ML023640237
| ML023640237 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/20/2002 |
| From: | Richards S NRC/NRR/DLPM/LPD1 |
| To: | Keiser H Public Service Enterprise Group |
| Taylor R, NRR/SRXB, 415-1869 | |
| References | |
| NOED 02-6-002 | |
| Download: ML023640237 (5) | |
Text
December 20, 2002 Mr. Harold W. Keiser Chief Nuclear Officer and President PSEG Nuclear LLC-X04 Post Office Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR PSEG NUCLEAR, LLC, REGARDING HOPE CREEK GENERATING STATION, NOED NO. 02-6-002
Dear Mr. Keiser:
In your December 17, 2002, letter (Enclosure 1), PSEG Nuclear LLC (PSEG or the licensee) requested that the Nuclear Regulatory Commission (NRC) exercise discretion not to enforce compliance with a surveillance condition required in Technical Specification (TS) 4.8.1.1.2.h.14 for the Hope Creek Generating Station (Hope Creek). Your letter documented information previously discussed with the NRC in a telephone conference on December 13, 2002. The principal NRC staff members who participated in that telephone conference are listed in .
On December 11, 2002, an NRC safety system design inspection (SSDI) team questioned the scope of testing performed on Emergency Diesel Generator (EDG) output breaker lockout relays in accordance with TS 4.8.1.1.2.h.14. This TS, in part, required each EDG to be demonstrated OPERABLE [a]t least once per 18 months during shutdown, by . . .
- 14. Verifying that the following diesel generator lockout features prevent diesel generator starting only when required:
a) Engine overspeed, generator differential, and low lube oil pressure (regular lockout relay, (1) 86R).
b) Backup generator differential and generator overcurrent (backup lockout relay, (1) 86B).
c) Generator ground and lockout relays - regular, backup and test, energized (breaker failure lockout relay, (1) 86F).
On December 12, 2002, at 1:07 p.m., PSEG declared all four EDGs inoperable due to a failure to fully comply with TS Surveillance Requirement 4.8.1.1.2.h.14.a. PSEG then invoked TS 4.0.3 which permitted 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the required surveillance activities.
During the morning of December 13, the SSDI team further identified that the licensee had not performed the testing of all the lockout features required by TS 4.8.1.1.2.h.14.b and c. The NRC also questioned the licensee regarding how it complied with the TS requirement to perform the surveillance testing during shutdown.
H. Keiser In a subsequent phone call, PSEG requested that a Notice of Enforcement Discretion (NOED) be granted to allow PSEG to meet the surveillance testing requirements when conducting the EDG surveillance testing at power vice during shutdown conditions. This request was made pursuant to the NRCs policy regarding exercise of discretion for an operating facility, set out in Section VII.c. of the General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The licensee requested that the NOED be effective for the period until the NRC issues approval of its proposed amendment, submitted December 17, 2002, to allow a one-time change to TS 4.8.1.1.2.h.14 permitting the surveillance to be completed during power operations. During the phone call, the licensee stated that it had completed the testing on three of the four EDGs, and would complete the final EDG within the time allowed by the TS. During the call, the NRC agreed that completing the remaining tests required by TS 4.8.1.1.2.h.14 could be done, without NRC approval, with the unit operating vice shutdown. However, a NOED was needed only to satisfy the issue of noncompliance with the requirement to conduct the surveillance during shutdown. This letter documents our telephone conversation on December 13, 2002, when we orally issued this NOED at approximately 3:30 p.m.
The staff has reviewed the information provided by the licensee during both the conference call and the subsequent written NOED request, dated December 17, 2002. PSEG stated in its submittal that it had performed the required surveillance during power operations to demonstrate that the inputs to the lockout relays would function properly. The licensee stated that the purpose of the NOED was to allow credit to be taken for testing performed during power operation to meet a portion of the EDG testing that is required by the TS to be performed during shutdown. The licensee requested the NOED because verbatim compliance with TS 4.8.1.1.2.h.14 would have required the testing to be conducted while shutdown. The NRC understands that the licensee did not take any additional compensatory measures since the testing performed demonstrated the proper operation of the affected relays.
