IR 05000272/2014005
| ML15030A400 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/30/2015 |
| From: | Glenn Dentel Reactor Projects Branch 3 |
| To: | Joyce T Public Service Enterprise Group |
| Dentel G | |
| References | |
| IR 2014005 | |
| Download: ML15030A400 (68) | |
Text
{{#Wiki_filter: UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 January 30, 2015 Mr. Thomas President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038 SUBJECT: SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 - NRC INTEGRATED INSPECTION REPORT 05000272/2014005 AND 05000311/2014005
Dear Mr. Joyce:
On December 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Salem Nuclear Generating Station, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed on January 20, 2015, with Mr. John Perry, Salem Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents four NRC-identified findings and one self-revealing finding of very low safety significance (Green). All 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 (CAP), the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2.a of the NRC Enforcement Policy. 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, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Salem Nuclear Generating Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Salem Nuclear Generating Station.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, /RA/ Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-272, 50-311 License Nos. DPR-70, DPR-75
Enclosure:
Inspection Report 05000272/2014005 and 05000311/2014005 w/Attachment: Supplementary Information
REGION I== Docket Nos. 50-272, 50-311 License Nos. DPR-70, DPR-75 Report Nos. 05000272/2014005 and 05000311/2014005 Licensee: PSEG Nuclear LLC (PSEG) Facility: Salem Nuclear Generating Station, Units 1 and 2 Location: P.O. Box 236 Hancocks Bridge, NJ 08038 Dates: October 1, 2014 through December 31, 2014 Inspectors: P. Finney, Senior Resident Inspector A. Ziedonis, Resident Inspector R. Barkley, Senior Project Engineer E. Burket, Emergency Preparedness Inspector C. Cahill, Senior Reactor Analyst H. Gray, Senior Reactor Inspector A. DeFrancisco, Project Engineer M. Draxton, Project Engineer R. Nimitz, Senior Health Physicist T. OHara, Reactor Engineer D. Silk, Senior Operations Engineer Approved By: Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY
Inspection Report (IR) 05000272/2014005, 05000311/2014005; 10/01/2014 - 12/31/2014;
Salem Nuclear Generating Station Units 1 and 2; Operability Determinations and Functionality Assessments, Refueling and Other Outage Activities, Radiological Hazard Assessment and Exposure Controls, Problem Identification and Resolution, Follow-up of Events and Notices of Enforcement Discretion.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified four NRC-identified findings and one self-revealing finding of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.
Cornerstone: Initiating Events
SLIV. Inspectors identified a Severity Level IV (SLIV) NCV of 10 CFR 50.72(b)(2)(iv)(B)when PSEG failed to make the required event notification within four hours for a valid actuation of the reactor protection system (RPS) when the reactor was critical. Inspectors determined that a manual reactor trip on October 19, 2014, was not in accordance with PSEGs preplanned documented procedural sequence and, therefore, reportable. PSEG entered this in their CAP (20668967) and reported this RPS actuation by updating a previous report (EN 50550) on November 24, 2014.
Failing to submit an event notification in accordance with 10 CFR 50.72 within the required time was a performance deficiency that was reasonably within PSEGs ability to foresee and correct, and should have been prevented. Since the failure to submit a required event report impacts the regulatory process, traditional enforcement applied and the violation was assessed using Section 2.2.4 of the NRCs Enforcement Policy. Using the example listed in Section 6.9.d.9, A licensee fails to make a report required by 10 CFR 50.72, the issue was determined to be a Severity Level IV violation. The inspectors reviewed the condition for reactor oversight process significance and concluded there was no associated finding.
Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, a cross-cutting aspect is not assigned to this violation in accordance with IMC 0612. (Section 4OA3)
- Green.
The inspectors identified a Green NCV of TS 6.8.1, Procedures and Programs, when PSEG operators did not implement the procedure steps to trip the main turbine, and manually initiate auxiliary feedwater (AFW), during shutdown for a refueling outage on October 19, 2014. Consequently, operator response to degrading equipment conditions resulted in an unplanned manual reactor trip and coincident AFW actuation. PSEGs immediate corrective actions included conducting crew performance reviews documented as part of the post-trip review by the sites Plant Operations Review Committee (PORC), and subsequent coaching of operator performance.
