05000354/FIN-2015008-03
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Finding | |
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| Title | Failure to Monitor the Reactor Manual Control System under 50.65(a)(1) due to Inadequate Maintenance Rule Functional Failure Evaluations |
| Description | The inspectors identified a Green NCV of 10 CFR 50.65(a)(1) due to inadequate maintenance rule monitoring of the Reactor Manual Control System (RMCS). Specifically, PSEG did not properly evaluate and account for 52 maintenance preventable functional failures (MPFFs) across various systems, which were discovered by PSEG during a 2013 self-assessment of the Maintenance Rule Program. The inspectors determined that the multiple functional failures and a repeat MPFF experienced by RMCS demonstrated that the performance of RMCS was not being effectively controlled through appropriate preventive maintenance, and additional monitoring actions were required by 10 CFR 50.65(a)(1) and the PSEG Maintenance Rule Program. In response to this finding, PSEG plans to re-evaluate the 52 MPFFs for potential repeat MPFFs, generate a new notification for any repeat MPFFs identified, and conduct a work group evaluation to determine the cause of the improperly evaluated MPFFs. This issue was determined to be more than minor in accordance with IMC 0612 Appendix B, Issue Screening, because it was associated with 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. Specifically, because PSEG did not identify the repeat MPFF and implement required (a)(1) corrective actions and goals, PSEG missed an opportunity to assure reliability of RMCS by preventing additional failures. The inspectors determined that this finding was of very low safety significance (Green) using Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, because the finding did not 1) affect a single reactor protection system (RPS) trip signal to initiate a reactor scram and the function of other redundant trips or diverse methods of reactor shutdown; 2) involve control manipulations that unintentionally added positive reactivity; or, 3) result in mismanagement of reactivity by operators. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, which states that licensees are expected to take effective corrective actions to address issues in a timely manner commensurate with their safety significance. In this case, PSEG failed to take effective corrective actions to resolve a known maintenance rule program deficiency with respect to non-conservative functional failure cause determination evaluations (FFCDEs). This directly led to inadequate reliability monitoring of RMCS under the maintenance rule, and potentially affected other maintenance rule systems as well. |
| Site: | Hope Creek  |
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| Report | IR 05000354/2015008 Section 4OA2 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | G Dentel J Hawkins M Draxton M Fannon N Warnek |
| Violation of: | 10 CFR 50.65(a)(1) 10 CFR 50.65 |
| CCA | P.3, Resolution |
| INPO aspect | PI.3 |
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Finding - Hope Creek - IR 05000354/2015008 | |||||||||||||||||||||||||||||||||||||
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Finding List (Hope Creek) @ 2015Q1
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