IR 05000272/2009007
| ML092320430 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/19/2009 |
| From: | Racquel Powell NRC/RGN-I/DRP/PB7 |
| To: | Joyce T Public Service Enterprise Group |
| powell r j | |
| References | |
| IR-09-007 | |
| Download: ML092320430 (22) | |
Text
August 19, 2009
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000272/2009007 AND 05000311/2009007
Dear Mr. Joyce:
On July 9, 2009, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Salem Nuclear Generating Station, Units 1 and 2. The enclosed report documents the inspection results discussed on July 9, 2009 with Mr. E. Eilola and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspectors concluded that Public Service Enterprise Group Nuclear, LLC (PSEG) was generally effective in identifying, evaluating, and resolving problems. PSEG personnel identified problems and entered them into the corrective action program at a low threshold. PSEG prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. In general, PSEG reviewed and applied lessons learned from industry operating experience when appropriate, and, in most cases, audits and self-assessments were critical with appropriate actions taken to address identified issues.
This report documents one NRC-identified finding of very low safety significance (Green). The inspectors determined that this finding also involved a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV, 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 the Salem Nuclear Generating Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis of your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at the Salem Nuclear Generating Station. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 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 NRC Public Document Room or from the Publically Available Records (PARS) component of the NRCs document 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/
Raymond J. Powell, Chief Technical Support and Assessment Branch Division of Reactor Projects
Docket Nos: 50-272, 50-311 License Nos: DPR-70, DPR-75
Enclosure:
Inspection Report 05000272/2009007 and 05000311/2009007
w/ Attachment: Supplemental Information
cc w/encl:
W. Levis, President and Chief Operating Officer, PSEG Power R. Braun, Site Vice President P. Davison, Director of Nuclear Oversight E. Johnson, Director of Finance E. Eilola, Salem Plant Manager J. Keenan, Manager Licensing, PSEG L. Peterson, Chief of Police and Emergency Management Coordinator P. Baldauf, Assistant Director, NJ Radiation Protection Programs P. Mulligan, Chief, NJ Bureau of Nuclear Engineering, DEP H. Otto, Ph.D., Administrator, DE Interagency Programs, DNREC Div of Water Resources Consumer Advocate, Office of Consumer Advocate, Commonwealth of Pennsylvania N. Cohen, Coordinator - Unplug Salem Campaign E. Zobian, Coordinator - Jersey Shore Anti Nuclear Alliance A. Muller, Executive Director, Green Delaware V. Cebulaski, General Solicitor, PSEG
SUMMARY OF FINDINGS
IR 05000272/2009007 and 05000311/2009007; 06/22/2009 - 07/09/2009; Salem Nuclear
Generating Station, Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems. The inspectors identified one finding in the area of corrective actions.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified one finding of very low safety significance (Green) during this inspection and classified this finding as a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0305,
Operating Reactor Assessment Program. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Identification and Resolution of Problems
The inspectors concluded that Public Service Enterprise Group Nuclear, LLC (PSEG) was generally effective in identifying, evaluating, and resolving problems. PSEG personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, PSEG appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that PSEG typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the area of effectiveness of corrective actions.
The inspectors concluded that, in general, PSEG adequately identified, reviewed, and applied relevant industry operating experience to Salem Nuclear Generating Station (Salem) operations.
In addition, based on those items selected for review by inspectors, PSEGs audits and self-assessments were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify conditions that could have had a negative impact on the sites safety conscious work environment.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a non-cited violation of very low safety significance of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(1), for PSEGs failure to monitor the performance of the service water system against established (a)(1) goals in a manner sufficient to provide reasonable assurance that the system was capable of fulfilling its intended function. PSEG also failed to take corrective action when system performance exceeded the (a)(1) unavailability goals. Specifically, PSEG failed to establish (a)(1)goals and monitor service water system performance from January 2008 through
October 2008. Additionally, the inspectors identified a second example of this issue when PSEG failed to recognize that the service water system exceeded the new (a)(1)monitoring goals from April 2009 through June 2009. PSEG entered this issue into their corrective action program under notifications 20422672 and 20422673.
This finding is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). This finding is not suitable for evaluation using the SDP because the performance deficiency did not cause the degraded equipment performance. Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Per the guidance provided in Inspection Procedure 71111.12, this issue is considered to be a Category II finding and thus, per NRC management review, is considered to be
- Green.
