IR 05000272/2018002
| ML18207A221 | |
| Person / Time | |
|---|---|
| Site: | Salem |
| Issue date: | 07/26/2018 |
| From: | Fred Bower Reactor Projects Branch 3 |
| To: | Sena P Public Service Enterprise Group |
| References | |
| IR 2018002 | |
| Download: ML18207A221 (22) | |
Text
July 26, 2018
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -
INTEGRATED INSPECTION REPORT 05000272/2018002 AND 05000311/2018002
Dear Mr. Sena:
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Stations (Salem) Units 1 and 2. On July 10, 2018, the NRC inspectors discussed the results of this inspection with Mr. Charles McFeaters, Salem Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Salem. In addition, if you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at Salem. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Fred L. Bower, III, Chief Reactor Projects Branch 3 Division of Reactor Projects
Docket Nos.: 50-272 and 50-311 License Nos.: DPR-70 and DPR-75
Enclosure:
Inspection Report 05000272/2018002 and 05000311/2018002
Inspection Report
Docket Nos.
50-272 and 50-311
License Nos.
Report Nos.
05000272/2018002 and 05000311/2018002
Enterprise Identifier: I-2018-002-0060
PSEG:
Facility:
Salem Nuclear Generating Station (Salem) Units 1 and 2
Location:
Hancocks Bridge, NJ 08038
Dates:
April 1, 2018 through June 30, 2018
Inspectors:
P. Finney, Senior Resident Inspector
A. Ziedonis, Resident Inspector
L. Dumont, Reactor Inspector
M. Orr, Reactor Inspector
J. Schoppy, Senior Reactor Inspector
D. Tifft, Regional State Liaison Officer
J. Furia, Senior Health Physicist
Approved By:
Fred L. Bower, III, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring PSEGs performance at
Salem Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC identified and self-revealing findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Inadequate Design Change for Service Water Pumps Cornerstone Significance Cross-Cutting Aspect Inspection Results Section Mitigating Systems
Green NCV 05000272&311/2018-002-01 Closed P.2 - Problem Identification and Resolution -
Evaluation 71111.18 A self-revealing Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Appendix B, Criterion III, Design Control, was identified because PSEG item equivalency evaluation (IEE) 80102443 did not evaluate the use of a chromium oxide spray coating for suitability of application in a brackish river water environment. Consequently, the coating material delaminated, which resulted in a failed in-service test (IST), inoperability and unavailability of the 26 service water (SW) pump as well as the subsequent unavailability of the 16, 21, and 24 SW pumps to perform replacements of those pumps with the same coating.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. There were no operational power changes of regulatory significance for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. On May 7, the unit was manually tripped for an elevated 21 reactor coolant pump (RCP) winding temperature indication. The unit was returned to rated thermal power on May 9. There were no other operational power changes of regulatory significance for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess PSEGs performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Summer Readiness (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate AC power systems.
71111.04 - Equipment Alignment
Partial Walkdown (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2, 21 safety injection (SI) train during 22 train valve maintenance on May 2, 2018
- (2) Unit 2, emergency diesel generators (EDGs) during 2C EDG unavailability on June 11, 2018
- (3) Unit 2, 22 component cooling water (CCW) with the 21 CCW train inoperable on June 14, 2018
- (4) Common, chilled water during a cross-tie configuration on April 11, 2018
71111.05A/Q - Fire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 1, reactor plant auxiliary equipment area on May 11, 2018
- (2) Unit 2, EDG fuel oil storage pump and tank area on April 26, 2018
- (3) Unit 2, auxiliary feedwater (AFW) pumps area on May 10, 2018
- (4) Unit 2, 4160 Volt switchgear room on May 21, 2018
- (5) Common, auxiliary building ventilation areas on April 17, 2018
71111.06 - Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the Auxiliary Building from demineralized water piping on June 14, 2018.
