On June 30, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Salem Nuclear Generating Station, Unit Nos. 1 and 2.
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -NRC INTEGRATED INSPECTION
REPORT 05000272/2007003 and
Based
on the results of this inspection, the NRC has determined that a Severity Level
IV violation of NRC requirements occurred.
The
violation was evaluated in accordance with the NRC Enforcement Policy included
on the NRC’s web site at www.nrc.gov;
select What We Do,
Enforcement,
then Enforcement Policy. The violation is cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding it are described in detail
in the subject inspection
report.
The violation is being cited in the Notice because PSEG Nuclear LLC did not meet
the requirements of 10 Code of Federal Regulations (CFR) 50.55a(g)(5)
50.55a(g)(5)
During
an NRC inspection conducted between April 2, 2007, and April 27, 2007, a
violation of NRC requirements was identified. In accordance with the NRC
Enforcement Policy, the
violation
is listed below:10 CFR 50.55a(g)(5)
Commission
not later than 12 months after the expiration of the initial 120-month period of
operation from start of facility commercial operation and each subsequent
120-month
period
of operation during which the examination is determined to be impractical. 10
CFR 50.55a(g)(5)
Contrary
to the above, PSEG Nuclear LLC determined that conformance with the code requirement
for 100% inspection of 69 Class 1 welds and 29 Class 2 welds at Salem Nuclear
Generating Station, Unit 2, during ISI interval 2 (May 10, 1992 - November 23,
2003), was impractical, however, (1) the basis for the termination was not
demonstrated
to
the satisfaction of the Commission within 12 months after the expiration of ISI
interval 2; and, (2) while PSEG notified the Commission of its determination on
March 21, 2006,
28
months after the end of ISI interval 2, it did not submit the information
necessary to support the determinations.
This
is a Severity Level IV violation (Supplement I).
This
violation is a result of PSEG Nuclear LLC’ s failure to apply for a relief
request for the inservice inspection (ISI) program within 12 months after the
completion of the second ISI interval.
You
are required to respond to this letter and you should follow the instructions
specified in the enclosed Notice when preparing your response. In addition to
the information required in the
Notice,
your reply should include: (1) an evaluation demonstrating that Salem Unit 2
systems affected by this failure were operable during the period from November
23, 2003, to the
present;
and (2) an assessment of the effect of the incomplete inspections on the current
ISI interval 3 which began on November 24, 2003. The NRC will use your response,
in part, to
determine
whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
And
here’s the other findings:
Cornerstone:
Initiating Events
•
Green. A self-revealing finding for improper
maintenance on a demineralizer sight glass
was identified when the sight
glass catastrophically failed
and
initiated
a condensate system transient that resulted in a reactor
trip.
Contrary to vendor recommendations that each sight glass be installed and
torqued in
place
only one time, maintenance technicians had re-installed the sight glass on the
demineralizer following vessel maintenance. PSEG replaced all Unit 2
demineralizer
sight glasses before the subsequent Unit 2 startup. The finding is greater than
minor because it is associated with the equipment performance
attribute
of the Initiating Events cornerstone, and because it adversely affects the
cornerstone objective of limiting the likelihood of those events that upset
plant
stability
and challenge critical safety functions during power operations. The inspectors
conducted a Phase 1 SDP screening in accordance with IMC 0609
and
determined that the finding is of very low safety significance. The
finding has a cross-cutting aspect
in the area of human performance
because
PSEG did not ensure that complete, accurate, and up to date design
documentation, procedures, and work packages were available
(H.2.c).
Specifically,
vendor documentation for the demineralizer sight glass was not available on
site, and as a result, PSEG did not incorporate appropriate vendor
guidance
regarding reinstallation and torque requirements for the sight glass into plant
procedures. (Section 4OA3)
•
Green. A self-revealing NCV for failure to comply with 10 CFR 50, Appendix B,
Criterion V, “Instruction, Procedures, and Drawings,” was identified when
operators discovered the 21 CAC in an inoperable condition on May 1, 2007. In
accordance with post-maintenance testing procedures for the 22 CAC, operators
placed the 21 CAC in the pump down mode. When the test of the 22 CAC was
aborted, operators did not return the 21 CAC to operable status in accordance
with procedures. The 21 CAC was inoperable for approximately six hours.
PSEG
restored the 21 CAC to operable status and entered the issue into the corrective
action program (CAP) as notifications 20322784 and 20322793. This finding is
greater than minor because the performance deficiency is associated with
the equipment performance attribute of the Mitigating Systems cornerstone, and
affected the cornerstone objective to ensure the availability and reliability of
systems that respond to initiating events to prevent undesirable consequences.
The inspectors conducted a Phase 1 SDP screening in accordance with IMC
0609,
and determined the finding is of very low risk significance. The
finding has a cross-cutting aspect in the area of human performance
because PSEG personnel did not use human error prevention techniques (H.4.a).
Specifically, an operator did not identify an incorrect switch position because
the operator did not verify the expected system response when placing
the
21 CAC switch to run. (Section 1R13)
•
Green. A self-revealing NCV for failure to comply with 10 CFR, Appendix B,
Criterion V, “Instruction, Procedures, and Drawings,” was identified when
operators discovered a significant leak in the copper oil filter tubing on the
22 CAC on May 1, 2007, that made the 22 CAC inoperable. PSEG
had not inspected or replaced the affected tubing as specified
in the maintenance
procedure.
PSEG replaced the tubing and returned the 22 CAC to service. This resulted in
ten hours of unplanned unavailability on the 22 CAC. The finding is greater than
minor because it is associated with the equipment performance attribute of the
Mitigating Systems cornerstone, and affected the cornerstone objective to ensure
the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The inspectors conducted
a Phase 1 SDP screening in accordance with IMC 0609 and determined that the
finding is of very low safety significance.
The
finding has a cross-cutting aspect in the area of problem identification and
resolution because
PSEG did not take appropriate corrective actions to address safety issues and
adverse trends in a timely manner commensurate with their safety significance
(P.1.d). Specifically, corrective actions to prevent CAC tubing failures were
ineffective because the visual inspections required by the procedure revision
incorporated after previous CAC oil tubing failures, may
not have identified degraded copper tubing in time to prevent tubing failure. (1R12)
•
Green. The inspectors identified an NCV for failure to comply with 10 CFR 50,
Appendix B, Criterion V, “Instruction, Procedures, and Drawings,” when
operators did not implement additional log readings for service water (SW) heat
exchangers (HXs) as specified by plant procedures during extended periods of
high river detritus from March through May of 2007. This required PSEG to take
the 12 CC HX out of service for 45 hours to complete system flushes in May and
June 2007 to restore full operability. The finding is more than minor because it
is associated with the equipment performance attribute of the Mitigating Systems
cornerstone and affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. The inspectors conducted a Phase 1 SDP
screening in accordance with IMC 0609 and determined that the finding is of very
low
safety significance.
The finding has a cross-cutting aspect in the area of human performance because PSEG personnel did not follow plant procedures (H.4.b). Specifically, operators did not implement additional log readings for SW HXs as specified by plant procedures during extended periods of high river detritus from March through May of 2007. (Section 1R15)