With respect to assigning a cross-cutting aspect to this finding, the inspectors determined that the most meaningful insight into PSEGs performance was a programmatic concern with the implementation of the maintenance rule program at Salem. PSEG acknowledged this programmatic concern, which included ownership and accountability issues, initiated a focused self-assessment of the maintenance rule program, and will assign corrective actions as appropriate. This insight is not aligned with the specific performance deficiency attributes defined in IMC 0305 and, as such, the inspectors have not assigned a cross-cutting aspect to this finding. (Section 4OA2.1.c)
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that describe PSEGs corrective action program at Salem Nuclear Generating Station (Salem). PSEG personnel identified problems by initiating notifications for conditions adverse to quality, plant equipment deficiencies, industrial or radiological safety concerns, or other significant issues. Notifications are subsequently screened for operability, categorized by significance level (1 for the most significant through 5 for less significant), and assigned to personnel for evaluation and resolution or trending.
To assess the effectiveness of the corrective action program at Salem, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation, and corrective action implementation. The inspectors compared performance in these three areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and PSEG procedure LS-AA-125, Corrective Action Program Procedure. The scope of the inspectors review for each of these areas is described below. All documents reviewed during this inspection are listed in the Attachment.
Effectiveness of Problem Identification
The inspectors reviewed a sample of plan-of-the-day (POD) meeting packages and meeting minutes for a sample of Plant Operations Review Committee (PORC) meetings, Nuclear Safety Review Board (NSRB) meetings, and Maintenance Rule Expert Panel meetings. The inspectors also attended POD, Management Review Committee (MRC),and Station Ownership Committee (SOC) meetings to ensure that PSEG entered issues discussed at these meetings into the corrective action program for evaluation and resolution as appropriate.
The inspectors reviewed the condition of the service water system, chilled water system, component cooling water system, and the 115 volts alternating current (VAC) vital instrument bus inverters. The inspectors reviewed system health reports, a sample of preventative and corrective maintenance work orders, surveillance test procedures, and performed a field walkdown of accessible portions of these systems. The inspectors also observed performance of a surveillance test on the auxiliary feedwater system. The inspectors performed these reviews to verify that PSEG entered conditions adverse to quality into the corrective action program as appropriate.
The inspectors reviewed Salem Emergency Preparedness (EP) Training Drill Evaluation Reports to ensure that the station entered EP drill performance deficiencies into the corrective action program as appropriate.
The inspectors evaluated the results of PSEG periodic equipment and human performance trend analyses and quarterly system health reports for risk significant systems. The inspectors also reviewed a sample of notifications written to document issues identified through internal self-assessments, audits, and the operating experience (OE) program.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization for a sample of notifications issued since the last NRC biennial Problem Identification and Resolution (PI&R)inspection performed in March 2007. The inspectors considered risk insights from the stations risk analysis and ensured that selected notifications were properly distributed across the seven cornerstones of safety and the emergency preparedness, engineering, maintenance, operations, physical security, chemistry, and radiation safety functional areas. The inspectors samples in this area were focused on the service water, chilled water, 115 VAC vital instrument bus inverters, and component cooling water systems, but were not limited to these areas.
The inspectors also observed two daily notification screening meetings conducted by the SOC during the onsite weeks. During these meetings, PSEG personnel reviewed new and existing notifications for prioritization and assignment. The inspectors also reviewed notifications that were assigned lower levels of significance and did not include formal cause evaluations to ensure they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems. The inspectors also observed an MRC meeting during which PSEG managers reviewed completed root cause evaluations, as well as selected apparent cause evaluations and corrective action assignments.
Effectiveness of Corrective Actions
The inspectors selected a risk-informed sample of notifications issued since the last NRC biennial PI&R inspection performed in March 2007. The inspectors considered risk insights from Salems risk analysis and ensured that the selected notifications were appropriately distributed across the seven cornerstones of safety and the emergency preparedness, engineering, maintenance, operations, physical security, chemistry, and radiation safety functional areas. The inspectors samples in this area were focused on the service water system, chilled water system, component cooling water system, and the 115 VAC vital instrument bus inverters, but were not limited to these areas. The inspectors reviewed PSEGs completed corrective actions through documentation review and, in some cases, field walkdowns. The inspectors also reviewed a sample of corrective actions for notifications greater than two years old. The inspectors selected these items based on risk significance to verify that appropriate interim corrective actions were in place and that PSEG appropriately documented and adequately supported the basis for not completing the specified corrective actions.
