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Only
a couple of months after NRC decreed that PSEG had their
Safety Conscious Work Environment problems ‘fixed’,
NRC’s own inspection reports of Salem and Hope Creek reveal
that the same ‘cross-cutting’ human error problems are
alive and well at Salem and Hope Creek. Below
is an edited portion of the 2 reports. The complete
reports are available on NRC”s ADAMS library: The
bold highlighting was added by me as well. Norm
November
7, 2006 Mr.
William Levis Senior
Vice President and Chief Nuclear Officer PSEG
LLC - N09 P.
O. Box 236 Hancocks
Bridge, NJ 08038 SUBJECT:
HOPE CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT
05000354/2006004 SUMMARY
OF FINDINGS IR
05000354/20060004; 07/01/2006 - 09/30/2006; Hope Creek
Generating Station; Maintenance
Effectiveness, and Maintenance Risk Assessments and
Emergent Work Control. The
report covered a 13-week period of inspection by resident
inspectors, and announced inspections
by regional reactor inspectors and a senior health physics
inspector. One Green non-cited
violation (NCV) and one green finding were identified. The
significance of most findings
is indicated by their color (Green, White, Yellow, or Red)
using Inspection Manual Chapter
(IMC) 0609, "Significance Determination Process"
(SDP). Findings for which the SDP does
not apply may be Green or be assigned a severity level
after NRC management review. The
NRC’s program for overseeing the safe operation of
commercial nuclear power reactors is described
in NUREG-1649, "Reactor Oversight Process,"
Revision 3, dated July 2000. A.
NRC-Identified and Self-Revealing Findings Cornerstone:
Initiating Events Green.
A self-revealing finding was identified when an operations
work control supervisor
caused an inadvertent trip of the 10K107 instrument air
compressor. During
a tagging operation on the 00K107 air compressor, the
supervisor verified that
a key would fit properly in the 00K107 air compressor
uninterruptible power supply
(UPS) by testing it in the in-service 10K107 air
compressor UPS. When the
supervisor removed the key, the 10K107 air compressor
tripped resulting in an
instrument air system transient. PSEG stopped all work
activities to brief crews
on the transient, proper use of human performance tools,
and site procedures. This
performance deficiency is more than minor because it is
associated with the configuration
control and human performance attributes of the Initiating
Events Cornerstone
and affected the cornerstone’s objective to limit the
likelihood of those
events that upset plant stability and challenge critical
safety functions during
power operations. The inspectors completed a Phase 1
screening of the finding
using Appendix A of Inspection Manual “Determining the Significance
of Reactor Inspection Findings for At-Power Situations,”
and determined
that a more detailed Phase 2 evaluation was required to
assess the safety
significance because the finding contributed to both the
likelihood of a reactor
trip and the likelihood that mitigation equipment would
not be available. The
finding was determined to be of very low safety
significance based upon a Significance
Determination Process Phase 2 evaluation. The
performance deficiency
had cross-cutting aspect in the area of human performance
related to the
work practices component in that the individual did not
use human performance
error prevention techniques and proceeded in the face of uncertainty.
(Section 1R13) iv
Enclosure Cornerstone:
Mitigating Systems C
Green.
A self-revealing, non-cited violation of 10 CFR 50,
Appendix B, Criterion XVI,
"Corrective Action," was identified when the 'A'
core spray pump minimum flow
check valve remained open, resulting in 56 hours of
unplanned unavailability of
the 'A' core spray loop. PSEG did not implement corrective
actions developed following
a similar condition on the ‘C’ core spray check valve
on November 12, 2004.
PSEG’s corrective actions included repairing the check
valve, updating the
check valve maintenance procedure, and creation of
periodic preventative maintenance
tasks to internally inspect the core spray pump minimum
flow check valve. This
performance deficiency is more than minor because it is
associated with the equipment
performance attribute of the Mitigating Systems
Cornerstone and affected
the cornerstone’s objective to ensure the availability,
reliability, and capability
of systems that respond to initiating events to prevent
undesirable consequences.
