View source for LR-N970572, Responds to NRC Re Violations Noted in Insp Rept 50-354/97-04.Corrective Actions:Developed Case Study for Tabletop Discussions W/Operating Crews

{{Adams
| number = ML20216J309
| issue date = 09/09/1997
| title = Responds to NRC Re Violations Noted in Insp Rept 50-354/97-04.Corrective Actions:Developed Case Study for Tabletop Discussions W/Operating Crews
| author name = Storz L
| author affiliation = PUBLIC SERVICE ELECTRIC &amp; GAS CO. OF NEW JERSEY
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000354
| license number = 
| contact person = 
| document report number = 50-354-97-04, 50-354-97-4, LR-N970572, NUDOCS 9709170238
| title reference date = 08-11-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 6
}}

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Pubhc SerwC9 tlectre and Gas
!                                                        Cortrany Louis F. Stor:                      Puble Servce Doctnc and Ga5 Cunpany      P.O. Box 236. Hancocks Ondge,14) 08038 (M339-$700 ben.c vp hwowo Naar Owmes LR-N970572 SEP 091997 United States Nuclear Regulatory Commission Document Control Desk Washington, DC           20555 REPLY TO NCTICE OF VIOLATION INSPECTION REPORT NO. 50-354/97-04 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Gentlemen:
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|date=August 11, 1997|text=letter dated August 11, 1997}}.                      This violation involved not fully understanding the degraded condition of a High Pressure Coolant Injection Valve before removing the "A" and "C" Residual Heat Removal systems from service. This was cited as a violation of 10CFR50, Appendix B, Criterion XVI. The details of the reply are contained in the attachment to this letter.
Should you have any questions or comments on this transmittal, do not hesitate to contact us.
Sincerely, L. F. Storz k
Senior Vice Pret1)1 dent             -
Nuclear Operations Attachment (1) r3 e-u-       I 4 .-.w. c n 9709170238 970909 PDR   ADOCK 05000354 (iqiminilmil)til
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SEP 091997 Document Control Desk               'LR-N970572 C Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris USNRC Senior Resident Inspector (X24)
Mr. K. Tosch, Manager IV Bi'reau of Nuckear Engineering 33 Arctic Park, cay CN 415 Trenton, NJ    08625

                . Attachment 1                                                                                      LR-N970572 RESPONSE TO APPENDIX B, CRITERION XV% VIOLATION INSPECTION REPORT NO. 50-354/97-04 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 I . DRECBIPTION OP_VIOLAT.19H The description of the violation contained in the Notice of Violation received in the {{letter dated|date=August 11, 1997|text=August 11, 1997, letter}} is as follows:
                   "10 CFR 50 Appendix B Criterion XVI requires in part that j
conditions adverse to quality such as equipment non-
)                  conformances be promptly identified and corrected.                                                 Contrary l                 to the above, on June 16, 1997, an inoperable high pressure coolant injection system (HPCI) injection valve was not promptly identified. Specifically, a degraded HPCI                                                              1 injection valve condition was not fully understood before                                                       j the "A" and "C" residual heat removal systems were                                                              1 intentionally removed from service."                                                                            !
l This is a Severity Level IV violation (Supplement I).
II.        BEPLY TO VIOLATION 4
A. EHE&G Positio.D PSE&G agrees with the violation as stated in the description of violation. However, PSE&G takes exception with the statement in the inspection report that the initial decision to maintain the operability of the High Pressure Coolant Injection (HPCI) system was non-conservative. The i                 operators followed the normal plant processes, which included an operability determination, a follow-up i                 assessment, initiation of a temporary modification, and a validation of the original assumptions. The operators exercised prudent judgment and had reasonable assurance of operability when they allowed the "A" and "C" Residual Heat Removal system to be removed from service.
Description of Event On June 16, 1997, while performing a HPCI valve surveillance test, the HPCI full flow test return valve failed to stroke open. Several hours earlier, the valve had been successfully stroked for the same test. Troubleshooting determined that an interlock contact on a HPCI injection valve was open and should be closed to allow the HPCI full flow test return valve to open. The Work It Now (WIN) team determined this by jumpering the appropriate contact and the HPCI full flow test return valve was verified to stroke.                                                   At 1

