Wednesday, May 16, 2007
Below
are edited lowlights from the Salem/Hope Creek Problem ID inspection.
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Larger font emphasis is mine, not NRC’s.
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As
I point out by the highlighted items, the cross-cutting/ Norm Salem
Nuclear Generating Station Units 1 and 2 and Hope Creek; Biennial
Baseline Inspection of the Identification and Resolution of Problems
(PI&R) The
inspectors identified two findings related to your Fitness-For- Based
on the samples selected for review, the team concluded that overall,
problems were properly identified, evaluated, and corrected. There were
four Green findings identified by the inspectors during this inspection.
The four findings were determined to be violations of NRC requirements. In
addition, some minor issues were identified, including conditions
adverse to quality that had not been entered into the corrective action
program and narrowly focused or incomplete evaluations of problems. A.
NRC Identified and Self-Revealing Findings Cornerstone:
Initiating Events C
Green. A self-revealing non-cited violation of
Technical Specification 6.8.1 was identified when improper maintenance
caused the 12 control area chiller to trip The
performance deficiency was determined to be more than minor because it
rendered the 12 chiller unavailable for use. The performance deficiency
was determined to be of very low risk significance (Green) by a Phase 3
analysis by a regional Senior Risk Analyst. The
performance deficiency had a cross-cutting aspect in the area of human
performance because PSEG
personnel did not follow applicable maintenance procedures when
performing maintenance on the 12 control area chiller unloader device.
(Section 4OA2.3.a) |
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Cornerstone:
Mitigating Systems
C
Green. The NRC identified a non-cited violation of 10 CFR
50, Appendix B,
criterion XVI, ‘Corrective Action’, when the 22 service water (SW) suction
strainer tripped on February 24, 2007, rendering
the 22 service water pump
unavailable for 44 hours to repair the strainer. PSEG
[
did not identify or correct
deficiencies that caused five trips of the 22 SW strainer since March 2006.
PSEG
replaced the 22 service water strainer assembly on March 23, 2007.
The
performance deficiency was determined to be more than minor because it rendered
the 22 service water pump unavailable for use. The finding was determined to be
of very low safety significance (Green) based on a Phase 3 analysis by the
regional Senior Risk Analyst.
The finding had a cross-cutting aspect in the area of Problem Identification and
Resolution in that PSEG
did not thoroughly evaluate a problem such that resolutions addressed
causes and extent of condition. (Section 4OA2.3.b)
Cornerstone:
Physical Security
•
Green. The NRC identified a non-cited violation of 10 CFR 26, Appendix A,
subpart B, 2.3 (1) when the inspectors observed PSEG
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’s fitness-for-
collection technicians and security officers perform urine and breath collection
on
co-workers on March 21, 2007. PSEG
implemented immediate corrective
actions by stopping the practice of collection personnel performing urine and
breath collections on other collection technicians, enhancing the station FFD
procedures, and by conducting FFD testing of the affected individuals.
The
performance deficiency was determined to be more than minor because, if left
uncorrected, it would affect the integrity of the FFD program. The finding was
determined to be of very low safety significance (Green) using the Physical
Protection Significance Determination Process. The finding
had a cross-cutting aspect in the area of Human Performance in
that PSEG
did not have FFD adequate procedures that ensured that the regulatory
requirements prohibiting collectors from collecting samples from co-workers were
followed. (Section 4OA2.3.c.)
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Green. The NRC identified a non-cited violation of 10 CFR 26, Appendix A,
Subpart B, 2.4 (g) (20) when the inspectors observed PSEG
’s fitness-for-
(FFD) collection technicians leaving split FFD urine specimens in unsealed
aliquot tubes and sealed specimen containers in unattended work areas on
March 21, 2007. The licensee implemented immediate corrective measures by
capping and sealing FFD aliquot specimens, requiring that FFD donors witness
the transfer of their FFD urine specimen to a laboratory technician through a
chain-of-custody form, and by sampling an additional 25 percent of PSEG
employees for a FFD test.
The
performance deficiency was determined to be more than minor because, if left
uncorrected, it could affect the integrity of the FFD program. The inspector
determined that the finding was of very low safety significance (Green) using
the Physical Protection Significance Determination Process. The finding
had a cross-cutting aspect in the area of Human Performance in
that PSEG
failed to effectively communicate expectations regarding procedural
compliance and personnel did not follow procedures. (Section 4OA2.3.d.)
Hhousekeeping
and cleanliness of the plant were good with the
exception of a few areas. Particularly, the service water intake structure (SWIS)
pump rooms were dimly lit due to a number of failed lights, had many wet spots
and puddles on the floor due to various water and oil leaks, and contained
several items that were being stored there (hoses, scaffolding, and tools)
contrary to station standards. Further, permanent scaffolding built in the SWIS
pump rooms obstructed lighting and interfered with the viewing of some
components.
