ML20149H926
| ML20149H926 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 07/18/1997 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| References | |
| 50-354-97-01, 50-354-97-1, EA-97-160, NUDOCS 9707250253 | |
| Download: ML20149H926 (4) | |
See also: IR 05000354/1997001
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July 18,1997
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EA 97-160
Mr. Leon R. Eliason
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President and Chief Nuclear Officer
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Pohlic Service Electric and Gas Company
P.O. Box 236
Hancocks Bridge, NJ 08038
SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE (NRC INSPECTION
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REPORT 50-354/97-01)
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Dear Mr. Eliason:
This letter refers to NRC Inspection Report 50-354/97-01 completed on March 17,1997 at
the Hope Creek Generating Station. During the inspection the NRC identified, in section
E1, that a design change package which added crosstie piping in the RHR system was
based on a weak 10 CFR 50.59 evaluation. Based on further NRC review, we concluded
that your evaluation failed to identify an unreviewed safety question prior to implementing
the modification.
This information was provided to you as a clarification of earlier findings during a June 26,
1997 teleconference between Mr. M. Bezilla, PSE&G, and Mr. J. Linville, of NRC Region I.
At that time, you were also informed that the NRC has concluded that the failure to obtain
NRC approval prior to implementation of a design change that involved an unreviewed
safety question constituted an apparent violation of NRC requirements set forth in 10 CFR 50.59. Another apparent violation associated with the safety evaluation for the RHR
crosstie design change was also identified. This apparent violation involved the failure to
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perform related monthly ECCS flowpath verification surveillance testing in accordance with
TS 4.5.1.a.1.b as described in your LER 97-005. These apparent violations are being
considered for escalated enforcement action in accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions" (Enforcement Po! icy), NUREG-1600.
Accordingly, no Notice of Violation is presently being issued for these findings. In
addition, please be advised that the number and characterization of apparent violations
may change as a result of further NRC review.
A predecisional enforcement conference is currently scheduled for 10:00 a.m., August 12,
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1997, to review the matter. The decision to hold a predecisional enforcement conference
does not mean that the NRC has determined that a violation has occurred or that
enforcement action will be taken. This conference is being held to obtain information to
enable the NRC to make an enforcement decision, such as a common understanding of the
facts, root causes, missed opportunities to identify the apparent violation sooner,
corrective actions, significance of the issues and the need for lasting and effective
corrective action.
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9707250253 970718
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Mr. L. Eliason
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in particular, we want to understand the results of your evaluation of the 10 CFR 50.59
and engineering performance issues as described in your LER 97-005 and your assessment
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of the effectiveness of the increased 10 CFR 50.59 training and qualification requirements
that were implemented, in part, in response to previous violations of 10 CFR 50.59 as
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outlined in your violation response letter dated November 22,1996. In addition, this is an ,
opportunity for you to identify any errors in our assessment and for you to provide any
information concerning your perspectives on 1) the severity of the violation (s), 2) the
application of the factors that the NRC considers when it determines the amount of a civil
penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy,
and 3) any other application of the Enforcement Policy to this case, including the exercise
of discretion in accordance with Section Vll. This conference will be open to public
observation.
You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regarding these apparent violations is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter
and its enclosure will be placed in the NRC Public Document Room.
Sincerely,
Original Signed By
Richard J. Crienjak for:
Charles W. Hehl, Director
Division of Reactor Projects
Docket No.
50-354
Licensee No. NPF-57
Enclosures:
Excerpts NRC Inspection Report 50-354/97-01
Enforcement Policy: Section V, "Predecisional Enforcement Conferences"
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Mr. L. Eliason
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cc w/ encl:
' L. Storz, Senior Vice President - Nuclear Operations
E. Simpson, Senior Vice President - Nuclear Engineering
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E. Salowitz, Director - Nuclear Business Support
A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
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J. A. Isabella, Manager, Joint Generation
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Atlantic Electric
M. Bezilla, General Manager - Hope Creek Operations
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J. McMahon, Director - Quality Assurance & Nuclear Safety Review
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D. Powell, Manager - Licensing and Regulation
R. Kankus, Joint Owner Affairs
A. C. Tapert, Program Administrator
Jeffrey J. Keenan, Esquire
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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Distribution w/enci:
Region i Docket Room (with concurrences)
W. Axelson, DRA
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K. Gallagher
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D. Screnci, PAO
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
PUBLIC
Distribution w/ encl: (Via E-Mail)
. R. Zimmerman, ADPR, NRR
Fay Davis, NRR
Anne Nicosia, NRR
L. Lieberman, OE (OEMAIL)
B. Fewell, ORA
D. Holody, EO, RI
W. Dean, OEDO
D. Jaffe, Project Manager, NRR
Inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: g:\\ branch 3\\rhr_xtie.hc
Ts recilve a copy of this docunvynt, indicate in the boa: "C" = Copy without attachment / enclosure
'E' = Copy with attachment /enclosu,e
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= No copy
OFFICE
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RI:DRP/
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NAME
DOK
JLinville Q'l
CHehfg/r
DHolody4{r
DATE
- 7/08/9(
07/ 4/97 "
07//1/97
07/if/97 '
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OFFICIAL RECORD COPY
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ENCLOSURE 1
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UNnED STATES
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NUCLEAR REGULATORY COMMISSION
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475 ALLENDALE HoAD
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KING oF PRUsslA. PENNSYLVANIA 19406-1415
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April 14, 1997
EA97-160
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Mr. Leon R. Eliason
Chief Nuclear Officer and President
Nuclear Business Unit.