The inspectors reviewed notifications for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues.
The inspectors reviewed PSEGs timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of notifications associated with selected NCVs and findings to verify that PSEG personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate PSEGs actions related to the service water system, the chilled water system, and the radiation safety functional area.
b. Assessment
Effectiveness of Problem Identification
Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that PSEG identified problems and entered them into the corrective action program at a low threshold. PSEG staff at Salem initiated approximately 43,000 notifications between January 2007 and May 2009. The inspectors observed managers and supervisors at the POD, SOC, and MRC meetings appropriately questioning and challenging notifications to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that PSEG trended equipment and programmatic issues, and appropriately documented identified problems in notifications. The inspectors also concluded that personnel were identifying trends at low levels. In general, the inspectors did not identify any additional issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution.
Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined that, in general, PSEG appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
PSEG screened notifications for operability and reportability, categorized the notifications by significance, and assigned actions to the appropriate department for evaluation and resolution. The notification screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment (SCWE) during the conduct of the reviews.
PSEG categorized notifications for evaluation and resolution commensurate with the significance of the issues. Based on the samples of notifications reviewed, the guidance provided by PSEG corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of the issues. The station performed operability and reportability determinations when conditions warranted and the evaluations generally supported the conclusions. Causal analyses appropriately considered extent of condition, generic issues, and previous occurrences. During this inspection, the inspectors noted that PSEGs root cause analyses were thorough, and corrective and preventive actions addressed the identified causes.
Effectiveness of Corrective Actions
The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, PSEG identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last PI&R inspection were timely and effective.
The inspectors did note some weaknesses in Salems resolution of degraded conditions, documentation of actions, and completion of identified corrective actions which resulted in repetitive failures of the 115VAC vital instrument bus inverters. On July 22, 2006, following a failure of the 1B vital instrument bus inverter, Salem identified that certain components of the vital instrument bus inverters were susceptible to age-related degradation. Specifically, PSEG identified that components in these inverters exceeded their vendor-recommended 10-year service life and that there was no preventive maintenance plan in place to replace these components prior to the end of service life.
PSEG entered the issue into the corrective action program, proposed corrective actions, and developed a performance centered maintenance (PCM) template for the inverters.
However, the station delayed implementation of the actions due to challenges in requisitioning new parts and refueling outage (RFO) scheduling issues. This delay resulted in more age-related degradation failures of the vital instrument bus inverters, specifically, the 1D vital instrument bus inverter failure on August 24, 2008, and the 2B/2C vital instrument bus inverter failures on December 31, 2008, and January 1, 2009, respectively. This issue is documented in PSEGs corrective action program, and PSEG has scheduled replacement of the components susceptible to age-related degradation and increased the monitoring frequency of the inverters until the components can be replaced.
The inspectors independently evaluated this issue for significance in accordance with IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues. Although the components exceed their vendor-specified lifetime, failure of these components would not result in a complete loss of power to a vital bus due to the availability of two back-up sources of power, and therefore did not have a significant impact on plant operations. The inspectors consider this issue to be of minor significance, and, as a result, it is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
In addition to the issue described above, the inspectors identified one example where ineffective corrective actions contributed to a more than minor violation in which PSEG did not monitor the performance of the service water system as required by 10 CFR 50.65 paragraph (a)(1). This finding is documented in Section 4OA2.1.c.
c. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(1), for PSEGs failure to monitor the performance of the service water system against established goals in a manner sufficient to provide reasonable assurance that the system was capable of fulfilling its intended function. PSEG also failed to take corrective action when system performance exceeded the (a)(1) unavailability goals.
Description.
On December 16, 2007, and January 30, 2008, Salem experienced repeat maintenance preventable functional failures of the 11 service water pump and strainer.
The service water pumps ensure adequate cooling of safety-related equipment during an accident and consequently are scoped into the maintenance rule. PSEG had placed the service water system in (a)(1) status for previous performance issues, but the pumps and strainers were not subject to additional monitoring at the time of these events.
