ML20249A107

Notice of Violation from Insp on 980405-0516.Violation Noted:During Refueling Outage RF03 in Dec 1990 Licensee Did Not Maintain RHR Sys in Operation

ML20249A107
Person / Time
Site:	Hope Creek
Issue date:	06/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20249A104	List: IR 05000354/1998005 ML20249A103 ML20249A107
References
50-354-98-05, 50-354-98-5, NUDOCS 9806160067
Download: ML20249A107 (3)

Text

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b APPENDIX A NOTICE OF VIOLATION Public Service Electric and Gas Company Docket No: 50-354 Hope Creek Generating Station License No: NPF-57 During an inspection conducted on April 5,1998, through May 16,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (60FR 34381: June 30,1995/NUREG-1600), the violations are listed below.

A. 10 CFR 50.59, " Changes, tests and experiments," in part, permits the licenteo to make changes to its facility and proce'dures as described in the final safety analysis report (FSAR) and conduct tests or experiments not described in the safety analysis report without prior Commission approval provided the change does not involve a change in the technical specifications or an Unreviewed Safety Question (USO).

The licensee shall maintain records of changes in the facility and these records must  ;

include a written safety evaluation which provides the bases for the determination that the change does not involve a USQ.

FSAR Section 9.1.3.2.3 establishes that the design and operation of the fuel pool cooling and cleanup systems for the decay heat associated with a full core offload is based, in part, on the operation or availability of the residual heat removal (RHR) system to augment the fuel pool cooling and cleanup (FPCC) system.

Contrary to the above, during refueling outage RF03 in December 1990, the licenseo did not maintain the RHR system in operation or available to augment the FPCC i system which represented a change to the facility as described in the FSAR and did  !

not perform a review of this change to demonstrate that the change did not involve l a USO.

This is a Severity Level IV violation (Supplement 1). I B. 10 CFR 50 Appendix B Criterion XI requires, in part, that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service be identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable l design documents. The test program shallinclude, as appropriate, proof tests prior

. to installation and operational tests during nuclear power plant operation of structures, systems, and components.

Contrary to the above, two examples of inadequate testing requirements associated with a design change modification to the Hope Creek safety-related control area chilled water system chillers were identified as follows:

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(1) As of April 7,1998, a complete proof test prior to installation and an operational test had not been performed to verify that check valves 1KBV-1243 through 1KVB-1250 would provide a relatively leak tight boundary and ensure that the backup safety-related pneumatic supplies for the chiller condenser cooling water pressure control valves would remain available for four hours after a loss of power event.

(2) On April 8,1998, the backup safety-related pneumatic pressure regulators (1KBPCV-11464, -11466, and -11467) for the chiller condenser cooling water pressure control valves were found set below minimum design requirements. Operational tests had also not been performed to ensure that pressure regulators 1KBPCV-1164 through 1KBPV-1171 would remain properly set in accordance with design requirements.

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

C. 10 CFR Appendix B Criterion XVI (Corrective Action) requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, and nonconformances are promptly identified ar:d corrected.

Contrary to the above, on December 10,1997, PSE&G engineers determined that the minimum cooling water inlet temperature for the safety-related control area chilled water system chillers should be changed in a more limiting direction to 70 degrees Fahrenheit from 55 degrees Fahrenheit. On April 9,1998, the operations department management, still unaware of any necessary change to the minimum allowed cooling water temperature, used 55 degrees Fahrenheit as a basis for determining inoperability when they made a four-hour event notification to the NRC.

Hope Creek abnormal operating procedure, l.oss ofInstrument Air and/or Service Air, HC.OP-AB.ZZ-0131(O) - Rev.14, and pending change, HFSAR 97-080, to the Hope Creek Updated FinalSafety Analysis Report (UFSAR) also incorrectly stated that 55 degrees Fahrenheit was the minimum cooling water temperature below which the safety-related backup pneumatic supply needed to remain operable. The change in minimum cooling water inlet temperature to a more limiting value was not corrected until May 7,1998, when guidance was provided to operators specifying the new 70 degrees Fahrenheit minimum cooling water temperature.

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

Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas Company 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 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 or severity level, (2) the

3 corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violationt., and (4) the date when full compliance will be -

achieved. :Your response may reference or include 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. Where good cause is shown,-

consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Enforcement Coordinator, USNRC, Region 1,475 Allendale Road, King of Prussia, Pennsylvania 19406-1415..

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 withholding of such material, you mual 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 4th day of June 1998.

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