge, NJ 08038

SUBJECT:

NRC INSPECTION REPORT 50-354/98-05

Dear Mr. Keiser:

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This letter refers to your July 6,1998 correspondence (LR-N980316),in response to our

June 4,1998, 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 Notice of Violation identified four examples of

violations of NRC requirements. One violation involved the failure to maintain the residual

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heat removal system available during a 1990 refueling outage when the reactor was off-

loaded. The remaining three violation examples were related to a modification that was

installed during the Fall 1997 refueling outage and was associated with ventilation system

safety related chillers.

Your response to the violation indicated that you have corrected the specific violations and

have initiated measures to prevent recurrence. Your response to the violations will be

examined during a future inspection.

Your cooperation with us is appreciated.

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Sincerely,

ORIGINAL SIGNED BY:

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James C. Linville, Chief

Projects Branch 3

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Division of Reactor Projects

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Docket No. 50-354

9007290032 990721

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Mr. Harold W. Keiser

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cc:

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L. Storz, Senior Vice President - Nuclear Operations

E. Simpson, Senior Vice President - Nuclear Engineering

E. Salowitz, Director - Nuclear Business Support

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M. Bezilla, General Manager - Hope Creek Operations

J. McMahon, Director - QA/ Nuclear Training / Emergency Preparedness

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D. Powell, Director - Licensing / Regulation & Fuels

A. C. Tepert, Program Administrator

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cc w/cy of Licensee's Letter:

A. F. Kirby,111, 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

Consumer Advocate, Office of Consumer Advocate

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William Conklin, Public Safety Consultant, Lower Alloways Creek Township

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State of New Jersey

State of Delaware

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Mr. Harold W.' Keiser

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- Distribution w/ copy of Licensee's Response Letter:

Region I Docket Room (with concurrences)

' J. Linville, DRP

S. Barber, DRP

C. O'Daniell, DRP

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- D.' Screnci, PAO

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Nuclear Safety Information Center (NSIC)

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NRC Resident inspector

B. McCabe, OEDO

R. Ennis, Project Manager, NRR

R. Capra, PD1-2, NRR

inspection Program Branch, NRR (IPAS)

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R. Correia, NRR

F. Talbot, NRR

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~ DOCUMENT NAME: G:\\BHANCH3\\1-HC\\9805 RESP.lR

, TJ receive e copy of this doonmert. Indicate in the box:

"C" = Copy without ettechmerWenclosure

• E" = Copy with ettschment/ enclosure

"N" = No

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NAME --

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DATE

07/21/98

07/1

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0FFICIAL RECORD COPY

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Public Service

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Electric and Gas

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H r:ld W. Keiser

Pubhc Service Electne and Gas Company

PO Box 236, Hancocks Bndge. NJ 08038 609-339-1100

Chief Nuclear Officer & President

Nuclear Business Unit

LR-N980316

United States Nuclear Regulatory Commission

Document Control Desk

Washington, DC 20555

Gentlemen:

REPLY TO NOTICE OF VIOLATION

INSPECTION REPORT 354/98-05

HOPE CREEK GENERATING STATION

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FACILITY OPERATING LICENSE NPF-57

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DOCKET NO. 50-354

Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company

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(PSE&G) hereby submits a reply to the Notice of Violation (NOV) issued to the Hope

Creek Generating Station in a letter dated June 4,1998.

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The PSE&G response for this violation is contained in the Attachment to this letter. If

you have any questions or comments on this transmittal, please contact Paul Duke at

(609) 339-1466.

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Sincerely,

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Attachment

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JUL 061998

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Document Co@pi Desk

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- LR-N980316

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Mr. H. Miller, Administrator - Region l

U. S. Nuclear Regulatory Commission

475 Allendale Road

King of Prussia, PA '9406

Mr. R. Ennis, Licensing Project Manager - Hope Creek

U. S. Nuclear Regulatory Commission

One White Flint North

11555 Rockville Pike

Mail Stop 14E21

Rockville, MD 20852

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Mr. S. Pindale (X24)

USNRC Senior Resident inspector- HC

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Mr. K. Tosch, Manager IV

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Bureau of Nuclear Engineering

P. O. Box 415

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Trenton, NJ 08625

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JUL 061998

Document. Content Desk

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LR-N980316

PRD

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CNO & President - NBU (N09)

Senior Vice President - Nuclear Engineering (N19)

Senior Vice President - Nuclear Operations (XO4)

Genere! Manager - Hope Creek Operations (H07)

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Director- QA/NT/EP (X01)

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Director- System Engineering (H16)

Director- Design Engineering (N23)

Director - Engineering Assurance (N25)

Director - Licensing / Regulation and Fuels (N21)

Manager - Financial Control & Co-Owner Affairs (N07)

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Operations Manager - Hope Creek (H01)

Manager - Hope Creek Maintenance (H07)

' Manager - Hope Creek System Engineering (H18)

Mechanical Design Manager (N24)

Manager-Quality Assessment-NBU (X16)

Program Manager - Nuclear Review Board (N38)

Manager- Hope Creek Licensing (N21)

J. Keenan, Esq. (N21)

Records Management (N21)

