IR 05000354/1997009
| ML20217C600 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/20/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H Public Service Enterprise Group |
| Shared Package | |
| ML20217C605 | List: |
| References | |
| 50-354-97-09, 50-354-97-80, 50-354-97-81, 50-354-97-9, EA-97-144, EA-97-563, NUDOCS 9803270085 | |
| Download: ML20217C600 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $55,000 (NRC Innpection Reports No. 50-354/97-09;97-80;97-81)
Dear Mr. Keiser:
This letter refers to the three NRC inspections conducted on February 24-28, 1997, August 25-29,1997, and October 5,1997 - November 15,1997, at the Hope Creek Nuclear Generating Station at Hancocks Bridge, New Jersey, the findings of which were discussed with members of your staff during exit meetings on February 28,1997, August 29,1997, and l
November 21,1997. The first two referenced inspections focused on your implementation of the maintenance rule at Hope Creek. The third inspection was a routine integrated inspection. During the inspections, apparent violations of NRC requirements were idmtified related to the failure to properly implement the maintenance rule, as well as the failure by operators to follow procedures governing operation of the control rod drive system. The inspection reports addressing these issues were previously forwarded to you on April 18,1997, December 1,1997, and December 10,1997. On January 14,1998, two j
predecisional anforcement conferences (conferences) were conducted with Mr. L. Storz and i
other members of the PSE&G staff, to discuss the violations, their causes, and your corrective I
actions.
Based on the information developed during the inspections and the information provided during the conferences, the NRC has determined that three violations of NRC requirements occurred.
The violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil
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Penalty (Notice), and the circumstances surrounding the violations are described in detail in the subject inspection reports. The first violation, which is set forth in Section I of the enclosed Notice, involves the failure by an operating crew to follow procedures and act conservatively during a test to demonstrate core shutdown margin. During the test, certain control rods atuck while being withdrawn, and elevated hydraulic system drive water pressures were used to free the stuck rods. However, the operating crew did not return control rod drive water pressure to the normal operating range after each stuck control rod was freed, as is required by your abnormal operating procedures. The two other violations, l
which are related to the maintenance rule and are set forth in Section ll of the enclosed 9803270085 900320
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j Public Service Electric and
Gas Company Notice, involve (1) the failure to include certain systems, components and functions within the scope of the maintenance rule; and (2) the failure to adequately demonstrate that the performance or condition of a number of systems, components and functions was being effectively controlled through the performance of appropriate preventive maintenance.
The first violation occurred in November 1997 during the conduct of the shutdown margin test while the reactor was in the cold shutdown condition with the vessel hqad removed. During that test, which involved the full withdrawal of 20 control rods, operators had invoked a j
special test exception to permit conduct of this infrequently performed evolution since the test required the mode switch to be placed in the startup position in order to defeat an interlock that allowed only one rod to be withdrawn in this condition. Since operators experienced
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difficulty withdrawing several of the designated rods, the control rod drive (CRD) hydrauliv
system drive water pressure was increased, in accordance with the stuck control rod abnormal i
procedure, to free the stuck rods. However, after individual rods were freed, the operators i
did not immediately restore the drive water pressure to the normal range, as required. Rather, when subsequent rods were withdrawn, the operators inappropriately remained in the stuck rod procedure without first meeting the prerequisite for unsuccessful control rod movement.
This created the potential for control rod withdrawal at speeds exceeding design limits for reactivity addition. Subsequent review revealed that several rods were, in fact, withdrawn from the core at speeds faster than normal, although not in excess of the design limits.
The NRC is particularly concerned that operators did not adhere to the abnormal operating i
procedures in that (1) drive water pressures were not returned to the normal operating range j
following successful control rod movement at elevated pressures; (2) drive pressures were not
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reduced to the normal range before subsequent initial control rod withdrawal attempts; and (3) operators did not follow established standards for reactivity manipulations and move
control rods in a cautious manner. Although the operators completed the evolution without incident, their actions to add positive reactivity to the new reactor core at increased rates had the potential to cause an inadvertent criticality. The risk of inadvertent criticality was greater j
in this case because several safety barriers were either defeated or degraded at the time.
Specifically, the reactor vessel head was removed; the "one-rod-out" interlock feature was defeated to perform the test; the moderator temperature was below 100'F (increasing core reactivity); and the rod worth minimizer was inoperable. The NRC notes that source range
nuclear instrumentation was available to mitigate an inadvertent criticality by actuating an automatic reactor scram from a single source range channel.
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This event also was of significant regulatory concern because this demonstration was an infrequently performed evolution, and no additional management oversight or control was hfforded to the activity. Although NRC inspectors informed personnel ;n the control room of j
the departure from the stuck rod procedure, including three licensed operators, a formerly i
licensed quality assurance inspector, and the reactor engineering supervisor, no action was taken to address the control rod manipulation violation until the inspector discussed the issue with senior plant management.
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Public Service Electric and
. Gas Company The event is of further concern because prior occurrences at Hope Creek and other facilities involving control rod manipulations, provided opportunities to insure appropriate control of reactivity management activities. For example, although your licensed operators had received training regarding an occurrence at the Zion Nuclear Station in 1997 involving a loss of reactivity control, this training was not effective in increasing operators' awareness of the importance of operations standards prior to and during control rod movements. In addition, l
on October 23,1996, the NRC issued to you a $150,000 civil penalty, for, in part, a violation at Hope Creek relatsd to control rod withdrawal. Notwithstanding those prior opportunities,
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It is clear that your staff lacked an appropriate appreciation of the safety significance of reactivity changes based on control rod movement.
