ML20199L443

Forwards Insp Rept 50-354/97-10 on 971126-980103 & Nov. Noted Several Instances of Inadequate Development or Implementation of TS-required Procedures That Resulted in Unplanned Challenges to Plant Operators & Equipmemt

ML20199L443
Person / Time
Site:	Hope Creek
Issue date:	02/03/1998
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Keiser H Public Service Enterprise Group
Shared Package
ML20199L447	List: ML20199L443 ML20199L479 ML20199L532
References
50-354-97-10, EA-98-037, EA-98-37, NUDOCS 9802090203
Download: ML20199L443 (4)

See also: IR 05000354/1997010

Text

,.

.

_ _ _ _ _ _

W,

'>

'

.

1-

,

t

>

-

February 3,1998

EA 98-037,

,

1 Mr. Harold W. Keiser

'

Executive Vice President -

Nuclear Business Unit:

Public Service Electric and Gas Company:

Post Office Box 236 :

- Hancocks Bridge, NJ 08038 <

-

' SUBJECT:

NRC INTEGRATED INSPECTION REPORT 50-354/9710

NOT!CE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION

y

IDear Mr. Keiser:

' On January 3,1998, the NRC completed an inspection at your Hope Creek reactor facility.

L-

1The enclosed report presents.the results of that insp6ction.

'

<

R

Throughout the seven week inspection period, your conduct of ' activities at the Hope Creek:

,*

facility was generally characterized by safety-conscious operations, and appropriate -

i

engineering and plant support practices.- Good quality assurance department oversight of,

4-

station activities was evident. Aggressive efforts to reduce the backlogs of temporary

_ modifications'and operability determinations were effective. Though several equipmenti

'

>

F

odeficiencies and delays _ were encountered, we noted good control and cc.iservative :

'

1 operations during the reactor start up and power ascension following the refueling outage.-

Based on our observations'of you serformance during the refueling ' outage and plant start t

(up, the NRC has determined that violations of NRC requirements occurred.;These

7 violations are cited in the enclosed Notice of Violation (Notice) and the circumstances

1

i surrounding them are described in detsil in the subject inspection _ report < We are

concerned that corrective actions implemented in response to prior problems in both -

'

_

,

1 maintenance and engineering activities have been iasc than fully effective. Specifically, we -

noted 'several instaraos of inadequate development'or implementation of technical --

<

specification-required procedures that resulted in unplanned challenges to plant operators

for important to-safety equipment. Though some of these issues were identified during

system testing, they nonetheless resulted from personnel errors and ir adequate -

r supervisory. reviews and oversight. These causes appear repetitive of those identified for

-

D

'~

numerous previous events, questioning the effectiveness of prior corrective ' action

'

-

initiatives. An NRC-identified error in a test procedure which implements a technical

'

specification ~ surveillance requirement for electrical protection' assemblies was of concern

since this procedure was established after your technical specification surveillance .

Improvement program was completed. This finding raises qasstions as to the

f

effectiveness of your process for implementing Technical Specification changes.

I

9902090203 990203

"

f

POR

ADOCK 05000354

/

0

PDR

l

,y

.

.

,N.

~

'

'

,

J

.

a

..

.

. . -

,

-

. - -

.

. .

_

2

. Mr. Harold W. Keiser;

1

.You are required to respond to this letter and sitooid foliow the instructions specified in the -

g

,

i"?

~

- enciesed Notice when preparing your response. The NRC will use ycur response, in part,

to determine whether further enforcement action is necessary to ensure compliance with-

l

- - regulatory requirements.

Additionally, the December 5,1997 reactor core isolation cooling system (RCIC) system

failure resulted from ineffective corrective actions following your 1996 RCIC overspeed ~

W

- event.: Failures of Terry turbine governor valves has bu.n the subject of several industryi

-1

operating experience information documents as well as generic NRC communications.-

-In contrast, the NRC reviewed your self identified issue involving the faileo inservico -

surveillance test of the reactor building to-torus vacuum breakt.r instrument air check

valves TN3 issue ste.mmed from an inadequate initial design review, and was an apparent

violation of NRC requirements which was considered for escalated enfor:.ement and

+ lect to a civil penalty. - However, after consultation with the Director, Office of

i Avcement, I have been authorized to not issue a Notics of Violation and_not propose a

y.1 penalty in this case in accoidance with the provisions provided in Section Vll.B.3 of

.the NRC's Enforcement Policy. This decision was made after consideration that: (1) the

Evlolatiottwas identified by your_ staff's good questioning attitudes during a voluntary -

. Initiatives; (2) corrective actions, both taken and planned, were comprehensive and timely;

l

- (3) the condition's were subtle in nature and not likely to be disclosod through routine 1

,

L

surveijance or quality assurance activities; arxl (4) the violations are not reasonably linked

L

to current performance. The exercise of discretion acknowledges your good effort to:

identify and correct subtle violations, that would not be identified by routinc efforts, before

- the degraded safety systems are called upon.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures will be placed in the NRC Public Document Room (PDR).

Sincerely,

' Ori inal Signed By:

9

,

__

Charles W. Hehl, Director

Division _of Reactor Projects

Docket No.: 50-354

License No

NPF-57

- Enclosures:

1.

Notice of Violation

2.

Inspection Report 50-354/9710

-

i4

4

%

- _ _ _ -

_ _ _ _ .

..

3

Mri Harold W. Keiser-

cc w/ encl: .

,

L Storz, Senior Vice President - Nuclear Operations

E, Simpson, Senior Vice President - Nuclear Eng,;neering

' l

E. Salowitz, Director - Nuclear Business Support

A. F. Kirby, Ill,, External Operations Nuclear, Delmarva Power & Light Co.--

!J. A. Isabella, Manager, Joint Generatien

' Atlantic Eiectric'

M. Berilla, General Manager - Hope Creek Operations

J. McMahon, Director - QA/ Nuclear Training / Emergency Preparedness

D. Powell, Director - Licensing / Regulation & Fuels

R. Kankus, Joint Owner Affairs

A. C. Tapert, Program Administrator

Jeffrey J. Keenan, Esquire

- Consumer Advocate, Office of Consumer Advocate

William Conklin, Public Safety Consultant, Lower Alloways Creek Township

.

.

_

State of New Jersey-

State of Delaware -

4

,

,

o

%

..

.

4

Mr. Harold W. Keiser

' Distribution w/ encl:

Region i Docket Room (with concurrences)

Nuclear Safety information Center (NSIC)

. NRC Resident inspector

PUBLIC

H. Miller, RA/W Axelson, DRA

J. Linville, DRP

S. Barber, ORP

L. Harrison, DRP.

C. O'Daniell, DRP

D. Holody, EO, Rl

Distribution w/ encl: (Via E Mall)

B. McCabe, OEDO

J Stolz, PDI 2, NRR

- B. Mozafari, Project Manager, NRR

R. Correia, NRR

F. Talbot, NRR

inspection Program Branch, NRR (IPAS)

DOCDESK

R. Zimmerman, NRR

J. Lieberman, OE

.-J. Goldberg, OGC

DOCUMENT NAME: G:\\ BRANCH 3\\lR9710.HC

Ta receive a copy of this document,Jndicato in the box: 'C' = Cocy without attachment / enclosure T = Copy with attachment / enclosure "N" = No copy

OFFICE

Rl/DRP

,/ l

Rf/ Off

(\\, j

/

l

l

NAME

JLinville Q//

(',1f) Y Hl W 8

DATE ~.

01/29/98 )

0)/h9E -

01/ /98

01/ /98

01/ /98

OFFICIAL RECORD COPY

_ ___ A