ML20151Z111
| ML20151Z111 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/11/1998 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H Public Service Enterprise Group |
| References | |
| 50-354-98-06, 50-354-98-6, NUDOCS 9809210163 | |
| Download: ML20151Z111 (3) | |
See also: IR 05000354/1998006
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September 11,1998
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Mr. Harold W. Keiser
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Executive Vice President
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Nuclear Business Unit
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Public Service Electric & Gas Company
. PO Box 236
Hancocks Bridge, NJ 08038
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SUBJECT:
NRC Inspection Report 50-354/98-06
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Dear Mr. Keiser:
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This letter refers to your August 18,1998, correspondence (LR-N98376),in response to
our July 21,1998, letter regarding the Hope Creek facility.
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Thank you for informing us of the corrective and preventive actions for the Notice of
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Violation, as documented in your letter. The Notice of Violation identified two violations.
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One violation was cited for failing to sample, analyze and report emergency diesel
generator fuel oil deliveries for particulate concentration. The second violation was cited
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for incorrectly changing the design basis of the reactor core isolation cooling (RCIC) system
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during a modification by removing a timing sequence feature for the RCIC turbine steam
line stop valve.
Your response to the violations indicated that you have corrected thr. specific violations
and have initiated measures to prevent recurrence. Your response to the violations will be
examined during a future inspection.
In addition, your August 18,1998, correspondence provides clarification of Section R4.1
of the subject inspection report. Specifically, your staff confirmed that chemistry -
personnel did, in f act, provide verbal communications to control room personnel that a
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. standby liquid control sample result was suspected to be inaccurate. We acknowledge
your comment regarding this communication.
Yaur cooperation with us is appreciated.
Sincerely,
Original Signed By:
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James C. Linville, Chief
Projects Branch 3
Division of Reactor Projects
Docket No. 50-354
9809210163 990911
ADOCK 05000354
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Mr. Harold W. Keiser
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Hope Creek Generating Station
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sc w/o cv of Licensee's Response Letter:
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L. Storz, Senior Vice President - Nuclear Operations
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E. Simpson, Senior Vice President - Nuclear Engineering
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E. Salowitz, Director'- Nuclear Business Support
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M. Bezilla, General Manager - Hope Creek Operations
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J. McMahon, Director - QA/ Nuclear Training / Emergency Preparedness
D. Powell, Director - Licensing / Regulation & Fuels
A. C. Tapert, Program Administrator
cc w/cy of Licensee's Letter:
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A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
J. A. Isabella, Manager, Joint Generation
Atlantic Electric
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R. Kankus, Joint Owner Affairs
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Jeffrey J. Keenan, Esquire
Consumer Advocate, Office of Consumer Advocate
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William Conklin, Public Safety Consultant, Lower Alloways Cinek Township
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State of New Jersey
State of Delaware
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Mr. Harold W. Keiser
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Hope ' Creek Generating Station
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Distribution w/coov of Licensee's Response Letter:
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Region i Docket Room (with concurrences)
. Nuclear Safety Information Center (NSIC)
NRC Resident inspector
J. Linville, DRP
S. Barber, DRP
C. O'Daniell, DRP
D. Screnci, PAO
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B. McCabe, OEDO
R. Ennis, Project Manager, NRR
R. Capra, PD1-2, NRR
inspection Program Branch, NRR (IPAS)
R. Correia, NRR
F. Talbot, NRR
DOCDESK
PUBLIC
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DOCUMENT NAME: G:\\ BRANCH 3\\REPLYLTR\\HC9806.RPY
Ts receive a copy of this document, Indicate in the box: 'C' = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
"N* =
No copy -
OFFICE
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NAME
JLinville W
DATE
09/10/98f
09/ /98
~l 09/ /98
09/ /98
09/ /98
OFFICIAL RECORD COPY
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Pubhc Service
Electnc and Gas
Company
Louis F. stor
Pubhc Service Electoc and Gas Company
P.O. Box 236, Hancocks Bridge, FU 08038
609 339-5700
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Senor Vice President Nuclear Operatons
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AUG 181998
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LR-N98376
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United States Nuclear Regulatory Commission
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Document Control Desk
Washington, DC 20555
Gentlemen:
REPLY TO NOTICE OF VIOLATION
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INSPECTION REPORT 354/98-06
HOPE CREEK GENERATING STATION
FACILITY OPERATING LICENSE NPF-57
DOCKET NO. 50-354
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Pursuant to the provisions of 10CFR2.201, Public Service Electric and Gas Company
(PSE&G) hereby submits'a reply to the Notice of Violation (NOV) issued to the Hope
Creek Generating Station in a letter dated July 21,1998.