Therefore, given the regulatory significance of this violation, the violation has been categorized in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, at Severity Level lli.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000is i
considered for a Severity Level ill violation. Because your facility has been the subject of j
escalated enforcement actions within the last 2 years', the NRC considered whether credit
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was warranted for /dentification and Correct /ve Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit was not warranted for identification because the violation was identified by NRC inspectors. In addition, your recognition of the concerns raised by the inspectors was not prompt. Credit was warranted for corrective actions because your root cause assessment and subsequent actions were considered prompt and comprehensive. Those actions, as described in the inspection report and ~at the conference, included: (1) initiation of a condition report necessitating completion of a detailed root cause analysis; (2) revision and reinforcement of operating standards and expectations regarding reactivity manipulations; (3) revisions to infrequently performed test procedure controls to enhance management oversight; and (4) personnel changes. -
Therefore, to emphasize the importance of your operating staff understanding and adhering to established reactivity management standards, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalty (Notice) in the base amount of $55,000 for the Severity Level lil violation.
With respect to the violations of the maintenance rule as set forth in Section ll of the Notice, these violations collectively represent a programmatic breakdown in the development and implementation of the Rule. The NRC recognizes that considerable progress was made in the months prior to the initial inspection.'
Nonetheless, these findings demonstrate that management had not applied sufficient resources to assure adequate implementation of the program. Therefore, the violations have been categorized in the aggregate as a Severity Level lit problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600.
For example, on October 23,1996, a $150,000 cMI penalty was issued for several Severity Level lli vloistons, includir<l violations involving the failure to plan appropriate surveiller.co testing Silowing completion of maintenance on control rod drives, as well as control rod withdrawal speeds being hxcess of the values assumed in the Updated Final Safety Analysis Report (Reference: EAs96-125,96-281).
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Public Service Electric and
Gas Company The Commission determined that a maintenance rule was necessary to assure licensees monitor the effectiveness of maintenance to minimize the likelihood of failure of safety-significant equipment that could initiate or adversely affect a transient or accident. Even though the final rule was issued in July 1991,it did not become effective until July 1996.
During the five year interim period before the rule became effective, the staff and the industry worked in concert to assure licensees had developed useful guidance and clearly understood the manner in which NRC would inspect implementation. This was accomplished through public workshops and a pilot inspection program, the results of which were documented and shared with the industry.
Notwithstanding the time allotted to implement this program, as well as the guidance provided for establishing a program to meet the Maintenance Rule, your program at Hope Creek was determined to be w ak in a number of key aspects. At the conference, you acknowledged the program deficiencies and noted that implementation of the rule program did not meet your expectations. The NRC believes that inadequate management oversight, ineffective integration of industry insights, and insufficient self assessments represent some of the overall causes of the program weaknesses.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000is considered for a Severity Level lli problem. Since Hope Creek has been the subject of escalated enforcement actions within the last 2 years, as already stated herein, the NRC considered whether credit was warranted for /dentification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement
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l Policy for the Severity Level lil problem. Credit is warranted for /dentification because the NRC recognizes that your staff identified, prior to the inspection, similar deficiencies with implementation of the maintenance rule and recognized the need to take appropriate corrective action. Credit is also warranted for Corrective Actions, because your corrective actions, which were inspected in August 1997, were considered prompt and comprehensive. These actions were described in NRC Inspection Report No. 97-81.
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Therefore, to encourage prompt identification and comprehensive correction of violations, I l
have been authorized, after consultation with the Director, Office of Enfon.sment, not to propose a civil penalty in this case. However, similar violations in the future could result in
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a civil penalty.
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You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement' action is necessary to ensure compliance with regulatory requirements.
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Public Service Electric and
Gas Company in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
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Hu ert J. Miller Regional Administrator Docket No. 50-354 License No. NPF-54 Enclosure: Notice of Violation and Proposed imposition of Civil Penalty l
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Public Service Electric and
Gas Company l
cc w/ encl:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engineering E. Salowitz, Director - Nuclear Business Support j
l A. Kirby, lil, External Operations - Nuclear, Delmarva Power & Light Co.
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J. Isabella, Manager, Joint Generation Atlantic Electric l
M. Bezilla, General Manager - Hope Creek Operations J. McMahon, Director - Quality Assurance & Nuclear Safety Review D. Powell, Manager - Licensing and Regulation R. Kankus, Joint Owner Affairs A. Tapert, Program Administrator J. Keenan, Esquire l
Consumer Advocate, Office of Consumer Advocate j
l W. Conklin, Public Safety Consultant, Lower Alloways Creek Township
State of New Jersey i
j State of Delaware l
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Public Service Electric and Gas Company l
DISTRIBUTION:
l PUBLIC i
SECY CA LCallan, EDO l
AThadani, DEDE JLieberman, OE HMiller, RI i
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FDavis, OGC j
SCollins, NRR l
RZimmerman, NRR l
l Enforcement Coordinators RI, Ril, Rlli, RIV l
BBeecher, GPA/PA GCaputo, O1 DBangart, OSP HBell, OlG TMartin, AEOD OE:Chron l
OE:EA l
DCS l
NUDOCS l
DScrenci, PAO-RI l
NSheehan, PAO-Ri
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LTremper, OC l
Nuclear Safety Information Center (NSIC)
NRC Resident inspector - Hope ' Creek i
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