- Public Service Electric and Gas Company
Post Office Box 236
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Hancocks Bridge, NJ 08038 -
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-354/97-01
Dear Mr. Eliason:
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On March 17i 1997, the NRC completed an inspection at your Hope Creek reactor facility.
The enclosed report presents the results of that inspection.
During.the 6-week period covered by this inspection, your conduct of activities at the Hope
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Creek facility was generally characterized by safety-conscious operations, sound
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maintenance practices, and careful radiological work controls. We were encouraged by
some of the conclusions in the operations and maintenance areas, particularly regarding
improved material conditions; the aggressive posture of your independent oversight groups;
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and detailed self-assessment activities, While these latter two issues were considered
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positively, the findings of these activities also' indicated the need for continued
improvement in maintenance and operations.
We are concerned about two violations of NRC requirements'that were identified in the
first instance,' NRC inspectors identified that the use and control of scaffolding in safety-
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related areas of the plant was not in accordance with your station administrative
, procedures. This violation is cited in the enclosed Notice of Violation, and the
circumstances surrounding the violation are described in detail in the enclosed report.
Please note that you are required to respond to this letter and should follow the
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. instructions specified in the enclosed Notice when preparing your response. ~ In the second
instance, a repeat surveillance test failure of a testable check valve in the reactor core
isolation cooling system revealed ineffective corrective action implementation for previous
like failures. This latter violation of 10 CFR 50 Appendix B, Criterion XVI, resulted in LER
50-354/97-03 00 being submitted. Based on a review of the referenced LER, the
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inspectors noted that your analysis and corrective actions for this event were appropriate.
As such, this violation is being treated as a cited violation not requiring a response. If,
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however, you determine that a response is otherwise warranted for this violation, please
note that you should follow the instructions specified in the enclosed Notice of Violation.
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Mr. L. Eliason
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and
its enclosures will be placed in the NRC Public Document Room (PDR).
Sincerely,
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. Linvil , hief '
rojects Branch 3
Division of Reactor Projects
Docket No.: 50-354
License No: NPF-57
Enclosures:
Notice of Violation Not Requiring Response
Inspection Report 50-354/97-01
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April 14, 1997
EA97-160
Mr. Leon R. Eliason
Chief Nuclear Officer and President
Nuclear Business Unit
Public Service Electric and Gas Company
Post Office Box 236
Hancocks Bridge, NJ 08038
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-354/97-01
Dear Mr. Eliason:
On March 17,1997, the NRC completed an inspection at your Hope Creek reactor facility.
The enclosed rcoort presents the results of that inspection.
During the 6-week period covered by this inspection, your conduct of activities at the Hope
Creek facility was generally characterized by safety-conscious operations, sound
maintenance practices, and careful radiological work controls. We were encouraged by
some of the conclusions in the operations and maintenance areas, particularly regarding
I
improved material conditions; the aggressive posture of your independent oversight groups;
and detailed self-assessment activities. While these latter two issues were considered
positively, the findings of these activities also indicated the need for continued
improvement in maintenance and operations.
We are concerned about two violations of NRC requirements that were identified, in the
j
first instance, NRC inspectors identified that the use and control of scaffolding in safety-
1
related areas of the plant was not in accordance with your station administrative
procedures. This violation is cited in the enclosed Notice of Violation, and the
circumstances surrounding the violation are described in detailin the enclosed report.
,
Please note that you are required to respond to this letter and should follow the
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instructions specified in the enclosed Notice when preparing your response. In the second
instance, a repeat surveillance test failure of a testable check valve in the reactor core
isolation cooling system revealed ineffective corrective action implementation for previous
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like failures. This latter violation of 10 CFR 50 Appendix B, Criterion XVI, resulted in LER
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50-354/97-03-00 being submitted. Based on a review of the referenced LER, the
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inspectors noted that your analysis and corrective actions for this event were appropriate.
As such, this violation is being treated as a cited violation not requiring a response, if,
!
however, you determine that a response is otherwise warranted for this violation, please
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note that you should follow the instructions specified in the enclosed Notice of Violation.
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9704180206 970414
ADOCK 05000354
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Mr. L. Eliason
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter
and its enclosures will be placed in the NRC Public Document Room (PDR).
