The inspectors reviewed procedure HC.ER-AP.BB-0002(Q) Rev. 4, Hope Creek Reactor Recirculation Piping Vibration Monitoring, and its application prior to the June 7, 2005 event.
PSEG noted during discussions with the inspectors that the vendor-provided acceptance criteria values in the vibration monitoring procedure were based on large
bore piping stresses only, and there would not have been recorded data processed prior to June 2005, that would have led
PSEG to inspect the FO50A position indicating device. Operation of the plant with
reactor coolant system (
RCS)
pressure boundary leakage is prohibited by
TS 3.4.3.2.a and constitutes a violation of TS requirements. Although
PSEG did not identify the position indicator leak until June 7, 2005, and met the associated TS action statement from the point of discovery, it is reasonable to conclude that the
pressure boundary leak existed for some in-determinant period of time prior to discovery and during plant operations, contrary to the requirements of the technical specifications, which prohibits plant operation with
pressure boundary leakage. However, this fact alone does not constitute a performance deficiency. The inspectors determined the FO50A valve position indicator
pressure boundary leakage was of very low safety significance. Assuming worst case degradation, the leakage would not have increased due to internal restriction in the position indicator tube. The leakage would have remained within the capacity of the
control rod drive pumps and would not have likely affected other mitigation systems resulting in a total loss of their safety function. The inspectors concluded that the
RCS pressure boundary leak resulted from an equipment failure that was not avoidable by the implementation of reasonable quality measures or management controls. The inspectors also concluded that
PSEG took appropriate actions to correct the condition and adequately characterized the extent of condition and safety significance. Accordingly, although
RCS pressure boundary leakage is a violation of NRC requirements, the NRC has decided to exercise
enforcement discretion in accordance with VII.B.6 of the
NRC Enforcement Policy and refrain from issuing enforcement action for the violation (
EA-05-229).