In response to the repeat maintenance preventable functional failures, and in accordance with guidance described in PSEG procedure ER-AA-310-1005, Maintenance Rule - Dispositioning Between (a)(1) and (a)(2), the inspectors determined that Salem should have performed an (a)(1) determination and held a Maintenance Rule Expert Panel meeting by March 2008 to discuss a plan for monitoring service water system performance and develop (a)(1) goals to ensure the system was capable of fulfilling its safety function. Additionally, these goals should have been in place by May 2008, 60 days after the Maintenance Rule Expert Panel meeting. Instead, on March 30, 2008, PSEG generated an action tracking item (ACIT) assignment to the system manager to perform the (a)(1) determination within 30 days. Due to resource challenges surrounding the refueling outage, the station did not meet this due date, and in July 2008, PSEG generated a notification detailing the missed deadline.
On October 2, 2008, the Maintenance Rule Expert Panel met and approved (a)(1) goals and an (a)(1) monitoring plan for the service water system. One of the goals approved by the panel was to maintain system unavailability less than 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> per train over an 18 month period. The inspectors determined that between May 2008, when PSEG should have had (a)(1) goals, and October 2008, when (a)(1) goals actually were established, system performance exceeded the 600-hour unavailability goal 12 times.
PSEG should have evaluated each failure to meet the system (a)(1) unavailability goal and taken appropriate corrective action, as stated in 10 CFR 50.65(a)(1).
The inspectors identified a second example where PSEG should have identified that service water exceeded the (a)(1) monitoring goals and taken appropriate corrective actions as required by 10 CFR 50.65(a)(1). During the October 2, 2008 maintenance rule expert panel meeting, PSEG determined that the 600-hour (a)(1) unavailability goal was too aggressive, and assigned an action to the system manager to propose a more appropriate goal. The panel also approved the 600-hour goal as an interim goal. On February 19, 2009, the maintenance rule expert panel approved a revised (a)(1) goal of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of unavailability per train over an 18 month period and extended the monitoring time from December 2008 through December 2012. PSEG planned to continue (a)(1) monitoring of system performance by performing monthly reviews of service water system unavailability data. Service water system unavailability exceeded the (a)(1) unavailability goal of 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> for the 21 pump from April 2009 through June 2009, but PSEG did not recognize that they had failed to meet the system goals, nor did they take any additional corrective actions as required by 10 CFR 50.65(a)(1) until the inspectors identified the issue in June 2009. PSEG has entered this issue into their corrective action program for evaluation under notifications 20422672 and 20422673.
Analysis.
The inspectors determined that PSEGs failure to establish goals and monitor service water system performance from March 2008 through October 2008 and their subsequent failure to take corrective actions when system performance exceeded unavailability goals in April 2009 was a performance deficiency. This finding is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and dependability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage).
This finding is not suitable for evaluation using the Significance Determination Process (SDP) because the performance deficiency did not cause the degraded equipment performance. Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Per the guidance provided in Inspection Procedure 71111.12, this issue is considered to be a Category II finding and thus, per NRC management review, is considered to be Green.
With respect to assigning a cross-cutting aspect to this finding, the inspectors determined that the most meaningful insight into PSEGs performance was a programmatic concern with the implementation of the maintenance rule program at Salem. PSEG acknowledged this programmatic concern, which included ownership and accountability issues, initiated a focused self-assessment of the maintenance rule program, and will assign corrective actions as appropriate. This insight is not aligned with the specific performance deficiency attributes defined in IMC 0305 and, as such, the inspectors have not assigned a cross-cutting aspect to this finding.
Enforcement.
10CFR 50.65(a)(1) requires, in part, that licensees shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph
- (b) of this section, are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken. Contrary to this, PSEG experienced repeat maintenance preventable functional failures of the service water strainers in December 2007 and January 2008, yet did not establish (a)(1) goals to monitor system performance until October 2008. During this unmonitored period, system performance exceeded the eventual 600-hour unavailability goal 12 times. Additionally, the inspectors identified a second example of this issue when PSEG failed to recognize they did not meet the revised (a)(1) goals and take appropriate corrective action when the service water system exceeded its 800-hour unavailability goal from April through June 2009.
Because this violation was of very low safety significance and PSEG has entered this issue into their corrective action program under notifications 20422672 and 20422673, the inspectors are treating this violation as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. (NCV 05000272/2009007-01; 05000311/2009007-01, Failure to Establish Goals and Monitor for (a)(1) Service Water System.)
