ML20135D207
| ML20135D207 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/05/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20135D179 | List: |
| References | |
| 50-354-96-09, 50-354-96-9, NUDOCS 9612090291 | |
| Download: ML20135D207 (2) | |
Text
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l-3 APPENDIX A NOTICE OF VIOLATION l
Public Service Electric and Gas Company Docket No:
50-354 i
Hope Creek Generating Station License No: NPF-57 l
During an NRC inspection conducted on September 22,1996 to November 9,1996, l
violations of NRC requirements were identified. In accordance with the " General l
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
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A.
Technical Specification 6.5.2, Nuclear Safety Review and Audit, requires, in part, I
that Hope Creek will have an Offsite Safety Review (OSR) staff consisting of at least four dedicated, full-time engineers; and, that the OSR staff shall review, in part, proposed changes to the Technical Specifications or the Operating License.
Contrary to the above, OSR staffing and review requirements were not met for the l
following two examples:
(1) from September 26,1996 until October 9,1996, the Hope Creek OSR did i
not have a staff consisting of at least four dedicated, full-time engineers; I
- and, (ii)
License Change Request (LCR) 95-23, dated October 7,1995 and LCR 95-23 revision, dated October 27,1995, were not reviewed by the OSR.
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This is a Severity Level IV violation (Supplement 1).
l B.
10 CFR 50.59 requires, in part, that licensees maintain records of changes to the facility as described in the final safety analysis report (FSAR). These records must include a written safety evaluation which provides the bases for the determination that the changes do not involve an unreviewed safety question.
j Contrary to the above, on October 29,1996, the NRC determined that PSE&G had conducted a de facto change of the facility as described in the FSAR without a written safety evaluation which provided the bases that the change did not constitute an unreviewed safety question. This is evidenced by the following two examples where the facility design does not meet the FSAR description:
l 1.
Section 8.1.4.14.1.3 of the FSAR states that "Non-Class 1E circuits or equipment may be connected to Class 1E equipment or circuits by the use of approved qualified isolation devices to assure that, in the event of failure of the non-Class 1E equipment, the Class 1E equipment will continue to perform its function."
In the design of the Class 1E emergency diesel generator room ventilation system, PSE&G incorrectly used qualified isolation devices in non-Class 1E l
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9612090291 961205 PDR ADOCK 05000354 G
PDR I
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circuits and failed to assure that, in the event of a failure of these circuits, the Class 1E ventilation system could continue to perform its function.
2.
Sections 1.8.1.53 and 8.1.4.10 of the FSAR requires compliance with IEEE 379-1972 and Sections 5.2 through 5.5 of IEEE 379-1977, respectively.
IEEE 379 requires, in part, that single failure analyses of Class 1E systems be preconditioned by the failures that non-Class 1E systems--which are coupled in some manner to the Class 1E systems--may cause.
In their single failure analysis of the Class 1E emergency diesel generator j
room ventilation system, PSE&G failed to precondition it by the potential failures of the non-Class 1E fire suppression system with which it is coupled electrically and mechanically, thereby failing to recognize that the ventilation system did not meet the single failure criterion.
This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each violation: (1) the reason for i
the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room, to the extent passible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of 1
withholding (e.g., explain why the disclosure of information will create an unwarranted I
invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provido the level of protection described in 10 CFR 73.21.
l Dated at King of Prussia, Pennsylvania this 5th day of December 1996