ML20249A203

Notice of Violation from Insp on 980223-0319 & 0427-30. Violation Noted:Conditions Adverse to Quality Were Not Promptly Identified & Corrected

ML20249A203
Person / Time
Site:	Hope Creek
Issue date:	06/10/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20249A198	List: IR 05000354/1998080 ML20249A197 ML20249A203
References
50-354-98-80, NUDOCS 9806160174
Download: ML20249A203 (6)

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.o NOTICE OF VIOLATION Public Service Electric and Gas Company Docket No: 50-354 Hope Creek Generating Station License No: NPF-57 1

During an NRC inspection conducted between February 23,1998, and March 19,1998, j violations of NRC requirements were identified. In accordance with the " General j Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50.59, paragraph (b), states, in part, that licensees "shall maintain records of changes ... to the extent that these changes constitute changes to in the facility as described in the safety analysis report .... These records must include a written l safety evaluation which provides the bases for the determination that the change i does not involve an unreviewed safety question."

Section 3.5.1.1,3 of the UFSAR states " Equipment and components installed in ,

safety-related plant areas outside the primary containment are designed and i installed so that they do not present gravitational missile hazard to safety-related structures-systems and components during or after a SSE .... Non-permanently installed equipment is either removed from the safety-related areas or secured in place before reactor operation to ensure that it does not become dislodged and present a missile hazard.

Contrary to the above, for an indeterminate time, before March 19,1998, the licensee non-permanently installed temperature and humidity recorders in the main control room and in the remote shut-down panel room, two safety-related areas outside the primary containment. They did not remove them from the areas or secure them in place before reactor operation, nor did they prepare a written safety evaluation which provided the bases for their conclusion that the instruments did not present a missile hazard to safety-related structures, systems and components in the rooms and that the facility change did not involve an unreviewed safety question.

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

B. 10 CFR 50, Appendix B, Criterion XI, " Test Control," requires, in part: "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test pr.ocedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include ... operational tests during nuclear power plant operation .... Test results shall be documented and evaluated to assure that test requirements have been satisfied."

l Contrary to the above, on and before March 19,1998, the licensee did not establish a test program to demonstrate that structures, systems, and components would perform satisfactory!y in service, or tests were not conducted in accordance with test procedures and the results were not evaluated to assure that the test requirements had been satisfied, as listed in the following examples:

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'2 l 1. In November 1991, the performance capacity test results for battery 1DD447 were not corrected for the actual test temperature, in accordance with the applicable surveillance test procedure, and the test results were not j properly evaluated to assure that the test requirements had been satisfied.

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2. . IEEE Standard 450-1995,to which the Hope Creek UFSAR states conformance, specifies that a decrease in battery capacity of more than 10%

from the average of the previous tests should result in the licensee's increasing the test frequency from five years to 18 months.

In December 1995, test results showed that the capacity of battery 1DD447 had dropped by 21.6% from the previous test. Despite the large drop in capacity, the licensee failed to evaluate the test results, calculate the

~ average capacity drop, and determine whether the battery test frequency should be increased to 18 months. {

3. Items b and e of UFSAR Table 9.4-6 state that: (b) "For systems that must perform a safety-related function, periodic inservice testing of fans, valves,

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> . controls, and instrumentation in the systems is performed. Motor-operated --

valves and dampers are tested by opening and closing the valve or damper.'

Temperature, differential pressure readings, and flow capacity are recorded";

and (e) " Standby units are tested at periodic intervals to verify the operation of essential features. Periodic tests of the actuation circuitry and the system components are conducted during normal operation."

l Prior to March 19,1998, the licensee had not established a test program to i demonstrate the control equipment room supply and the control area battery )

exhaust systems would perform satisfactorily in service in that they had not established a program for the periodic inservice testing the systems components, as described under item (b) of Table 9.4-6 of the UFSAR.

Instead, the licensee only checked the functionality of individual components i under the preventive maintenance program. In addition, the licensee did not periodically test the automatic standby features of these systems, as specified in item (e) of the same UFSAR table.

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

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. C. - 10 CFR 50, Appendix B, Criterion lil, " Design Control," requires, in part, that:

" Measures be established to assure that applicable regulatory requirements and the design basis ... for structures, systems, and components ... are correctly translated into specifications, drawings, procedures, and instructions .... The design control

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i measures shall provide for verifying or checking the adequacy of design ...."  !

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. Contrary to the above, on and before March 19,1998, the design basis for structures, systems. and components were not correctly translated in specifications, 1

drawings, procedures, and instructions and the design control measures did not provide for verifying or checking the adequacy of the design, as identified in the l

.following examples:

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' 1. . In April 1991, the design basis for the thermal overload devices associated

., _ _ . with the RCIC and HPCI loads powered from the de motor control center was not correctly translated into design specifications, in that the licensee used as a design input for_ the reactor building ambient temperature 104*F rather than 148*F, as specified in the calculations of record.

2.' in April 1991, the design basis for the 20 kVA safety-related inverters was not correctly translated in inverters protective device design specifications in

, that the licensee failed to consider the inverters minimum voltage and efficiency in the setting of the protective devices.

3. Items 5.f. and 6 f. In Table 3.3.2-2 of the Hope Creek technical specifications r rate that signals are generated to isolate the reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) turbine steam supply, if the difference between the room exhaust ind supply air temperatures exceeds 70*F. The table also specifies c:. al!)wable differential temperature of 80*F.

On March 12,-1996, the licensee approved a design change to move the-temperature' sensors in the supply air ducts of the RCIC and HPCI rooms downstream of in-duct heaters. However, the design control measures were inadequate in that the verification process of the design change failed to-

. check the adequacy of the revised design and its impact on the TS-apacified setpoints.