Cables (1 Sample)
The inspectors evaluated cable submergence protection in:
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator requalification training that involved a battery ground, loss of containment air particulate detector, small and large break loss of coolant, and a swap to cold leg recirculation on April 17, 2018.
Operator Performance (1 Sample)
The inspectors observed a Unit 2 reactor startup following a forced outage on May 8, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Unit 2, 26 SW pump delamination on April 18, 2018
- (2) Unit 2, chillers following multiple failures on June 18, 2018
- (3) Common, MSPI diesel generator testing on June 22, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 1, 1A EDG availability during an instrumented run on April 30, 2018
- (2) Unit 2, 2D vital instrument bus inverter unlatched transfers on April 3, 2018
- (3) Unit 2, 26 SW pump failed retest on April 4, 2018
- (6) Common, chilled water cross-tie configuration for maintenance on April 11, 2018
- (7) Common, 23 charging pump unavailability on April 23, 2018
71111.15 - Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 1, 1SD1 shutdown bank control rod position indication on April 18, 2018
- (2) Unit 1, outer airlock door surveillance in alert range on April 25, 2018
- (3) Unit 2, 22 chiller trip on oil leak on April 6, 2018
- (4) Unit 2, intermediate range nuclear instrument (IRNI) failed channel check on May 8, 2018
- (5) Unit 2, SW tornado missile non-conformance on June 1, 2018
- (6) Unit 2, 21 SW pump degradation on June 8, 2018
71111.17T - Evaluations of Changes, Tests and Experiments
The inspectors evaluated the following from April 30, 2018, to May 4, 2018:
10 CFR 50.59 Evaluations
- (1) S2017-043, Reactor Coolant Pump Seals - Installation of SHIELD Seal (DCP 80109340) 50.59 Evaluation, Revision 0
10 CFR 50.59 Screening/Applicability Determinations
- (1) S2016-116, Auxiliary Feed Pump Room Controls, Local Temperature Switches and Control Room CMC Switches, 50.59 Screening Revision 0
- (2) S2016-120, S1(S2).OP-SO.FO-0001, Emergency Diesel Fuel Oil System Operation, Revision 11(13), 50.59 Screening Revision 0
- (3) S2016-123, S1.OP-AR.DG-0001, Diesel Generator Alarm Response, Revision 15, 50.59 Screening Revision 0
- (4) S2016-148, S1.OP-AB.CC-0001, Component Cooling Abnormality, Revision 15, 50.59 Screening Revision 0
- (5) S2016-165, Replace GE TEC Containment Penetration Breakers, 50.59 Screening Revision 0
- (6) S2016-175, 2-EOP-SGTR-1, Steam Generator Tube Rupture, Revision 31, 50.59 Screening Revision 0
- (7) S2016-252, PORVs Accumulators Capacity Analysis, 50.59 Screening Revision 0
- (8) S2016-281, S1.OP-DL.ZZ-0003, Control Room Log - Modes 1-4, Revision 83, 50.59 Screening Revision 0
- (9) S2016-291, S1(S2).OP-SO.AF-0001, Auxiliary Feedwater System Operation, and S1(S2).OP-ST.AF-0011, Auxiliary Feed Water Alternate Suction Source Verification Modes 1-3, Revisions 34(42), 4(4), 50.59 Screening Revision 0
- (10) S2017-021, SC.OP-AR.AF-0001, MSPI Auxiliary Feedwater Pump Diesel Alarm Response, Revision 0, 50.59 Screening Revision 0
- (11) S2017-094, Salem 1 and 2 PAT Controller Replacement, 50.59 Screening Revision 0
- (12) S2017-122, Revision of Technical Specification 3/4.7.3 Basis, 50.59 Screening Revision 0
- (13) S2017-126, NUCR 70186659 - 0055, Reactor Trip Breaker Predefined Change Request, 50.59 Screening Revision 0
- (14) S2017-140, S2.OP-SO.DG-0002, 2B Diesel Generator Operation, Revision 38, 50.59 Screening Revision 0
