IR 05000354/1997007

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/97-07 on 971113

ML20203G367
Person / Time
Site:	Hope Creek
Issue date:	02/24/1998
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 9803020286
Download: ML20203G367 (3)

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February 24,1998 Mr. Harold Executive Vice President c 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:

This letter refers to your January 12,1998, correspondence (LR N97800),in response to three of the five violations cited in our November 13,1997 letter. The three violations involved: 1) a f ailure to perform an appropriate 10CRF50.59 safety evaluation for a modification to the reactor core isolation >:ooling (RCIC) turbine trip logic on reactor vessel high water level 2) a failure to follow the requirements of 10CFR50.49 applicable to the envirc.nmental qualification of five Struthers-Dunn relays; and 3) a failure to follow the requirements of 10CFR50, Appendix B, Criterion Ill, Design Control, when extending the service life of safety related Agastat and Telemechanique rolays in mild environments.

Your response to the other ttvo violations have already been received in PSE&G letter LR-N97767 dated December 12,1997.

Thank you for informing us of the corrective and preventive actions for the Notice of Violation, as documented in your letter. We will evaluate the effectiveness of these corrective actions in an upcoming Engineering Core inspection.

If you have additional concerns or comments, please feel free to contact us. Your  ;

cooperation is aporeciated. AI

Sincerely, ORIG 1NAL SIGNED BY:

James C. Linville, Chief Projects Branch 3 Division of Resctor Projects Docket No. 50 354 MOO $3 g

9803020286 900224 PDR ADOCK 05000354 ll ll ll lllllllllli.o o -

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Mr. Harold cc:

L. Storz, 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 - QA/ Nuclear Trair6::t dmergery Preparedness D. Powell, Manager - Licensing and Rogt. U -

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, Esqu!re 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 . Distribution w/ copy of Licensee's Response Letter:

Region i Docket Roorn (with concurrences)

Nuclear Safety information Center (NSIC)

PUBLIC NRC Resident inspector C. O'Daniell, DRP D. Serenci, PAO J. Linville, DRP S. Barber, DRP B. McCabe, OEDO J. Stolz, PD1 2, NRR B. Mozaf ari, Project Manager, NRR R. Correia, NRR F. Talbot, NRR

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Inspection Program Branch, NRR (IPAS)

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' DOCUMENT NAME: G:\ BRANCH 3\REPLYLTR\9707RPL.HC T3 receive a copy of this document. Indicate in the box: "c" = Copy wthout attachment / enclosure T = Copy with attachment / enclosure "N* = No copy

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OFFICE Rl/DRP j / l / l / l l l NAME JLinville Tf DATE O2/13/98# .

02/ /98 02/ /98 02/ /98 02/ /98 OFFICIAL RECORD COPY l

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'JAN 121998 LR-N97800 United States Nuclear Reg' '.atory Commission Document Control Desk Washington, DC 20555 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-07 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSR 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 promptly identify an inoperable electric motor-driven fire pump, as required by 10CFR50, Appendix B, Criterion XVI; 2) two e examples of a failure to folicw procedures, as required by

/ Techr.ical 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.

The response to the first two violations was pr'ovided via PSE&G letter LR-N97767, dated December 12, 1997. As discussed with NRC management on November 18, 1997, the details of this reply will address the remaining three violations listed above.

Should you have any questions cr comments on this transmittal, do not hesitate to contact us.

Sincerely

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FEB-1*/-1998 -- 14'33

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n Document Control Desk -2- JAN 121998 f

LR-N97800 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 ockville, MD 20850 Mr. S. Morris - (X24)

j USNRC Senior Resident Inspector *HC Mr. X. Tosch, Manager IV 4 Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625 C

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FEB-17-1998 ?14834

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~ Attachment 1 LR-N97800 r RESPONSE TO NOTICE OF VIOLATIott-

' INSPECTION REPORT NO. 50-354/97-07 i ENOPE CREEK GENERATING STATION t DOCRET NO. 50-354:

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REPLY TO TME NOTICE OF VIOLATXON A. 10 CFR 50.59 Violation ,

s 1. Descrintion of the__ Notice of Violation #

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"10 CFR '50. 59 (b) (1) requires, in part, that the licensee >

shall maintain records of changes in the facility made-pursuant to this section, to the_ extent that these changes  ;

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analysis report-(UFS72). These records must include a written safety evaluation which provides the bases for the

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determination that the change does not involve.an unreviewed a safety question.

