EA-04-086 - Hope Creek 1 (PSEG Nuclear LLC)

May 10, 2004

EA-04-086

Mr. Roy A. Anderson
Chief Nuclear Officer and President
PSEG Nuclear LLC - N09
P. O. Box 236
Hancocks Bridge, NJ 08038

SUBJECT:

FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND NOTICE OF VIOLATION (NRC Inspection Report 05000354/2003006) Hope Creek Nuclear Generating Station

Dear Mr. Anderson:

The purpose of this letter is to provide you with the final results of our significance determination for the preliminary White finding identified at the Hope Creek Nuclear Generating Station during an inspection completed on December 31, 2003. The results of the inspection were discussed with Mr. J. Hutton and other members of your staff on January 21, 2004. The inspection finding was assessed using the significance determination process and was preliminarily characterized as White, a finding with low to moderate importance to safety, which may require additional NRC inspections.

This preliminary White finding resulted from a self-revealing event and involved maintenance procedures that you found had failed to contain adequate instructions and were not followed, which contributed to the "A" station service water system (SSWS) traveling screen failure that occurred on July 1, 2003. The unavailability of the SSWS traveling screen increased the likelihood of the loss of service water initiating event and affected the ability of a service water pump train to mitigate the effects of initiating events.

Regarding the finding, a maintenance procedure did not include appropriate quantitative acceptance criteria to ensure that the SSWS traveling screen head-shaft key was installed correctly, and as a result, the key was cut too short by maintenance workers. Also, the traveling screen basket chains had not been tensioned adequately in accordance with another maintenance procedure, and they failed to document that this procedure had been completed.

In a letter dated April 20, 2004, the NRC transmitted the referenced inspection report and informed you that the staff had sufficient information to make an enforcement decision. However, you were given an opportunity to request a regulatory conference or to provide a written response. In a telephone conversation on May 3, 2004, Mr. S. Mannon, PSEG Nuclear LLC, informed Mr. W. Lanning, NRC, Region I, that the licensee will not request a Regulatory Conference nor provide a written response prior to issuance of this Final Significance Determination.

After considering the information developed during the inspection, the NRC has concluded that the inspection finding at Hope Creek is appropriately characterized as White, an issue with low to moderate importance to safety, which may require additional NRC inspection. Although you have not indicated a desire to do so, our process allows 30 calendar days from the date of this letter to appeal the staff's determination of significance for the identified White finding. Such appeals will be considered to have merit only if they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.

The NRC has also determined that the White finding resulted in two examples of a violation of 10 CFR 50, Appendix B, Criterion V, as described in the enclosed Notice of Violation (Notice). The circumstances surrounding this violation are described in detail in the subject inspection report. In accordance with the NRC Enforcement Policy, NUREG-1600, the Notice is considered escalated enforcement action because it is associated with a White finding. You are required to respond within 30 days of the date of this letter and should follow the instructions specified in the enclosed Notice when preparing your response.

This issue causes the Hope Creek facility to be in the regulatory response band of the NRC Action Matrix, and we will notify you, by separate correspondence, of any further action we plan to take.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at the Public NRC Library. The NRC also includes Issued Significant Enforcement Actions on its Web site.

		Sincerely,
		/RA/
		Hubert J. Miller Regional Administrator

Docket No. 50-354
License No. NPF-57

Enclosure: Notice of Violation

cc w/encl:
C. Bakken, Senior Vice President Nuclear Operations
M. Brothers, Vice President - Site Operations
J. T. Carlin, Vice President Nuclear Assurance
D. F. Garchow, Vice President, Engineering and Technical Support
W. F. Sperry, Director Business Support
S. Mannon, Manager - Licensing (Acting)
J. A. Hutton, Hope Creek Plant Manager
R. Kankus, Joint Owner Affairs
J. J. Keenan, Esquire
Consumer Advocate, Office of Consumer Advocate
F. Pompper, Chief of Police and Emergency Management Coordinator
M. Wetterhahn, Esquire
J. Lipoti Ph.D., Assistant Director of Radiation Programs, State of New Jersey
H. Otto, Ph.D., DNREC Division of Water Resources, State of Delaware
N. Cohen, Coordinator - Unplug Salem Campaign
W. Costanzo, Technical Advisor - Jersey Shore Nuclear Watch
E. Zobian, Coordinator - Jersey Shore Anti Nuclear Alliance

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NOTICE OF VIOLATION

PSEG Nuclear LLC Hope Creek Nuclear Generating Station

Docket No. 50-354 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.

Pursuant to the provisions of 10 CFR 2.201, PSEG Nuclear LLC is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA-04-086" and should include for the violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), which is accessible from the NRC Web site at the Public NRC Library. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated this 10th day of May 2004.