ML20029E009
| ML20029E009 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/05/1994 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| References | |
| EA-91-110, GL-89-10, NUDOCS 9405160043 | |
| Download: ML20029E009 (5) | |
See also: IR 05000354/1991080
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May 5, 1994
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Docket No. 50-354
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License No. NPF-57
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EA 91-110
Mr. Steven E. Miltenberger
Vice President and Chief Nuclear Officer
Public Service Electric and Gas Company
Post Office Box 236
Hancocks Bridge, New Jersey 08038
Dear Mr. Miltenberger:
Subject: NRC Team Inspection Report No. 50-354/91-80
This letter refers to the NRC tean . pection conducted between July 15-19, 1991, at the Hope
Creek Generating Statson, Hancocks Bridge, New Jersey, and continued in the Region I office
antil August 13, 1991, in evaluate the reliability of the Motor Operated Valves (MOVs) at the
Hope Creek facility, as well s review of your response to NRC Generic I2tter 89-10 and its
three supplements, that described concerns regarding the known industry problem with MOVs.
The inspection report was sent to you on August 14, 1991. This also refers to the subsequent
investigation conducted by the NRC Office ofInvestigations (01). A copy of the synopsis of
the OI investigation was sent to you on October 20,1993.
During the inspection, three apparent violations of NRC requirements were identified. In
addition, a d:viation was identified involving the faihr 'o meet a commitment made in a letter,
dated August 31,1990, to establish an MOV prog
January 1,1991. On September 9,
1991, the NRC conducted an enforcemtnt confer
you and members of your staff to
discuss the violations and deviation, their causes
r corrective actions. A Notice of
Violation for two of the apparent violations and a i
. of Deviation were sent to you by a
letter dated October 10, 1991.
The third apparent violation involved the possible transmittal of inaccurate and incomplete
information to the NRC in a letter dated March 8,1991, in response to Generic Letter 89-10,
Supplement 3, which requested that you evaluate the capability of MOVs used for containment
isolation in the steam lines of certain safety systems to perform their intended safety function
during design basis accident conditions. The March letter stated that the MOVs were capable
of performing their safety function and that this conclusion was baset w a comprehensive
evaluation of thrust requirements in light of design base parameters, standa:d methodologies and
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the latest diagnostic test results (with an Attachment referenced). This apparent violation was
further discussed during a second enforcement conference conducted in the Region I office wiB
you and members of your staff on December 20,1993.
GIGEED MAIL
RETURN RECEllYr REOUESTED
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OFFICIAL RECORD COPY
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Public Service Electric and
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You denied this apparent violation at the September 1991 enforcement conference based, in part,
on:
(1) your contention that your response was complete and accurate based upon your
engineering judgement and evaluation (some of which was not documented) and (2) your belief
that the evaluation was comprehensive, although not documented and not communicated
adequately to the NRC in the March 8,1991 letter or during the inspection. You also noted that
subsequent reevaluation of data confirmed the operability conclusion stated in your
March 8,1991 response. At the December 20,1993 conference, you also demonstrated the
accuracy of the information, noting that a comprehensive evaluation was done at the time,
although you acknowledged that the evaluation was not well documented, and more information
could have been provided in the response. While the NRC agrees that your evaluation, as
described during the December 1993 enforcement conference, was not well documented and
more inforrnation could have been provided to the NRC in your response, the NRC has decided.
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after considersion of your response, that you did not violate 10 CFR 50.9.
Nonetheless, the NRC believes that adequate management attention was not directed to the
evaluation, analysis, and response concerning MOV operability and effectiveness in light of the
prior notice of industry concerns with MOVs as expressed by the N'RC in the Generic Letter and
its supplements. In particular, we note that the then Vice President of Nuclear Engineering
signed the March 8,1991 response, even though he acknowledged to the NP.C that he had not
read it fully. This revelation is especially troubling since licensees are responsible for ensuring
the completeness and accuracy of information submitted to the NRC and licensee management
is primarily responsible in this area. That a senior licensee manager would submit information
without having read the document undermines the confidence that the NRC must have in
licensees. You should reemphasize to your staff the importance of appropriate evaluation and
review of information submitted to the NRC.
The NRC does recognize that subsequent to the inspection and September 1991 enforcement
conference, corrective actions were taken to improve the adequacy of future responses to the
NRC. These actions, which were either described at the enforcement conference or during the
O! investigation, included: (1) counseling of all management personnel directly involved in this
matter; (2) independently assessing the circumstances leading to the response by your Nuclear
Safety Review Group; (3) informing all nuclear department personnel of expectations regarding
communications with the NRC; (4) resubmitting a response to Generic Letter 89-10, Supplement
3; (5) revising the maintenance procedures to require 10 CFR 50.59 evaluations; (6) issuing a
nuclear department administrative procedure to clarify the operating experience feedback
program; (7) publishing a policy to clarify requirements for processing of vendor technical
documents received by your staff; and (8) taking disciplinary action against several individuals
involved in the preparation, evaluation, and review of the response.
OFFICIAL RECORD COPY
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I%lic Service Electric and
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No resIx>nse to this letter is required. In accordance with 10 CFR 2.790 of the NRC's " Rules
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of Practice," a copy of this letter will be placed in the NRC's Public Document Room.
Sincerely,
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P 'r.a! 3 ;aed Dy:
L .. 3 T. ;;.tain
Thomas T. Martin
Regional Administrator
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Public Service Electric and
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Cc:
J. Hagan, Vice President, Nuclear Operations
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S. LaBruna, Vice President, Engineering and Plant Betterment
C. Schaefer, External Operations, Nuclear, Delmarva Power and Light Company
P. Curham, Manager, Joint Generation Department, Atlantic Electric Company
R. Hovey, General Manager, Hope Creek Operations
F. Thomson, Manager, Licensing and Regulation
J. Robb, Director, Joint Owner Affairs
A. Tapert, Program Administrator
R. Fryling, Jr., Esquire
M. Wetterhahn, Esquire
W. Conklin, Public Safety Consultant, Lower Alloways Creek Township
Consumer Advocate, Office of Consumer Advocate
K. Abraham, PAO-RI (2)
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
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