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 05000311/2007003 AND NOTICE OF VIOLATION

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) (iii) and 10 CFR

50.55a(g)(5) (iv) for Salem Nuclear Generating Station, Unit 2, which affected the ability of the NRC to perform its regulatory function.

 

 

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) (iv) states in part that where an examination requirement by the code or addenda is determined to be impractical by the licensee and is not included in the revised inservice inspection (ISI) program as permitted by paragraph (g)(4) of this section, the basis for this determination must be demonstrated to the satisfaction of the

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) (iii) states in part that if the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in Section 50.4, information to support the determinations.

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)