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Microfilm Copy

File Nos.1.2.1,3.1 (HC iP,354/98-05)

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ATTACHMENT

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RESPONSE TO NOTICE OF VIOLATION

INSPECTION REPORT NO. 50-354/98-05

HOPE CREEK GENERATING STATION

DOCKET NO. 50-354

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A.10 CFR 50.59 Violation

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1. Description of the Notice of Violation

10 CFR 50.59, " Changes, tests and experiments," in part, permits the licensee to

make changes to its facility and procedures as described in the final safety

analysis report (FSAR) and conduct tests or experiments not described in the

safety analysis report without prior Commission approval provided the change

does not involve a change in the technical specifications or an Unreviewed

Safety Question (USO). The licensee shall maintain records of changes in the

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facility and these records must include a written safety evaluation which provides

the bases for the determination that the change does not involve a USQ.

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FSAR Section 9.1.3.2.3 establishes that the design and operation of the fuel pool

cooling and cleanup systems for the decay heat associated with a full core

offload is based, in part, on the operation or availability of the residual heat

removal (RHR) system to augment the fuel pool cooling and cleanup (FPCC)

system.

Contrary to the above, during refueling outage a F03 in December 1990, the

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licensee did not maintain the RHR system in operation or available to augment

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the FPCC system which represented a change to the facility as described in the

FSAR and did not perform a review of this change to demonstrate that the

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change did not involve a USQ.

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This is a Severity Level IV violation (Supplement 1).

2. Reply to Notice of Violation

PSE&G agrees with the violation.

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3. Reason for the Violation

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PSE&G attributed the cause for this violation to inadequate procedures for

outage reviews and controls. Altemate means of decay heat removal were

evaluated before the RFO3 full core offload to ensure sufficient decay heat

removal capacity. However, the requirement to compare the alternate decay

heat removal methods with those described in the Hope Creek Up6;ted Final

Safety Analysis Report (UFSAR) and to evaluate deviations in accordance with

10 CFR 50.59 was not recognized.

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Attachment'

LR-N980316

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4. Corrective Steps that Have Been Taken and Results Achieved

The interschon among Nuclear Fuels, System Engineering and Outage

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Management has been proceduralized. The station outage risk management

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procedure was revised to include guidance on the development of decay heat

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load estimates and heat-up curves for outage planning. The guidance includes

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verification of adequate decay heat removal capability throughout the outage

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schedule.

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For the full core offload performed during refueling outage RFO7, completed in

December 1997, the decay heat removal method was evaluated in accordance

with 10 CFR 50.59 and found not to involve an Unreviewed Safety Question.

5. Corrective Steps that Will Be Taken to Avoid Further Violations

No additional corrective actions are planned.

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6. Date When Full Compliance Will be Achieved

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Hope Creek achieved full compliance when the RHR system was returned to

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available status and the core reload was completeu during RFO3.

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B.10 CFR 50 Appendix B Criterion XI Violation

1. Description of the Notice of Violation

10 CFR 50 Appendix B Criterion XI requires, in part, that all testing required to

demonstrate that structures, systems, and components will perform satisfactorily

in service be identified and performed in accordance with written test procedures

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which incorporate the requirements and acceptance limits contained in

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applicable design documents. The test program shall include, as appropriate,

proof tests prior to installation and operational tests during nuclear power plant

operation of structures, systems, and components.

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Contrary to the above, two examples of inadequate testing requirements

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associated with a design change modification to the Hope Creek safety-related

control area chilled water system chillers were identified as follows:

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(1) As of April 7,1998, a complete proof test prior to installation and an

operational test had not been performed to verify that check valves 1KBV-

1243 through 1KVB-1250 [ sic) would provide a relatively leak tight boundary

and ensure that the backup safety-related pneumatic supplies for the chiller

condenser cooling water pressure control valves would remain available for

four hours after a loss of power event.

(2) On April 8,1998, the backup safety-related pneumatic preseure regulators

(1KBPCV-11464, -11466, and -11467) for the chiller condenser cooling water

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LR-N980316

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pressiird'c6ntrol valves were found set below minimum design requirements.

Operational tests had also not been performed to ensure that pressure

regulators 1KBPCV-1164 (sic] through 1KBPV-1171 [ sic] would remain

property set in accordance with design requirements.

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

2. Reply to Notice of V%Iation

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PSE&G agrees with the violation.

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3. Reason for the Violation

Example (1)

PSE&G attributed the cause of the failure to establish inservice testing (IST)

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. requirements and to periodically perform ISTs to personnel error. Personnel

preparing the design change package (DCP) and performing design specialty

reviews did not ensure the DCP was reviewed by the IST group. Deficiencies in

the standard DCP format contributed to the violation. The design interface

record had a single signoff for IST and for valve programs.

As part of the post-modification testing, an external leak check was perfomied

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and the valves were functionally tested. Both tests were satisfactory. However,

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since the design change packages that added the check valves for the backup

pneumatic supply were not reviewed by the IST group, IST requirements for the

valves were not established.

