Below
is a text excerpt of the latest NRC Salem inspection. Highlights and bold
faces were added by me. The report clearly shows that
Safety
culture continues to degrade at
I
have the entire report as a PDF file and will be glad to email it to you. You
can also read it in ADAMS at the NRC website.
Norm
July
28, 2005
Mr.
William Levis
Chief
Nuclear Officer and President
PSEG
LLC - N09
SUBJECT:
REPORT
05000272/2005003 and 05000311/2005003
Dear
Mr. Levis:
On
June 30, 2005, the US Nuclear Regulatory Commission (NRC) completed an
inspection at
the
the
inspection findings, which were discussed on June 30, 2005, with Mr. Tom Joyce
and other
members
of your staff.
.
The
report documents five NRC-identified findings and three self-revealing
findings of very low
safety
significance (Green). Seven of these findings were determined to involve
violations of
NRC
requirements.
However, because of the very low safety significance and because they are
entered
into your corrective action program, the NRC is treating these findings as
non-cited
violations
(NCVs) consistent with Section VI.A of the NRC Enforcement Policy.
Additionally,
licensee-identified
violations which were determined to be of very low safety significance are
listed
in this report. If you contest any NCV in this report, you should provide a
response within
30
days of the date of this inspection report, with the basis for your denial, to
the Nuclear
Regulatory
Commission, ATTN: Document Control Desk,
copies
to the Regional Administrator, Region I; the Director, Office of Enforcement,
and the NRC
Resident
Inspector at the
R.
Laufer, NRR
S.
Bailey, PM, NRR
R.
Ennis, PM, NRR (backup)
Region
I Docket Room (with concurrences)
ROPreports@nrc.gov
DOCUMENT
NAME: E:\Filenet\ML052090344.wpd
A.
NRC-Identified and Self-Revealing Findings
Cornerstone:
Initiating Events
!
Green.
The inspectors identified a non-cited violation, in that, corrective actions
established
in July 1998 to identify, clean, and inspect Unit 2 reactor coolant
system
(RCS) instrument tubing were not implemented. Because these
corrective
actions were not implemented, four through-wall cracks were identified
in
RCS instrument tubing in April 2005.
This finding was a non-cited violation of
10
CFR 50, Appendix B, Criterion XVI, “Corrective Actions.”
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequences or potential for impacting the NRC’s regulatory function, and
was
not the result of any willful violation of NRC requirements. This finding was
more
than minor because it was associated with the equipment performance
attribute
of the initiating events cornerstone and affected the objective to limit the
likelihood
of those events that upset plant stability and challenge critical safety
functions
during shut down as well as power operations. 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 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
had a problem identification and resolution (corrective action) cross
cutting
aspect. (Section 1R08.1)
Enclosure
iv
Cornerstone:
Mitigating Systems
!
Green.
A self-revealing finding was identified when the 22 charging pump was
rendered
unavailable to repair a degraded discharge check valve. Corrective
actions
from a similar occurrence on Unit 1 in June 2004 were not implemented in
a
timely manner to prevent recurrence.
This finding was a non-cited violation of
10
CFR 50 Appendix B, Criterion XVI, “Corrective Actions.”
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequences or potential for impacting the NRC’s regulatory function and
was
not the result of any willful violation of NRC requirements. This finding was
more
than minor because it was associated with the equipment performance
attribute
of the mitigating systems cornerstone and affected the objective to
ensure
the availability of systems that respond to initiating events to prevent
undesirable
consequences. 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.” The finding was not a design or
qualification
deficiency that resulted in a loss of function, did not result in an
actual
loss of system safety function, did not represent the actual loss of a safety
function
of a single train for greater than its Technical Specification allowed
outage
time, and was not screened as potentially risk significant from external
events.
The
performance deficiency had a problem identification and resolution
(corrective
actions) cross cutting aspect. (Section 1R12)
!
Green.
The inspectors identified a non-cited
violation, in that, the Unit 2 reactor
sump
room door was contrary to plant design.
The configuration discrepancy
reduced
the available margin to identify and isolate a postulated service water
leak
from a containment fan coil unit prior to flooding safety-related equipment
during
loss-of-coolant accident conditions. The finding was a non-cited violation
of
10 CFR 50, Appendix B, Criterion III, “Design Control.”
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequences or potential for impacting the NRC’s regulatory function and
was
not the result of any willful violation of NRC requirements. This finding was
more
than minor because it was associated with the design control attribute of
the
mitigating systems cornerstone and affected the objective to ensure the
reliability
of systems that respond to initiating events to prevent undesirable
consequences.
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.”
The finding was a design control deficiency that did not result in a
loss
of function. (Section 1R15)
Cornerstone:
Barrier Integrity
!
Green.
A self-revealing finding was identified when the 15 containment fan coil
unit
(CFCU) failed to start in high speed on May 24, 2005. PSEG determined that
charging
spring toggle switches on the high and low speed CFCU breakers were
Enclosure
v
mis-positioned
during a surveillance test on May 18, 2005. The configuration
control
error rendered the CFCU inoperable for 160 hours.
The finding was a
non-cited
violation of 10 CFR 50, Appendix B, Criterion V, “Instructions,
Procedures,
and Drawings.”
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequences or potential for impacting the NRC’s regulatory function and
was
not the result of any willful violation of NRC requirements. This finding was
more
than minor because it was associated with the structure, system, or
component
performance attribute of the barrier integrity cornerstone and affected
the
cornerstone objective to provide reasonable assurance that containment
barriers
protect the public from radio nuclide releases caused by accidents or
events.
