ML20215F931
| ML20215F931 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/29/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NLR-N86134, NUDOCS 8610160423 | |
| Download: ML20215F931 (3) | |
Text
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o es Public Service Electric and Gas Cornpany Corbin A. McNeill, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609339-4800 Vice President -
Nuclear September 29, 1986 NLR-N86134 h-U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Dr. Thomas E. Murley, Administrator Office of Inspection and Enforcement Gentlemen:
NRC INSPECTION REPORT #86-35 DOCKET NO. 50-354 HOPE CREEK GENERATING STATION Public Service Electric and Gas Company (PSE&G) is in receipt of your letter dated August 26, 1986, which transmitted a Notice of Violation concerning a failure to comply with the requirements of 10CFR50 Appendix B, Criterion V and Criterion XI.
Pursuant to the provisions of 10CFR2.201, our responses to the Notice of Violation are provided in Attachment 1.
This submittal is late, as agreed to by Mr.
L. Wink of your staf f.
Sincerely,
-7 t
Attachmen&.
C Mr. James M. Taylor, Director Office of Inspection and Enforcement Washington, DC 20555 NRC Resident Inspector P.O.
Box 241 Hancocks Bridge, NJ 08038 0149423 860929
.M VCK.0500035a G
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ATTACHMENT 1 10 CFR 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NUMBER 50-354/86-35 ITEM A Your letter dated August 26, 1986 identified two Violations.
One of the Violations cited a failure to comply with the requirements of 10 CFR 50, Appendix B, Criterion V and Technical Specification 6.8.1.a (through its reference to Regulatory Guide 1.33, Re v.
2, and ANSI N18.7-1976, Section 5.3) that " Activities affecting quality shall be prescribed by documented procedures appropriate to the circumstances."
As described in the Notice of Violation, the inspector noted, prior to implementing step 5.3.1 of power ascention tes t TE-SU.BD-142, that the step was not appropriate to the circumstances, in that it would have resulted in the termination of reactor core isolation cooling (RCIC) flow to the reactor vessel.
1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE VIOLATION.
The Notice of Violation and inspection report allude to the postulated detrimental effects of a termination of RCIC flow to the reactor vessel during performance of this test procedure.
Contrary to this, the purpose of the test was to vary RCIC flow to the reactor vessel... including the reduction of flow from near rated flow to a very low flow condition.
The reduction to a low (or zero) flow value was a planned evolution for which adequate preparations were made to preclude both equipment damage and low reactor water level. A loss of flow to the reactor vessel during the referenced step in the procedure would have not satisfied the test objective in that the low flow data point would not have been obtained.
2.
THE ROOT CAUSE OF THE INCIDENT WAS A TEST PROCEDURE INADEOUACY WHEREIN A LOW RCIC TURBINE SPEED WAS SPECIFIED.
INSTEAD OF A LOW PUMP FLOW VALUE.
3.
IMMEDIATE CORRECTIVE ACTIONS:
As noted in the inspection report, the procedural step was modified to incorporate a pump flow value instead of a turbine speed value prior to performance of the step.
Additionally, all other RCIC and HPCI test procedures were reviewed for this type of problem and are being changed, as necessary, prior to performance of the af fected procedures.
4.
WE ARE IN PULL COMPLIANCE.
_1_
e, ATTACHMENT 1 (CONT'D)
ITEM B Your letter also identified a second violation concerning f ailure to comply with the requirements of 10 CFR 50, Appendix B, Criterion XI, which states that " Testing be performed in accordance with written test procedures," and further requires that " Test results shall be evaluated to assure that test requirements have been satisfied."
As described in the Notice of Violation, calculations required by step 2.15 of power ascension test TE-SU.ZZ-041 were not performed in accordance with the equations provided in the procedure and a review of the test results later f ailed to identify the error.
1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE VIOLATION.
2.
THE ROOT CAUSE OF THE VIOLATION WAS PERSONNEL ERROR WHEREIN A MATHEMATICAL ERROR WAS MADE DURING THE PERFORMANCE OF THE CALCULATIONS IN STEP 2.15 OF TEST PROCEDURE, TE-SU.ZZ-041.
3.
IMMEDIATE CORRECTIVE ACTIONS:
a)
The Power Ascension Manager counselled all test engineers to 1) provide greater attention to detailed analysis-type steps (such as calculations) and 2) take the necessary time to make periodic overview evaluations of detailed steps.
b)
The number of senior independent review personnel was increased to enhance the quality of the independent review process.
4.
WE ARE IN FULL COMPLIANCE NOW.
RECEIVED-REGION 1 1987 OCT -8 A!4 & 37 tu e
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