ML20151Z594
| ML20151Z594 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/11/1998 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H Public Service Enterprise Group |
| References | |
| 50-354-98-02, 50-354-98-2, NUDOCS 9809220035 | |
| Download: ML20151Z594 (3) | |
See also: IR 05000354/1998002
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September 11,1998
Mr. Harold W. Keiser -
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President and Chief Nuclear Officer
Nuclear Business Unit
Public Service Electric & Gas Company
PO Box 236
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. Hancocks Bridge, NJ 08038
SUBJECT:
Inspection Report 50-354/98-02
Dear Mr. Keiser:
This letter refers to your May 26,1998, correspondence (LR-N980253),in response to our
April 23,1998 letter regarding the Hope Creek facility.
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Thank you for informing us of the corrective and preventive actions for the Notice of
Violation,'as documented in your letter. The violation involved three examples of failure to
follow administrative controls to ensure proper evaluation and installation of temporary
equipment nearby or supporting the service water system at the service water intake
structure. Your response to the violation indicated that you have corrected the specific '
violations and initiated measures to prevent recurrence. Your response to the violations
will be examined during a future inspection.
Your cooperation with us is appreciated.
Sincerely,
Original Signed by:
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James C. Linville, Chief
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Projects Branch 3
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Division of Reactor Projects
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Docket No. 50-354
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9809220035 990911
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ADOCK 05000354
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Mr. Harold W. Keiser
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cc w/o cy of Licensee's Response Letter:
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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
J. McMahon, Director - QA/ Nuclear Training / Emergency Preparedness
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D.' Powell, Director - Licensing / Regulation & Fuels
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A. C. Tapert, Program Administrator
cc w/cy of Licensee's Response Letter-
A. F. Kirby, lil, 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
State of New Jersey
State of Delaware
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Mr. Harold W. Keiser
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Distribution w/ copy'of Licensee's Response Letter:
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Region i Docket Room (with concurrences)
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Nuclear Safety information Center (NSIC)
NRC Resident inspector -
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PUBLIC
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J. Linville, DRP
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S. Barber, DRP
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L. Harrison, DRP
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C. O'Daniell, DRP
D. Screnci, PAO
B. McCabe, OEDO
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R. Capra, PD1-2, NRR
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R. Ennis, Acting Project Manager, NRR
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R. Correia, NRR
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F. Talbot, NRR :
Inspection Program Branch, NRR (IPAS)
DOCDESK
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DOCUMENT NAME: P.: -
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T3 receive e copy of this document, Indicate in the bou: "C" = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
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~ No copy
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OFFICE
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NAME
JLinville W[
DATE
09/10/98U
09/ /98
09/ /98
09/ /98
09/ /98
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OFFICIAL RECORD COPY
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Public Serv,ce
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MAY 2 61998
c=vany
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Putse semce Doctric and Gas Company
P.O. Box 236. Hancocks Bndge. NJ 08038
009-339-5700
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LR-N980253
United States Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
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Gentlemen:
REPLY TO NOTICE OF VIOLATION
INSPECTION REPORT 354/9842
HOPE CREEK GENERATING STATION
FACILITY OPERATING LICENSE NPF-57
DOCKET NO. 354
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Pursuant to the provisions of 10CFR2.201, Public Service Electric and Gas Company
(PSE&G) hereby submits a reply to the Notice of Violation (NOV) issued to the Hope
Creek Generating Station in a letter dated April 23,1998. The violation involved control
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of temporary equipment in the service water intake structure. Three examples were
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given that contributed to this violation.
This inspection report stated that the administrative controls used to ensure the proper
evaluation and installation of temporary equipment were not always being followed in
the service water intake structure. Although each example of this problem was minor,
the number of these issues suggests that the material condition of the service water
intake structure may warrant increased management attention. As a management
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team, we are committed to improving the maintenance and material condition of the
- service water intake structure. In order to accomplish this improvement, the service
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water intake structure housekeeping responsibilities are being assigned to the
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maintenance supervisors. Additionally, a list of expectations is being developed, and
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the maintenance supervisors will be accountable to maintain the service wr=ter intake
structure in accordance with these management expectations.
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The PSE&G response for this violation is contained in Attachment 1 of this letter. If you
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have any questions or comments on this transmittal, please contact Robin Ritzman at
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(609) 339-1445.
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Sincerely,
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LR,N980253
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United States Nuclear Regulatory Commission
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Document Control Desk
Washington, DC 20555
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Mr. H. Miller, Administrator- Region 1
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U. S. Nuclear Regulatory Commission
475 Allendale Road
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King of Prussia, PA 19406
Mr. R. Ennis, Licensing Project Manager - Hope Creek
U. S. Nuclear Regulatory Commission
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One White Flint North
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11555 Rockville Pike
Mail Stop 14E21
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Rcckville, MD 20852
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Mr. S. Pindale (X24)
USNRC Senior Resident inspector- HC
Mr. K. Tosch, Manager IV
Bureau of Nuclear Engineering
P. O. Box 415
Trenton, NJ 08625
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ATTACHMENT
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RESPONSE TO NOTICE OF VIOLATION
INSPECTION REPORT NO. 50-354/98 02
HOPE CREEK GENERATING STATION
DOCKET NO. 50-354
VIOLATION RELA 1ED TO CONTROL OF TEMPORARY EQUIPMENT IN THE
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SERVICE WATER INTAKE STRUCTURE
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1.
Description of Violation
During an NRC inspection conducted on February 22,1998 to April 4,1998, 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:
10 CFR 50 Appendix B Criterion V requires in part that activities affecting quality shall
be accomplished in accordance with established procedures. These procedures shall
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include appropriate quantitative or qualitative accomplishment criteria.