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Sincerely,
,
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ORIGINAL SIGNED BY:
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James C. Linville, Chief
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Projects Branch 3
Division of Reactor Projects
Docket No.: 50-354
License No: NPF-57
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Enclosures:
Notice of Violation Not Requiring Response
inspection Report 50-354/97-01
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Mr. L. Eliason
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cc w/ encl-
L. Storz, Senior Vice President'- Nuclear Operations
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E. Simpson, Senior Vice President - Nuclear Engineering
E. Salowitz, Director - Nuclear Business Support
A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
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J. A. Isabe!!a, Mariager, Joint Generation
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Atlantic Electric
M. Bezilla, General Manager - Hope Creek Operations
J. Benjamin, Director - Quality Assurance & Nuclear Safety Review
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D. Powell, Manager - Licensing and Regulation
R. Kankus, Joint Owner Affairs
A. C. Tapert, Program Administrator
Jeffrey J. Keenan, Esquire
M. J. Wetterhahn, Esquire
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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EXECUTIVE SUMMARY
Hope Creek Generating Station
NRC Inspection Report 50-354/97-01
This integrated inspection included aspects of licensee operations, engineenng,'
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maintenance, and plant support. The report covers a 6-week period of resident inspecton.
One specialinspection activity, a Maintenance Rule team inspection, occurred during this
period; however, the results of that inspection will be documented in NRC Inspection
Report No. 50-354/97-80.
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Operations
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As a result of the lack of explicit procedural guidance, some operators were confused
regarding the main steam line isolation actuation setpoints for the high radiation safety
feature per the requirements of technical specification 3.3.2 during planned hydrogen
water chemistry injection (HWCl) system flow reductions. (Section 01.2)
Operators were found to be effectively controlling standby safety auxiliaries cooling system
(SACS, soop temperature; however, operational guidance was not thorough. Additionally,
the UFSAR did not accurately reflect the current design basis and operating condition
which permits continuous SACS flow to the residual heat removal heat exchangers,
however, the licensee had previously recognized this problem and had initiated appropriate
changes to the UFSAR. (Section 01.3)
Operator response to two plant events was good, in that the necessary immediate actions
were taken; the events were properly classified in accordance with the licensee's Event
Classification Guide (Emergency Plan); and, NRC reporting requirements were met.
(Section 01.4)
The inspectors concluded that operator performance improvements had occurred during
this period. (Section 02.1)
The inspectors concluded that the licensee's QA/NSR report on an event involving an
inadvertent half scram was accurate, comprehensive and complete. This report was
viewed as an indicator of good performance in self-assessment activities. Further, station
personnel performance as described in the report during this event indicated weaknesses in
the use of the corrective actions program, due to personnel not documenting Action
Requests in a timely manner and in proper log keeping by plant operators regarding plant
conditions. These concerns were considered examples of a non-cited violation. (Section
07.1)
Based on a review of selected records and reports, the inspectors concluded that the
licensee's self assessment process and corrective action program were being appropriately
used and provided valuable performance assessment information to station management.
(Section 07.2)
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LVlaintenance
The licensee adequatoly planned and controlled the observed maintenance and surveillance
activities. The work was conducted in a professional manner and timely completed to
ensure that equipment restoration to service was within the technical specification
requirements for all observed activities. (Section M1.1)
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The licensee's analysis and corrective actions for a human error event leading to a primary
containment isolation system actuation were appropriate. (Section M2.1)
The licensee management actions to reduce the backlog of corrective maintenance work
were evident. While too early to conclude that the management of the work process had
been improved significantly, the trend information from the licensee performance indicators
was positive. (Section M2.2)
The licensee plans and corrective actions were found reasonable for the identified concerns
with degraded Agastat GP Series and Struthers-Dunn relays. However, the NRC was
concerned that: (1) the material condition of the plant was adversely affected by these
degraded conditions; (2) the conditions indicated weaknesses in the licensee's planned
maintenance program and industry operating experience program; and, (3) extensive
evaluation and repairs were necessary to resolve these relay problems while the plant was
on line. (Section M2.3)
Hope Creek test procedures for safety-related ventilation trains do not implement technical
specification surveillance requirements consistently. (Section M3.1)
The QA audit of the maintenance program showed that additional improvements were
warranted in the maintenance area. The audit activity was well planned and excellently
performed. The audit findings were well supported by observations and provided
significant information to mai.;gement in order to improve the rnaintenance programs.
(Section M7)
Enaineerin_g
The licensee's implementation of Design Change Package (DCP) No. 4EC-3411 was, in
part, based upon a weak 10 CFR 50.59 evaluation, which indicated a weakness in the
engineering development, review and approval process of 10 CFR 10 CFR 50.59
evaluations to support design changes. The licensee's evaluation failed to identify a
potential unreviewed safety question involving a malfunction of equipment important to
safety (Iow pressure coolant injection system) and need for a technical specification
requirement change in order to implement the modification. Further, since this DCP was
implemented over the course of several years with different parties involved in the 10 CFR 50.59 review and approval, it was further concluded that numerous opportunities were
available for the licensee to identify this problem. (Section E1.1)
While a potential unreviewed safety question was identified, the inspector verified that the
residual heat removal (RHR) system cross-tie isolation valves were properly installed,
providing double isolation capability; and, that the valves were being maintained closed
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ensuring the independence of the low pressure coolant injection (LPCI) subsystems.
(Section E1.1)
The inspector also concluded that DCP 4EC-3411 documentation was thorough. The
observed portions of the completed field work indicated good installation implementation.