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The violations contained in Appendix A of the July 21,1998 letter concerned: 1) failure
to sample and analyze diesel fuel oil deliveries for particulate; and 2) incorrectly
changing the design basis of the reactor core isolation cooling system by removing a
timing sequence feature for the RCIC turbine steam line stop valve.
The diesel fuel oil violation resulted in PSE&G requesting enforcement discretion for
Technical Specification 3.8.1.1.b to allow an additional seven days of allowed outage
time for the 'B' Emergency Diesel Generator. This request was to permit draining,
' cleaning and refilling of the 'C' and 'D' Fuel Oil Storage Tanks. The NRC granted the
enforcement discretion in a conference call on May 22,1998 and formalized the
enforcement discretion in a letter dated May 27,1998.
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Document Control Desk
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AUG 18 W
LR-N98376
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You expressed concern regarding design errors; PSE&G is also concerned about this
issue. Engineering Management has taken action to improve the engineering rigor and
precision in the review and development of design modifications. You will find
additional actions PSE&G is taking to address this issue in letter LR-N98344 dated
August 6,1998.
PSE&G also would like to clarify one of the statements in Inspection Report 354/98-06.
In Section IV, Plant Support, subsection R4.1 the inspection report states that the
chemistry department did not properly inform the control room operators of Standby
Liquid Control sample results that were suspected to be inaccurate. Operations
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management confirmed at the exit meeting that this was, in fact, communicated to the
Senior Shift Superintendent and that the control room was aware of the situation when
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The PSE&G response for these violations is contained in Attachment 1 of this letter.
Should you have any questions or comments on this transmittal, do not hesitate to
contact us.
Sincerely,
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Document Control Desk
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LR-N98376
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Mr. H. Miller, Administrator - Region i
U. S. Nuclear Regulatory Commission
'475 Allendals Road
King of Prussia, PA 19406
Mr. R. Ennis, Licensing Project Manager - Hope' Creek
U. S. Nuclear Regulatory Commission
One White Flint North
11555 Rockville Pike
Mail Stop 14E21
Rockville, MD 20852
Mr. S. Pindale (X24)
USNRC Senior Resident inspector- HC
Mr. K. Tosch, Manager IV
Bureau of Nuclear Engineering
P. O. Box 415
Trenton, NJ 08625
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LR-N98344-
Attachment 1
RESPONSE TO NOTICE OF V.lOLATION
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INSPECTION REPORT NO. 50 354/98-06
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HOPE CREEK GENERATING STATION
DOCKET NO. 50-354
A. Diesel Fuel Oil Sampling Violation
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1. Description of the Notice of Violation
Technical Specification 6.8.1 requires, in part, that written procedures shall be
established, implemented, and maintained for applicable activities recommended
in Appendix A of NRC Regulatory Guide 1.33, Revision 2, February 1978.
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AppeMix A of NRC Regulatory Guide 1.33, Revision 2, February 1978 (Section
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10) recommends that chemical control procedures be written to prescribe the
nature and frequency of sampling and analyses.
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. Hope Creek chemistry procedure HC.CH-AP.ZZ-0041 (Q), Hope Creek
Generating Station DieselFuel Oil Testing Program, Revision 2, Section 5.1,
requires that all diesel fuel oil deliveries (via tank truck) will be sampled and
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analyzed for particulates, and results reported by written notification within 14
days of sample receipt to the Hope Creek System Manager and the Fuel Oil
Program Manager.-
Contrary to the above, as of October 1997, chemistry technicians did not sample
and analyze diesel fuel oil deliveries for particulates, and did not report results by
written notification within 14 days of sample receipt to the Hope Creek System
Manager and the Fuel Oil Program Manager.
