ML20199L479

Notice of Violation from Insp on 971126-980103.Violation Noted:On 971124,maint Technicians Failed to Follow HC.IC-DC.ZZ-0140(Q),Rev 3, Device/Equipment Calibration Masonleilan Pressure & Temperature Controllers

ML20199L479
Person / Time
Site:	Hope Creek
Issue date:	02/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20199L447	List: IR 05000354/1997010 ML20199L443 ML20199L479
References
50-354-97-10, NUDOCS 9802090210
Download: ML20199L479 (3)

Text

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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 NRC inspection conducted between November 26,1997, and January 3,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. Hope Creek technical specification (TE) 6.8.1 requires, in part, that written procedures shall be established, implemented and maintained for applicable activities specified in Appendix A of Regulatory Guide (RG) 1.33, Revision 2. TS 6.8.1 also requires that written procedures shall be established for surveillance and test activities of safety-related equipment. ,

Appendix A of RG 1.33 requires that procedurcs be established for startup, operation, and shutdown of the Reactor Core Isolation Cooling (RCIC) system, as well as for the control of maintenance, repair or replac' 'nt of components that can affect the performance of safety-related equipme.

Contrary to the above, three examples of failures to either establish or implemen.

the above rr. quired procedures were identified:

a. On November 24,1997, maintenance technicians failed to follow Hope Creek procedure HC.lC-DC.ZZ-0140 (Q), Revision 3, " Device / Equipment Calibration Masonellan Pressure and Temperature Controllers,"in that they did not restore a gain adjustment in the "B" control room ventilation system chiller pressure contro' valve circuitry to the proper value following an instrument calibration. This led to two subsequent trips of the safety-related chiller due to high back pressure.

b. On December 30,1997,it was identified that procedure HC.OP-SO.BD- ,

0001(Q), Revision 16, " Operation of the Reactor Core Isolation Cooling System," failed to provide adequato guidance for resetting the turbine mechanical overspeed trip device. As a result, the RCIC turbine trip throttle valve could not be re-opened for several hours following system maintenance,

c. On January 3,1998,it was identified that maintenance department procedure HC.MD-ST.SB-0006(Q) Revision 0, "1B Month Electrical Protection Assembly Chann'e l Calibration," established in part to implement the surveillance test requirements of technical specification 4.8.4.6.b, did not incorporate the appropriate acceptance criteria for under-frequency channel calibrations. Specifically, step 5.9.8 of the noted procedure lists the h$$$$34PDR

2 acceptance criteria as "2: 57 Hertz," while the associated technical specification specifies the criteria as "57 Hertz, - 0% + 2%."

These are Severity Level IV Violations (Supplement 1).

2. 10 CFR 50, Appendix B, Criterion V, requires in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures or drawings.

Contrary to the above, on November 29.1997,it was identified that no instruction, procedure, or drawing was provided to workers regarding the correct orientation of a reactor water cleanup system (RWCU) flow measurement orifice plate during system maintenance. Specifically, while restoring from a corrective maintenance activity to repair an associated RWCU piping flange leak, technicians installed the noted orifice plate backwards in part because no specific guidance for proper reassembly was provided. The orifice plate provides a flow signal to primary containment isolation logic.

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

3. 10 CFR 50, Appendix B, Criterion XVI, requires in part that for significant conditions adverse to quality such as failures, malfunctions, and deficiencies, measures shall be established to assure that the cause of the condition is determined and corrective actions are tsken to preclude repetition.

Contrary to the above, prior to December 5,1997, corrective measures implemented subsequent to a December 28,1996 failure of the RCIC turbine governor valve assembly were insufficient to preclude recurrence. Specificaily, the governor valve stem was replaced folbwing the 1996 e' vent with a material design that exhibits an increased thermal expansion rate as material temperature increases.

The engineering analysis which supported the stem material change did not account for this factor, and led to governor valve stem binding and a RCIC system failure on December 5,1997.

This is Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Pubic 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

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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, (2) the corrective stops that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will ba achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not

3 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.

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 3rd day of February,1998

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