Testing considerations were found appropriate and test completion timely. (Section E1.1)
A repeat failure of the reactor core isolation cooling (RCIC) system turbine exhaust checx
valve inservice test highlighted past deficiencies in PSE&G's design change process to
ensure that modifications implemented to correct failures were designed appropriately.
Also, this repeat failure indicated a weakness in the corrective action program to ensure
that the failure was corrected. H;. wever, the recent effort to identify causal factors
associated with this evert ::.d develop lasting corrective actions was good. (Section E2.1)
Poor implementation of established scaffolding control guidance enabled the installation
and retention of several scaffolds in safety-related areas, including the "A" and "B"
residual heat removal pump rooms and the standby liquid control pump room in the reactor
building of the Hope Creek station without adequately evaluating the impact of these
structures on the design and licensing basis of the facility. This was considered a violation
of licensee procedure controls. (Section E2.2)
Plant Suonort
PSE&G appropriately tested the EDG room ventilation fire dampers and has established
appropriate controls to ensure this activity is completed on a periodic basis and in
accordance with the programmatic description in the UFSAR. (Section F2.1)
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IH. Enaineerina
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Conduct of Engineering
E1.1
Desian and Installation of Plant Modifications + Shutdown Coolina Cross-tie
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a.
Insoection Scoce (375511
The inspectors reviewed selected portions of the completed design change
packages that installed the cross-tie capability to the RHR system during Refueling
Outages 5 and 6 to determine if adequate controls were implemented to maintain
the original design basis of the affected sy!tems and to ascertain if the plant
modification packages contained clear and ccurate installation and test
instructions.
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The inspectors reviewed selected portions c(f Design Change Package (DCP) No.
4EC-3411 to ascertain that the design, instaMation and testing of the RHR cross-tie
subsystems were accomplished safely and introduced no unreviewed safety
questions.
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Observations and Findinas
DCP 4EC-3411 involved the modification of the RHR system to install a discharge
cross-tie between the "C" header and the "A" RHR heat exchanger, and also
between the "D" header and the "B" RHR heat exchanger. This modification
involved: the installation of two 18-inch cross-tie headers and associated vents and
drains; installation of structural supports for the new cross-tie piping and
modification of original piping and structural supports in the RHR rooms to eliminate
interference with the new equipment; core bore new wall penetrations to facilitate
the installation of the new piping; changes to the pump start control interlocks to
add a new key-lock bypass switch for the "C" and "D" RHR pumps to permit pump
start with their respective torus suction valves closed; and, installation of four (two
per cross-tie) new 18-inch, 300 psi, Anchor Darling cross-tie gate isolation valves,
two of which were to have Limitorque motor-operators.
The installation of this modification was completed over several years commencing
with work on the "A" and "C" cross-tie during Refueling Outage 5 in March 1994,
an6 completing with "B" and "D" cross-tie during Refueling Outage 6 in March
1996.
In the area of design control, the inspector observed that the rnodification packages
provided adequate post-modification testing instructions. The testing requirements
were reviewed and found consistent with the appropriate requirements. Also noted
was that some testing had not been completed for the motor operators on the new
cross-tie isolation valves. However, that part of the design change, providing
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electrical power to the motor operators, had not yet been field completed.
Therefore, deferring the motor operator testing was not a problem.
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The inspector noted, that considering the complexity of the DCP, very few field
changes were required for this modification, indicating that the change package was
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of high quality. A sample of SORC meeting minutes were reviewed to ensure that
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the DCP and the associated 10 CFR 50.59 safety evaluation were reviewed and
approved by SORC prior to implementation. During a review of one of the
associated SORC meeting minutes, dated September 27,1995, the inspector noted
that SORC had reoucated the PRA group perform an analysis of the design change
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due to the creation of new high stress locations for the associated piping. PRA
provided an estirnate that the introduction of the new high stress locations for the
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moderate energy _ RHR piping resulted in at worst, an insignificant increase in the
average Core Damage Frequency. SORC then approved the 10 CFR 50.59
evaluation based on this clarification.
Tne inspector noted that the design change review and approval and the necessary
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procurement of components was completed in a timely manner to support the
modification implementation. Further, the modification package provided clear
installation instructions. Also, the inspector reviewed the UFSAR changes that
were made to incorporate the new design, and found that the licensee had properly
revised the UFSAR. The inspector walked down accessible portions of this
modification and found that the as-built configuration agreed with the design
drawings and that the new flow path valves were allin their required positions
(closed) per the licensee's system alignment procedures for the current operating
condition (power operations).
The inspector reviewed the associated 10 CFR 50.59 evaluations for the
modification and found that they were written clearly and except as described
below, provided sufficient bases for the acceptance of the proposed modification.
One concern that the inspector noted was that the safety evaluation did not
consider an erroneous valve lineup that would lead to two of the RHR subsystems
(Low Pressure Coolant injection or LPCI subsystems) being cross-tied 'during power
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operations as a credible failure. It appeared to the inspector that the licensee
accepted this design because the modification was single-failure proof (included
dual isolation valves) and had appropriate administrative controls to ensure proper
valve lineup, that the original design and licensing basis (as stated in Section 6.3 of
the UFSAR) of having four separate LPCI subsystems was maintained.
