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Forwards Insp Rept 50-354/97-10 on 971126-980103 & Nov. Noted Several Instances of Inadequate Development or Implementation of TS-required Procedures That Resulted in Unplanned Challenges to Plant Operators & Equipmemt
	ML20199L443
Person / Time
Site:	Hope Creek
Issue date:	02/03/1998
From:	Hehl C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Keiser H; Public Service Enterprise Group
Shared Package
ML20199L447	List: IR 05000354/1997010; ML20199L443; ML20199L479;
References
	50-354-97-10, EA-98-037, EA-98-37, NUDOCS 9802090203
	Download: ML20199L443 (4)
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February 3,1998

EA 98-037,

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1 Mr. Harold W. Keiser

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Executive Vice President -

Nuclear Business Unit:

Public Service Electric and Gas Company:

Post Office Box 236 :

- Hancocks Bridge, NJ 08038 <

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' SUBJECT:

NRC INTEGRATED INSPECTION REPORT 50-354/9710

NOT!CE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION

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IDear Mr. Keiser:

' On January 3,1998, the NRC completed an inspection at your Hope Creek reactor facility.

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1The enclosed report presents.the results of that insp6ction.

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Throughout the seven week inspection period, your conduct of ' activities at the Hope Creek:

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facility was generally characterized by safety-conscious operations, and appropriate -

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engineering and plant support practices.- Good quality assurance department oversight of,

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station activities was evident. Aggressive efforts to reduce the backlogs of temporary

_ modifications'and operability determinations were effective. Though several equipmenti

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odeficiencies and delays _ were encountered, we noted good control and cc.iservative :

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1 operations during the reactor start up and power ascension following the refueling outage.-

Based on our observations'of you serformance during the refueling ' outage and plant start t

(up, the NRC has determined that violations of NRC requirements occurred.;These

7 violations are cited in the enclosed Notice of Violation (Notice) and the circumstances

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i surrounding them are described in detsil in the subject inspection _ report < We are

concerned that corrective actions implemented in response to prior problems in both -

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1 maintenance and engineering activities have been iasc than fully effective. Specifically, we -

noted 'several instaraos of inadequate development'or implementation of technical --

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specification-required procedures that resulted in unplanned challenges to plant operators

for important to-safety equipment. Though some of these issues were identified during

system testing, they nonetheless resulted from personnel errors and ir adequate -

r supervisory. reviews and oversight. These causes appear repetitive of those identified for

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numerous previous events, questioning the effectiveness of prior corrective ' action

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initiatives. An NRC-identified error in a test procedure which implements a technical

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specification ~ surveillance requirement for electrical protection' assemblies was of concern

since this procedure was established after your technical specification surveillance .

Improvement program was completed. This finding raises qasstions as to the

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effectiveness of your process for implementing Technical Specification changes.

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. Mr. Harold W. Keiser;

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.You are required to respond to this letter and sitooid foliow the instructions specified in the -

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- enciesed Notice when preparing your response. The NRC will use ycur response, in part,

to determine whether further enforcement action is necessary to ensure compliance with-

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- - regulatory requirements.

Additionally, the December 5,1997 reactor core isolation cooling system (RCIC) system

failure resulted from ineffective corrective actions following your 1996 RCIC overspeed ~

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- event.: Failures of Terry turbine governor valves has bu.n the subject of several industryi

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operating experience information documents as well as generic NRC communications.-

-In contrast, the NRC reviewed your self identified issue involving the faileo inservico -

surveillance test of the reactor building to-torus vacuum breakt.r instrument air check

valves TN3 issue ste.mmed from an inadequate initial design review, and was an apparent

violation of NRC requirements which was considered for escalated enfor:.ement and

+ lect to a civil penalty. - However, after consultation with the Director, Office of

i Avcement, I have been authorized to not issue a Notics of Violation and_not propose a

y.1 penalty in this case in accoidance with the provisions provided in Section Vll.B.3 of

.the NRC's Enforcement Policy. This decision was made after consideration that: (1) the

Evlolatiottwas identified by your_ staff's good questioning attitudes during a voluntary -

. Initiatives; (2) corrective actions, both taken and planned, were comprehensive and timely;

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- (3) the condition's were subtle in nature and not likely to be disclosod through routine 1

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surveijance or quality assurance activities; arxl (4) the violations are not reasonably linked

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to current performance. The exercise of discretion acknowledges your good effort to:

identify and correct subtle violations, that would not be identified by routinc efforts, before

- the degraded safety systems are called upon.

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,

' Ori inal Signed By:

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Charles W. Hehl, Director

Division _of Reactor Projects

Docket No.: 50-354

License No: NPF-57

- Enclosures:

1.

Notice of Violation

2.

Inspection Report 50-354/9710

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Mri Harold W. Keiser-

cc w/ encl: .

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L Storz, Senior Vice President - Nuclear Operations

E, Simpson, Senior Vice President - Nuclear Eng,;neering

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E. Salowitz, Director - Nuclear Business Support

A. F. Kirby, Ill,, External Operations Nuclear, Delmarva Power & Light Co.--

!J. A. Isabella, Manager, Joint Generatien

' Atlantic Eiectric'

M. Berilla, General Manager - Hope Creek Operations

J. McMahon, Director - QA/ Nuclear Training / Emergency Preparedness

D. Powell, Director - Licensing / Regulation & Fuels

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

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State of New Jersey-

State of Delaware -

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Mr. Harold W. Keiser

' Distribution w/ encl:

Region i Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

. NRC Resident inspector

PUBLIC

H. Miller, RA/W Axelson, DRA

J. Linville, DRP

S. Barber, ORP

L. Harrison, DRP.

C. O'Daniell, DRP

D. Holody, EO, Rl

Distribution w/ encl: (Via E Mall)

B. McCabe, OEDO

J Stolz, PDI 2, NRR

- B. Mozafari, Project Manager, NRR

R. Correia, NRR

F. Talbot, NRR

inspection Program Branch, NRR (IPAS)

DOCDESK

R. Zimmerman, NRR

J. Lieberman, OE

.-J. Goldberg, OGC

DOCUMENT NAME: G:\\ BRANCH 3\\lR9710.HC

Ta receive a copy of this document,Jndicato in the box: 'C' = Cocy without attachment / enclosure T = Copy with attachment / enclosure "N" = No copy

OFFICE

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DATE ~.

01/29/98 )

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01/ /98

OFFICIAL RECORD COPY

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ML20199L443

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