IR 05000354/1997001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/97-01-04

ML20203D735
Person / Time
Site:	Hope Creek
Issue date:	12/05/1997
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Eliason L Public Service Enterprise Group
References
50-354-97-01, 50-354-97-1, EA-97-160, NUDOCS 9712160276
Download: ML20203D735 (3)

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s December 5,1997 Mr. Leon Chief Nuclear Officer & President Nuclear. Business Unit Public Service Electric & Gas Company PO Box 236 Hancocks Bridge, NJ 08038 SUBJECT: VIOLATION 50-354/97-01-04(EA 97160)

Dear Mr. Eliason:

This letter refers to your November 18,1997 correspondence, in response to our October 20,1997 letter.

Thank you for informing us of the corrective and preventive actions for the Notice of Violation, as documented in your letter. The violation involved inadequate safety evaluations performed under 10 CFR 50.59 associated with the installation of a crosstie line and associated valving between residual heat removal subsystems A and C, which resulted in an unreviewed safety question. Your response to the violation indicates that you have implemented measures to prevent recurrence, including locking closed one of the valves in the A/C crosstie line thereby restoring compliance with Technical Specifications.

Additionally your corrective measures included establishment of a qualification program to ensure that personnel performing 10 CFR 50.59 evaluations are properly trained and qualified. We will review the effectiveness of these actione during a future inspection.

Your cooperati2n with us is appreciated.

Sincerely, Original Signed By: James C. Linville, Chief Projects Branch 3 Division of Reactor Projects Docket No. 50-354 i

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Mr. Leon cc w/o cy of Licensee's Response Letter: ' L. Storz, Senior Vice President Nuclear Operations E. Simpson Senior Vice President Nuclear Engineering E. Salowitz, Director Nuclear Business Support M. Bezilla, General Manager Hope Creek Operations J. McMahon, D!:ector . Quality Assurance / Nuclear Training / Emergency PreparedM!,s

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D. Powell, Director . Licensing / Regulation & Fuels A. C. Tapert, Program Administrator cc w/cy of t.icensee's Response Letter: A. F. Kirby, Ill, External Operations Nuclear, Delmarva Power & Light Co.

J. A. Isabella, Manager, Joint Generation Atlantic Electric R. Kankua, Joint Owner Alf airs Jeffrey J. Keenan, Esquire Consumer Advocate, Office of Consumer Advocate William Cenklin, Public Safety Consultant, Lnwor Alloways Creek Townsh p State of New Jersey State of Delaware -

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Mr. Leon i Distribution w/ copy of Licensee's Response Letter: Region i Docket Rooin (with concurrences) Nuclear Safety information Center (NSIC) PUBLIC l NRC Resident inspector J. Linville, DRP , S. Barber, DRP i J. Stolz, PD12, NRR B. Morafari, Project Manager, NRR i R. Correia, NRR F. Talbot, NRR Inspection Program Branch, NRR (IPAS)  ; DOCDESK ,

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DOCUMENT NAME: G:\ BRANCH 3\REPLYLTR\HC9701.RPY Ta rocsive a copy of this document, lid: ate in the boa: 'C' = Copy weout attechment> enclosure T = Copy with attachment / enclosure *N"= No N

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O'FICE Rl/DRP /l / l / l l [ NAME JLinville tpf DATE 12/03/97 v 12/ /97 12/ /97 12/ /97 12/ /97 OFFICIAL RECORD COPY -

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    [ octric a'4 Gas Compaar E C. Simpeon  Put>lec Servce Decttc and Gas C'artpany P O. Box 236, Harv. cks Brege. NJ 08038 009-339-17Co wan.P ~<.u.av m LR N970706 NOV 181997 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50 354/97-01 HOPE CREEK GENERATING STATION       y FACILITY OPERATING LICENSE NFF 57 DOCKET NO. 50 554 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 October 20,1997.

The details of the reply are contained in the attachments to this letter.

Should you have any questions or comments on this transmittal, do not hesitate to contact us.