Contrary to the above, three exarnples of inadequate accomplishment of procedure
controls associated with temporary equipment installed in the Hope Creek service water
intake structure maintenance were identified.
(1)
On February 24,1998, maintenance technicians erected a scaffold work platform
around the "B" service water pump strainer, and on March 31,1998, maintenance
technicians erected a scaffold work platform around the "D" service water pump strainer
without performing the administrative controls and inspections required by maintenance
procedure SH.MD-AP.ZZ-0023 (Q), Revision 0, " Scaffolding Erection, Modification and
Dismantling Guidelines."
(2)
On February 24,1998, several plugs were installed in the floor drains for both the
. "A" & "C" service water bay and the "B" & "D" service water bay without the
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administrative controls required by PSE&G Nuclear Administrative Procedure NC.NA-
AP.ZZ-0013 (Q), Revision 5, " Control of Temporary Modifications."
(3)-
On February 14,1998, equipment operators used a troubleshooting plan and
installed a temporary discharge hose on the "A" & "C" service water bay t' imp pump
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system withcut completing a 10 CFR 50.59 safety evaluation. Hope Cree
troubleshooting procedure, HC.OP-GP.ZZ-0008 (Q), Revision 1, " Operations
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Troubleshooting," requires that a troubleshooting plan not be approved if a 10 CFR 50.59 safety evaluation is required. PSE&G engineers later determined that a 10 CFR 50.50 safety evaluation was required.
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ATTACHMENT
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This is a Severity Level IV violation (Supplement 1).
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Reply to Notice of Volation
PSE&G agrees with the violation.
3.
Reason for the Violation
Violation (1)
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On February 24,1998, maintenance technicians erected a work platform around the "B"
service water pump strainer without adequate administrative controls. A work order
activity was initiated to control the future installation of the work platform. On March 31,
1998, maintenance technicians erected a work platform around the "D" service water
pump strainer without using the new work activity.
After the work platform was constructed, the platform was removed from the scope of
the scaffolding program. Maintenance did not establish administrative controls for
platform installation to replace the scaffolding program controls prior to February 24,
1998. A work order activity to govem the installation of the platform was added to the
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recurring task work orders. The administrative controls were not implemented on March
31,1998, because, although the maintenance department had developed a work order
activity to control the platform installation, the existence of the new work activity had not
been effectively communicated to the individuals installing the platform.
Violation (2)
Plugs were installed in the floor drains for both the "A" and "C" service water bay and
the "B" and "D" service water bay without the required administrative controls due to a
failure to follow administrative procedures. The investigation into this procedural
violaton did not reveal when or why the drain plugs were installed. The drain plugs
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appeared to have been installed years ago, possibly during plant construction.
Violation (3) .
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On February 14,1998, equipment operators used a troubleshooting plan and installed a
temporary discharge hose on the "A" & "C" service water bay sump pump system
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without completing a 10CFR50.59 safety evaluation. The troubleshooting procedure
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required the Shift Technical Advisor (STA) to determine if a 10CFR50.59 safety
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evaluation was required. The STA incorrectly determined that a 10CFR50.59 safety
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evaluation was not required because he did not recognize that a change to a drawing
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ATTACHMENT
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included in the Safety Ard,c Report required a 10CFR50.59 safety evaluation. As a
result, the troubleshooting plan was conducted withoid the necessary.10CFR50.59
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review, which is a violation of station procedures.
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4.
Corrective Steps That Have Been Taken and Results Achieved
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Violation (1)
a) A work order activity was added to the Service Water Strainer preventive
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maintenance work order to control platform installation.
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b) The Service Water Strainer procedures that use the platform were revised to include
steps about platform installation and inspection.
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c) The work order activity and the procedure revisionc have been reviewed with the
maintenance department at a tailgate session.
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Violation (2)
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a) The floor drain plugs were removed from the "A" and "C" service water bay and the
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"B" and "D" service water bay.
b) The procedural requirements for controlling floor drain plugs were reviewed with
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operations personnel.
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Violation (3)
a) The 10CFR50.59 safety evaluation was completed after the troubleshooting process
was transferred to the control of the temporary modification process.
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b) A night order entry was made discussing the lessons leamed from this event.
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c) MARC principles were applied for the human performance issues related to this
problem.
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5.
Corrective Steps That Will Be Taken to Avoid Further Violations
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Violation (1)
No further corrective actions are required.
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ATTACHMENT
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Violation (2)
The procedural requirements for controlling floor drain plugs will be reviewed with
maintenance personnel by June 20,1998.
Violation (3)
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a) The operations troubleshooting procedure will be reviewed to determine if enhanced
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guidance relative to the need for 10CFR50.59 safety evaluations is required. This
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review will be completed by July 3,1998.
b) The STA qualifications will be revised to include the necessary 10CFR50.59 training.
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The STA's who are not 10CFR50.59 qualified will be scheduled for training. The
qualifications will be revised, the training files will be reviewed, and STA's will be
scheduled for training, as appropriate, by June 30,1998.
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Date When Full Compliance Will Be Achieved
Violation (1)
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Full compliance was achieved on April 21,1998, when the procedure revisions
implementing the adequate administrative controls were approved.
Violation (2)
Full compliance was achieved by March 27,1998, when the floor drain plugs were
verified to have been removed.
Violation (3)
Full compliance was achieved on February 19,1998, when a temporary modification
with a 10CFR50.59 Safety Evaluation was approved and implemented.
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