ML20140G851
| ML20140G851 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/12/1997 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eliason L Public Service Enterprise Group |
| References | |
| 50-354-97-01, 50-354-97-1, NUDOCS 9706170107 | |
| Download: ML20140G851 (3) | |
See also: IR 05000354/1997001
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June 12, 1997
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Mr. Leon R. Eliason
Chief Nuclear Officer and President
Nuclear Business Unit
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Public Service Electric & Gas Company
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Post Office Box 236
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Hancocks Bridge, New Jersey 08038
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SUBJECT: NRC INSPECTION NOS. 50-354/97-01
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Dear Mr. Eliason-
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This letter refers to your May 13,1997 correspondence, in response to our April 14,1997
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letter.
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Thank you for informing us of the corrective and preventive acdans documented in your
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letter regarding the evaluation, control and tracking of temperary tcaffolding in your Hope
Creek facility. To date, your immediate actions appear to be er ctive. However, these
actions will be examined further during future inspections at Hope Creek.
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Your cooperation with us is appreciated.
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Sincerely,
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ORIGINAL SIGNED BY:
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James C. Linville, Chief
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Projects Branch 3
Division of Reactor Projects
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Docket No.
50-354
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9706170107 970612
ADOCK 05000354
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Mr. L. Eliason
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cc:
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L. Storz, Senior Vice President - Nuclear Operations
E. Simpson, Senior Vice President - Nuclear Engineering
E. Salowitz, Director - Nuclear Business Support
M. Bezilla, General Manager - Hope Creek Operations
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J. McMahon, Director - Quality Assurance & Nuclear Safety Review
D. Powell, Manager - Licensing and Regulation
A. C. Tapert, Program Administrator
L. G. Canton, Regional Director, FEMA, Region 11 (EP Exercise /lRs Only)
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cc w/ copy of licensee letter:
A. F. Kirby, Ill, External Operations - Nuclear, Delmarva Power & Light Co.
J. A. Isabella, Manager, Joint Generation
Atlantic Electric
R. Kankus, Joint Owner Affairs
Jeffrey J. Keenan, Esquire
M. J. Wetterhahn, Esquire
Consumer Advocate, Office of Consumer Advocate
William Conklin, Public Safety Consultant, Lower Alloways Creek Township
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State of New Jersey
State of Delaware
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Mr. L. Eliason
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Distribution w/ copy of licensee letter:
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Region i Docket Room (with concurrences)
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K. Gallagher, DRP
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D. Screnci, PAO
J. Linville, DRP
S. Barber, DRP
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Nuclear Safety Information Center (NSIC)
NRC Resident inspector
W. Dean, OEDO
D. Jaffe, Project Nianager, NRR
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J. Stolz, PDI-2, NRR
Inspection Program Branch, NRR (IPAS)
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R. Correia, NRR
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F. Talbot, NRR
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DOCDESK
PUBLIC
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DOCUMENT NAME:g:\\ BRANCH 3\\REPLYLTR.HC
To receive e copy of this document, indicate in the box: 'C" = Copy without ettechment/ enclosure
- E' = Copy with attachment / enclosure
"N ~ = No copy
OFFICE
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NAME
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DATE
64g/97
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OFFICIAL RECORD COPY
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Pubhc Service
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Electne and Gas
Company
Louis F. Storr
Public Service Electric and Gac Company
P.O. Box 236 Hancocks Bridge. NJ 08038
609-339-5700'
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s.a ve. n o m. m .,on.,
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MAY 13 1997
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LR-N970290
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United States Nuclear-Regulatory Commission
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Document Control Desk
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20555
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REPLY TO NOTICE OF VIOLATION
INSPECTION REPORT NO. 50-354/97-01
HOPE CREEK GENERATING STATION
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FACILITY OPERATING LICENSE NPF-57
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DOCKET No. 50-354
Ladies & Gentlemen:
Pursuant to the provisions of 10CFR2.201, Public Service
Electric and Gas Company (PSE&G) hereby submits a reply to
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the notice of violation (NOV) issued to the Hope Creek
Generating Station in a letter dated April 14, 1997.
The
details of the reply are contained in the attachments to
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this letter.
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Should you have any questions or comments on this
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transmittal, do not hesitate to contact us.
Sincerely,
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Attachment
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Printed on
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Document Control Desk
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LR-N970290
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Mr. H. J.-Miller, Administrator - Region I
U.
S. Nuclear Regulatory Commission
475 Allendale Road
King of Prussia, PA 19406
Mr. D.,Jaffe, Licensing Project Manager - Hope Creek
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U.
S. Nuclear Regulatory Commission
One White Flint North
'11555 Rockville Pike
Mail Stop 14E21
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Rockville, MD 20852
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Mr. R. Summers
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USNRC Senior Resident Inspector (X24)
Mr. K. Tosch, Manager IV
Bureau of Nuclear Engineering
33 Arctic Parkway
CN 415
Trenton, NJ
08625
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REF:
LR-N970290
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STATE OF NEW JERSEY )
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SS.
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COUNTY OF SALEM
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Louis F.
Storz, being duly sworn according to law deposes and
says:
I am Sr. Vice President Nuclear Operations of Public Service
Electric and Gas Company, and as such, I find the matters set
forth in the above referenced letter, concerning the Hope Creek
Generating Station, are true to the best of my knowledge,
information and belief.