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of operating experience issues to confirm that PSEG appropriately evaluated the operating experience information for applicability to Salem and had taken appropriate actions, when warranted. The inspectors reviewed notifications which evaluated operating experience documents associated with a sample of NRC generic communications, reports made pursuant to 10 CFR Part 21, Reporting of Defects and Non-Compliance, and industry operating experience. A list of the documents reviewed is included in the Attachment to this report.
b. Assessment
The inspectors determined that, in general, PSEG appropriately considered industry operating experience information for applicability and used the information to identify corrective and preventive actions and prevent similar issues when appropriate. The inspectors did identify two instances where PSEG either did document or did not fully evaluate the operating experience in their corrective action program. In the first instance, PSEG evaluated an issue for Hope Creek Generating Station, which shares the same corrective action program as Salem, but did not write a notification to evaluate applicability to Salem. In response to this observation, PSEG initiated notification 20422395 to complete the assessment for Salem. In the second instance, Salem evaluated applicability of the equipment issue described in the operating experience, but did not consider the potential human performance and procedure adequacy issues that were also described. PSEG initiated notification 20422313 to complete this assessment.
These results are consistent with the results of a PSEG self assessment completed in early 2009 under work order 70094452. PSEG is developing a plan to improve performance in the operating experience area.
The inspectors independently evaluated these deficiencies for significance in accordance with IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues. Because these deficiencies had no impact on plant operations, the inspectors consider these issues to be of minor significance, and, as a result, they are not subject to enforcement action in accordance with the NRCs Enforcement Policy.
c. Findings
No findings of significance were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if problems identified through these assessments were entered into the corrective action program, when appropriate, and whether PSEG initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection. A list of documents reviewed is included in the Attachment to this report.
b. Assessment
The inspectors concluded that self-assessments, audits, and other internal PSEG assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that PSEG personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. PSEG completed these audits and self-assessments to a sufficient depth to identify issues which were entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings of significance were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at Salem. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program (ECP) coordinators to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the ECP files to ensure that PSEG entered issues into the corrective action program when appropriate. The inspectors also reviewed a sample of anonymous notifications and the site nuclear culture survey performed in 2008 to gain insights into SCWE at Salem.
b. Assessment
During interviews, plant staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the ECP. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable SCWE and no significant challenges to the free flow of information.
c. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On July 9, 2009, the inspectors presented the inspection results to Mr. E. Eilola, Plant Manager, and other members of the Salem staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
E. Eilola
Plant Manager
H. Berrick
Licensing Engineer, Regulatory Compliance
D. Boyle
Maintenance Rule Program Engineer
T. Cachaza
Station Corrective Action Program Coordinator (CAPCO)
S. Cornman
Technical Analyst, Salem Maintenance Planning (Maintenance CAPCO)
- S. Crampton System Manager, Auxiliary Feedwater and Component Cooling Water Systems
E. Davis
Staff Engineer Nuclear, Chemist
R. DeNight
Nuclear Shift Supervisor
- R. DeS anctis Director, Maintenance
A. Garcia
System Manager, Service Water
J. Garecht
Shift Operations Superintendent
W. Guthrie
Manager, Security Operations
M. Gwirtz
Director, Operations
W. Hammond Work Control Corrective Action Program Coordinator (CAPCO)
F. Hummel
System Manager, Chilled Water System
A. Johnson
Manager, Mechanical/Structural Design
M. Lenoir
Mechanical Maintenance Supervisor
- W. Mattingly Manager, Regulatory Assurance
R. Moore
Manager, Electrical Systems
J. Morrison
Maintenance Superintendent
G. Pahwa
89-13 Program Coordinator
M. Patti
Manager, Security Programs
G. Pupek
Operations Engineer
C. Pupek
PRA Manager
P. Quick
EP Manager, Salem
M. Rahmani
System Manager, 115VAC
T. Ram
System Manager, 115VAC
E. Villar
Licensing Engineer
R. Vondrasek EP Coordinator
A. Wesolek
Radiation Protection Corrective Action Program Coordinator (CAPCO)
State of New Jersey Bureau of Nuclear Engineering
- E. Rosenfeld, Engineer
LIST OF ITEMS
OPEN, CLOSED, AND DISCUSSED
Opened and Closed
- 05000272,311/2009007-01 NCV Failure to Establish Goals and Monitor for (a)(1) Service Water System