Wednesday, May 16, 2007

Below are edited lowlights from the Salem/Hope Creek Problem ID inspection.

. Larger font emphasis is mine, not NRC’s.

 

 

 

 

As I point out by the highlighted items, the cross-cutting/ human performance/ safety culture problems remain, even though NRC has said that Safety Culture at PSEG is just grand.

 

 

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- Duty Program, a program common to both Salem and Hope Creek stations, therefore this report includes the Hope Creek Nuclear Generating Station so that the findings are appropriately docketed.

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
and remain unavailable for approximately 70 hours on July 15, 2006.
Maintenance was incorrectly performed o
n a chiller unloader device that caused
the chiller to overcool the chilled water system resulting in a valid automatic
freeze-protection trip of the refrigerant compressor. PSEG  repaired the chiller,
verified that the other five chiller units were correctly maintained, trained
maintenance technicians on the error, and are currently reviewing the
maintenance procedure for enhancement opportunities.

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)

 

 

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 [ ’s fitness-for- duty (FFD)
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.)

• 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- duty
(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. 65(a)(1). Following correction of the evaluations, none of the systems exceeded established goal parameters and thus did not require a reevaluation in accordance with 10CFR50.65(a) (1). The missed evaluations were not a violation of regulatory requirements.

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- 01,

 

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.