- (15) S2017-146, Work Clearance Document Reviews, 50.59 Screening Revision 0
- (16) S2017-155, S1.OP-SO.DG-0001 OTSC 37A (70195272), 1A Diesel Generator Operation, 50.59 Screening Revision 0
- (17) S2017-173, Procedure Revisions to Support Installation of Fisher Thermo Scientific Nuclear Instrumentation for Salem 1 during 1R25 (Batch AD-AA-101-1003-F8),50.59 Screening Revision 0
- (18) S2017-211, SC.CH-AD.DA-0405, Chemical Addition to Emergency Diesel Generator Jacket Water System, Revision 2, 50.59 Screening Revision 0
- (19) S2017-235, S1(S2)-EOP-FRHS-1, Restore Coincidence for FRHS-1 Feed and Bleed Initiation - Response to Loss of Secondary Heat Sink, Revisions 34(34),50.59 Screening Revision 0
- (20) S2017-237, S1.0P-DL.ZZ-0006-Fl, Primary Plant Log, Revision 14, 50.59 Screening Revision 0
- (21) S2017-245, VTD 320832, Rev 16, Emergency Operating Procedure Setpoint Document, Revision 16, 50.59 Screening Revision 0
- (22) S2018-010, Chilled Water Technical Specification LAR Calculations, 50.59 Screening Revision 0
- (23) S2018-020, S1(S2).OP-SO.CBV-0001, Containment Ventilation Operation, Revision 27(34), 50.59 Screening Revision 0
- (24) S2018-030, SAP Order 80121775, DS1.5-0560, Salem Common BEACON 6.8.4 Upgrade, 50.59 Screening Revision 0
71111.18 - Plant Modifications
The inspectors evaluated the following temporary or permanent modifications:
- (1) SW pump shaft coating Item Equivalency Evaluation 80102443
71111.19 - Post Maintenance Testing
The inspectors evaluated post maintenance testing for the following maintenance/repair activities:
- (1) Unit 1, 1B EDG following scheduled maintenance on June 6, 2018
- (3) Unit 2, Intermediate Range Nuclear Instrument 2N36 following corrective maintenance on May 9, 2018
- (4) Unit 2, 21 chiller following compressor replacement on May 29, 2018
- (6) Unit 2, 2C EDG following starting air solenoid valve replacement on June 12, 2018
71111.20 - Refueling and Other Outage Activities
The inspectors evaluated Unit 2 forced outage activities following a manual reactor trip for an elevated RCP winding temperature indication from May 7 to 9, 2018.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine
- (1) Unit 1, 1A EDG monthly run, on April 30, 2018
- (2) Unit 2, 21 SI pump, on May 5, 2018
- (3) Common, main control room envelope tracer gas testing on May 18, 2018
Inservice (2 Samples)
- (1) Unit 1, 11 AFW pump, on May 2, 2018
- (2) Unit 2, 23 SW pump, on May 22, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated the conduct of a routine PSEG emergency planning drill on March 27, 2018.
Drill/Training Evolution (1 Sample)
The inspectors evaluated a simulator-based licensed operator requalification training evolution for licensed operators that involved a battery ground, loss of containment air particulate detector, a secondary steam leak, a large break loss of coolant, and a swap to cold leg recirculationon on May 15,
RADIATION SAFETY
Cornerstone: Occupational and Public Radiation Safety
71124.01 - Radiological Hazard Assessment and Exposure Controls
Contamination and Radioactive Material Control (1 sample)
The inspectors observed the monitoring of potentially contaminated material leaving the radiological controlled area and inspected the methods and radiation monitoring instrumentation used for control, survey, and release of that material.
Risk-Significant HRA and VHRA Controls (1 sample)
The inspectors reviewed the procedures and controls for HRAs, VHRAs, and radiological transient areas in the plant.
