ML20237D033
| ML20237D033 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/18/1998 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-354-98-06, 50-354-98-6, LR-N98376, NUDOCS 9808240321 | |
| Download: ML20237D033 (7) | |
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- g' ectIic nI as Cornpany Louis F. storz -
Public Service Electric and Gas Company P,o. Box 236, Hancocks Bridge. NJ 08038 609-339-5700 Senior Vice Presderit. Nuclear Operatlans AUG 1819lB LR-N98376
. United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i
Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT 354/98-06 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 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 j
' Creek Generating Station in a letter dated July 21,1998.
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.
l The diesel fuel oil violation resulted in PSE&G requesting enforcement discretion for i
b 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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l You expressed concern regarding design errors; PSE&G is also concerned about this i
issue. Engineering Management has taken action to.mprove 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 l
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 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 it occurred.
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,
/
Es
Document Control Desk p gg i g mg
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LR-N98376 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 White. nnt 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 i
95-4933 f
' ocum:nt Centr:I De:k D
LR-N98344
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RESPONSE TO NOTICE OF VIOLATION l
lNSPECTION REPORT NO. 50-354/98-06 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 A. Diesel Fuel Oil Sampilng Violation
- 1. Description of the Notice of Violation Technical Specification 6.8.1 requirea, 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.
1 Appendix A of NRC Regulatory Guide 133, Revision 2, February 1978 (Section l
- 10) recommends that chemical control procedures be written to prescribe the j
nature and frequency of sampling and analyses.
Hope Creek chemistry procedure HC.CH-AP.ZZ-0041 (Q), Hope Creek
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Generating Station Diesel Fuel Oil Testing Program, Revision 2, Section 5.1, l
requires that all diesel fuel oil deliveries (via tank truck) will be sampled and analyzed for particulate, 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 particulate, 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 I).
- 2. Reply to Notice of Violation PSE&G agrees with the violation.
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Docum:nt C::ntral De2k LR-N98344 l
- 3. Reason for the Violation I
The reason for this violation was personnel error. The Diesel Fuel Oil Testing Program was incorporated in the Hope Creek License in License Amendment l
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.
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- 4. Corrective Steps that Have Been Taken and Results Achieved a) Hope Creek System Eng..'.aring has assumed responsibility for management of the Hope Creek Diesel Fuel Oil Testing program which includes data i
evaluation and trending.
i b) Sampling of new fuel oil for particulate prior to addition to a Fuel Oil Storage Tank recommenced May 20,1998.
i c) Procedure HC.CH-AP.ZZ-0041 (Q) 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 corrective 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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Docum:nt C::ntrol Desk LR-N98344 B. Criterion XI Violation -
- 1. Description of the Notice of Violation-10 CFR Part 50, Appendix B, Criterion 111 (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 shay provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the pctformance of a suitable testing program.
'l Contrary to the above, during the RFO7 refueling outage (Fall-Winter 1997),
design change package (DCP) 4EC-3638 incorrectly changed the design basis 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).
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- 2. Reolv to Notice of Violation PSE&G agrees with the violation.
- 3. Reason for the Violation l
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 llne 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 review. Testing the throttle function of this valve was not part of the DCP testing and therefore not found during the post modification testing.
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- 4. Corrective Steps that Have Been Taken and Results Achieved a) A review was performed of the remaining control circuits for MOVs for Salem
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and Hope Creek that were similarly modified. This review did not identify any further problems.
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b) The installation of DCP 4EC-3638 has been corrected and the function of the timing sequence feature for Valve 1FCHV-F045 was reinstated. Additionally, the design package for DCP 4EC-3638 was corrected.
- 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 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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