ML20237A734

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Responds to NRC Re Violations Noted in Insp Rept 50-354/98-80.Corrective actions:re-evaluated Results of Nov 1991 1DD447 Battery Capacity Performance Test & Concluded That 1DD447 Satisfied TS Surveillance Requirements
ML20237A734
Person / Time
Site: Hope Creek 
Issue date: 08/06/1998
From: Eric Simpson
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-354-98-80, LR-N98344, NUDOCS 9808170058
Download: ML20237A734 (23)
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Electne ard Gas Cornpany E. C. simpson Pubhc Service Elecinc and Gas Company PO. Box 230. Hancocks Bndge NJ 08038 609-339-1700 Sernor V ce President Nuclear Engsnwing l

AUG 061998 LR-N98344 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT 354/98-80 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 l

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 June 10,1998.

l The PSE&G response for this violation is contained in Attachmer.t 1 of this letter.

PSE&G requested a 30 day extension to submit this response through the Hope Creek Senior Resident inspector, Mr. Steve Pindale, which was granted by NRC Region I management on June 19,1998.

The violations contained in the inspection report are being used in self-assessments by PSE&G to continue Hope Creek's performance improvement. The deficiencies noted by the NRC have been comprehensively evaluated and Hope Creek's programs are being enhanced where required to improve station performance. Specifically, Engineering management will continue to focus on the areas of engineering rigor and precision in the review and development of design basis information. The individual l

examples cited in the violations have been corrected or action plans have been

}l established in the Corrective Action Program to address those issues.

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In addition, PSE&G notes that the conclusions presented by the NRC in this inspection l

report regarding design basis conformance are consistent and in line with the Dg' 10CFR50.54(f) reviews of Hope Creek systems presently being conducted. This inspection report will be used to focus PSE&G's emphasis in the continuing design basis reviews of Hope Creek. As stated in the response to these violations, i

9858190088 980006 PDR ADOCK 05000354 G

PDR

@ Pmted r>n Recycted Paper

Document Control Desk AUG 061998 LR-N98344 PSE&G will share the details of the inspection report findings and our corrective actions with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) training to improve Engineering performance.

If you have any questions or comments on this transmittal, please contact James Priest at (609) 339 5434.

Sincerel,

C Mr. H. Miller, Administrator - Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One Wnite 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 l

- Atta:hm nt ATTACHMENT RESPONSE TO NOTICE OF VIOLATION I

l

'lNSPECTION REPORT NO. 50-354/98-80

. HOPE CREEK GENERATING STATION DOCKET NO. 50-354 l

A.10CFR50.59 Violation l

1. Description of the Notice of Violation i

10 CFR 50.59, paragraph (b), states, in part, that licensees "shall maintain l

records of changes... to the extent that these changes constitute changes to in l

the facility as described in the safety analysis report.... These records must L

include a written safety evaluation which provides the bases for the l

l determination that the change does not involve an unreviewed safety question."

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i Section 3.5.1.1.3 of the UFSAR states " Equipment and components installed in i

safety-related plant areas outside the primary containment are designed and l

installed so that they do not present gravitational missile hazard to safety-related structures-systems and components during or after a SSE.... Non-permanently i

installed equipment is either removed from the safety-related areas or secured in place before reactor operation to ensure that it does not become dislodged and present a missile hazard.

l Contrary to the above, for an indeterminate time, before March 19,1998, the

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licensee non-permanently installed temperature and humidity recorders in the l

main control room and in the remote shut-down panel room, two safety-related I

areas outside the primary containment. They did not remove them from the areas or secure them in place before reactor operation, nor did they prepare a l

written safety evaluation which provided the bases for their conclusion that the L

instruments did not present a missile hazard to safety-related structures, i

l systems and components in the rooms and that the facility change did not I

involve an unreviewed safety question.