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Subscribed and Sworn before me
this /g fh
day of
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1997
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Woary'Publifof[ewOersey
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KIMBERLY JD BROWN
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NOTARY PUBllC 0F NEW JEREEY
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My commission expires on
My Commission Enites April 21,1998
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ATTACHMENT 1
SCAFFOLDING DEFICIENCIES
INSPECTION REPORT NO. 50-354/97-01
HOPE CREEK GENERATING STATION
DOCKET NO. 50-354
LR-N970290
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DESCRIPTION OF VIOLATICN
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The description of the violation contained in the notice of
violation received in the April 14, 1997 letter is as
follows:
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A.
Violation
"10 CFR 50 Appendix B Criterion V requires in part that
activities affecting quality shall be accomplished in
accordance with established procedures.
These procedures
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shall include appropriate quantitative or qualitative
acceptance criteria.
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PSE&G Nuclear Administrative Procedure NC.NA-AP.ZZ-0023 (Q),
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Revision 4, " Scaffolding and Transient Loads Control,"
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requires that scaffolding installed in the (Hope Creek)
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station be appropriately tracked in a control log,
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periodically inspected for compliance with construction
criteria, and promptly removed after completion of the work
activity requiring the scaffolding.
Contrary to the above, on February 26, 1997, it was
determined that several scaffolds installed in safety-
related areas, including the "A"
and
"B" RHR pump rooms and
the standby liquid control pump room in the reactor building
of the Hope Creek station lacked appropriate construction
documentation, had insufficient periodic inspections, and
were not removed within a timely manner following the work
activities that required the temporary structures.
This is a Severity Level IV Violation (Supplement I)."
II.
REPLY TO VIOLATION
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PSE&G Position
PSE&G agrees with the violation.
B.
Reason for the Violation
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Procedure NC.NA-AP.ZZ-0023 (Q) , Scaffolding and Transient
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Loads Control, provides detailed guidelines for scaffold
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Attachm2nt 1
LR-N970290
Response to Scaffolding Violation
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erection to satisfy the requirements for seismic II/I, fire
protection, ventilation, and industrial safety.
Recent
scaffolding walkdowns identified deviations from NC.NA-
AP . Z Z-0023 (Q) , including:
insufficient periodic
inspections, inadequate documentation for variances,
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untimely removal of scaffolding, and incorrect scaffold
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logs.
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Based upon review of the failures to adhere to NC.NA-AP.ZZ-
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0023 (Q) and review of the procedure and associated training,
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the cause of the failure to comply with the procedure is
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inadequate design and monitoring of the scaffolding program.
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Lack of program ownership in addition to inadequate training
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resulting in human errors also contributed to the violation.
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With regard to inadequate design of the program, the
instructions for installation and removal of scaffolding are
contained in an upper-tier administrative procedure that
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controls both scaffolding and transient loads.
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combination of these two factors resulted in a cumbersome
and unclear procedure.
With regard to inadequate training, personnel involved in
the installation and removal of scaffolding are provided
with only 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of a combination of classroom and hands on
training.
Because there are no qualification requirements
for personnel involved with scaffolding, not all personnel
performing the work had received training.
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With regard to inadequate monitoring of the program, a
method or requirement to audit the scaffold control log and
the periodic inspections on a recurring basis did not exist
and therefore audits were not performed.
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As a result of the deficient procedure, inadequate training,
and lack of program ownership, adherence to the procedure
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was not consistent.
Periodic inspections were not performed
as required, forms were not completed as required, and
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scaffolding was not removed in a timely manner following
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completion of work activities.
C.
Corrective Steps That Have Been Taken or Are Ongoing
and Results Achieved
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Equipment operability concerns resulting from seismic
proximity problems with scaffolding installed in the
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'A'
and
'B'
Residual Heat Removal pump rooms were
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resolved.
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Attschment 1
LR-N970290
Response to Scaffolding Violation
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2.
The scaffolding installed in the Standby Liquid Control
pump room has been inspected and the appropriate NC.NA-
AP . ZZ-0023 (Q) documentation has been completed.
3.
Actions have been taken to ensure that the scaffolding
currently installed in seismic controls areas is
supported by the appropriate NC.NA-AP.ZZ-0023 (Q)
documentation and has current inspections.
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Scaffolding supporting completed work activities has
been evaluated for removal.
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A single organization has been appointed as owner of
the scaffold program.
6.
Meetings were conducted with Hope Creek Maintenance,
Civil Design Engineering and Nuclear Operations
Services personnel to discuss the seismic II/I
requirements of NC.NA-AP. ZZ-0023 (Q) .
7.
Procedure adherence expectations were re-emphasized to
the Civil Engineering Group.
8.
Procedure adherence expectations are being re-
emphasized during the Hope Creek Maintenance
Intervention, which began on April 21, 1997.
D.
Corrective Steps That Will Bo Taken to Avoid Further
Violations
1.
Interim guidance for scaffold use and control will be
communicated to appropriate departments by May 16,
1997.
This guidance is consistent with, but in
addition to, NC.NA-AP.ZZ-0023 (Q) .
2.
Scaffolding installed in high radiation areas will be
inspected based upon ALARA concerns.
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3.
Scaffolding deemed acceptable to be removed will be
removed by May 23, 1997.
Scaffolding removal in high
radiation areas will be based upon ALARA concerns.
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4.
To address the cause of inadequate program design and
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monitoring, the Scaffolding and Transient Loads Control
Procedure, NC.NA-AP. ZZ-0023 (Q) , will be revised by July
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15, 1997.
The revised procedure will continue to
control scaffolding and will address the timeliness
issue discussed in this violation.
The control of
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