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The inspector considered that the UFSAR description of LPCI stated:
"LPCI is an operating mode of the RHR system. Four pumps deliver water
from the suppression chamber to four separate reactor vessel nozzles and
inject directly into the core shroud region. . . ."
Also, Section 5.4.7.1 of the UFSAR describes the design bases of the RHR System
as:
"The RHR System consists of four independent loops A, B, C and D as
shown in Figure 5.4-13. Each loop contains a motor driven pump, piping,
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valves, instrumentation, and controls. Each loop takes suction from the
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suppression pool and is capable of discharging water to the reactor vessel
via separate LPCl nozzles, or back to the suppression pool via a full flow test
line."
Further clarification of this original licensing basis is found in Section 6.3.1 of
NUREG 1048, Safety Evaluation Report related to the operation of the Hope Creek
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Generating Station, which states:
"The LPCI system is provided to replace reactor vessel water inventory after
large pipe breaks. The system is an operating mode of the residual heat
removal system. It consists of four independent loops. Each loop has a
motor-driven pump that takes suction from the suppression pool and supplies
water to the reactor vessel at a flow rate of about 10,000 gpm. Four
separate nozzles discharge directly inside the core shroud. . . ."
In the onginal design of the RHR system, the LPCI injection flow path was
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physically separate with no interconnection of piping from the RHR pumps to the
reactor vessel. The suction of the RHR pumps utilized separate suction strainers
from the suppression pool with individual suction isolation valves; however, a cross-
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tie with dual manual isolation valves connected the suction supply lines. After
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reviewing the pertinent design basis documentation, the inspector concluded that
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the modification installing the cross-tie between the discharge or injection paths,
still adequately assured electrical separation of the independent LPCI subsystems;
however, the mechanical separation criteria were changed.
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The licensee's 10 CFR 50.59 evaluations recognized this change and did properly
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evaluate the potential for internal flooding events, etc., as a result of pipe breaks.
However, the 10 CFR 50.59 evaluations did not rigorously review the potential loss
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of more than one LPCs flow path resulting from an erroneous valve alignment that
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could change the expected availability of the LPCI subsystems to respond to a
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postulated LOCA event. Design Change Package Nos.1 and 2 of the DCP, which
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installed the cross-tie between the "A" and "C" RHR injection loops, did not
consider a review of the ECCS TS when determining the acceptability of the design
change. Further, the 10 CFR 50.59 evaluation concluded that there was no
"Unreviewed Safety Question" due to the fact that " . . .neither the performance of
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the systems required to mitigate the consequences of an accident is being changed,
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nor are the initiating event mechanisms being changed. . .." While Package No. 3,
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which installed the cross-tie between the "B" and "D" RHR injection loops, did
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review the ECCS technical specifications, it still concluded that there was no
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"Unreviewed Safety Question" on the same basis as stated in DCP Package Nos.1
and 2.
The inspector questioned with this conclusion because the DCP changed the design
of a system that is used to mitigate the consequences of an accident, namely, the
LPCI mode of the RHR system. Because the original design of the LPCI system had
no chance of two injection paths being cross-tied during an accident mitigation, the
probability of such an event after implementing the DCP may be greater. The
modification created a potential accident without an LPCI independent injection flow
.
.
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17
path, if the respective isolation valves were erroneously left open during power
operation. Further, the licensee's evaluations did not address the consequences of
such a malfunction of the LPCI system as could occur with the cross-tie valves
open during power operations.
.
After the inspector raised the concern about the inappropriate consideration of the
affect on the LPCI system, the licensee identified that d.+ cross-tie valves should
probably have been considered part of the LPCI flow path for surveillance testing
per TS 4.5.1 (b). This surveillance demonstrates that the ECCS flow path valves
are in their correct position on a monthly basis, if not locked, sealed, or otherwise
secured in position. The applicable surveillance test procedures had not been
changed upon implementation of the DCP. However, the inspectors were informed
that the valves were being visually observed on a monthly basis in order to satisfy
extended containment boundary procedure requirements that were changed to
incorporate the DCP implementation.
The inspector concluded that the four,18 inch, cross-tie isolation valves should
have been considered part of the LPCI flow path. Failure to ensure that the ECCS
surveillance test procedure accurately reflected the actual design of the system was
viewed as a further indication of a weak engineering evaluation to support the DCP.
However, baseu on a review of the current standard technical specifications, as well
as the technical specifications for the Limerick station that employs a similar design,
the inspector noted that RHR cross-tie isolation valves received specific surveillance
requirements beyond that of TS 4.5.1 (b). The standard technical specifications
required a monthly surveillance requirement specifically for the RHR cross tie
isolation valves to ensure that they were closed and their motor operators de-
energized. The standard technical specification bases described that this
requirement ensured that the LPCI loops remained independent, so that a
malfunction in one subsystem would not affect any other subsystem. Therefore,
the inspector was further concerned that the engineering evaluation for this
modification should have identified the unreviewed safety question described above,
and should have resulted in a technical specification change incorporating the
requirements of the standard technical specifications, or similar, for the LPCI cross-
tie isolation valves. This itern is unresolved pending further NRC review. (UNR 50-
354/97-01 04)
c.