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

2. Reply to Notice of Violation PSERG agrees with the violation.

Page 1 of 1 i

-e e

e Attachm:nt LR-N98344

3. Reason for the Violation PSE&G attributes the cause of the failure to perform a 10CFR50.59 safety evaluation for the installation of the hygrothermographs to procedure non-compliance. The hygrothermographs (M&TE) were installed for an extended period of time and were not properly controlled nor removed in accordance with plant procedures NC.NA-AP ZZ-0022, " Measuring and Test Equipment, Lifting and Rigging, and Tool Control' or NC.NA-AP.ZZ-0083, " Transient Loads." The lack of a questioning attitude by station personnel concerning the control of this installed M&TE resulted in this condition existing for an extended period of time.
4. Corrective Steps that Have Been Taken and Results Achieved The subject M&TE was removed from the control room and remote shutdown panel room.
5. Corrective Steps that Will Be Taken to Avoid Further Violations
a. An assessment of NC.NA-AP.ZZ-0083," Transient Loads," and NC.NA-AP.ZZ-0022, " Measuring and Test Equipment, Lifting and Rigging, and Tool Control," procedure requirements will be performed to determine if enhancements are necessary to improve the seismic hazards evaluation and control of temporary equipment. In addition, the assessment will also evaluate the control room configuration to ensure that potential seismic hazards are appropriately controlled. Deficiencies will be identified and resolved using the Corrective Action Program. This assessment will be completed by August 30,1998.

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b. The details of this event will be rolled out to operating shift crews and controls technicians to re-enforce the requirements for the control of M&TE and temporary equipment. The requirements of NC.NA-AP.ZZ-0083 pertaining to the evaluation and restraint of potential seismic hazards will also be reviewed. The rollout will be completed by August 30,1998.
c. The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineer:ng Support Personnel (ESP) training to emphasize the importance of controlling temporary equipment and evaluating potential seismic hazards. This training will be completed by December 31,1998.

6.

Date When Full Compliance Will be Achieved -

Hope Creek achieved full compliance when the subject M&TE was removed from the control room and remote shutdown panel room.

Page 2 of 21 I

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AttachmInt.

LR-N98344 B. Criterion XI Violation

1. Description of the Notice of Violation 10 CFR 50, Appendix B, Criterion XI, " Test Control," requires, in part: "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include... operatior.al tests during nuclear power plant operation.... Test results shall be documented and evaluated to assure that test requirements have been satisfied."

Contrary to the above, on and before March 19,1998, the licensee did not establish a test program to demonstrate that structures, systems, and components would perform satisfactorily in service, or tests were not conducted in accordance with test procedures and the results were not evaluated to assure that the test requirements had been satisfied, as listed in the following examples:

1.

In November 1991, the performance capacity test results for battery.

1DD447 were not corrected for the actual test temperature, in accordance with the applicable surveillance test procedure, and the test results were not properly evaluated to assure that the test requirements had been satisfied.

2.

IEEE Standard 450-1995, to which the Hope Creek UFSAR states conformance, specifies that a decrease in battery capacity of more than 10% from the average of the previous tests should result in the licensee's

. increasing the test frequency from five years to 18 months.

In December 1995, test results showed that the capacity of battery 1DD447 had dropped by 21.6% from the previous test. Despite the large drop in capacity, the licensee failed to evaluate the test results, calculate the average capacity drop, and determine whether the battery test frequency should be increased to 18 months.

J 3.

Items b and e of UFSAR Table 9.4-6 state that: (b) *For systems that must perform a safety-related function, periodic inservice testing of fans, L

valves, controls, and instrumentation in the systems is performed. Motor-operated valves and dampers are tested by opening and closing the valve or damper. Temperature, differential pressure readings, and flow capacity are recorded"; and (e) " Standby units are tested at periodic intervals to verify the operation of essential features. Periodic tests of the actuation Page 3 of 21

Attachmont LR-N98344 circuitry and the system components are conducted during normal operation."

Prior to March 19,1998, the licensee had not established a test program to demonstrate the control equipment room supply and the control area battery exhaust systems would perform satisfactorily in service in that they had not established a program for the periodic inservice testing the systems components, as described under item (b) of Table 9.4-6 of the UFSAR. Instead, the licensee only checked the functionality ofindividual components under the preventive maintenance program. In addition, the licensee did not periodically test the automatic standby features of these systems, as specified in item (e) of the same UFSAR table.

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

2. Reply to Notice of Violation PSE&G agrees with the violation.

EXAMPLE 1

3. Reason for the Violation PSE&G has attributed the cause of the inadequate 1DD447 battery performance test to deficient surveillance procedures. The surveillance test procedure provided no guidance on conducting a battery performance capacity test following an interruption in the test. As a result, the wrong electrolyte temperature was used to determine battery capacity.
4. Corrective Steps that Have Been Taken and Results Achieved The results of the November 1991,1DD447 battery capacity performance test

- were re-evaluated to account for the control power interruption experienced during the test. The evaluation concluded that the 1DD447 satisfied the Technical Specification surveillance requirements.

i 5. Corrective Steps that Will Be Taken to Avoid Further Violations 1

l The battery capacity performance surveillance test procedure will be revised to include guidance on conducting a battery performance capacity test following an interruption in the test. This procedure revision will be completed by October 30, i

1998 I

6. Date When Full Compliance Will be Achieved I

l L

l Page 4 of 21

Attachm:nt LR-N98344

. Full compliance was achieved by July 27,1998, with the completion of the correct evaluation of the November 1991, battery capacity performance test.

l EXAMPLE 2

3. Reason for the Violation PSE&G has attributed the cause of the failure to increase the frequency of the l

1DD447 battery capacity performance test to inadequate surveillance j

procedures. The surveillance test procedure provided no guidance or criteria to determine if a test frequency change was required.