The inspectors determined PSEGs failure to trip the main turbine and establish AFW flow on October 19, in accordance with (IAW) abnormal and shutdown procedures, constituted a performance deficiency. The finding was more than minor because it was associated with the Human Performance attribute of the Initiating Event cornerstone, and adversely affected its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, not following procedures in response to the 1B main power transformer (MPT) challenges resulted in an unplanned manual reactor trip and coincident Engineered Safety Features (ESF) AFW system actuation. In accordance with IMC 0609, Attachment 4, and Exhibit 1 of Appendix A, the inspectors determined that this finding is of very low safety significance, or Green, because the finding did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because PSEG operators did not follow procedures in response to degrading 1B MPT conditions during shutdown for a refueling outage on October 19. [H.8] (Section 1R20)
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because PSEG staff did not promptly correct a condition adverse to quality related to failed Unit 2 reactor coolant pump (RCP) turning vane bolts. Specifically, PSEG staffs use as is evaluation in 2012 was not technically adequate to support their conclusion that contact between the pump turning vane and rotating impeller was acceptable in the event all turning vane bolts failed. As a result, PSEG did not complete corrective actions to perform a pump specific technical analysis or replace the bolts until this issue was identified in July 2014. PSEG completed corrective actions to replace all Unit 2 RCP turning vane bolts with an improved material and measured pump internal dimensions to determine that, for each pump, turning vane to impeller contact would not have prevented proper RCP coast down, invalidate their locked rotor analysis, or result in debris that could impact the reactor coolant system. PSEG staff entered this issue into their CAP (notifications 20660176, 20660177, 20660191, 20660175 and 20660173).
Failure to promptly correct a condition adverse to quality was a performance deficiency. The finding was evaluated in accordance with IMC 0612, Appendix B, and determined to be more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the dropped turning vanes adversely affected the operating RCP lineup, and the supporting documentation errors brought into question their effect on the RCP locked rotor accident analysis and resulted in additional field work. The finding was then evaluated using IMC 0609, Attachment 4 and Appendix A, where it was screened to Green because it was a qualification deficiency of a mitigating component, the RCP as related to its coast down capability that ultimately retained its functionality. The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because PSEG, in addition to prior operating experience-related reports, had two opportunities in 2011 and 2012 when broken bolts were discovered, to thoroughly evaluate the technical basis for their conclusion that RCP turning vane dislodgement and contact with rotating pump components was acceptable. When PSEG thoroughly considered the problem in 2014, they determined that there was not adequate pump specific internal clearance information to support their prior technical conclusions that turning vane contact was acceptable. [P.2] (Section 4OA2)
Cornerstone: Barrier Integrity
- Green.
A self-revealing, Green NCV of TS 6.8.1, Procedures and Programs, was identified when PSEG did not correctly implement procedures associated with Safeguard Equipment Control (SEC) surveillance testing during solid reactor coolant system (RCS) operations.
Consequently, this resulted in lifting a low temperature over-pressure protection valve during solid pressurizer operations. PSEG immediately stabilized reactor pressure, completed a prompt investigation and an apparent cause evaluation, submitted a Special Report to the NRC in accordance with TS 6.9.2, and entered this in their CAP (20665897).
Non-compliance with TS 6.8.1 procedures was a performance deficiency. This issue was determined to be more than minor because it was associated with the human performance attribute of the Barrier Integrity cornerstone, and adversely affected its objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. It was also similar to IMC 0612, Appendix E, example 4.b, in that not accomplishing activities in accordance with procedures is more than minor if it results in a trip or transient. Specifically, not following procedures resulted in an RCS pressure transient that caused a protective relief valve to lift. Since the finding was not associated with a freeze seal, nozzle dam, criticality drain-down path, leakage path, or safety injection actuation, and did not involve or result in PORV unavailability or a setpoint issue, it screened to
- Green.
The finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, in that individuals are expected to follow processes, procedures, and work instructions. Specifically, PSEG operators did not follow procedures nor review procedures before work to validate appropriateness and timing. [H.8] (Section 1R15)
Cornerstone: Occupational Radiation Safety
- Green.
