ML20102A021
| ML20102A021 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 07/17/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92097, NUDOCS 9207240001 | |
| Download: ML20102A021 (9) | |
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'0 Pubhc Service Electnc and Gas Cornpany Stanley LaBruna Pubbc Service Electnc and Gas Company P.O. Box 236. Hancocks Ondge, NJ 08038 609-339 1200 vec m.$ont - utw owess JUL 171992 NLR-N92097 United States Nuclear Reaulatory Commission Dac9me:.t. Control Desk Washingtrin, DC 20555 Gentlemen:
REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION INSPECTION REPohT NO. 50-354/92-03 HOPE CREEK GENERATlHG STATION FACILITY OPEh'"ING LICEI!SE NPF-57 DOCKET NO. %-3f4 Public Service Electric and Gas Company (PSE&G) is in receipt of your letter, dated June 10, 1992, which transmitted a Notice of Violation and a Notice of Deviation resulting from a surveillance test inspection that had been conducted from April 6 through 21, 1992.
This letter was received by PSE&G on June 18, 1992.
Pursuant to the proviE,lons of 10 CFR 2.201, our response to these notices is provided in Attachment 1.
Sincerely, sf
- / lg WrW Affidavit Attachment I
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N-Document Control Desk-2 NLR-N92097:
JUL 171992
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Mr. T. T;. Martin, Administrator-_- Region I TU. : S.tNuclear RegulatoryLCommission 1475-Allendale Road
' King of/ Prussia, PA.19406 R
(Mr.:J.: Stone,. Licensing Project Manager (Acting)
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EU. S.= Nuclear RegulatoryEcommission one White Flint North 11555 Rockville1 Pike Rockville, MD-20852-
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Ms. A.:Keller U.:S.: Nuclear-Regulatory Commission one White! Flint North 11555:Rockville Pike Rockville, MD-20B52 Mr. T.-P.-JohnsonL(S05)
USNRC Senior-Resident Inspector
- Mr.
K.- Tosch,. Chief-
--NJ; Department of Environmental-Protection DivicionloffEnvironmental Quality
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LBureautof Nuclear' Engineering CN14151 Trenton, NJ 08625
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NLR-N92097
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STATE OF NEW JERSEY
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COUNTY _OF SALEM
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'S, LaBruna, being duly sworn according to law' deposes and says:
I am Vice President - Nuclear Operations of Public Service-Electric and Gas Company, and as such, I find the matters set forth on our letter dated concerning the
- Hope creek Generating Station, JUL 1 7 1992 are true to the best of my knowledge, information and belief,
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Subscrib' and Sworn o hefore me this
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day of.
. W 44, 1992 AALL A--.
y6tary Public-of Ney Jerse%HERRY L CAGLE NOTARY Pl]BLIC 0F NEW JERSEY My commission expires on
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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION AND NOTICE OF DEVIATION INSPECTIOI: REPORT NO. 50-354/92-03 g
g HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 d
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NLR-N92097 ID I
I.
INTRODUCTIOli A team c' throo UCNRC Region-I inspectors conducted a "Survoillance test" inspection during the period of April 6 through April 16.
The pvrpose of the inspection was to datormino the adequacy of survoillanco tests for solacted safety systelus and to assess the extent to which periodic testing assures that the safoty functions of the systems would bo fulfilled under i
design conditions.
The systems selected for review were the High Pressure Coolant Injection System, the Filtration, Rocirculation and Ventilation System, and the Low pressure coolant Injection modo of the Residual Heat Removal System.
This was a pilot type of inspection which had been performed at onl;/ two other facilities, both of which wuro PWRs.
As a result of this inspection, the following Notico of Violation and Notice of Deviation were issued.
II.
REPLY TO NOTICE OF VIOLAi10ff A.
Description of Violation "10 CFR 50 Appendix B, critorion XI requires, in part, that all testing required to demonstrate that systems will perform satisfactorily in service will be identified and periormed in accordance with writton tost proceduros which incorporate the requirements'and acceptance limits contained in applicable design documents.
Contrary to the above, the design safety function of the Filtration, Recirculation, and Vontilation System Auto-Lead / Auto-Start circuitry to detect a failure of the lead ventilation on't to start and automatically start the standby
-vontilation ur.it, together with its associated swo minuto time
. delay, is-not periodically tested to essure the availability and proper operation of the FRVS during design basis conditions."
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NLR-N92 097 I
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Reason for Violation PSE&G has determined that the automatiu process feature associated with the standby FRVS Ventilation unit should have been included in the surveillance test program but was left out as e result of an apparent oversight.
C.
Correctivo Stops Taken
- 1.
Subsequent to last conversations betwoon P,EE&G and the inspection team memboro, further procedura reviews woro conducted tu datormine whether the subject testing was encompassed by other than FRVS proceduros.
