Power Reactor Event Number: 41117

Facility: HOPE CREEK Region: 1 State: NJ Unit: [1] [ ] [ ] RX Type: [1] GE-4 NRC Notified By: BO BEYL HQ OPS Officer: BILL HUFFMAN

 Notification Date: 10/12/2004 Notification Time: 19:45 [ET] Event Date: 10/12/2004 Event Time: 19:34 [EDT] Last Update Date: 10/12/2004

 Emergency Class: NON EMERGENCY 10 CFR Section: OTHER UNSPEC REQMNT Person (Organization): BRIAN MCDERMOTT (R1) BILL BATEMAN (NRR) RICHARD WESSMAN (IRD) Unit SCRAM Code RX CRIT Initial PWR Initial RX Mode Current PWR Current RX Mode 1 N N 0 Cold Shutdown 0 Cold Shutdown

Event Text DISCOVERY OF AFTER-THE-FACT EMERGENCY CONDITION (UNUSUAL EVENT)

 "During a review of post trip activities associated with MANUAL REACTOR SCRAM DUE TO A STEAM LEAK IN THE TURBINE BUILDING (Event 41110) on 10/10/04, it was determined that Technical Specifications actions requirements were inappropriately applied.

With both loops of RHR in suppression pool cooling (necessary with SRV's controlling reactor pressure), procedural guidance requires that the affected loop of RHR be declared inoperable when in a secondary mode of operation.

With both loops of RHR thus inoperable, the applicable Technical Specification Action TS 3.6.2.3 Action b requires that the plant be in at least HOT SHUTDOWN within 12 hours and in COLD SHUTDOWN within the next 24 hours.

"In accordance with the Technical Specification, this action was entered on 10/10/04 at 1831.

The required time to cold shutdown was incorrectly noted as 0631 on 10/12/04.

 The required time was based on the combination of the 12 hours to hot shutdown and 24 to cold shutdown (or 36 hours).

Because the plant was already in hot shutdown, the action should have been to place the plant in cold shutdown within 24 hours or by 1831 on 10/11/04.

 "As a result of this error, planning activities and cooldown to cold shutdown condition was predicated on a target time of 0631 on 10/12/04 resulting in the plant exceeding the 24 hour AOT.

 This constitutes a condition prohibited by Technical Specifications.

The plant achieved cold shutdown on 10/12/04 at 0509 hours.

"In addition, Emergency Classification Guide (ECG) Initiating Condition 8.5 states that the inability to reach required operational condition within Technical Specification Limits and requires the declaration of an Unusual Event if the plant is not brought to the required Operational Condition within the Technical Specification required time limit.

 "There are no safety consequences associated with this error.

There were no issues associated with the transition to cold shutdown that would have constituted an emergency condition requiring initiation of the Emergency Plan.

 The missed LCO and subsequent classification was based on an erroneous TS Action time and, as such, exceeding the specification occurred as a result of scheduling not plant conditions.

" The licensee will inform the NRC resident inspector.