4. Corrective Steps that Have Been Taken and Results Achieved The average of the previous 1DD447 battery caparity tests was recalculated to include the results of the pre-operational acceptance capacity test. The calculation resulted in an actual battery capacity drop of less that 10% when performing the December 1995, capacity test. Therefore, a change in test l

frequency was determined to be unnecessary.

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5. Corrective Steps that Will Be Taken to Avoid Further Violations The battery capacity performance surveillance test procedure will be revised to include criteria to calculate and record the average of the battery capacity tests, and determine if a change in test frequency is required. This procedure revision will be completed by October 30,1998.
6. Date When Full Compliance Will be Achieved i

1 Full compliance was achieved by March 19,1998, with the completion of the correct evaluation of the December 1995, battery capacity performance test.

1 EXAMPLE 3

. 3. Reason for the Violation sThe cause of the failure to test the control equipment room supply and the i

control area battery exhaust systems, or periodically test the automatic standby features of these systems, was attributed to an over-reliance on Technical j

Specification surveillance requirements for Auxiliary Building ventilation and 1

Control Room Emergency Filtration systems to satisfy UFSAR testing requirements, i

Page 5 of 21

___ _ _-____-__:__ _ _ ___ _-_=_-

Atta:hm:nt LR-N98344

4. Corrective Steps that Have Been Taken and Results Achieved
a. The Corrective Action Program has been used to evaluate the testing requirements for the control equipment room supply and the control area battery exhaust systems. As a result, the need to establish preventative maintenance type tasks to document pressure and flow capacity for these systems and verify the auto-start capability of these systems, in conformance with the UFSAR, was identified.
b. The periodic monitoring of system operation and functionality testing has continued to demonstrate system performance.
5. Corrective Steps that Will Be Taken to Avoid Further Violations
a. The tasks required for proper testing of the control equipment room supply and the control area battery exhaust systems will be generated by September 30,1998.
b. A testing program for other risk significant systems will be developed to appropriately address 10CFR50, Appendix B, Criterion XI requirements. The program will be established by July 31,1999.
6. Date When Full Compliance Will be Achieved Full compliance will be achieved by September 30,1998, when the tasks required for proper testing of the control equipment room supply and the control area battery exhaust systems are scheduled in accordance with the work week scheduling program.

C. Criterion lli Violation

1. Description of the Notice of Violation 10 CFR 50, Appendix B, Criterion Ill, " Design Control," requires, in pM, that:

' Measures be established to assure that applicable regulatory requirements and the design basis... for structures, systems, and components... are correctly translated into specifications, drawings, procedures, and instructions.... The design control measures shall provide for verifying or checking the adequacy of design..."

Contrary to the above, on and before March 19,1998, the design basis for structures, systems, and components were not correctly translated in specifications, drawings, procedures, and instructions and the design control

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Attachm:nt LR-N98344 measures did not provide for verifying or checking the adequacy of the design, as identified in the following examples:

1.

In April 1991, the design basis for the thermal overload devices associated with the RCIC and HPCI loads powered from the de motor control center was not correctly translated into design specifications, in that the licensee used as a design input for the reactor building ambient temperature 104*F rather than 148 F, as specified in the calculations of record.

2.

. In April 1991, the design basis for the 20 kVA safety-related inverters was not correctly translated in inverters protective device design specifications in that the licensee failed to consider the inverters minimum voltage and efficiency in the setting of the protective devices.

3.

Items 5.f. and 6.f. in Table 3.3.2-2 of the Hope Creek technical specifications state that signals are generated to isolate the reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) turbine steam supply, if the difference between the room exhaust and supply air temperatures exceeds 70 F. The table also specifies an allowable

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differential temperature of 80*F.

I On March 12,1996, the licensee approved a design change to move the temperature sensors in the supply air ducts of the RCIC and HPCI rooms downstream of in-duct heaters. However, the design control measures were inadequate in that the verification process of the design change failed to check the adequacy of the revised design and its impact on the TS-specified setpoints.