Example (2)

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PSE&G attributed the cause of the failure to maintain the backup pneumatic

pressure regulator settings to personnel error, most likely after the modification

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was completed. The regulator settings were verified as part of the post-

modification testing. The most likely scenario is misadjustment by an operator

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during rounds or during a routine maintenance activity. Deficiencies in the

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procedure changes and in operator training for the design change package

contributed to the violation.

4. Corrective Steps that Have Been Taken and Results Achieved

Example (1)

a. The check valves were tested satisfactorily.

b. IST procedures for the check valves have been developed.

c. The format for the design change interface record was revised to require a

separate signoff for the IST review.

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d. A detailed roll out of this event and its implications was provided to affected

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design engineering personnel.

e. Personnelinvolved were counseled concerning performance in this event.

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Example (2)

a. The backup pneumatic supply regulator settings were restored to their

required values,

b. Interim guidance on the operation of the backup pneumatic supply system

was provided to operators.

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c. IST procedures for the check valves have been developed. The procedures

include periodic verification of the pressure regulator settings for the backup

pneumatic supply.

5. Corrective Steps that Will Be Taken to Avoid Further Violations

Example (1)

No additional corrective actions are planned.

Example (2)

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a. This violation will be incorporated in operator continuing training by

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September 1,1998.

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b. Lessons leamed from this violation will be communicated to Engineering

personnel by September 30,1998.

6. Date When Full Compliance Will be Achieved

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Example (1)

Hope Creek achieved full compliance on April 8,1998 when the inservice testing

was performed satisfactorily on the backup pneumatic supply check valves. The

valves have been added to the IST program.

Example (2)

Hope Creek achieved full compliance on April 8,1998 when the backup

pneumatic supply regulator settings were restored to their required values.

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C.10 CFR 50-Appendix B Critorion XVI Violation

1. Description of the Notice of Violation

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10 CFR Appendix B Criterion XVI (Corrective Action) requires, in part, that

measures shall be established to assure that conditions adverse to quality, such

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as failures, malfunctions, deficiencies, deviations, and nonconformances are

promptly identified and corrected.

Contrary to the above, on December 10,1997, PSE&G engineers determined

that the minimum cooling water inlet temperature for the safety-related control

area chilled water system chillers should be changed in a more limiting direction

to 70 degrees Fahrenheit from 55 degrees Fahrenheit. On April 9,1998, the

operations department management, still unaware of any necessary change to

the minimum allowed cooling water temperature, used 55 degrees Fahrenheit as

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a basis for determining inoperability when they made a four-hour event

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notification to the NRC. Hope Creek abnormal operating procedure, Loss of

Instrument Air and/or Service Air, HC.OP-AB.ZZ-0131(Q) - Rev.14, and pending

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change, HFSAR 97-080, to the Hope Creek Updated Final Safety Analysis

Report (UFSAR) also incorrectly stated that 55 degrees Fahrenheit was the

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minimum cooling water temperature below which the safety-related backup

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pneumatic supply needed to remain operable. The change in minimum cooling

water inlet temperature to a more limiting value was not corrected until May 7,

1998, when guidance was provided to operators specifying the new 70 degrees

Fahrenheit minimum cooling water temperature.

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This is a Severity Level IV violation (Supplement 1).

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2. Reply to Notice of Violatior

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PSE&G agrees with the violation.

3. Reason for the Violation

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PSE&G attributed the cause for this violation to personnel error. In December,

1997, the responsible engineer concluded that the minimum Safety Auxiliaries

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Cooling system (SACS) temperature for Control Room chiller operation with full

SACS flow is higher (more limiting) than the minimum temperature used for

design of the backup pneumatic supply modification. The 55 degrees Fahrenheit

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temperature was an appropriate limit for a fully loaded chiller; but it is more

conservative to assume that the chiller is lightly loaded. The responsible

engineer, who is no longer employed by PSE&G, recognized the need for

corrective action but did not initiate an Action Request as required by PSE&G's

Corrective Action Program to ensure the non-conservative design assumption

was reviewed for its effect on chiller operability.

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4. CorrectidSteps that Have Been Taken and Results Achieved

a. An Action Request to document this condition was initiated.

b. The backup pneumatic supply was restored and the Control Room chillers

were retumed to OPERABLE status on April 8,1998.

c. A detailed roll out of this event and its implications was provided to affected

design engineering personnel.

5. Corrective Steps that Will Be Taken to Avoid Further Violations

a. An evaluation to determine the correct minimum SACS temperature for chiller

operation without the Instrument Air system or backup pneumatic supply will

be completed by August 21,1998. Temporary administrative controls are in

place to ensure the backup pneumatic supply remains in service when SACS

temperature is less than 70 degrees Fahrenheit (for Control Room chillers) or

62 degrees Fahrenheit (for 1E Panel Room chillers).

b. Operating procedures will be revised as necessary by September 18,1998 to

include the results of the evaluation described above.

c. Lessons learned from this violation will be communicated to Engineering

personnel by September 30,1998.

6. Date When Full Compliance Will be Achieved

Hopi Creek achieved full compliance on April 8,1998 when the backup

pneumatic supply to the chiller pressure control valves was restored.

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