~ 4. Section 8.3.2.1.2.2 of the UFSAR states, "The initial battery capacity is 25% greater than required. This margin is consistent with the battery replacement criterion ... in IEEE 450-1975 and is in addition to a 5 to 10 percent margin allowed for load growth and/or for less than optimum operating condition of the battery."

On August 27,1997, the design control measures were not in place for the design margin of the battery in that the licensee issued a UFSAR change notice reducing the minimum battery design margin stated in the UFSAR from 5% to 0% without verifying the adequacy of the battery design under less than optimum operating conditions.

5. . In May 1985, the design control measures were not in place to assure that the design basis for the heating and ventilation (HVAC) system of the control room and the safety-related panel room was correctly translated in surveillance procedures, in that the chilled water outlet temperature for these areas was set to be maintained between 43 and 47*F and between 45 and J 49*F, respectively.yThe chilled water temperature limits specified in the  :

- FSAR and in the HVAC design calculations were 45 and 47*F, respectively.

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, 6. In March 1996, the licensee approved a design change to install a RHR L

cross-over pipe in the "D" RHR room. However, the design control measures were inadequate, in that the verification process of the design change failed to ensure, prior to the installation of the design modification, that the placement of an 18-inch RHR pipe in close proximity of the ECCS room cooler air inlet did not block and reduce the cooler air flow rates and impact the room cooler performance.

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

D.  : 10 CFR 50, Appendix B, Criterion XVI, requires, in part, that: " Measure shall be

. established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..."

e Contrary to the above, on and before March 19,1998, conditions adverse to quality were not promptly identified and corrected. In addition, for significant conditions- e

. adverse to quality, corrective action was not taken to preclude repetition, as listed-in the following examples.

L 1. NRC Information Notice (lN) 97-53 and other industry data apprised licensees that the switchgear is in an unanalyzed condition when the circuit breakers are left in a racked-out position.

In 1997, the licensee's review of the IN evaluated only the seismic hazards from 480 Vac circuit breakers in the racked-out position, but failed to identify and correct the hazards from the 125 and 250 Vdc circuit breakers, and failed to identify and correct the unanalyzed condition of all safety-l . related low voltage (125 Vde, 250 Vde, and 480 Vac) switchgear with l circuit breakers in the racked-out position.

I r 2. The licensee failed to preclude repetitive battery charger losses, a significant condition adverse to quality, in that the corrective actions taken to address a failure of the battery charger overvoltage shutdown did not prevent further failures.

3. Between July 1996 and March 1998,the licensee failed to assure the ability of the hydrogen-oxygen analyzer system to perform its post-accident function, a significant condition adverse to quality, in that the actions taken to address the drop of reagent gas pressure below the minimum required, did not prevent further pressure drops. j

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4. Following their discovery, in April 1997, of age-related degradation of normally-energized Struthers-Dunn relays, the licensee failed to identify and

, promptly correct a condition adverse to quality, in that they did not ensure that the normally-energized relays that were not being replaced would be able to perform their safety functions during and following a seismic event.

5. Following their determination, in November 1997, that the operating temperature rise of normally-energized Agastat E7000 relays in harsh environment exceeded the qualification temperature of the relays, the licensee failed to identify and promptly correct a condition adverse to quality, in that their analysis was insufficient to assure the ability of the relays to perform their post-accident safety functions.

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

E. Licensee condition 2.C.7 requires, in part, that PSE&G implement and maintain in effect all provisions of the approved Fire Protection Program. Step 5.4.3 of fire protection procedure HC.FP-AP.ZZ-0004, Revision 3, " Actions for inoperable Fire

. Protection - Hope Creek Station," which is part of the Hope Creek fire protection - I

. program, requires that, in the event a standby 8-hour battery-powered emergency light unit becomes inoperable, the NSS/SNSS be notified.

Contrary to the above, on March 23,1997, fire protection technicians identified five inoperable emergency lighting units due to dead batteries, but failed to notify the NSS/SNSS.

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

F. Hope Creek Technical Specification 3.7.3 requires, in part, that flood protection be provided for all safety related systems, components and structures when the water level of the Delaware reaches 95 feet PSE&G datum at the service water intake structure. With the water level at the service water intake structure above 95 feet PSE&G datum, initiate and complete: (1) the closing of all service water intake structure watertight perimeter flood doors identified in Table 3.7.3-1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />; and (2) the closing of all power block watertight perimeter flood doors identified in Table 3.7.3-1 within 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Once closed, all access through the doors shall be

, administratively controlled. 1 Contrary to the above, on March 9,1998, with Delaware River water level still above 95 feet PSE&G datum, operators failed to administratively control all access i

. through four service water intake structure watertight flood doors, identified in Table 3.7.3-1,in that they closed, but immediately reopened the doors without posting an individual at the doors to control access.

l This is a Severity Level IV violation (Supplement I), i l

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, Pursuant to the provisions of 10 CFR 2.201, Public Service Electric & Gas Company is l- 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 I

, 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 l

corrective steps 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 be achieved. .Your response may reference or include previous docketed correspondence, if l: .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, .. - ;

l Washington, DC 20555-0001. I Because your response will be placed in the NRC Public Document Room (PDR), to the - -

L, A extent possible, it should not include any personal privacy, proprietary, or safeguards - -

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information so that it can be placed in the PDR without redaction. If personal privacy or- i 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 muit specifically identify the portions of your response  ;

that you seek to have withheld and provide in detail the bases for your claim'of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy nr 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

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protection described in 10 CFR 73.21.

, Dated at King of Prussia, Pennsylvania

. this 10th day of June,1998 f

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