The NRCs basis for approving this enforcement discretion considered the fact that no risk was involved in granting the request, to not grant the NOED would result in an unnecessary operational transient of the plant, and that the request only involved allowing the licensee to credit testing, that the TS specifically identified as being conducted while shutdown, to be performed while operating. The staff concluded that Criterion B.2.1.1.a and the applicable criteria in Section C.4 to NRC Manual Chapter 9900, Technical Guidance, Operations - Notices of Enforcement Discretion, were met. Criterion B.2.1.1.a states that for an operating plant, the NOED is intended to avoid unnecessary transients as a result of compliance with the license condition and, thus, minimize potential safety consequences and operational risks.
On the basis of the staffs evaluation of your request, we have concluded that a NOED was warranted because we were satisfied that this action involved no safety impact, did not result in an increase in risk, was consistent with the enforcement policy and staff guidance, and had no adverse impact on public health and safety. Therefore, we are exercising discretion to not enforce compliance with the TS requirement to perform TS 4.8.1.1.2.h.14 during shutdown, for the period from approximately 3:30 p.m. on December 13, 2002, until issuance of the license amendment, submitted December 17, 2002. The licensees amendment proposes to remove the requirement, on a one-time basis, for the surveillance to be performed while shutdown. The staff plans to complete its review and issue an exigent license amendment within about 4 weeks of the date of this letter.
H. Keiser As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Additionally, NRCs inspection of the licensees testing activities will be documented in NRC Inspection Report 05000354/2003002.
Sincerely,
/RA/
Stuart A. Richards, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reaction Regulation
Enclosures:
- 1. NOED Request from Hope Creek dated December 17, 2002
- 2. December 13, 2002, Hope Creek NOED Call Participants Docket No. 50-354 cc w/encls: See next page
H. Keiser As stated in the Enforcement Policy, action will be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.
Additionally, NRCs inspection of the licensees testing activities will be documented in NRC Inspection Report 05000354/2003002.
Sincerely,
/RA/
Stuart A. Richards, Director Project Directorate I Division of Licensing Project Management Office of Nuclear Reaction Regulation
Enclosures:
- 1. NOED Request from Hope Creek dated December 17, 2002
- 2. December 13, 2002, Hope Creek NOED Call Participants Docket No. 50-354 cc w/encls: See next page Distribution:
PUBLIC A. Blough, RI J. Andersen PDI-2 Reading B. Holian, RI G. Meyer, RI H. Miller, RI/J. Wiggins, RI (1) W. Beckner F. Bower, RI S. Collins/J. Johnson J. Calvo G. Wunder B. Sheron J. Clifford R. Taylor F. Congel, OE R. Dennig R. Fretz J. Zwolinski/T. Marsh C. Holden J. Schoppy, SRI - Hope Creek S. Richards H. Nieh B. Maroney L. Cox T. Bergman B. Platchek, RI ACRS OEWEB (E-mail address for OE webmaster)
OGC NOED (Electronic copy to this E-mail address)
- Concurrence via telephone conversation ADAMS Accession Number: ML023640237 *See previous concurrence OFFICE PDI-2/DLPM PDI-2/PM PDI-2/LA(A) EEIB/SC*
NAME RTaylor SRichards for RFretz MOBrien for LCox OChopra for CHolden DATE 12/20/02 12/20/02 12/20/02 12/19/02 OFFICE RORP/SC* RGN-I/DRP/DD** PDI-2/SC PDI-2/PD NAME RDennig BHolian SRichards for JClifford SRichards DATE 12/19/02 12/20/02 12/20/02 12/20/02 OFFICIAL RECORD COPY
December 13, 2002, Hope Creek NOED Call Participants The principal PSEG and NRC staff members who participated in a telephone conference on December 13, 2002, are listed below.
NRC Headquarters Staff Stuart Richards, Director, PD-1, Division of Licensing Project Management (DLPM)
Robert Dennig, Chief, Technical Specifications Section Robert Taylor, Acting Hope Creek Project Manager, PD-1, DLPM NRC Region I Staff Brian Holian, Deputy Director, Division of Reactor Projects (DRP)
Richard Crlenjak, Deputy Director, Division of Reactor Safety (DRS)
Lawrence Doerflein, Chief, Systems Branch, DRS Richard Barkley, Senior Project Engineer, DRP Fred Bower, Salem Resident Inspector, DRP Gene Cobey, Senior Risk Analyst, DRS Stephen Pindale, Senior Reactor Inspector, DRS Wayne Schmidt, Senior Reactor Inspector, DRS Joseph Schoppy, Senior Resident Inspector, Hope Creek Enclosure 2