IR 05000354/1988200
| ML20206D787 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/11/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Miltenberger S Public Service Enterprise Group |
| Shared Package | |
| ML20206D793 | List: |
| References | |
| NUDOCS 8811170274 | |
| Download: ML20206D787 (6) | |
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UNITED STATES
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November 11, 1988
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Docket No. 50-354 Mr. S. Vice President and Chief Nuclear Officer Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038
Dear Mr. Miltenberger:
SUBJECT: HOPE CREEK EMERGENCY OPERATING PROCEDURES INSPECTION (50-354/88-200)
This letter forwards the report and the executive sumary of the emergency operating procedures (EOPs) inspection performed by an NRC inspection team from September 6 through September 16, 1988. The activities involved are authorized by NRC Operating License No. NPF-57 for the Hope Creek Nuclear Generating Station. At the conclusion of the inspection, the team discussed the findings with the members of your staff identified in Attachment A of the enclosed inspection report.
Areas examined during the inspection included review of the E0Ps, the documents used to develop the E0Ps, the E0P validation and verification program, and the E0P training program.
In addition the inspection included a walkdown of the E0Ps in the control room and plant, evaluation of operator performance of E0Ps on your site-specific simulator, and perfonnance of a human factors evaluation of the E0Ps.
An overview of the inspection and the team's findings are provided in the enclosed executive summary. Details of the inspection are providad in the enclosed inspection report.
The team determined that the Hope Creek E0Ps, when used by trained operators, can function adequately to mitigate the consequences of an accident. However,
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the team identified a number of weaknesses involving the development and 1mplementation of the E0Ps. These include the need to correct errors in the E0Ps, E0P support procedures, and E0P calculations, and the need to evaluate the review and control process and take action to improve these processes and to eliminate errors of the type identified by the team.
Your written responses to the two unresolved and two open items identified in paragraphs 3.1.1, 3.1.3.c.(2), 3.1.4.b, and 3.1.7 of the enclosed inspection report are requested within 60 days of receipt of this letter.
Region I will review the report and will take enforcement action or follow up findings as appropriate.
8911170274 GG1111 FDR ADOCK 05000354 O
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Nr. S E. Miltenberg2r-2-
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In accordance with 10 CFR 2.790(a), a copy of this letter and uclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this inspection, please contact me or i
Mr. J. Cumins (301-492-0957) of this office.
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Sincerely
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Steven A. Varga, Director
Division of Reactor Projects I/II t
Office of Nuclear Reacto Regulation
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Enclosures:
I 1.
Executive Sumary 2.
Inspection Report 50-354/88-200 cc w/ encl: See next page
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cc w/ enclosures:
M. J. Wetterhahn, Esquire Conner a Wetternann Suits 1050 1747 Pennsylvania Avenue Washington, D.C.
20006
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R. Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, New Jersey 07101 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 241 Hancocks Bridge, New Jersey 08038 Mr. J. Haga,1 General Manager - Hope Creek Operations Hope Creek Generating Station P.O. Box 118 Hancocks Bridge, New Jersey 08038 Mr. B. A. Preston, Manager Licensirg and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge. New Jersey 08038 Regional Administrator, Region 1
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U.S. Nuclear Regulatory Commission
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475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. David M. Scott, Chief Bureau of Nuclear Engineering Division of Environmental Quality Department of Environmental Protection
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State of New Jersey CN 411 Trenton, New Jersey 08625 Institute of Nuclear Powt.' Operations
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1100 Circle 75 Parkway t
Atlanta, Georgia 30339
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'Mr.
S'. E. Miltenbergor-4 Noember 11, 1988 i
Distribution Docket File 50-354
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Team Members Regional Administrators
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-DATE :10/JI/88
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EXECUTIVE SUMMARY JNSPECTION REPORT 50-354/88-200 HOPE CREEK NUCLEAR GENERATING STATION
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During the period September 6-16, 1988, an NRC inspection team evaluated the Hope Creek Nuclear Generating Station emergency operating procedures (COPS).
The inspection was conducted to verify that the E0Ps were technically accurate; that their specified actions could be physically carried out in the plant using existing equipment, instrumentation, and controls; and that the plant staff could correctly perform the procedures. The inspection also verified that the licensee's program for development and implementation of the E0ps was in accordance with the requirements of NUREG-0737, "Requirements for Emergency Response Capability," Supplement 1.
The inspection was conducted in accordance with the guidelines in Temporary Instruction (11) 2515/.o?. "Emergency Operating Procedures Team Inspections."
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Inspection Scope To evaluate the E0Ps, the team:
Reviewed the E0Ps and the procedures generation package (PGP) used for E0P
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development which had been submitied to the NRC; Compared the E0Ps with the owners' group emergency procedure guidelines
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(EPGs), and reviewed the adequacy of the licensee's justification of deviations from the guidelines;
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Performed inplant walkdowns of the E0Ps;
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Evaluated the E0Ps durirg the execution of accident scenarios on the
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site-specific simulator; and Performed human factors evaluation of the E0Ps during all phases of the
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inspection.
SUMMARY OF SIGNIFICANT FINDINGS The team identified nurerous instances of; incorrect procedures and calculations.
These problems included:
incorrect system alignments and restoration steps, missing or out-of-sequence procedure steps. ambiguous procedure steps, ir. correct calculation inp9t data, and calculations not revised when input data changed.
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The team also identified a number of unjustified deviations from the NRC-approved Boiling Water Reactor Owners' Group (BWROG) emergency procedure guidelines (EPGs) and the licensee's plant-specific technical guidelines. Some of those deviations (such as changes in procedure step sequence) appeared to be safety significant.
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The licensee's quality assurance program for procedure anc
'" ' sion control had been applied to the E0Ps but not to any of the E0P-related I.
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$pecifically, the review and approval processes had not been implemented for the PGP documents, calculations, and supportino or basis documents.
Pre-staging of equipment and material required to accomplish specific E0P tasks during the response to an event was generally good.
It was especially good for the dedi-
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cated equipment kits in the control room and the banana plugs installed in electrical equipment cabinets to aid in the installation of jumpers. However, the team identified several problems with special equipment.
For example, the team noted that ladders needed for inaccessible equipment, protective clothing and equipment, and hardware for special installations had not been staged.
Equipment labeling was generally good, especially with regard to some of the labeling in relay cabinets.
However, the team identified several cases of unlabeled or poorly labeled equipment.
Although the team identified several problems involving the licensee's containment venting procedures, these procedures were considered a strength.
This determination was based on the diversity and capability of the vent paths available.
CONCLUSIONS In general, the team found the E0Ps technically accurate and able to be performed by the plant staff using existing plant equipment, instruments, and controls.
The flowchart E0Ps provided a set of procedures that operators could I
implement during events, with a high confidence level that t^ajor sy:rptomatic
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response areas would not be overlooked.
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The E0Ps were generally good, but the lack of attention to detail in many areas detracted from the quality of the procedures.
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