05000354/FIN-2015001-01
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Finding | |
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Title | Failure to Identify and Correct a Condition Adverse to Quality Associated with the Reactor Core Isolation Cooling System Insulation and Oil |
Description | A self-revealing finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, was identified because PSEG did not promptly identify and correct a condition adverse to quality (CAQ). Specifically, PSEG failed to identify a deficiency with the reactor core isolation cooling (RCIC) turbine thermal insulation on July 28, August 19, and November 18, 2014; and failed to initiate a notification (NOTF) identifying an adverse trend in RCIC oil moisture content and level on November 18, 2014 and in January 2015. The failure to identify and correct a CAQ resulted in high moisture content in the RCIC oil. PSEGs corrective actions included replacing the RCIC system oil on February 19, 2015 and repairing the non-conforming turbine insulation on February 25, 2015. The performance deficiency (PD) was determined to be more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). This PD was also similar to examples 3.j and 3.k of NRC IMC 0612, Appendix E, in that the increased moisture content in the RCIC oil created a reasonable doubt of operability of the RCIC system. The inspectors determined the finding to be of very low safety significance (Green) in accordance with Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, because: it was not a deficiency affecting the design or qualification of the mitigating system; it did not represent a loss of system function; it did not represent the loss of function for any TS system, train, or component beyond the allowed TS outage time; and it did not represent an actual loss of function of any non TS trains of equipment designated as high safety significance in accordance with PSEGs maintenance rule program. The inspectors determined the finding had a cross-cutting aspect in the area of Problem Identification and Resolution (PI&R), Trending, because PSEG did not periodically analyze information from the corrective action program and other assessments in the aggregate to identify programmatic and other common cause issues. Specifically, PSEG did not analyze multiple RCIC system oil sample results or RCIC system NOTFs in the aggregate to identify a CAQ. |
Site: | Hope Creek |
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Report | IR 05000354/2015001 Section 1R15 |
Date counted | Mar 31, 2015 (2015Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | E Burket G Dentel J Hawkins R Nimitz S Haney |
Violation of: | 10 CFR 50 Appendix B Criterion XVI Technical Specification |
CCA | P.4, Trending |
INPO aspect | PI.4 |
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Finding - Hope Creek - IR 05000354/2015001 | |||||||||||||||||||||||||||||||||||||
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Finding List (Hope Creek) @ 2015Q1
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