The inspectors identified NCV of very low safety significance (Green) associated with failure to implement TS 6.12.2 access controls for a High Radiation Area (HRA)exhibiting accessible radiation dose rates exceeding 1 rem/hr at 30 cm. Specifically, on October 28, 2014, NRC inspectors found the access door to the Unit 1 Containment Regenerative Heat Exchanger Room unlocked and unguarded, and the area exhibited accessible radiation dose rates of up to 1.4 rem/hr at 30 cm. PSEG immediately locked access to this area and entered this issue into its CAP (Notification 20667323).
The failure to establish and implement TS 6.12 HRA access controls is a performance deficiency (PD) which was within PSEGs ability to foresee and correct and should have been prevented. The PD was determined to be more than minor because, if left uncorrected, the PD had the potential to lead to a more significant safety concern if personnel were exposed to elevated radiation dose rates. Further, the PD was related to the programs and process attribute of the Occupational Radiation Safety cornerstone, and adversely affected the cornerstone objective to ensure adequate protection of worker from radiation exposure. The finding was assessed using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, and was determined to be of very low safety significance (Green) because the finding did not involve: (1) As-Low-As-Reasonably
Achievable (ALARA) planning and controls; (2) a radiological overexposure; (3) a substantial potential for an overexposure; or (4) a compromised ability to assess dose. This finding was associated with the Resolution aspect of the Problem Identification and Resolution cross-cutting area in that PSEG did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, PSEG did not repair a long standing broken High Radiation Area access door lock resulting in extended use of an alternate lock and chain remedy that could not be readily verified in the locked condition and led to human error in not successfully locking the door from prior egress. [P.3] (2RS1)
REPORT DETAILS
Summary of Plant Status
Unit 1 began the inspection period at 100 percent power. On October 19, the unit was shut down for refueling and maintenance outage number 23 (1R23). Operators commenced a reactor startup on November 21 and the unit reached 100 percent power on November 26.
On the following day, the unit was reduced to approximately 61% in response to a leak on the control oil supply line to the 12 Steam Generator Feedpump (SGFP) low pressure steam supply stop valve. PSEG conducted repairs, restored the SGFP to service, and 100 percent power was reached on November 28. The unit remained at or near 100 percent power for the remainder of the inspection period.
Unit 2 began the inspection period at 100 percent power. On October 28, the unit was reduced to 55 percent power in support of maintenance on the 12 service water (SW) return header.
The unit was restored to 100 percent power on October 29. On November 7, the unit was reduced to 80 percent power in support of restoration from maintenance on the 12 SW return header. The unit reached 100 percent the following day and remained at or near that power level for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
During the week of October 12, inspectors performed a review of PSEGs readiness for the hurricane season. The review focused on the SW intake structure, the circulating water intake structure, and auxiliary building penetrations. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs), control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure PSEG personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including PSEGs seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hurricane conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed PSEGs preparations for the onset of freezing temperatures and heavy rain on December 8. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the inner and outer steam penetrations and the SW intake structure. The inspectors verified that operator actions defined in PSEGs adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
b. Findings
No findings were identified.
.3 External Flooding
a. Inspection Scope
During the week of September 17 and November 24, the inspectors performed an inspection of the external flood protection measures for the Salem Unit 2 electrical penetration area. The inspectors reviewed TSs, procedures, design documents, and the UFSAR, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of all external areas of the plant to ensure that PSEG erected flood protection measures in accordance with design specifications.
The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if PSEG planned or established adequate measures to protect against external flooding events.
b. Findings
No findings were identified. ==1R04 Equipment Alignment
.1 Partial System Walkdowns
==
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems: Unit 1, containment lineup to support core reload on November 5 Unit 2, SW system following restoration from a valve mispositioning event on October 29 Common, control area ventilation in accident pressurized mode during a 1B vital instrument bus failure on October 29 The inspectors selected these systems based on their risk-significance relative to the Reactor Safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders (WOs), notifications, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PSEG staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On October 2 and December 18 respectively, the inspectors performed a walkdown of accessible portions of the Unit 1, 11 safety injection system, and the Unit 2, component cooling water system, to verify the existing equipment lineup was correct.
The inspectors reviewed operating procedures, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, equipment cooling, hanger and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related notifications and WOs to ensure PSEG appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified. ==1R05 Fire Protection