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Sincerely, ,

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NOV 181997 Document Control Desk 2 LR-N 0700 C Mr. H. J. Miller, Administrator Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. D. Jaffe, Licenaiag 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 Res'hnt inspector (X24) Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. O. Box 415 Trenton, NJ 08625

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REF: LR N970706 i I STATE OF NEW JERSEY ) SS.  ;

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COUNTY OF SALEM )

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E. C. Simpson, being duly sworn according to law deposes and says: I am Senior Vice President Nuclear Engineering of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Hope Creek Generating Station, are true to the best of my' ,

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knowledge, information and belief,

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_ ATTACHMENT TO LR.970706  : REPLY NOTICE OF VIOLATION FOR RHR CROSS TIE MODl/ICATION j i l 1, DESCRIPTION.0F NOTICLy1QLAIjQN

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During an NRC inspection conducted between February 2 and March 2,1997, for , which exit meetings were held on March 27,1997 and June 26,1997, a violation  ;

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of NRC requirements was identified. In accordance with the " General Policy and Procedure for NRC Enforcement Actions," NUREG.1600, the violation is set forth below: i

 "10 CFR 50.59(a)(1) states, in part, that the holder of a license may make  ,

changes in the facility as described in the safety smalysis report, without prior l Commission approval, unless the proposed changes involve changes in the , ' Technical Specifications (TS) incorporated in the license, or an unreviewed safety l

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question (USQ).10 CFR 50.59(a)(2) states, in pari, that an unreviewed safety question shall be deemed to exist if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created.10 CFR 50.59(b)(1) requires, in part, that the records of changes to the facility must include a written safety evaluation.  ; Contrary to the above, in April 1994, the licensee made changes to the facility as described in sections 5.4.7.1 and 6.3 of the Updated Final Safety Analysis Report (UFSAR) that involved a USO without prior Commission approval. Specifically, a cross tie line and associated valving were installed between residual heat removal ,

 (RHR) subsystems A and C. The written safety evaluations for this change, described in Design Change Package (DCP) 4EC 3411, were inadequate in that:

1. The safety evaluation did not identify that installation of the cross tie involved a USO. The change involved a USQ because the loss of independence of the . Iow pressure coolant injection (LPCI) subsystems during a loss of coolant accident, which could result from a valve alignment error in which the cross-tie - isolation valves were left open, created the possibility of a malfunction of a different type than any previously evaluated in the UFSAR. As a result, the - licensee made a change to the facility as described in the UFSAR that involved - a USQ, without prior Commission approval; and 2. The safety evaluations for the design change failed to identity the need to j

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include cross tie isolation valves in the monthly emergency core cooling system (ECCS) flowpath verification required by TS. As a result, from April 7,1994, until December 22,1995, the cross tie isolation valves, which were not locked closed, were not verified to be in the correct position at least once per 31 days as required by TS 4.5.1.a.1.b. (01013) This is a Severity Level 111 violation (Supplement 1)."

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. Attachment     LR N970706

' Reply to Notica of Violation II. REPLY To.Y101. ail 0N A. ESE&GEnaltion PSE&G agrees with the notice of violation.

B. Reason _forthe_VJola1Lon The 10CFR50.59 evaluation that supporied installation of the cross tie lina and two cross tie valves between the "A" and "C" RHR subsytems analyzed a configuration with one cross tie valve open and one closed. Preparation and

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review of the safety evaluation failed to identify this configuration as an unreviewed safety question (USQ). Based upon the results of a May 1997 common cause assessment, this failure is attributed to lack of clearly defineo expectations, a less than adequate program evaluation process, and lack of commitment to program implementation.

The safety evaluation also failed to list Technical Specification 3/4.5.1, *ECCS - Operating", as having been reviewed for potential changes. The failure to properly identify all potential Technical Specifications impacted by the design change contributed to missing Surveillance Requirement 4.5.1.a.1.b, which specifies verifying that each valve in the flow path that is not locked, sealed, or otherwise secured in position is in its correct position. This failure is attributed to personnel error and inadequate review of the 10CFR50.59 safety evaluation.