Conclusion
The inspector concluded that the licensee's implementation of Design Change
Package No. 4EC-3411 was, in part, based upon a weak 10 CFR 50.59 evaluation,
which indicated a weakness in the erigineering development, review and approval
l
process of 10 CFR 50.59 evaluations to support design changes. The licensee's
evaluation failed to identify a potential unreviewed safety question and the need for
a technical specification change in order to implement the modification. Further,
since this DCP was implemented over the course of several years with different
parties involved in the 10 CFR 50.59 review and approval, it was further concluded
that numerous opportunities were available for the licensee to identify this problem.
,
While there may be an unreviewed safety question, the inspector verified that the
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cross-tie isolation valves were properly installed, providing double isolation
capability; and, that the valves were being maintained closed ensuring the
. independence of the LPCI subsystems.
The inspector also concluded that the DCP documentation was thorough. The
observed portions of the completed field work indicated good installation
implementation. Testing considerations were found appropriate and test completion
was timely.
.
E2
Engineering Support of Facilities and Equipment
E2.1
Testable Check Valve Failures
a.
Insoection Scope (37551. 62707)
The inspectors reviewed PSE&G's response to a failed inservice test of the RCIC
system turbine exhaust check valve. The assessment included an evaluation of the
licensee's reporting of this event, short term corrective actions, and effectiveness of
corrective action program implementation,
b.
Observations and Findinas
On February 4,1997, operators declared the RCIC system inoperable following an
inservice test failure of the associated systern turbine exhaust check valve, a
testable 10" Anchor Darling swing check. During the test of this valve, the
operators were unable to engage the valve disc with a cam that is attached to the
test handle. A subsequent internalinspection by maintenance technicians revealed
that the cam, which is positioned on the valve disc hinge shaft with a set screw,
had slipped from its required position, rendering the valve untestable. Technicians
adjusted the cam position as required and fixed it in place with the set screw. The
valve was reassembled and the RCIC system was declared operable on February 5.
In part because operators reported this event per 10 CFR 50.72 as an unplanned
inoperability of a single train safety system, Hope Creek management assigned a
significance level 1 condition report to the engineering department to perform a
detailed root cause evaluation of the event. The inspectors interviewed the
responsible engineering personnel as well as the documented root cause
determinations, along with recommended corrective actions. As a result of the
investigation, PSE&G determined that this same check valve had failed two times
previously, in 1992 and 1995, for similar reasons. Additionally, the analogous high
pressure coolant injection (HPCI) check valve had failed under these circumstances
in 1989.
l
The licensee's investigation concluded that a 1989 DCP which modified a
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population of nearly 45 swing check valves with the test handle mechanism (to
!
facilitate periodic inservice tests), f ailed to provide adequate technical guidance to
ensure that the set screw which secures the cam to the disc hinge shaft would
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remain engaged. Specifically, though the modification concept included a provision
,
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ENCLOSURE 2
,
34386
Feder-1 Register / Vol. 60, No.126 / Frid:y, Juna 30, 1995 / Notices
,
fact:rs in arriving at the appropriate
is not held, the licensee will normally
is a matter of public record, such as an
severity level will be dependent on the
be requested to provide a written
adjudicatory decision by the
circumstances of the violation.
response to an inspection mport, if '
flow 1ver,if a licensee refuses to correct issued, as to the licensee's views on the Department of labor. In addition, with
a minor violation within a reasonable
the approval of the Executive Director
apparent violations and their root
for Operations, conferences will not be
,
l
tims such that it willfully continues, the causes and a description of planned or open to the public where good cause has
vi .lation should be categorized at least
implemented corrective action.
been shown after balancing the benefit
at a Severity LevelIV.
During the predecisional enforcement
D. Violotions of Reporting Requirements c nference, the licensee, vendor, or
of the pulf.c observation against the
potentlalimpact on the agency's
Ths NRC expects licensees to provide other persons will be given an
enforcement action in a particular case.
complete, accurate, and timely
opportunity to provide information
As soon as it is determined that a
consistent with the purpose of the
conference will be open to public
information and reports. Accordingly,
conference, including an explanation to observation, the NRC will notify the
unless otherwise categorir.ed in the
i
Suppliments, the severity level of a
the NRC of the immediate corrective
licensee that the conference will be
violation involving the failure to mal'
actions (if any) that were taken
open to public observation as part of the
a required report to the NRC will be
following identification of the potential agency's trial program. Consistent with
l
based upon the significance of and the
violation or nonconformance and the
the agency's policy on open meetings,
circumstances surrounding the matter -
long-term comprehensive actions that
" Staff Meetings Open to Public,"
that should have been reported.
were taken or will be taken to prevent
published September 20,1994 (59 FR
flowzver, the severity level of an
recurrence. Licensees, vendors, or other 48340), the NRC intends to announce
untimily report, in contrast to no report, persons will be told when a meeting is
open conferences normally at least 10
may be reduced depending on the
a predecisional enforcement conference. working days in advance of conferences
A predecisional enforcement
through (1) notices posted in the Public
circumstances surrounding the matter.
