ML20196J653

Notice of Violation from Insp on 970202 & 0317.Violation Noted:In Apr 1994,licensee Made Changes to Facility That Involved USQ Without Prior Commission Approval

ML20196J653
Person / Time
Site:	Hope Creek
Issue date:	10/20/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20196J644	List: ML20196J637 ML20196J653
References
50-354-97-01, 50-354-97-1, EA-97-160, NUDOCS 9812100163
Download: ML20196J653 (2)

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ENCLOSURE NOTICE OF VIOLATION l

Public Service Electric and Gas Company Docket No. 50-354 Hope Creek License No. NPF-57 EA 97-160 During an NRCinspection conducted between February 2 and March 17,1997,for which exit meetings were held on March 27,1997 and June 26,1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is set forth below:

10 CFR 50.59(a)(1) states, in part, that the holder of a license may make changes in i

' the facility as described in the safety analysis report, without prior Commission approval, unless the proposed changes involve changes in the Technical Specifications

, (TS) incorporated in the license, or an unreviewed safety question (USQ). 10 CFR 50.59(a)(2) states,in part, that an unreviewed safety question shall be deemed to exist if a possibility for an accident or malfunction of a different type than any evaluated  !

previously in the safety analysis report may be created.10 CFR 50.59(b)(1) requires, in part, that the records of changes to the facility must include a written safety I evaluation.

Contrary to the above, in April 1994, the licensee made changes to the facility as i

described in sections 5.4.7.1 and 6.3 of the Updated Final Safety Analysis Report (UFSAR) that involved a USQ without prior Commission approval. Specifically, a crosstie line and associated valving were installed between residual heat removal (RHR) l subsystems A and C. The written safety evaluations for this change, described in Design Change Package (DCP) 4EC-3411, were inadequate in that:

i 1. The safety evaluations did not identify that installation of the crosstie involved a USQ. The change involved a USQ because the loss of independence of the low pressure coolant injection (LPCI) subsystems during a loss of coolant

! accident, which could result from a valve alignment error in which the crosstie I isolation valves were left open, created the possibility of a malfunction of a different type than any previously evaluated in the UFSAR. As a result, the licensee made a change to the facility as described in the UFSAR that involved a USQ, without prior Commission approval; and

2. The safety evaluations for the design change failed to identify the need to l include the crosstie isolation valves in the monthly emergency core cooling i

system (ECCS) flowpath verification required by TS. As a result, from April 7, 1994, until December 22,1995, the crosstie isolation valves, which were not

, locked closed, were not verified to be in the correct position at least once per

31 days as required by TS 4.5.1.a.1.b. (01013)

This is a Severity Level lil violation (Supplement 1).

4 9812100163 971020 gDR ADOCK 05000354 PDR

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Enclosure 2

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l Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas C0mpany 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 l 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 the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achisved, (3) the corrective steps that will be taken to avoid further violations, and (4) the i

i date when full compliance will be achieved. Your response may reference orinclude 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. I Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, 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 withhofding of such material, you mM11 specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted 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 provide the level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this / day of October 1997 L

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