05000354/FIN-2016003-01
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Finding | |
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| Title | Inadequate Implementation of Adverse Condition Monitoring Actions for the High Pressure Coolant Injection System |
| Description | A self-revealing preliminary White finding and apparent violation (AV) of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Technical Specification (TS) 3.5.1.c, Emergency Core Cooling Systems - High Pressure Coolant Injection (HPCI), was identified because PSEG did not detect and act upon an adverse trend of water intrusion into the HPCI oil system. Specifically, PSEG did not adequately implement procedure OP-AA-108-111, Adverse Condition Monitoring (ACM) and Contingency Planning, and the ACM HC 15-008 action to perform monthly HPCI turbine oil analysis for water contamination with known steam leakage by the Steam Admission Valve (FD-F001). Because these monthly oil samples were collected but were not analyzed for water content, PSEG did not identify significant moisture contamination in the HPCI oil system and thus take the necessary response actions. As a result, on August 6, 2016, the HPCI governor control valve (FV-4879) failed to stroke open as required due to moisture-induced corrosion that degraded its hydraulic actuator (EG-R). Consequently, PSEG violated TS 3.5.1.c because, based on failure of the FV-4879 and the EG-R to actuate on August 6, 2016, the NRC determined that the HPCI system was inoperable for a period greater than its technical specification (TS) allowed outage time of 14 days. PSEGs immediate corrective actions included entering the issue into their Corrective Action Program (CAP) (NOTFs 20737383, 20738402 and 20738403); repairing the HPCI turbine insulation; replacing the HPCI EG-R; flushing the HPCI turbine oil system; and replenishing the system with new oil. This finding is more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, a loss of safety function occurred when elevated water concentration in the HPCI oil system corroded the EG-R, preventing the FV-4879 valve from opening and the HPCI system from starting/running. This resulted in HPCI system inoperability for greater than the 14 days allowed by TS. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors screened the finding for safety significance and determined that a detailed risk evaluation (DRE) was required based on the HPCI system being inoperable for greater than the TS allowed outage time of 14 days. The DRE was performed by a Region I senior reactor analyst (SRA) and concluded that the condition resulted in an increase in core damage frequency (CDF) of low E-6/yr., or of low-to-moderate safety significance (White). The SRA determined the increase in Large Early Release Frequency (LERF) was low E-7/yr., consistent with the significance determined for the internal and external event CDF. This finding had a cross-cutting aspect in the area of Human Performance, Conservative Bias, because PSEG did not use decision-making practices that emphasize prudent choices over those that are simply allowable. In addition, PSEG did not take timely action to address degraded conditions commensurate with their safety significance. |
| Site: | Hope Creek  |
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| Report | IR 05000354/2016003 Section 1R15 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | Violation: White |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | F Arner F Bower J Hawkins M Draxton R Nimitz R Vadella S Freeman S Haney W Cooka Rosebrookm Draxton D Beacon F Bower |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Hope Creek - IR 05000354/2016003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hope Creek) @ 2016Q3
Self-Identified List (Hope Creek)
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