4.

Section 8.3.2.1.2.2 of the UFSAR states, "The initial battery capacity is 25% greater than required. This margin is consistent with the battery replacement criterion.. in IEEE 450-1975 and is in addition to a 5 to 10 percent margin allowed for load growth and/or for less than optimum operating condition of the battery."

On August 27,1997, the design control measures were not in place for the design margin of the battery in that the licensee issued a UFSAR change notice reducing the minimum battery design margin stated in the UFSAR from 5% to 0% without verifying the adequacy of the battery design under less than optimum operating conditions.

5.

In May 1985, the design control measures were not in place to assure that the design basis for the heating and ventilation (HVAC) system of the control room and the safety-related panel room was correctly translated in l

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Page 7 of 21 I

Attachm:nt LR-N98344 surveillance procedures, in that the chilled water outlet temperature for these areas was set to be maintained between 43 and 47 F and between 45 and 49*F, respectively. The chilled water temperature limits specified in the FSAR and in the HVAC design calculations were 45 and 47 F, respectively.-

6.

In March 1996, the licensee approved a design change to install a RHR cross-over pipe in the "D" RHR room. However, the design control measures were inadequate, in that the verification process of the design change failed to ensure, prior to the installation of the design modification, that the placement of an 18-inch RHR pipe in close proximity of the ECCS room cooler air inlet did not block and reduce the cooler air flow rates and impact the room cooler performance.

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

2. Reply to Notice of Violation PSE&G agrees with the violation.

EXAMPLE 1

3. Reason for the Violation The cause of the failure to utilize post-accident Reactor Building temperatures for the selection and design of the RCIC and HPCI thermal overload devices was attributed to personnel error during the design of Hope Creek. The apparent cause of this error was attributed to incorrect assumptions on the bypass status of the thermal overload devices for RCIC and HPCl 250 Vdc systems in post accident conditions.
4. - Corrective Steps that Have Been Taken and Results Achieved
a. The Corrective Action Program is being utilized to update and change Engineering calculation E-7 9 to reflect the correct temperatures for the RCIC 3

and HPCI 250 Vdc thermal overload protection devices, in addition, in

. response to NRC Information Notice 92-18, a design change was L

implemented that removed the thermal overload protection devices from all of l

the RCIC motor-operated valves and one of the HPCI motor-operated valves.

l Page 8 of 21 i

a j

Attachm:nt-LR-N98344

5. Corrective Steps that Will Be Taken to Avoid Further Violations Revisions to Engineering calculation E-7.9 that are required to resolve this issue will be made upon NRC approval of changes to the Technical Specification battery minimum electrolyte temperature discussed in Example 4 of this violation.
6. Date When Full Compliance Will be Achieved Hope Creek will achieve full compliance when the required revisions to Engineering calculation E-7.9 are completed. This will be accomplished within 60 days following NRC approval of the Technical Specification changes discussed in Section 5 above.

EXAMPLE 2

3. Reason for the Violation The cause of the failure to incorporate design basis information on rninimum voltage and efficiency for the setting of the protective devices for the 20 kVA safety-related inverters was attributed to a less than adequate review of design basis material. As a result, the deviations from the full load current calculation E-7.9 were not adequately documented.
4. Corrective Steps that Have Been Taken and Results Achieved l

The current settings of the 20 kVA inverter protective devices were evaluated.

As a result of this evaluation, Engineering concluded that current settings are adequate and are consistent with the design basis information contained in Engineering calculation E-4.1. The information contained in Engineering i

calculation E-7.9, which was developed during the original plant design using full l

load current calculations, was determined to be inappropriate for use in I

establishing the 20 kVA inverter protective device settings.

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5. Corrective Steps that Will Be Taken to Avoid Further Violations I

l Revisions to Engineering calculation E-7.9 that are required to resolve this issue will be made upon NRC approval of changes to the Technical Specification i

battery minimum electrolyte temperature discussed in Example 4 of this violation.

6. Date When Full Compliance Will be Achieved Hope Creek will achieve full compliance when the required revisions to Engineering calculation E-7.9 are completed. This will be accomplished within Page 9 of 21

Atta:hmsnt '

LR-N98344 60 days following NRC approval of the Technical Specification changes discussed in Section 5 above.

