ML20248C425
| ML20248C425 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/26/1998 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-354-98-02, 50-354-98-2, NUDOCS 9806020147 | |
| Download: ML20248C425 (6) | |
Text
0-fc c MAY 2 61998 s
as Cornpany Louis F. storz Pubhc service Electric ard Gas Company P.O. Box 236. Hancocks Brdge, NJ 08038 609-339-5700 l
w,or v.c. n ioern. nuci.., opo,. ion.
WNMMM United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT 354/98-02 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 i
DOCKET NO. 354 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 invol esd control of temporary equipment in the service water intake structure. Three examples were 4
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 j
intake structure may warrant increased management attention. As a management 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 maintenance supervisors. Additionally, a list of expectations is being developed, and i
the maintenance supervisors will be accountable to maintain the service water intake structure in accordance with these management expectations.
The PSE&G response for this violation is contained in Attachment 1 of this letter. If you have any questions or comments on this transmittal, please contact Robin Ritzman at (609) 339-1445.
Sincerely, r
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C United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Mr. H. Miller, Administrator-Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, 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 I
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ATTACHMENT 4
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-354/98-02
]
HOPE CREEK GENERATING STATION 1
DOCKET NO. 50-354 VIOLATION RELATED TO CONTROL OF TEMPORARY EQUIPMENT IN THE SERVICE WATER INTAKE STRUCTURE 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 J
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.
Contrary to the above, three examples 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 withoet performing the administrative controls and inspections required by maintenance procedure OHf/,D-AP.ZZ-0023 (Q), Revision 0, " Scaffolding Erection, Modification and DismanG5 6didelines."
(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 administrative controls required by PSE&G Nuclear Administrative Procedure NC.NA-AP.ZZ-0013 (Q), Revision 5, " Control of Temporary Modifications."
1 (3)
On February 14,1998, equipment operators used a troubleshooting plan and f
installed a temporary discharge hose on the "A" & "C" service water bay sump pump system without completing a 10 CFR 50.59 safety evaluation. Hope Creek 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 50.59 safety evaluation was required.
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ATTACHMENT.
This is a Severity Level IV violation (Supplement 1).
j 2.
Reply to Notice of Violation PSE&G agrees with the violation.
~ 3.
Reason for the Violation Violation (1)
On February 24,1998, maintenance technicians erected a work platform around the "B" service water pump strainer without adequate administrative controls. A work order activit/ 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 L
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 govern 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 violation 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)~
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
~ without completing a 10CFR50.59 safety evaluation. The troubleshooting procedure
. req'uired the Shift Technical Advisor (STA) to determine if a 10CFR50.59 safety evaluation was required. The STA incorrectly determined that a 10CFR50.59 safety evaluation was not required because he did not recognize that a change to a drawing i
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ATTACHMENT included in the Safety Analysis Report required a 10CFR50.59 safety evaluation. As a result, the troubleshooting plan was conducted without the necessary 10CFR50.59 review, which is a violation of station procedures.
4.
Corrective Steps That Have Been Taken and Results Achieved Violation (1) a) A work order activity was added to the Service Water Strainer preventive maintenance work order to control platform installation.
b) The Service Water Strainer procedures that use the platform were revised to include steps about platform installation and inspection.
c) The work order activity and the procedure revisions have been reviewed with the maintenance department at a tailgate session.
Violation (2)
- a) The floor drain plugs were removed from the "A" and "C" service water bay and the "B" and "D" service water ' ay, o
b) The procedural requirements for controlling floor drain plugs were reviewed with operations personnel.
i 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 learned from this event.
c) MARC principles were applied for the human performance issues related to this problem.
5.
Corrective Steps That Will Be Taken to Avoid Further Violations Violation (1)-
No further corrective actions are required.
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n ATTACHMENT j.
Violation (2)
The procedural requirements for controlling floor drain plugs will be reviewed with l
maintenance personnel by June 20,1998.
Violation (3) _
a) The operations troubleshooting procedure will be reviewed to determine if enhanced guidance relative to the need for 10CFR50.59 safety evaluations is required. This l
review will be completed by July 3,1998.
b) The STA qualifications will be revised to include the necessary 10CFR50.59 training.
' 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)
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) l Full compliance was achieved on February 19,1998, when a temporary modification l
with a 10CFR50.59 Safety Evaluation was approved and implemented.
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