Section 7.4.1.1. of the UFSAR describes the functions and

operation of the reactor core isolation cooling (RCIC) system

and include a flow control diagram showing instantaneous tripping of the turbine on high vessel water level.

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Contrary to the above, on and before September 30, 1997, no written safety evaluation was performed to ensure that a change to the facility involving-the delay of the RCIC

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turbine trip on high reactor vessel water level did not involve an unreviewed safety question."

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

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2. - Reolv to Notice of Violation '

L PSEEG agrees with the violation.

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3.- Reason for the Violation

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2SE&G has attributed the cause of: the improper- 10- CFR 50.59 applicability review to-personnel error.- When reviewing the 10_CFR.50.59 applicability review'for?the proposed' design change, Engineering personnel determined that the addition of a time _ delay : relay -to suppress instrument ringing did.not

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alter any_ control-or logic functions of the Reactor Core

. Isolation- Coolingg(RCIC) system, anditherefore, did not

change lthe facility as-described-in the UFSAR. However, the reviewers!did-not recognize the need to revise the RCIC-functional' control diagrams, which do depict control aaui .

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logic time delay functions. As a result, a 10 CFR 50.59 m safety evaluation was not performed for the RCIC f

modifications (the High Pressure Coolant Injection System was similarly modified).

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Corrective Steos That Have Been Taken and Results Achieved a. A 10 CFR 50.59 safety evaluation and UFSAR change have b64n completed for the addition of the HPCI and RCIC time delay relay additions. The 10 CFR 50.59 safety evaluation concluded that the HPCI and RCIC modifications did not result in an Unreviewed Safety Question.

b. To preclude similar occurrences, a discussion of this issue has been included in an edition of the PSE&G 10CFR50.59 Newsletter.

5. Corrective Steos That Will Be Taken to Avoid Further Violations a. In lition to the 10CFR50.59 Newsletter, procedural gui ance concerning UFSAR changes and 10CFR50.59 will be provided by March 1, 1998.

6. Date When Full Comoliance Will Be Achieved

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r Full compliance was achieved on January 9, 1998, when the 10 CFR 50.59 safety evaluation and associated UFSAR change were completed for the HPCI and RCIC modifications.

B. 10 CFR 50.49 violation 1. Descriotion of the Notice of Violation

"10 CFR 50.49, sections (d) and (j) require, in part, that licensees prepare a list of electric equipment important to safety covered by this section [ requiring environmental qualification) and that a record of qualification be maintained in an auditable form to permit verification that each item of electric equipment important to safety is qualified for its application and meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Contrary to .e above, on or before April 7, 1997, five safety-related Struthers-Dunn relays located in a harsh environment were not included in the list of equipment important to safety requiring environmental qualification; fN were not replaced at the end of the qualified life specified for other relays subjected to the same conditione predicted to be present when they must perform their~ safety function; Page 2 of 6

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and were not adequately justified to be able to meet their

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requirements after the end of their qual!51ed This is a Severity Level IV violation (supplement I).

2. Renly to Notice of Violation PSE&G agrees with the violation relating to the failure to include the harsh environment Struthers-Dunn relays in the environmental qualification (EQ) program. However, PSE&G notes that an appropriate qualified life had been determined for these relays, and that these relays were replaced prior to the expiration of their qualified lives (see corrective actions for more details).

3. Reason for the violation PSE&G has attributed the cause of the failure to include four of the harsh environment Struthers-Dunn relays in the EQ Program to personnel errors during plant startup in the mid-1980s, when the EQ Program was developed. Specifically, an incomplete system bill of materials provided by a PSE&G vendor was used to develop the EQ Program scope. The relays were not identified on the Bill of Materials, and as a result, the relays were not included in the EQ Program. For the fifth relay, the cause was attributed to personnel error f

n in the first refueling outage. In this case, a design change was performed which failed to include an appropriate review and revision to the EQ Program to reflect the addition of the new relay.