- EXAMPLE 3 -

3. Reason for the Violation The cause of the less than adequate justification of the HPCI and RCIC room temperature sensor relocation was attributed to personnel error. Although the changes and their impact on Technical Specification setpoints were appropriately assessed, documentation of licensing and design basis evaluations provided in the 10CFR50.59 applicability'/ review was only implicitly discussed and not explicitly justified.
4. Corrective Steps that Have Been Taken and Results Achieved Engineering has re-reviewed the 10CFR50.59 applicability review performed for the HPCI and RCIC temperature sensor relocations. As a result of this review, Engineering concluded that the applicability review adequately justified the temperature sensor relocation.
5. Corrective Steps that Will Be Taken to Avoid Further Violations
a. Procedures controlling design change evaluations will be enhanced, as l

appropriate, to require documentation of design and licensing basis information assessed in the design change review. The procedure revisions will be completed by April 30,1999,

b. The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) training to improve Engineering performance. This training will be completed by December 31,1998.

'6. Date When Full Compliance Will be Achieved Hope Creek is in full compliance.

EXAMPLE 4 L

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3. Reason for the Violation p

.The cause of the failure to adequately verify the adequacy of Class-1E battery design under less than optimum operating conditions was attributed to personnel error. A less that adequate review of the Class-1E battery licensing basis i

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Page 10 of 21 p

4 AttachmInt LR-N98344 information resuud in the inadequate 10CFR50.59 safety evaluation being performed for the UFSAR change.

4. Corrective Steps _that Have Been Taken and Results Achieved j

j

a. The Corrective Action Program was used to document that the Class-1E batteries have sufficient margin to accommodate less than optimum operating i

conditions.

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b. Since the time of the battery margin reduction, a 10CFR50.59 Safety l

Evaluation Independent Review Team (SEIRT) was instituted to provide additional and independent oversight and review of Engineering-related 10CFR50.59 safety evaluations. Management will continue to monitor 10CFR50.59 performance on an ongoing basis.

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5. Corrective Steps that Will Be Taken to Avoid Further Violations The licensing basis for the Class-1E batteries will be revised to provide appropriate allocation of margin. This revision willinclude the submittal of a 1

Hope Creek License Chave Request (LCR) to increase minimum battery l

electrolyte temperature. 'i his LCR will be submitted to the NRC by October 31, 1998.-

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6. Date When Full Compliance Will be Achieved Hope Creek will achieve compliance when the licensing basis for the Class-1E batteries are revised to provide appropriate allocation of margin. To support this 4

licensing basis revision, a Hope Creek License Change Request (LCR) to increase minimum battery electrolyte temperature, which will provide ample battery margin to accommodate less than optimum operating conditions, will be submitted to the NRC by October 31,1998.

EXAMPLE 5

3. Reason for the Violation i

The cause of the inconsistency between the chilled water system procedural setpoint requirements and chilled water system settings assumed in the Hope i

Creek licensing and design bases was attributed to a failure to include j

instrument inaccuracy into the design basis calculations. As a result, the chined i

water system operating point did not correspond to the operating temperature assumed in the UFSAR.

i Page 11 of 21 L_-_____-____.

Attachm:nt LR-N98344 l

l 4 Corrective Steps that Have Been Taken and Results Achieved

a. The operation of the chilled water system was reviewed against chilled water system design basis information. Engineering has concluded that the current l

. chilled water system setpoints will not adversely impact operation of any i

chilled water support or supported system and changes to the chilled water system design basis information were implemented.

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b. As part of Hope Creek's development of changes to Hope Creek's Ultimate Heat Sink temperature limits, the Station Service Water System, the Safety Auxiliaries Cooling System, the Emergency Diesel Generators, HVAC and Filtration, Recirculation and Ventilation System have been reviewed to ensure that instrument inaccuracy is appropriately accounted for in design calculations. The Corrective Action Program is being used to track any required revisions to design basis documents as a result of these reviews.
5. Corrective Steps that Will Be Taken to Avoid Further Violations No additional corrective actions are planned.
6. Date When Full Compliance Will be Achieved Hope Creek is in full compliance.

EXAMPLE 6

3. Reason for the Violation The cause of the less than adequate justification of the RHR cross-tie piping installation was attributed to personnel error. A less than adequate review and assessment of the design change and its impact on ECCS room cooler operation J

resulted in an inadequate basis for acceptability of the RHR cross tie pipe

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installation in the 10CFR50.59 safety evaluation justification.

4. Corrective Steps that Have Been Taken and Results Achieved Engineering has evaluated the current installation of the RHR cross-tie piping and its impact on ECCS room cooler operation. Using the Corrective Action Program, Engineering has documented that the current installation of the RHR cross-tie piping is adequate and does not adversely impact operability of the ECCS room cooler.

l Page 12 of 21

. Attachmint LR-N98344

5. Corrective Steps that Will Be Taken to Avoid Further Violations
a. Procedures controlling design change evaluations will be enhanced, as appropriate, to require documentation of design and licensing basis information assessed in the design change review. The procedure revisions will be completed by April 30,1999.
b. The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) training to improve Engineering performance. This training will be completed by December 31,1998.