As a
. result of this review it was discovered that p*oceduro HC.OP-ST.KJ-0006(Q), " Integrated Emergency Df+ sol Generator 1BG400 Test - 18 Months", required the B FRVS Vontilation Unit-(BV-206) to be touted in both AUTO and
_ AUTO LEAD modes, although the two minuto timer is not tested.
A review of HC.OP-S't. KJ-0005 (Q), the equivalent procedure for the A FRVS Ventilation Unit indicated that the A unit in only tested in the AUTO LEAD modo.
Based on the proceding findings, the A ventilation unit i
has boon placed in AUTO LEAD and the D unit has. boon pinced in AUTO.
The units will remain in this configuration until the AUTO function of the A unit has boon tested.
HC.OP-ST.KJ-0005(Q) will be revised to test the AUTO and the AUTO LEAD modos of the A FRVS Ventilation Unit (AV-206)_ prior to its next scheduled performanco during
_the fourth refueling outago scheduled to start in September,-1992.
2.
A prcJoduro revision request has been initiated for HC.OP-ST.SM-0002(Q), "PCIS/Roactor Building Refuel Floor Containment Isolation Functional Test - 18 Months".
The revision will require the A and B ventilation units to be tested in AUTO modo and the associated tino delays to be veriflod.
This procedure will be revised prior to its next scheduled performance during thu fourth refueling outage scheduled to start in September,.1992.
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NLR-N92097 4
D.
Corrective Steps to Avoid Further Violations 1.
A review of plant systems will be conducted to determine whether there are any other functions that should be tested.
The objective of this review will will be to idnntity other system transfer functions, not currently teated, whose failure would result in a total loss of system safety function.
This review will be completed prior to startup from
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the fourth refueling outage scheduled to start in l
September, 1992.
2.
The AUTO and AUTO LEAD functions, along with the i
AUTO time delays, will be functionally tested on an la month interval, starting at the fourth refueling outage scheduled to start in September, 1?92.
E.
Date When Full Compliance will be Achieved As detailed above, PSE&G-will be in full compliance with this issue prior to startup from the fourth refueling outage scheduled to start in September, 1992.
P III. REPLY TO NOTICE OF DEVIATION A.
Description of Deviation
" Updated Final safety Analysis Report Table 6.3-2 states that the maximum opening time of Low Pressure Coolant Injection system injection valves is 24_ seconds to assure adequate system flow during Loss-of-coolant accident (LOCA) conditions.
- contrary to the aLove, surveillance test procedures HC.OP-ST. BC-0004 (5) (6) (7), "LPCI Subsystem ECCS Time Response Functional Test", incorrectly permitted the maximum opening time of the injection valves to be 27 seconds."
PSE&G notes that the above statement is incorrect in that the referenced procedures specify a may.imum opening-time of 40 seconds.
HC.OP-IS.BC-0105(Q) is the procedure which contained the 27 second maximum opening time requirement.
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o NLR-N92097 B.
Reason for Deviation 1
PSE&G believes that the reason for this deviation was a past interpretation of UFSAR Section 5.4.7.1.1.2 which states, in part:
"The pumps attain rated speed in 27 seconds and the injection valves will be fully open in 40 seconds.
These timer include diesel generator initiation time."
The value of 13 seconds was subtracted from the 40 seconds stated in the proceding excerpt to account for diesel generator initiation and signal generation timet this resulted in the test acceptance criteria of 27 seconds.
C..
Corrective Steps Initiated During the Inspection A review of all Residual Heat Removal (RHR) System procedures was initiated to determine applicability to this issue.
D.
Corrective Steps Taken Since Inspection 1.
The review of RHR system procedures was completed and identified the following procedures as being affected by thia issue:
HC.0P-IS.BC-0105(Q) " Residual Heat Removal System Valves - Cold Shutdown - Inservice Test" HC.0P-ST. BC-0004 (5) (6) (7) (Q) "LPCI Subsystem ECCS Time Rcsponse Functional Test" 2.
Procedure revision requests were initiated to incorporate the correct acceptance criteria into the procedures listed above.
The revision to HC.OP-IS.BC-0105(Q) was completed on May 15, 1992.
The revisions to HC.OP-ST.BC-0004 (5) (6) (7) (Q) will be c
l completed prior to their next scheduled performance during the fourth refueling outage ceneduled to start in September, 1992.
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E.
Corrective Steps to Avoid Further Deviations In addition to the review of Riin system procedures, PSE&G has completed a review of all Core Spray and !!1gh Pressure Coolant Injection System procedures for applicability to this issue.
The review indicated all procedures to be consistent with the UFSAR, Technical Specifications, and GE Design Specifications.
-l F.
Date When corrective Stops Will be completed As detailed above, PSE&G will be in full compliance with this issue prior to startup from the fourth refueling outage scheduled to start in September, 1992.
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