This is a Severity Level IV violation (Supplement 1).
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PSE&G agrees with the violation.
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LR-N98344
Attachment 1
3. Reason for the Violation
The reason for this violation was personnel error. The Diesel Fuel Oil Testing
Program was incorporated in the Hope Creek License in License Amendment
No.100, dated July 24,1997. Testing new fuel oil for particulate is not required
by the Technical Specification, but it is part of the Diesel Fuel Oil Testing
Program. New fuel was initially tested for particulate; however, testing was
inappropriately discontinued in October 1997 at the direction of the previous
Diesel Fuel Oil Program manager. This person has since left PSE&G.
4. Corrective Steos that Have Been Taken and Results Achieved
a) Hope Creek System Engineering has assumed responsibility for management
of the Hope Creek Diesel Fuel Oil Testing program which includes data
evaluation and trending.
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b) Sampling of new fuel oil for particulates prior to addition to a Fuel Oil Storage
Tank recommenced May 20,1998.
c) Procedure HC.CH-AP.ZZ-0041 (O) has been revised to verbally report results
of samples of new fuel oil to the Operations Shift Superintendent prior to
offloading of diesel fuel oil to the storage tanks.
5. Corrective Steps that Will Be Taken to Avoid Further Violations
No additional conective actions are planned.
6. Date When Full Compliance Will be Achieved
Hope Creek achieved full compliance on May 20,1998 when new testing of new
fuel was again commenced before addition to a Fuel Oil Storage Tank.
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LR-N98344
Attachment 1
B. Criterion XI Violation
1. Description of the Notice of Violation
10 CFR Part 50, Appendix B, Criterion lli (Design Control), requires, in part, that
measures shall be established to assure that applicable regulatory requirements
and the design bases are correctly translated into specifications, drawings,
procedures, and instructions. The design control measures shall provide for
verifying or checking the adequacy of design, such as by the performance of
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design reviews, by the use of alternate or simplified calculational methods, or by
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the performance of a suitable testing program.
Contrary to the above, during the RFO7 refueling outage (Fall - Winter 1997),
design change package (DCP) 4EC-3638 incorrectly changed the design basis
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of the reactor core isolation cooling (RCIC) system by removing a timing
sequence feature for the RCIC turbine steam line stop valve (F045). In addition,
a design review of DCP 4EC-3638 and post-modification testing for DCP 4EC-
3638 failed to identify the design error.
This is a Severity Level IV violation (Supplement I).
2. Repiv to Notice of Violation
PSE&G agrees with the violation.
3. Reason for the Violation
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The reason for this violation is personnel error in that the engineers did not
recognize that the 10-second timing sequence feature for the RCIC turbine
steam line stop valve,1FCHV-F045 RCIC, was impacted. The Design Change
deleted a test switch for the 1FCHV-F045 RCIC valve but failed to remove the
seal-in portion of the test circuit. This was missed during the DCP design and
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review. Testing the throttle function of this valve was not part of the DCP testing
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and therefore not found during the post modification testing.
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4. Corrective Steos that Have Been Taken and Results Achieved
a) A review was performed of the remaining control circuits for MOVs for Salem
and Hope Creek that were similarly modified. This review did not identify any
tether problems.
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LR-N98344
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Attachment 1
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b) The installation of DCP 4EC-3638 has been corrected and the function of the
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timing sequence feature for Valve 1FCHV-F045 was reinstated Additionally,
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the design package for DCP 4EC-3638 was corrected.
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S. Corrective Steos that Will Be Taken to Avoid Further Violations
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No additional corrective actions are planned.
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6. Date When Full Compliance Will be Achieved
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Hope Creek achieved full compliance on June 19,1998 when the 10-second
timing sequence feature for Valve 1FCHV-F045 was corrected to agree with the
design of the reactor core isolation cooling (RCIC) system.
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