ML20140G535
| ML20140G535 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/10/1997 |
| From: | Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| References | |
| 50-354-96-09, 50-354-96-9, NUDOCS 9706160333 | |
| Download: ML20140G535 (4) | |
Text
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b June 10, 1997 i
l Mr. Leon R. Eliason l
Chief Nuclear Officer & President l,
Nuclear Business Unit Public Service Electric and Gas Company P. O. Box 236
~ Hancocks Bridge, New Jersey 08038
SUBJECT:
INSPECTION REPORT NO. 50 354/96-09 (REPLY)
Dear Mr. Eliason:
This refers to your January 9,1997, correspondence and to the February 3,1997, submittal of licensee event report (LER) No. 97-001-00, in response to our letter, dated December 5,1997, regarding Hope Creek Generating Station. This correspondence dealt with your failure to evaluate and address de facto facility changes as described in the FSAR resulting from electrical and mechanical interactions between the emergency diesel j
generator (EDG) and the fire suppression systems..This failure was a violation of the l
10 CFR 50.59 requirements regarding modifications without a written safety evaluation.
We have reviewed this matter in accordance with NRC Inspection Manual i
Procedure 92903, " Engineering." We concur with your assessment of the causes of the I
occurrence which you have identified in the LER to be: (1) inadequate analysis to support l
-the exception to the standard review plan, and (2) human performance issues that led to j
delayed identification of the problem. We would like, however, to comment on two of t
your statements l
You concluded that, under sustaineo degraded voltage from the offsite power l
sources, an EDG system vulnerability ixisted. For this conclusion, you postulated that a fault in the non-Class 1E circuit potentially could maintain the 3ZZ relay energized and impact the continuous operation of the associated EDG. You also i
concluded that, under a loss of power condition, no vulnerabilities existed because, l
in this case, the 3ZZ relay circuit is de-energized.
l l
For the latter conclusion to be valid, you should have performed a physical examination of the 3ZZ relay circuits to evaluate potential interactions betweers i
l these circuits and other circuits that are re-energized following restoration of power 0
from the EDGs. A~ hot short through an installed jumper or faulty cross-connection
.would have impacted the continuous operation of the associated EDG in the same j
L manner as your evaluation found. Your reply did not specify that such examination j
had been done and that a hot short was not credible, f
s 9706160333 970610
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Mr. Leon R. Eliason 2
e The ability of the onsite electrical sources to perform their safety functions under design conditions depends, in part, on the continuous availability of the EDG room ventilation system. In its present design, as also recognized in section 9.5.1.6.30
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of the FSAR, an inadvertent actuation of the fire suppression system in any one of the EDG rooms, would prevent that EDG from running indefinitely. The second example in the Notice of Violation was the result of the NRC identifying this design deficiency and your failure to recognize, in your single failure analysis, that a coupling existed between the EDG room ventilation and fire suppression systems.
In responding to this violation example, you discussed again the electrical coupling through the 3ZZ relays which trip the recirculation fans, but failed to address the I
coupling through the fire dampers which close and shutdown the EDG room
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ventilation on a fire suppression system actuation. You addressed this issue in the l
section " Reason for the Violation," and stated that the design, as described in the above cited FSAR section, was an approved exception to the Standard Review Plan criteria. You further stated that you had described the details of this exception in your letter to the NRC, dated October 4,1996.
1 We reviewed your letter during the subject inspection and responded in detail to your position statements in section E8.1 of inspection report (IR) 50-354/96-09. At that time, we disagreed with your position, as we also disagreed previously in IR l
50-354/97-03. As we stated previously, if the design were viewed in the context of 10 CFR 50, Appendix R shutdown requirements, it would be acceptable and approvable, because such requirements are less stringent than those for a design basis accident (DBA). In addition, a DBA concurrent with a fire is not a design basis.
l During a DBA, inadvertent actuations of nonsafety-related systems, in addition to l
the single failure of an ar aident mitigating ustem or component, are admissible and -
l should be considered in the single failure aneaysis. Therefore, for DBA mitigation, the current fire suppression system design does not meet the single failure criterion
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and contradicts other FSAR statements, including sections 1.8.1.53, 8.1.4.10, and l
9.1.4.14.1.2.
In the LER, you stated that the orobability of a loss of offsite power and more than one inadvertent actuation of a fire suppression system was calculated to be 2.8 E-7 occurrences per year. Although probab!!isuc risk assessments cannot be used to justify design deficiencies, we would lle to point out that, based on the above, your analysis should have evaluated the probability of ontv one inadvertent actuation, since only one actuation would be sufficient to lower the quantity of l
accident mitigating equipment to less than the minimum required, if a second component is not available due to single failure.
l e
a
Mr. Leon R. Eliason 3
Your correspondence indicated that a permanent correction of the identified design deficiencies would be completed prior to restart following the next refueling outage. As a temporary measure to address these deficiencies you disconnected the 3ZZ relays and posted fire watches to compensate for the degraded fire system. We consider these j
temporary measures acceptable to address the first issue, above. They are insufficient, however, to address the inadvertent actuation concern.
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An additional response to the Notice of Violation and to the above comments is required.
Specifically, we request that you review the above NRC comments and assure that your corrective actions resolve all NRC concerns.
We appreciate your cooperation. If you have any questions, please call me at (610) 337-5376.
Sincerely,
.~
William H. Ruland, Chief Electrical Engineering Branch Division of Reactor Safety Docket No. 50-354 cc:
L. Storz, Senior Vice President - Nuclear Operations E. Simpson, Senior Vice President - Nuclear Engine:ering E. Salowitz, Director - Nuclear Business Support A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
J. A. Isabella, Manager, Joint Generation Atlantic Electric l
M. Bezilla, General Manager - Hope Creek Operations J. Benjamin, Director - Quality Assurance & Nuclear Safety Review
- 0. Powell, Manager - Licensing and Regulation R. Kankus, Joint Owner Affairs A. C. Tapert, Program Administrator Jeffrey J. Keenan, Esquire M. J. Wetterhahn, Esquire l
Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township State of New Jersey State of Delaware
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l Mr. Leon R. Eliason 4
Distribution:
Region i Docket Room (with concurrences)
K. Gallagher, DRP L. Nicholson, DRP S. Barber, DRP R. DePriest, DRP Nuclear Safety Information Center (NSIC)
NRC Resident inspector PUBLIC W. Dean, OEDO l
D. Jaffe, Project Manager, NRR l
J. Stolz, PDI-2, NRR l
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR D. Taylor, NRR DRS File l
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NAME ADellaGrecca LNjcholsonQp'd WRuland (JAf4 DATE 02/28/97 02/ fy /97 OW y/97 02/
/97 02/
/97 Di 0FFICIAL' RECORD COPY j
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