In accordance with IMC 0609, Appendix A, “Significance Determination
of
Reactor Inspection Findings for At-Power Situations,” the inspectors were
directed
to IMC 0609, Appendix H, “Containment Integrity Significance
Determination
Process,” because the finding represented an actual loss of
defense-in-depth
of a system that controls containment pressure. The finding
was
determined to be of very low safety significance (Green) because the
Units
include a large, dry containment, and containment fan coil unit failures do
not
significantly contribute to large early release frequency (LERF). The
performance
deficiency had a human performance (personnel) cross cutting
aspect.
(Section 1R04)
!
Green.
The inspectors identified a non-cited violation for a failure to accomplish
containment
closure precautions in accordance with established procedures when
the
outage equipment hatch was blocked with a Sea-Van container during Unit 2
core
alterations without a ready overhead crane.
This finding was a non-cited
violation
of 10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and
Drawings.”
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequence or potential for impacting the NRC’s regulatory function and
was
not the result of any willful violation of NRC requirements. The finding was
more
than minor because it was associated with the human performance attribute
of
the barrier integrity cornerstone and affected the objective to provide
reasonable
assurance that containment barriers protect the public from radio
nuclide
releases caused by accidents or events. In accordance with IMC 0609,
Appendix
G, “Shutdown Operations Significance Determination Process,” the
inspectors
conducted a Phase 1 SDP screening using checklist 4 and determined
the
finding to be of very low safety significance (Green). The finding did not
increase
the likelihood of a loss of RCS inventory, did not degrade the ability to
terminate
a leak path or add RCS inventory when needed, and did not degrade
the
ability to recover decay heat removal systems once lost. The
performance
deficiency
had a human performance (personnel) cross cutting aspect. (Section
1R20)
!
Green.
A self-revealing finding was identified when a portion of the 12 service
water
accumulator outlet line was found nearly full of silt. Established corrective
actions
to inspect for silt on an eighteenth-month frequency were inappropriately
deferred
in April 2004.
This finding was a non-cited violation of 10 CFR 50
Appendix
B, Criterion XVI, “Corrective Actions.”
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequence or potential for impacting the NRC’s regulatory function and
was
not the result of any willful violation of NRC requirements. The finding was
more
than minor because it was associated with the structure, system, or
component
(SSC) performance attribute of the barrier integrity cornerstone and
affected
the objective to provide reasonable assurance that containment barriers
protect
the public from radio nuclide releases caused by accidents or events. The
inspectors
determined that the finding was of very low safety significance (Green)
using
Inspection Manual Chapter (IMC) 0609, Appendix H, “Containment Integrity
Significance
Determination Process,” because the CFCUs are not important to
large
early release frequency, in that, the
containments
and the CFCUs only impact late containment failure and source
terms.
The performance
deficiency had problem identification and resolution
(evaluation
and corrective action) cross cutting aspects.
(Section 4OA2)
Cornerstone:
Emergency Preparedness (EP)
!
Green.
The inspectors identified that PSEG did not complete an independent
quality
assurance audit to assess all elements of the emergency preparedness
program
as required by federal regulations.
The finding was determined to be a
non-cited
violation 10 CFR 50.54(t), “Conditions of Licenses.”
Traditional
enforcement does not apply because the finding did not have any
actual
safety consequence or potential for impacting the NRC's regulatory
function,
and was not the result of any willful violation of NRC requirements. This
finding
was more than minor because it was associated with all attributes of the
emergency
preparedness cornerstone and affected the objective to ensure that
the
licensee is capable of implementing adequate measures to protect the health
and
safety of the public in the event of a radiological emergency. The inspectors
determined
that the finding was of very low safety significance (Green) using
Appendix
B of Inspection Manual Chapter 0609, "Emergency Preparedness
Significance
Determination Process, Sheet 1, Failure to Comply,” because it did
not
constitute a failure to meet an Emergency Preparedness planning standard or
risk
significant planning standard. (Section 1EP5)
Cornerstone:
Miscellaneous
!
Green.
The inspectors identified a finding for several lapses in the use of the
Executive
Review Board (ERB) process. This finding involved not properly
implementing
a corrective action which had been intended to improve
management
effectiveness in detecting and preventing retaliation and the
creation
of a chilling effect.
This finding was not a violation of regulatory
requirements.
Traditional
enforcement does not apply because the issue did not have any actual
safety
consequences or potential for impacting the NRC’s regulatory function, and
Enclosure
vii
was
not the result of any willful violation of NRC requirements. This finding was
more
than minor, because if left uncorrected, it would lead to the potential for
retaliation
and a chilled work environment. This finding was of very low safety
significance
(Green), based on management review, because there was no direct
impact
on human performance or equipment reliability. The performance
deficiency
had problem identification and resolution (corrective action) and safety
conscious
work environment cross cutting aspects. (Section 4OA2.4)
B.
Licensee Identified Violations
Violations
of very low safety significance, which were identified by PSEG, were reviewed
by
the inspectors. Corrective actions, taken or planned by PSEG have been entered
into
PSEG’s
corrective action program. The violation and corrective action tracking
numbers
are
listed in Section 4OA7 of this report.
Enclosure
REPORT
DETAILS
Summary
of Plant Status
Unit
1 began the period at 100% power. Operators commenced a controlled plant
shutdown on
April
19, 2005, to repair a valve on a boron injection tank sample line and returned
the plant to
100%
power on April 22, 2005.
Unit
2 began the period at 100% power and then operators commenced a reactor
shutdown and
plant
cooldown on April 6, 2005, to begin the fourteenth refueling outage (2R14). On
May 14,
2005,
99.5% power was achieved following the refueling outage. Unit 2 remained at or
near
99.5%
power due to balance of plant limitations. No power reductions greater than
20%
occurred
for the duration of the inspection period.
Coalition
for Peace and Justice; UNPLUG Salem Campaign,