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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/98-02 on 980423.Response Indicated Violations Corrected & Measures Initiated to Prevent Recurrence
	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)
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September 11,1998

Mr. Harold W. Keiser - l

President and Chief Nuclear Officer ;

Nuclear Business Unit

Public Service Electric & Gas Company

PO Box 236 !

. 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. '

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 !

Projects Branch 3 !

Division of Reactor Projects .

Docket No. 50-354

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9809220035 990911

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Mr. Harold W. Keiser 2

l- 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 j

D.' Powell, Director - Licensing / Regulation & Fuels '

A. C. Tapert, Program Administrator

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cc w/cy of Licensee's Response Letter- l

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 l

State of Delaware

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Mr. Harold W. Keiser 3 ,

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Distribution w/ copy'of Licensee's Response Letter:

Region i Docket Room (with concurrences) f

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Nuclear Safety information Center (NSIC) ;

NRC Resident inspector - I

PUBLIC

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J. Linville, DRP !

S. Barber, DRP

L. Harrison, DRP l'

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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 i

R. Correia, NRR '

F. Talbot, NRR :

Inspection Program Branch, NRR (IPAS)

DOCDESK

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DOCUMENT NAME: P.: -

T3 receive e copy of this document, Indicate in the bou: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N"= .

~ No copy '

OFFICE Rl/DRP _

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NAME JLinville W[

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DATE

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09/10/98U 09/ /98 09/ /98 09/ /98 09/ /98

OFFICIAL RECORD COPY

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Public Serv,ce

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l tmis F. Storz Putse semce Doctric and Gas Company P.O. Box 236. Hancocks Bndge. NJ 08038 009-339-5700 [

l LR-N980253

United States Nuclear Regulatory Commission

Document Control Desk

Washington, DC 20555 "

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

of temporary equipment in the service water intake structure. Three examples were ,

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 I

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 ,

water intake structure housekeeping responsibilities are being assigned to the '

l maintenance supervisors. Additionally, a list of expectations is being developed, and

i the maintenance supervisors will be accountable to maintain the service wr=ter intake

structure in accordance with these management expectations. I

The PSE&G response for this violation is contained in Attachment 1 of this letter. If you i

l have any questions or comments on this transmittal, please contact Robin Ritzman at l

l (609) 339-1445.

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LR,N980253 -2-

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C United States Nuclear Regulatory Commission I

Document Control Desk ,

Washington, DC 20555 i

Mr. H. Miller, Administrator- Region 1 !

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 i

One White Flint North l

11555 Rockville Pike

Mail Stop 14E21

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Rcckville, MD 20852 '

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

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 j

SERVICE WATER INTAKE STRUCTURE i

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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 ,

include appropriate quantitative or qualitative accomplishment criteria.

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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 I

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 1

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

i- system withcut completing a 10 CFR 50.59 safety evaluation. Hope Cree

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troubleshooting procedure, HC.OP-GP.ZZ-0008 (Q), Revision 1, " Operations

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

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2. Reply to Notice of Volation

PSE&G agrees with the violation. l

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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 !

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 '

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 l

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temporary discharge hose on the "A" & "C" service water bay sump pump system

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 ;

evaluation was required. The STA incorrectly determined that a 10CFR50.59 safety i

evaluation was not required because he did not recognize that a change to a drawing

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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 I

Violation (1)

a) A work order activity was added to the Service Water Strainer preventive i

maintenance work order to control platform installation. !

b) The Service Water Strainer procedures that use the platform were revised to include

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steps about platform installation and inspection. ;

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c) The work order activity and the procedure revisionc have been reviewed with the

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maintenance department at a tailgate session. ;

Violation (2) !

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a) The floor drain plugs were removed from the "A" and "C" service water bay and the

"B" and "D" service water bay. l

b) The procedural requirements for controlling floor drain plugs were reviewed with l

operations personnel. !

Violation (3)

a) The 10CFR50.59 safety evaluation was completed after the troubleshooting process ;

was transferred to the control of the temporary modification process. !

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. l

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Violation (2) i

The procedural requirements for controlling floor drain plugs will be reviewed with

maintenance personnel by June 20,1998.

Violation (3) .

a) The operations troubleshooting procedure will be reviewed to determine if enhanced j

guidance relative to the need for 10CFR50.59 safety evaluations is required. This {

review will be completed by July 3,1998. I

b) The STA qualifications will be revised to include the necessary 10CFR50.59 training. l

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.

6. Date When Full Compliance Will Be Achieved

Violation (1) j

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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ML20151Z594

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