conference is a meeting between the
Document Room,(2) a toll-free
A licensee will not normally be cited for
a f:llure to report a condition or event
NRC and the licensee. Conferences are
telephone recording at 800-952-9674,
unless the licensee was actually awa e
normally held in the regional offices
and (3) a toll-free electronic bulletin
cf tha condition or event that it failed
and are not normally open to public
board at 800-952-9676. In addition, the
to rsport. A licensee will, on the other
observation. However, a trial program le NRC will also issue a press release and
hand, normally be cited for a failure to
being conducted to open approximately notify appropriate State liaison officers
report a condition or event if the
25 percent of all eligible conferences for that a predecisional enforcement
'
licansee knew of the information to be
public observation, i.e., every fourth
conference has been scheduled and that
,
reported, but did not recognize that it
eligible conference involving one of
it is open to public observation.
was required to make a report.
three categories of licensees (reactor,
The public attending open
hospital, and other materials licensecs)
conferences under the trial program may
l
V.Predecisional Enforcement
will be open to the public. Conferences
observe but not participate in the
Conferences
will not normally be open to the public
conference. It is noted that the purpose
>
Whenever the NRC has learned of the if the enforcement actmn being
of conducting open conferences under
lat d.
the trial program is not to maximize
exist:nce of a potential violation for
contYould b'e taken a8ainst an
public attendance, but rather to
(t)
which escalated enforcement action
appears to be warranted, or recurring
individual, or if the action, though not
determine whether providing the public
nonconformance on the part of a
taken egainst an individual, turns on
with opportunities to be informed of
vindor, the NRC may provide an
whether an individual has committed - NRC activities la compatible with the
doing.
wron$nvolves significant personnel NRC's ability to exercise its regulatory
opportunity for a predecisional
(2)
and safety responsibilities. Therefore,
enforczment conference with th.e
licinsee, vendor, or other person before failures where the NRC has requested
members of the public will be allowed
taking enforcement action. The purpose that the individual (s) involved be
access to the NRC regional offices to
of the conference is to obtain
present at the conference;
attend open enforcement conferences in
informatlan that will assist the NRC in
(3)is based on the findings of an NRC accordance with the Standard
dittrmining the appropriate
Office of Investigations report; or
Operating Procedures For Providing
enforc: ment action, such as:(1) A
(4) 1nvolves safeguards information,
Security Support For NRC Hearings And
common understanding of facts, root
Privacy Act information, or information Meetings," published November 1,1991
causes and missed opportunities
which could be considered proprietary; (56 FR 56251). These procedures
In addition, conferences will not
provide that visitors may be subject to
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l
associtted with the apparent violations, normally be open to the public if:
personnel screening, that signs, banners,
(2) a common understanding of
(5) The conference involves medical
posters, etc., not larger than 18" be
corrective action taken or planned, and
misadministrations or overexposures
permitted, and that disruptive persons
I
(3) a common understanding of the
and the conference cannot be conducted may be removed,
cignificance ofissues and the need for
without disclosing the exposed
Members of the public attending open
lasting comprehensive corrective action. Individual's name; or
conferences will be reminded that (1)
If the NRC concludes that it has
(6) The conference will be conducted
the apparent violations discussed at
sufficitnt information to make an
by telephone or the conference will be
predecisional enforcement conferences
inf:rmed enforcement decision, a
conducted at a relatively small
are subject to further review and may be
conf;ronce will not normally be held
licensee's facility,
subject to change prior to any resulting
unless the licensee requests it. However,
Notwithstanding meeting any of these enforcement action and (2) the
an opportunity for a canference will
criteria, a conference may still be open
statements of views or expressions of
niemally be provided before issuing an
if the conference involves issues related opinion made by NRC employees at
ordir b:. sed on a violation of the rule on to an ongoing adjudicatory proceeding
predecisional enforcement conferences.
,
Deliberate Misconduct or a civil penalty with one or more intervenors or whe4e
or the lack thereof, are not intended to
to an unlicensed person. If a conference the evidentiary basis for the conference
represent final determinations or beliefs.
l
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Federal liegister / Vol. 60, No.126 / Friday, June 30, 1995 / Noticos
34387
Persons attending open conferences will to be under oath. Normally, responses
management involvement in licensed
be provided an opportunity to submit
under oath will be required only in
activities and a decrease in protection of
written comments concerning the trial
connection with Severity level 1, II, or
the public health and safety,
program anonymously to the regional
111 violations or orders,
office.These comments will ba
The NRC uses the Notice of Violation
1. Base Civil Penalty
subsequently forwarded to the Director
as the usual method for formalizin the
The NRC im
a different levels of
!
of the Office of Enforcement for review
existence of a violation. Issuance o a
penalties for diff rent severity level
i
and consideration.
Notice of Violation is normally the only violations and different classes of
'
When needed to protect the public
enforcement action taken, except in
licensees, vendors, and other persons.
health and safety or common defense
cases where the criterie for issuance of
Tables IA and 1B show the base civil
and security, escalated enforcement
civil penalties and orders, as set forth in penalties for various reactor, fuel cycle,
j
action, such as the issuance of an
Sections VI.B and VI.C. respectively, are
'
!