The inspectors determined the finding to be of very low
safety significance
(Green), based on a Phase 1 SDP screening. The
performance deficiency
had a cross-cutting aspect in the area of problem
identification and resolution
in the corrective action program component in that the
appropriate corrective
actions to address the missing pin on the ‘C’ core
spray minimum flow check
valve were not implemented in a timely manner to prevent a
similar failure in
the 'A' core spray minimum flow check valve. (Section
1R12) The
following violation of very low significance (Green) was
identified by PSEG and is a violation
of NRC requirements which meets the criteria of Section VI
of the NRC Enforcement
Policy, NUREG-1600, for being dispositioned as an NCV. C
Technical
Specification (TS) 3.4.2.1, "Safety/Relief
Valves," requires that 13 of the
14 safety relief valves (SRVs) open within a lift setpoint
of +/- 3 percent of the
specified code safety valve function lift setting.
Contrary to this requirement, on
April 21, 2006, PSEG identified that 3 of 14 SRVs
experienced setpoint drift outside
of the TS limit. PSEG entered this issue into their
corrective action program
as notification 20281208. This finding is of very low
safety significance, based
on a Phase 1 SDP screening, because the SRVs would have
functioned to
prevent a reactor vessel over-pressurization inoperability
of three SRVs, but did not result in a loss of system
safety function. November
8, 2006 Mr.
William Levis Senior
Vice President and Chief Nuclear Officer PSEG
LLC - N09 P.
O. Box 236 Hancocks
Bridge, NJ 08038 SUBJECT:
SALEM NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION
REPORT 05000272/2006004 and 05000311/200600 NRC-Identified
and Self-Revealing Findings Cornerstone:
Initiating Events C
Green.
The inspectors identified a non-cited violation of 10 CFR
50, Appendix B, Criterion
V, “Instructions, Procedures, and Drawings,”
for failure to accomplish maintenance
in accordance with procedures. PSEG maintenance personnel omitted
procedure steps to adequately tighten or properly lock a
locknut on the 22
service water strainer during preventive maintenance.
Consequently, the 22 service
water strainer motor tripped due to increased strainer
basket internal interference
after it was returned to service. The
finding is more than minor because it is associated with
the equipment performance
attribute of the Initiating Events cornerstone, and it
affected the cornerstone
objective. Unavailability of the 22 SWS and SWP increased
the likelihood
of a loss of service water. This finding also impacted the
Mitigating Systems
cornerstone objective to ensure the availability,
reliability, and capability of
systems that respond to initiating events to prevent
undesirable consequences.
Specifically, incorrectly performed maintenance degraded
both availability
and reliability of the 22 SWS and SWP. In accordance with
IMC 0609,
Appendix A, “Significance Determination of Reactor
Inspection Findings for
At-Power Situations,” the inspectors conducted a Phase 1
SDP screening and
determined that a more detailed Phase 2 evaluation was
required to assess the
safety significance because the performance deficiency
affected two cornerstones.
However, the Risk-Informed Inspection Notebook for Salem Nuclear
Generating Station does not evaluate loss of service water
initiating events.
Therefore, an NRC Region 1 Senior Reactor Analyst (SRA)
conducted a Phase
3 analysis and determined the finding was of very low
safety significance (Green).
The performance
deficiency has a cross-cutting aspect in the area of human
performance related to the work practices component,
because PSEG did
not effectively communicate expectations regarding
procedure compliance and
personnel did not follow procedures. (Section 1R12) iv
Enclosure C
Green.
The inspectors identified a non-cited violation for
PSEG’s failure to follow Salem
Technical Specification 3.4.11.1.b., Structural Integrity.
PSEG discovered a
leak on the instrument tubing for reactor coolant system
loop flow transmitter 2FT416
and did not properly classify and evaluate the leak for
operability or structural
integrity, or alternatively isolate the affected tubing. The
finding is more than minor because it affects the
Initiating Events cornerstone
objective to limit the likelihood of those events that
upset plant stability
and challenge critical safety functions during shutdown
and at power. The
inspectors determined that the finding was of very low
safety significance (Green)
using a Phase 1 screening in Appendix A of Inspection
Manual Chapter 0609,
“Determining the Significance of Reactor Inspection
Findings for At-Power Situations.”
It is expected that a tubing crack would result in an
increase in reactor
coolant system (RCS) leakage, and operators would take
action prior to exceeding
Technical Specification limits for RCS leakage. Therefore,
assuming worst
case degradation, the finding would not result in
exceeding the Technical Specification
limit for identified RCS leakage and would not have likely
affected other
mitigation systems resulting in a total loss of their
safety function. The performance
deficiency has a cross-cutting aspect in the area of
problem identification
and resolution, related to the corrective action program
component, because
PSEG did not thoroughly evaluate the condition. (Section
4OA3) |