As a result of valve position discrepancies identified during the March 1995 safety system functional review (SSFR) of the RHR system, the cross-tie valve that was designated to be open in accordance with the configuration analyzed in the safety evaluation for the cross-tie modification was red tagged closed. In addition, the Tagging Request Inquiry System (TRIS) was changed to indicate the subject valve should be closed in all modes. These actions eliminated the conditions that resulted in a USQ. Additional review resulted in locking one of the u;oss tie valves closed. This action restored compliance with Technical Specification 4.5.1.a.1.b since the cross-tie line was provided with a locked closed valve.

. C. Conective Steps That Have Been Taken_and Results Achievedi Contcliyelteps that HaveEten Iaken to Avoid Further Ylelations The following corrective actions have been taken: Page 2 of 4

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 , Attachment     - LR N970706

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R: ply to Notico cf VI:lation A_ CTIONS TO RESTORE COMPLIANCE

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1. As a result of findings during the March 1995 RHR SSFR, the cross tie valve , I that was designated to be open in accordance with the configuration analyzed in the safety evaluation was red tagged closed and TRIS was changed to indicate the subject valve should be closed in all modes. These actions eliminated the conditions that created the USQ since the possibility of placing the plant into the condition evaluated in the design change package as a result of failure to recognize the concern with the one valve t open configuration or as a result of the TRIS information was eliminated and  ! controls were in place to ensure the valves were maintained in a closed  ! position.  ;

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2. On December 22,1995, one of the valves in the A/C cross tie line was

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locked closed, restoring compliance with Technical Specification 4.5.1.a.1.b.

&CTIONS TO ADDRESS PERSONNEL ERROR ASSOCIATED WITH THE NEED TO INCORPORATE VALVES INTO SURVElLLANCE 4.5.1 A.1 B 3. Personnel involved with the failure to identify the need to include the cross-tie valves in the surveillance for Technical Specification 4.5.1.a.1.b have . been held accountabk) for their actions in accordance with PSE&G's disciplinary policy.

ACTIONS TO ADDRESS HUMAN PERFORMANCE CONCERNS ASSOCIATED

WITH 10CFR50.59 EVALUATIONS 4. In May 1997, a common cause analysis of the PSE&G 10CFR50.59 Program was completed. The analysis concluded that there was a lack of ' clearly defined expectations, a less than adequate program evaluation ' process, and lack of commitment to program implementation. As a result of  ; this analysis, a number of corrective actions were taken including the following: a. Management expectations and job performance standards for the 10CFR50.59 process have been established and clearly communicated ' to Engineering personnel. The job performance standards are being reinforced through periodic publication of lessons learned from critical reviews of safety evaluations and formalized feedback to the preparer.

. b. The quality of 10CFR50.59 evaluations prepared by Engineering is being measured and performance indicators have been developed to ' monitor performance in this area.

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Atta:hment LR N970706 i *' * Reply to N:tico cf VI:lation 5. Other enhancements in the 10CFR50.59 program have occurred (e.g., in 1996, an NBU wide qualification program was established to ensure that personnel performing 10CFR50.59 evaluations are properly trained and qualified).

. OTHER CORRECTIVE ACTIONS 6. As a result of a Technical Specification Improvement Program (TSSIP) ' finding, in Ociober 1996, the four cross tie vaives were added to the I containment integrity surveillance that verifies the status of primary containment penetrations on a monthly basis.

7. A review of other ECCS related design bases will be performed as part of 10CFR50.54(f) design and licensing review project and was described in a May 14,1997 letter. -

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8. A discussion of the issue will be included in an edition of the PSE&G 10CFR50.59 newsletter by December 31,1997.

9. A new surveillance requirement was added to the Technical Specifications to require performing a monthly position verification for the RHR discharge side cross tie valves.

, D. DAtt.When Full ComplianceEllLBe Achlered Full compliance was achieved with respect to the USQ issue in March 1995 when the condition that resulted in the USO (i.e., the valve evaluated to be configured open was red tagged closed and TRIS was changed to indicate tnat the valve should be closed in all modes) were aliminated. Full compliance was achieved with respect to Technical Specification 4.5.1.a.1.b in December 1995 when one of the cross tie valves was locked closed.

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