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6. Date When Full Compliance Will be Achieved Hope Creek is in full compliance.

D. Criterion XVI Violation

1. ' Description of the Notice of Violation 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that: Measure shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.. "

l l

Contrary to the above, on and before March 19,1998, conditions adverse to quality were not promptly identified and corrected. In addition, for significant conditions adverse to quality, corrective action was not taken to preclude repetition, as listed in the following examples.

1.

NRC Information Notice (IN) 97-53 and other industry data apprised licensees that the switchgear is in an unanalyzed condition when the circuit breakers are left in a racked-out position, in 1997, the licensee's review of the IN evaluated only the seismic hazards from 480 Vac circuit breakers in the racked-out position, but l

failed to identify and correct the hazards from the 125 and 250 Vdc circu" l

breakers, and failed to identify and correct the unanalyzed condition of ah

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safety-related low voltage (125 Vdc, 250 Vde, and 480 Vac) switchgear with circuit breakers in the racked-out position.

Page 13 of 21

Attachm:nt LR-N98344 l

2.

The licensee failed to pra$de repetitive battery charger losses, a significant condition adverse to quality, in that the corrective actions taken to address a failure of the battery charger over voltage shutdown did not l

prevent further failures.

3.

Between July 1996 and March 1998, the licensee failed to assure the ability of the hydrogen-oxygen analyzer system to perform its post-accident function, a significant condition adverse to quality, in that the actions taken to address the drop of reagent gas pressure below the minimum required, did not prevent further pressure drops.

4.

Following their discovery, in April 1997, of age-related degradation of normally-energized Struthers-Dunn relays, the licensee failed to identify and promptly correct a condition adverse to quality, in that they did not ensure that the normally-energized relays that were not being replaced would be able to perform their safety functions during and following a seismic event.

5.

Following their determination, in November 1997, that the operating temperature rise of normally-energized Agastat E7000 relays in harsh environment exceeded the qualification temperature of the relays, the

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licensee failed to identify and promptly correct a condition adverse to 1

quality, in that their analysis was insufficient to assure the ability of the l

relays to perform their post-accident safety functions.

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

2. Reply to Notice of Violation PSE&G agrees with the violation.

EXAMPLE 1

3. Reason for the Violation i

The cause of the failure to identify and correct the unanalyzed condition of safety-related low voltage switchgear in the racked-out position was attributed to i

a less that adequate understanding of seismic qualificatica requirements pertaining to breaker panel configuration in maintenance procedures.

4. Corrective Steps that Have Been Taken and Results Achieved
a. The breakers that were in the racked-out position were restored to a racked-in position.

l Page 14 of 21

V..

Attathm:nt LR-N98344

b. Engineering qualitatively assessed the breaker panel configuration with the breakers in the racked-out position. The assessment concluded that breakers in the racked-out position will not affect the operability of the switchgear during a seismic event. However, the racked-in position is preferred and appropriate controls will be implemented to ensure that breakers are not left in the racked-out position.
5. Corrective Steps that Will Be Taken to Avoid Further Violations l
a. Procedures to control the position of breakers will be revised to prevent l

leaving breakers in a permanently racked-out position. These revisions will L

be completed by December 5,1998.

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b. The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineering St sport Personnel (ESP) training to improve Engineering performance. This training will be completed by December 31,1998.
6. Date When Full Compliance Will be Achieved l

l With the restoration of breakers to a racked-in position, Hope Creek achieved full compliance.

l EXAMPLE 2

3. Reason for the Violation The cause of the failure to prevent repetitive battery charger over voltage shutdowns was attributed to an ineffective use of the Corrective Action Program L

to implement corrective actions required to address this condition adverse to quality in a timely manner to prevent recurrence of charger failures. As a result, i

l personnel failed to adequately monitor the implementation of procedure changes -

that were needed to address the battery charger failures.

4. Corrective Steps that Have Been Taken and Results Achieved
a. Activities required for the battery charger have been planned and scheduled.

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The Corrective Action Program will be used to track the continued implementation and completion of these activities.