The
inspectors identified that equipment malfunction identification system (EMIS)
tag use was inconsistent. The inspectors sampled ten tags hanging on
safety-related equipment in the plant and found that three of the ten tags were
associated with equipment issues that had already been repaired and
administratively closed in the CAP, potentially
masking new problems with the equipment. The inspectors identified
that the station was operating under two procedures for identification of
problems, one of which does not require use of EMIS tags. PSEG
wrote a notification to address the inconsistency and tasked the training group
to evaluate the need for training.
The
inspectors identified a number of minor issues during plant walkdowns that were
not identified by PSEG
in the CAP. For example, before an NRC tour of the Unit 1 auxiliary
building, the inspectors were briefed by radiation protection (RP) technicians
that radioactive spent resin, used to condition primary coolant, was being
drained from the number 1 Spent Resin Storage Tank (SRST) and, therefore, was a
new high radiation area posted in the plant. A draining evolution expected to be
completed in less than one hour took more than 36 hours to complete. PSEG
determined that the normal drain path was clogged. An alternate drain path was
used but was also draining much slower than expected. Although
operations and radiation protection personnel knew of the deficiency, the issue
was not entered into the CAP. Following questions from NRC
inspectors, PSEG
entered the issue into the CAP.
The
inspectors identified a number of maintenance rule (MR) functional failure
determinations for some equipment failures to be weak or incorrect.
Specifically, a sample of MR evaluations for the containment fan coil units,
control area chillers, and the gas-powered turbine generator provided examples
of misidentification of system functional failures (SFF) and maintenance
preventable functional failures (MPFF). All three of these systems were being
monitored against goals in accordance with10CFR50.
The
inspectors identified two instances where defective
equipment was not quarantined for troubleshooting in accordance with station
procedures, but instead was discarded. The first instance involved
troubleshooting a potentially degraded power cable for a containment fan coil
unit (CFCU) motor. Corrective actions were specified to retain and test the
cable to allow engineering to determine the cause of the problem. During
subsequent maintenance activities on the CFCU motor, the suspect cable was
discarded and the extent of cause was not completed. The second instance
involved the failure of damper ABV-1ABS4 on the Unit 1 turbine-driven auxiliary
feed pump high energy line break housing. The instrument air solenoid and the
damper actuator were replaced following the failure. However, the failed parts
were not quarantined and were discarded before engineering could inspect them
and determine the cause of the failure.
The
inspectors identified inconsistencies with documenting the operability of
systems, structures, or components (SSCs) in notifications. Inspectors observed
examples where the initial operability screening of an issue was not documented.
Nevertheless, staff at the SOC and MRC meetings assumed that an operability
determination had been made and did not question if the operability of the SSC
was known. One example was notification 20315317, “2CS26 Pipe Hanger is
Missing Pin.” The notification was created on March 5, 2007, at 1:46 p.m. At
the SOC meeting at 10:00 a.m. on March 6, 2007, there was no operability
declaration on the notification. The failure to document an SSC’s initial
operability screen has the potential to reduce the effectiveness of the SOC and
MRC.
The
inspectors identified one unresolved item. On October 5, 2005, PSEG
discovered that both dampers, S1-ABV-1ABS4 and S1-ABV-1ABS20, for the Unit
1 turbine-driven auxiliary feedwater (TDAFW) pump high energy line break (HELB)
enclosure failed. An operability determination was completed for the impact on
safety-related equipment for the failure of S1-ABV-1ABS4. However, an
operability determination was not performed for the cumulative impact of both
dampers failing for the TDAFW pump. The configuration resulting from the two
failed dampers may result in the inoperability of the TDAFW pump. PSEG
is analyzing the configuration to determine if the TDAFW pump was
inoperable beyond its TS allowed outage time. This issue is related to past
operability of the TDAFW pump. No current deficiencies were identified with the
TDAFW HELB dampers. This item is unresolved pending NRC review of PSEG
’s analysis of the TDAFW pump operability. (URI
05000272/2007006-
The inspectors determined that PSEG ’s audits and self-assessments were adequate. However, the inspectors identified a potential weakness in the methodology that PSEG used to assess problem identification effectiveness in the 2007 CAP FASA. The FASA evaluation consisted of a review of documentation, including notifications, corrective maintenance orders, operating logs, system engineering notebooks, and observation of management meetings. The FASA focused on whether identified problems were placed in the CAP. The inspectors identified that the self-assessment did not independently identify problems in the plant and measure the effectiveness of the staff to identify issues. This weakness was made apparent when, despite the very high volume of notifications generated at Salem, the inspectors identified several minor issues during plant walkdowns that were not in the CAP.