         . Attachment 1                                              LR-N970572 this time, the HPCI full flow test return valve did not
       .  -automatically close.      This allowed the valve surveillance     to be completed satisfactorily and an operability determination was performed which declared HPCI " operable but degraded".
The WIN team took resistance readings across contacts, one of which provides the automatic closure function of the HPCI         ,
full flow test return valve from the HPCI injection valve.
The reading from this contact was not fully consistent with the valvo position. The reason for this reading was unknown at the time, but was considered to be minor because the HPCI injection valve had stroked successfully during the surveillance test.
The initial evaluation of this condition concluded that the HPCI system was operable, but degraded.       This decision was based on the reasonable assurance of operability that was            l l          provided to the operators based on the fact that the HPCI            '
full flow test return valve acted as expected in that it did not._ automatically close. Also contributing to the decision was the fact that although the condition did prevent the use of HPCI in the full flow test mode of operation, the                 .
identified condition would not prevent HPCI from performing its safety function of automatically injecting into the Reactor Pressure Vessel.
On June 17, 1997, the "A" and "C" Residual Heat Removal (RHR) systems were removed from service to conduct scheduled maintenance activities. The Action Statements associated with Technical Specifications 3.5.1.b, Emergency Core Cooling Systems - Low Pressure Coolant Injection, and 3.6.2.3,   Suppression Pool Cooling, were entered at 0501.
Because the failure of the HPCI full flow test return valve prevented the use of HPCI in the pressure control mode, Engineering was tasked with developing a temporary modification that would allow this mode of HPCI to function.
During the process of researching and developing the temporary modification, additional concerns about the HPCI injection valve's status were raised by the Motor Operated Valve (MOV) Engineer.       These concerns were reviewed with Maintenance Engineering and a Maintenance Engineer was requested to validate the concerns and review the valve interlocks. At this point, Operations, Maintenance, and Engineering still believed that only the HPCI full flow test return valve was affected. Evaluation continued.through June 17, 1937.
1 In accordance with the established workplan, the       "A" RHR system was returned to an operable-status on June 18 at 0040. At approximately 0900, on June 18, Operations was informed    of the validated additional concerns with the HPCI injection valve.     ~ Based on these concerns, equipment in the "C" RHR system was restored and the system was returned to an operable-status on June 18 at 2047. Additionally, when 2
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      . Attachment 1                                        LR-N970572 Operations was informed of the validated additional concerns with the HPCI injection valve, a troubleshooting team consisting of Operaticns, Maintenance, and Engineering was established. A series of valve strokes was planned to be performed.
While stroking the HPCI full flow test valve open, the valve opened and then automatically closed, unlike the evolution on June 16. This response was not expected and additional troubleshooting was performed.
At 2015, on June .8,   HPCI was declared inoperable based on a review of the additional troubleshooting information (e.g.
contact readings associated with the HPCI full flow test valve) and because Operations no longer believed that a reasonable assurance of operability was being maintained.
Operations entered the Action Statement required by Technical Specification 3.5.1.c, Emergency Core Cooling 1
Systems - HPCI. The Action Statement associated with the HPCI LCO was conservatively back dated to 0330 on June 16, l
I when the issue with HPCI was first identified- Later that evening, around 2252, during subsequent troublerhooting, the HPCI injection valve did not stroke. It should be noted that the HPCI injection valve's limit switches were later determined to be the root cause of the HPCI valve performance issues.
Because the Action Statement was entered retroactively to 0330 on June 16, 1997, for a period of time on June 17 and 18, HPCI was technically inoperable in conjunction with "A" and "C" RHR outages. This combination is not addressed by Technical Specifications; therefore, Technical Specification 3.0.3 applied, and a plant shutdown would have commenced if the inoperability of HPCI had been recognized while both the "A" and "C" RHR were inoperable. Per Technical Specification 3.0.3 requirements, a plant shutdown would have been completed if neither HPCI nor one of the RHR loops had been restored to operability.
B. Enamon for the violation The apparent cause of the failure to enter 3.0.3 was the lack of recognition that HPCI was inoperable until June 18, 1997    In retrospect, the degraded HPCI injection valve condition was not fully understood before the "A" and "C" RHR systems were intentionally removed from service. The condition of the HPCI valves was not fully understood -
partially because this event included a different failure mechanism than previously experienced and, finally, the station organization did not ef fectively validat:e, verify, and interpret information gathered through troubleshooting.
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               . Attachment 1                                                                                     LR-N970572   I C.          Cp r r e c t i y e S tapJt.Th R.t_llaydian_TAhn D_A nd_ReAulta
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* Operations management developed a case study for tabletop discussions with the operating crews. This case study includes the specifics of this event, lessons learned from other historical events, and a comparison of what went right
 ,                and what went wrong in each of the events. The case study has been discussed with each of the operating crews, the tabletop discussions were completed by September 3, 1997.
D.          Corrective Steps Tha_t._Will Be Taken to Avoid _E.gr_ther Violatigaq Maintenance and System Engineering will use this event as a case study for tabletop discussions. This case study will include the specifics of this event, lessons learned from other historical events, and a comparison of what went right and what went wrong in each of the events. These tabletop discussions will be completed by January 31, 1998.
E. pate When Full Compliance Will Be Acilleved Full compliance was achieved when "A" and "C" RilR loops were returned to service on June 18, 1997 and the liPCI injection valve was repaired on June 21, 1997.
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