Immediately effective order, will be
met. However, special circumstances
materials, and vendor pro [uals are
ams. (Civil
penalties issued to indivi
taken before the conference. In these
regarding the violation findin8s may
determined on a case-by-case basis.) The
cases, a conference may be held after the warrant discretion being exercised such structure of these tables generally takes
escalated enfo cement action is taken,
that the NRC refrains from issuing a
into account the gravity of the violation
I
VI. Enforcement Actions
tfajionof nio
E' **#I * "*
"#*" " ""
.' ) $;"j I to pay as a secondary
"
e
ct
in adkition, licensees ere not ordinarily
This section describes the
c na eradonAnwany,opwadons
-
enforcement sanctions avallable to the
cited for violations resulting from
n
n8 Bream nu&ar makdal
NRC and specifies the conditions under matters not within their control, such as
inwntwies and gmat
otsdal
!
which each may be used. The basic
equipment failures that were not
cmsequences t the pu lic and licensen
enforcement sanctions are Notices of
avoidable by reasonable licensee quality
- E'
s receive higher civil
Violation, civil penalties, and orders of
assurance measures or management
PenaIt es. Regarding the secondary
various types. As discussed furtherin
controls. Generally, however, licensees
fa tor iability of various classes of
Section VI.D. related administrative
are held responsible for the acts of their
n t the NRC s (ntention that thehcensees
actions such as Notices of
emplo ees. Accordingly,this policy
Nonconformance, Notices of Deviation,
shoul not be construed to excuse
Confirmatory Action Letters, Letters of
personnel errors.
economic impact of a civil penalty be so
Reprimand, and Demands for
severe that it puts a licensee out of
Information are used to supplement the
B. CivilPenolty
business (orders, rather than civil
enforcement program. In selecting the
A civil penalty is a monetary penalty
Penalties, are used when the intent is to
enforcement sanctions or administrative that may be imposed for violation of (1) suspend or terminate licensed activities)
actions, the NRC will consider
certain specified licensing provisions of or adversely affects a licensee's ability
enforcement actions taken by other
the Atomic Energy Act or
to safely conduct licensed activities.
Federal or State regulatory bodies
supplementary NRC rules or orders: (2)
The deterrent effect of civil penalties is
having concurrent jurisdiction, such as
any requirement for which a license
best served when the amounts of the
in transportation matters. Usually,
may be revoked; or (3) reporting
psaldes take into accent a Hcensds
whenever a violation of NRC
requirements under section 206 of the
ability to pay. In determining the
requirements of more than a minor
Energy Reorganization Act. Civil
amount of civil penalties for licensees
concem is identified, enforcement
penalties are desi ned to deter future
for whom the tables do not reflect the
action is taken. The nature and extent of violations both b the involved licensee ability to pay or the gravity of the
the enforcement action is intended to
as well as by oth r licensees conducting violation, the NRC will consider as
reflect the aeriousness of the violation
similar activities and to emphasize the
necessary an increase or decrease on a
involved. For the vast majority of
need for licensees to identify violations case-by-case basis. Normally, if a
licensee can demonstrate financial
violations, a Notica of Violation or a
and take prompt comprehensive
Notice of Nonconformance is the normal corrective action,
hardship, the NRC will consider
action.
Civil penalties are considered for
Payments over time, including interest,
Severity level III violations. In addition, rather than reducing the amount of the
civil enalty. However, where a licensee
civil penalties will normally be assessed
P
A Notice of Violation is a w-itten
for Severity Level I and 11 violations and claims financial hardship, the licensee
notice setting forth one or more
knowing and conscious violations of the will normally be required to address
violations of a legally binding
reporting requirements of section 206 of why it has sufficient resources to safely
requirement. The Notice of Violation
the Energy Reorganization Act.
conduct licensed activities and pay
normally requires the recipient to
Civil penalties are used to encourage
license and inspection fees.
provide a written statement describing
prompt identification and prompt and
2. Civil Penalty Assessment
(1) the reasons for the violation or, if
comprehensive correction of violations,
contested, the basis for disputing the
to emphasize complianco in a manner
In an effort to (1) emphasize the
l
violation; (2) corrective steps that have
that deters future violations, and to
importance of adherence to
l
been taken and the results achieved; (3) serve to focus licensees' attention on
requirements and (2) reinforce prompt
'
corrective steps that will be taken to
violations of significant regulatory
self-identification of problems and root
prevent recurrence; and (4) the date
concern.
causes and prompt and comprehensive
when full compliance will be achieved.
Although management involvement,
correction of violations, the NRC
The NRC may waive all or portions of
direct or indirect,in a violation may
reviews each proposed civil penalty on
,
a wr!tten response to the extent relevant lead to an increase in the civil penalty,
its own merits and, after considering all
information has already been provided
the lack of management involvement
relevant circumstances, may adjust the
to the NRC in writing or documented in may not be used to mitigate a civil
base civil penalties shown in Table 1A
an NRC inspection report. The NRC may penalty. Allowing mitigation in the
and 1B for Severity LevelI,II, and 111
require responses to Notices of Violation latter case could encourage the lack of
violations as described below.
9
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