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Corrective Steos That Have Been Taken and Resultg Achieved a. The five Struthers-Dunn relays have been added to the Hope Creek EQ Program, b. Engineering has determined that the appropriate qualified service life for four of these Struthers-Dunn relays with the magnetic vinyl bearing pad material is approximately 12 years. The fifth relav, which is energized for 20% of the time has a calculated qualified life of approximately 20 years. Calculation STRDUN-ARRH-001 was used to make these determinations, which appropriately considered the post-accident operability period. The difference in qualified life of the magnetic-vinyl pad relays (12 years) and the other similar relaya (approximately 5 years) in the same panel is due to the fact that different qualification reports were used to determine the qualified life of the g ~s different relay designs (magnetic-vinyl vs. silicon-

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rubber bearing pads). The degradation experienced on the Struthers-Dunn relays (with magnetic vinyl bearing Page 3 of 6

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pads) prior to the end of their calculated service life f- s was determined to have no impact on operability.

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Engineering reached this determination since the relays were within the bounds of the testing conditions and that the degraded relays were not susceptible to any additional failure mechanisms which would have rendered the relays inoperable, c. A recurring task has been established to ensure that these five Struthers-Dunn relays are replaced prior to end of their qualified service lives. Four of the five relays were replaced with the improved silicon-rubber bearing pad material design prior to June-1997. The fifth relay (which is energized only 20% of the time) is scheduled to be replaced (in August 1999) prior to the end of its qualified service life (in 2006).

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5. Corrective Steos That Will Be Taken to Avoid Further Violations No additional corrective actions are planned.

6. Oate When Full Comoliance Will Be Achieved Hope creek achieved full compliance when the five harsh environment Struthers-Dunn relays were added to the Hope Creek EQ Program in April 1997.

D C. 10 CPR 50, Appendix B, Criterion III Violation

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1. Descriotion of the Notice of Violation

"10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures provided for verifying or checking the adequacy of design, such as by performance of design reviews, or by the performance of a suitable testing program.

Contrary to the above, on or before September 30, 1997, che contzol measures provided for verifying or checking the adequacy of the design were inadequate in that independent reviews of design calculations developed to extend the service life of safety-related Agastat and Telemechanique relays in a mild environment failed to verify the adequacy of the coil temperature rise used in the calculations. The use of incorrect coil temperature rise values resulted in longer service lives."

2. Ecolv 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 has attributed the cause. for the lower coil heat rise values used in the relay life extension calculations to personnel error. Since these relays were in mild envi. nments (where qualified service lives are not normally calculated as harsh environment EQ Program relays are), the Engineering personnel involved did not verify or validate assumptions and input parameters used in the relay life extension calculations. This inattention to detail resulted in the inappropriate establishment of service lives for the mi)C environment Agastat and Telemechanicue relays.

4. Corrective Steos That Have Been Taken and Results Achieved a. The Engineering personnel involved were held accountable for their actions in accordance with PSE&G's disciplinary policy.

b. The Agastat EGP type relays have been replaced at Hope

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Creek. In addition, the normally energized Agastat EGP relays service life has been reduced to 6.5 years, consistent with the Gener 1 Electric recommended service life. Although the service life of the E7000 relays has remained at approximately 11 years (and extended as appropriate to the next refueling outage for E7000 gs relays still in service), an evaluation will be conducted to determine if changes to the life are required.

15, 1998, This evaluation will be completed by January c. For the Telemechanique (Gould) J10/J13 relays, a new relay design was installed on the "A" and "B" emergency diesel generators. The new relay design will also be installed on the "C" and "D" emergency diesel generators during scheduled diesel maintenance outages in 1998. A service life extension of 3.5 years was calculated, which accounted for a 92 degree P measured heat rise in the relays. Although more conservative relay configurations would shorten the 3.5 year life extension, Engineering has concluded that the J10 and J13 relays on the 'C" and "D" diesel generators will remain operable prior to their scheduled replacements by June 1990.

5. Corrective Steos That Will_Be Taken to Avoid Further

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a. An evaluation will be conducted to determine it changee to the E7000 .~elay's service life are required. This evaluation will be completed by January 15, 1998.

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The new relay design (to replace the Gould J10 and J13 (N relay design) will be installed on the "C" and "D" emergency diesel generators during scheduled diesel .

maintenance outages in 1998 (first quarter of 1998 for the "D" emergency diesel generator, and the second quarter of 1998 for the "c" emergency diesel generator) .

c. The details of this event will be rolled out to

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appropriate Engineering rersonnel f by February 28, 1998.

6. Date When Full Comaliance Will Be Achieved Hope Creek is in full compliar.ce. The service lives of the relays in mild environment.s have been appropriately established for_each relay application. The current schedule

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for the replacement of relays will ensure appropriate relay removal prior to expiration of its associated service life.

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