LR-N04-0241, Reply to Notice of Violation EA-04-086 Issued on 05/10/2004

Reply to Notice of Violation EA-04-086 Issued on 05/10/2004

ML041740717
Person / Time
Site:	Hope Creek
Issue date:	06/08/2004
From:	Brothers M Public Service Enterprise Group
To:	Document Control Desk, NRC Region 1
References
EA-04-086, LR-N04-0241
Download: ML041740717 (5)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236

,I LR-N04-0241 O)PSEG NuclearLLC JUN 0 8 2004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 REPLY TO NOTICE OF VIOLATION EA-04-086 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 On May 10, 2004, the NRC issued a, "Final Significance Determination for a White Finding and Notice of Violation," concerning the 'A' station service water system (SSWS) traveling screen failure that occurred on July 1, 2003. Attachment 1 provides PSEG Nuclear's response to the Notice of Violation.

Should you have any questions concerning this submittal, please contact Brian Thomas at 856-339-2022.

Sincerely, Michael Brothers Vice President - Site Operations I,/

95-2168 REV. 7199

JUN 0 8 2004 Document Control Desk 2 LR-N04-0241 C Mr. Hubert J. Miller Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Attn: Mr. D. Collins, Licensing Project Manager - Hope Creek Mail Stop 08C2 Washington, DC 20555 USNRC Resident Inspector (X24)

Hope Creek Generating Station Mr. K Tosch, Manager IV Bureau of Nuclear Engineering P.O. Box 415 Trenton, NJ 08625 2

Attachment I LR-N04-0241 Reply to Notice of Violation EA-04-086 NOTICE OF VIOLATION PSEG Nuclear LLC Docket No. 50-354 Hope Creek Nuclear Generating Station License No. NPF-57 EA-04-086 During an NRC inspection conducted between September 28, 2003 and December 31, 2003, for which our exit meeting was held on January 21, 2004, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 50 Appendix B, Criterion V, "Instructions, Procedures and Drawings" requires that activities affecting the quality of safety-related equipment functions be accomplished in accordance with documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, between June 20 and June 26, 2003, the licensee replaced the head-shaft on the 'A" service water system traveling screen under Work Order 60037345. Procedures directed to be used by the work order failed to contain adequate instructions to perform the maintenance and were not followed, resulting in the subsequent failure of the traveling screen on July 1, 2003. Specifically,

1. Procedure HC.MD-CM.EP-0003(Q), 'Service Water Traveling Screens Overhaul and Repair," Revision 11, did not include appropriate quantitative acceptance criteria to ensure that the vendor-supplied service water system traveling screen head-shaft key was installed correctly. As a result, the key was cut too short during installation.

2. Procedure HC.MD-PM.EP-0001 (Q), 'Service Water Traveling Screen 12 Month Preventative Maintenance," Section 5.4.1, provided acceptance criteria to level the traveling water screen head-shaft while applying tension on the basket chains. The licensee determined that the traveling screen basket chains had not been tensioned adequately during the work, and the licensee failed to document in Work Order 60037345 that the procedure had been completed.

This violation is associated with a WHITE significance determination process finding.

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Attachment 1 LR-N04-0241 Reply to Notice of Violation EA-04-086 Reason for Violation The apparent cause of the failure of the "A"SSWS traveling screen was attributed to the head shaft key being cut too short due to the lack of procedural guidance for the minimum key length.

The failure to properly tension the basket chains under Work Order 60037345 was due to the procedure steps being marked as "not applicable" by Maintenance personnel.

The failure to document the work performed for the tensioning of the traveling screen basket chains in the work order is attributed to less than adequate adherence to maintenance standards for documenting work performed.

Corrective Actions Taken

1. Procedure HC.MD-CM.EP-0003(Q), 'Service Water Traveling Screen Overhaul and Repair," was revised on October 10, 2003, to add a note for the minimum gib key length. A step was also added to this procedure, to direct that the screen needs to be tensioned in accordance with procedure HC.MD-PM.EP-0001,

'Service Water Traveling Screen 12 Month Preventive Maintenance." (Order 70032466 Act 0060)

2. Procedure HC.MD-PM.EP-0001 (Q), 'Service Water Traveling Screen 12 Month Preventive Maintenance," was revised on October 22, 2003, to add a step to run the screen with a test pin after the screen is properly tensioned, if the procedure was being performed to correct mechanical binding or a shear pin failure, prior to returning the screen to service. (Order 70032466 Act 0070)

3. Procedure HC.OP-SO.EP-0001(Q), 'Service Water Traveling Screens System Operation," was revised on October 29, 2003, to include steps to run the screen with a test pin if the screen failed due to a shear pin failure. If the test pin fails during one revolution, then further corrective maintenance is required (possible tension adjustment needed) before the screen can be returned to service. (Order 70032466 Act 0080)

4. Procedure HC.MD-PM-EP-0001, was revised on February 7, 2004, to include a new methodology of tensioning the traveling screens by use of spring compression, headshaft level, and float. (Order 70034020 Act 0090 and Order 70032795 Act 0080)

5. On December 15, 2003, the Hope Creek Maintenance Manager issued a memo to the maintenance superintendents and supervisors concerning procedure 2

Attachment 1 LR-N04-0241 Reply to Notice of Violation EA-04-086 use/adherence and work practices/standards and the necessity to adhere to the maintenance standards. (Order 70033836 Activity 0210)

6. Procedure SH.MD-DG.ZZ-0007(Z), "Maintenance Standards," was revised on April 15, 2004, to add a checklist for Maintenance Technicians and Superviors regarding the proper documentation of work performed. (Order 70032507 Activity 0060).

7. Toolbox training was developed for Maintenance personnel to provide appropriate knowledge in the regulatory requirements associated with maintenance work documentation, completion and record keeping. The traning information was developed on February 1, 2004. The training is being conducted as part of the 2004 Maintenance continuing training. As of the middle of May 2004, approximately 50% of maintenance personnel have completed this training. (Order 70032507 Acts 0070 and 0080)

Corrective Actions to Prevent Recurrence The corrective actions to prevent recurrence are contained in the previous section.

Full Compliance Achieved PSEG Nuclear is in full compliance. -

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