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5. Corrective Steps that Will Be Taken to Avoid Further Violations
a. In addition to reducing battery charger trips, battery charger reliabuity will be improved when the battery charger PM program is revised. Improvements include the addition of calibration checks of the high voltage shutdown Page 15 of 21 l

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AttachmInt LR-N98344 setpoint, replacing control cards and filter capacitors, and measuring the ripple output voltage. These PM program improvements will be developed by September 30,1998.

b. The deficiencies identified in this violation, including the ineffective use of the Corrective Action Program will be reviewed with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) training to improve Engineering performance. This training will be completed by December 31,1998.
6. Date When Full Compliance Will be Achieved Hope Creek is in full compliance.

EXAMPLE 3-

3. Reason for the Violation The cause of the failure to assure the ability of the hydrogen-oxygen an4zer system to perform its post-accident function was attributed to less than adequate implementation of the corrective action program to maintain system reagent pressures.-
4. - Corrective Steps that Have Been Taken and Resu!ts Achieved l

l

a. Leaks affecting hydrogen-oxygen analyzer operation have been repaired and the system is performing satisfactorily.
b. The Corrective Action Program has been used to assess the ability of the l

hydrogen-oxygen analyzer system to support its safety-related functions.

This assessment has determined that the current weekly surveillance, which verifies that the reagent bottles are maintained at 800 psi or greater, is adequate to ensure that the hydrogen-oxygen analyzer can perform its safety j>

related function l

5. Corrective Steps that Will Be Taken to Avoid Further Violations
a. Benchmarking of hydrogen-oxygen analyzer reagent consumption will be i

completed to facilitate assessments of system performance and to develop i

possible procedure enhancements that improve system availability. The benchmarking will be complete by October 30,1998.

b. The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) i Page 16 of 21 L______________._

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7 Attachm:nt LR-N98344 training to improve Engineering performance. This training will be completed by December 31,1998.

6. Date When Full Compliance Will be Achieved Hope Creek is in full compliance.

EXAMPLE 4

3. Reason for the Violation The cause of the failure to perform an adequate assessment of Struthers-Dunn relay operability with degraded bearing pad material was attributed to a less than adequate questioning attitude. As a result, the operability assessment relied solely on engineering judgment and did not include seismic testing to verify operability.

I

4. Corrective Steps that Have Been Taken and Results Achieved The Struthers-Dunn relays with magnetic vinyl bearing pad material have been replaced with new relays with improved silicon bearing pads. Therefore, no operability issues currently exist with these relays.
5. Corrective Steps that Will Be Taken to Avoid Further Violations The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) training to improve Engineering performance. This training will be completed by December 31,1998.
6. Date When Full Compliance Will be Achieved With the removal of the degraded Struthers-Dunn relays, Hope Creek is in full compliance.

EXAMPLE 5 4

3. Reason for the Violation The cause of the failure to perform an adequate assessment of the operability of Agastat E7000 relays in harsh environments was attributed to a less than adequate questioning attitude. As a result, the operability assessment did not include a qualification test plan.

l Page 17 of 21

L-v Attachm:nt -

LR-N98344

4. Corrective Steps that Have Been Taken and Results Achieved
a. The Agastat E7000 relays in harsh environments have been re-evaluated to support the current basis for operability. To verify the conclusions of this evaluation, a qualification test plan will be implemented, which will demonstrate the ability of these relays to perform their safety-related functions with their postulated service conditions at Hope Creek. The completion of this qualification test is scheduled for Apni 15,1999.

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5. Corrective Steps that Will Be Taken to Avoid Further Violations j
a. A qualificatiordest plan will be implemented, which will demonstrate the ability of tha Agastat E7000 relays to perform their safety-related functions with the'r postulated service conditions at Hope Creek. The completion of this qualification test is scheduled for April 15,1999.

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b. The deficiencies identified in this violation will be reviewed with the technical support personnel as part of ongoing Engineering Support Personnel (ESP) training to improve Engineering performance. This training will be completed by December 31,1998.

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6. Date When Full Compliance Will be Achieved With the current evaluation of Agastat E7000 relay operability, Hope Creek is in full compliance.

E. License Condition 2.C.7 Violation I

1. Description of the Notice of Violation License condition 2.C.7 requires, in part, that PSE&G implement and maintain in effect all provisions of the approved Fire Protection Program. Step 5.4.3 of fire protection procedure HC.FP-AP.ZZ-0004, Revision 3, Actions for inoperable Fire j

Protection - Hope Creek Station, which is part of the Hope Creek fire protection program, requires that, in the event of a standby 8-hour battery-powered L

- emergency light unit becomes inoperable, the NSS/SNSS be notified.

j Contrary to the above, on March 23,1997, fire protection technicians identified five inoperable emergency lighting units due to dead batteries, but failed to notify the NSS/SNSS.

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

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Attachm:nt LR-N98344

2. Reply to Notice of Violation l

. PSE&G's investigation could not confirm that the shift was not properly notified; however, PSE&G agrees that a violation of License Condition 2.C.7 did occur since appropriate actions to identify and resolve the scope of the " Appendix R" emergency light battery deficiencies were not taken following the March 23,1997 identification.

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3. Reason for the Violation l

l LER 97-017-00 reported PSE&G's assessment of Hope Creek's failure to

(-

implement License Condition 2.C.7 requirements for " Appendix R" emergency L

light batteries. PSE&G attributed the cause for this violation to less than l

adequate administrative controls for impairment notifications, and similar to LER 97-017-00, less than adequate program oversight by Fire Protection management.

4. Corrective Steps that Have Been Taken and Results Achieveci l-
a. The impairment procedure and computer program, used when " Appendix R" emergency lighting deficiencies are identified, has been revised to include q

l notification and documentation of the operating shift SRO when an impairment is generated.

b. New Fire Protection management is providing increased oversight of the implementation of the " Appendix R" emergency light preventative maintenance program. This will help ensure that " Appendix R" emergency lights are maintained in compliance with License Condition 2.C.7.
c. The " Appendix R" emergency lighting preventative maintenance program has l

been modified to address the weaknesses that were identified during PSE&G's investigation into the causes of the 1997 battery surveillance test failures.

d. Incorporation of the fire protection surveillance into the station surveillance

- scheduling process, as described in LER 97-017-00, will provide additional oversight to ensure that the " Appendix R" emergency lights are appropriately maintained.

e. Management expectations concerning shift notification on impairments has been re-enforced with fire department technicians.

Page 19 of 21

Attachm:nt LR-N98344

5. Corrective Steps that Will Be Taken to Avoid Further Violations No additional corrective actions are planned.
6. Date When Full Compliance Will be Achieved l

Hope Creek achieveel full compliance when the " Appendix R" emergency light batteries were replaced and the lights were declared operable in February 1998.

. F. Technical Specification 3.7.3 Violation

1. Description of the Notice of Violation Hope Creek Technical Specification 3.7.3 requires, in part, that flood protection be provided for all safety related systems, components and structures when the water level of the Delaware reaches 95 feet PSE&G datum at the service water intake structure. With the water level at the service water intake structure above 95 feet PSE&G datum, initiate and complete: (1) the closing of all service water intake structure watertight perimeter flood doors identified in Table 3.7.3-1 within

.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; and (2) the closing of all power block watertight perimeter flood doors identified in Table 3.7.3-1 within 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Once closed, all access through the j

doors shall be administratively controlled.

l Contrary to the above, on March 9,1998, with Delaware River water level still above 95 feet PSE&G datum, operators failed to administratively control all l

access through four service water intake structure watertight flood doors, identified in Table 3.7.3-1, in that they closed, but immediately reopened the

. doors without posting an individual at the docrs to control access.

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

I

2. Reply to Notice of Violation PSE&G agrees that a vivew, occurred; however, as described in the following section, PSE&G considers a to be a violation of Technical Specification 6.8.1 due to the failure to establish sufficient procedural controls to implement the requirements of Technical Specification 3.7.3.
3. Reason for the Violation PSE&G attributed the cause of this violation to a less than adequate understanding of administrative controlimplementation requirements for flood protection door operation during elevated river water conditions. As a result, less than adequate administrative controls were implemented on March 9,1998, to Page 20 of 21 -
,w Attachm
nt LR-N98344 i

control access through the flood protection doors with river water levels in

)

excess of 95 feet.

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4. Corrective Steps that Have Been Taken and Results Achieved i
a. Procedure HC.OP-AB.ZZ-0139 was revised to provide specific requirements for administrative control ove access through the flood protection doors during elevated river water level conditions. When river water conditions have the potential to affect the operation of safety-related plant equipment, trained personnel will be stationed at re-opened flood protection doors.
b. The details of this event, along with the procedure revisions, were reviewed l

with the operating shift crews to provide a com. mon understanding of l

administrative control requirements imposed by Technical Specification 3.7.3.

5. Corrective Steps that Will Be Taken to Avoid Further Violations i

No additional corrective actions are planned.

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6. Date When Full Compliance Will be Achieved I

Hope Creek achieved full compliance on July 30,1998, when procedure revisions were completed to adequately implement the administrative requirements of Technical Specification 6.8.1.

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