71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Verification of Dose Estimates and Exposure Tracking Systems (1 sample)
The inspectors reviewed the current annual collective dose estimate; basis methodology; and measures to track, trend, and reduce occupational doses for ongoing work activities.
The inspectors reviewed post-job ALARA evaluations of excessive exposure.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 sample)
The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airborne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm set-points.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified PSEGs performance indicators submittals listed below for the period from March 2017 through March 2018.===
- (1) Unit 1 Unplanned Scrams per 7000 Critical Hours (IE01)
- (2) Unit 2 Unplanned Scrams per 7000 Critical Hours (IE01)
- (3) Unit 1 Unplanned Power Changes per 7000 Critical Hours (IE03)
- (4) Unit 2 Unplanned Power Changes per 7000 Critical Hours (IE03)
- (5) Unit 1 Unplanned Scrams with Complications (IE04)
- (6) Unit 2 Unplanned Scrams with Complications (IE04)
The inspectors verified PSEGs performance indicators submittals listed below for the period from December 2017 through December 2018. (2 Samples)
- (1) Unit 1 Safety System Functional Failures (MS05)
- (2) Unit 2 Safety System Functional Failures (MS05)
71152 - Problem Identification and Resolution
Semiannual Trend Review (1 Sample)
The inspectors reviewed the PSEGs corrective action program for trends that might be indicative of a more significant safety issue.
===71153 - Follow-up of Events and Notices of Enforcement Discretion
Events===
The inspectors evaluated response to the following events.
- (1) Unit 2, manual reactor trip in response to elevated 21 RCP winding temperature indication on May 7, 2018, EN#53386
INSPECTION RESULTS
Inadequate Design Change for Service Water Pumps Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000311/2018-002-01 Closed P.2 - Problem Identification and Resolution
- Evaluation 71111.18 A self-revealing Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Appendix B, Criterion III, Design Control, was identified because PSEG item equivalency evaluation (IEE) 80102443 did not evaluate the use of a chromium oxide spray coating for suitability of application in a brackish river water environment.
Consequently, the coating material delaminated, which resulted in a failed in-service test (IST), inoperability and unavailability of the 26 service water (SW) pump as well as the subsequent unavailability of the 16, 21, and 24 SW pumps to perform replacements of those pumps with the same coating.
Description:
On March 14, 2018, the 26 SW pump failed its quarterly IST, and was declared inoperable.
The SW system is designed with six SW pumps per Unit. Although Unit 2 entered a planned 72-hour shutdown limiting condition for operation (LCO) during the IST, operators manually realigned the SW system from the test lineup to a normal configuration such that no LCO was required with 26 SW pump inoperable. Maintenance technicians discovered a significant amount of river debris and foreign material internal to the pump, and determined pump replacement was required. On April 6, 2018, 26 SW pump was restored to OPERABLE after successfully replacing the pump and performing a successful post maintenance test (PMT).
PSEG performed Equipment Reliability Evaluation (ERE) 70199518, and concluded the cause of 26 SW pump IST failure was attributed to delamination of the chromium oxide spray coating material applied to the pump shaft and various pump internals. PSEG further determined that the delamination caused internal bearing rubbing and increased internal clearances, which allowed the buildup of river grass and foreign material to wedge between the increased clearances, thus changing the flow characteristics of the pump. Recent IST performance history did not require a transition to the IST alert range, which would have required increased frequency testing.
Although the ERE did not determine the cause of the delamination, PSEG wrote a separate notification (NOTF), 20793444, to investigate the adequacy of IEE 80102443, which approved use of the chromium oxide spray coating in 2011. PSEG determined that the IEE did not review the SW pump internals coating material for application in a brackish water environment. The IEE focused on SW pump bearing and bushing material change, and further stated that the coating would be applied to the shaft and various pump internals by a different vendor to harden the pump internals due to the new bearing material. However, the actual coating was not evaluated for acceptability as a non-identical replacement item by evaluating form, fit, and function, as required by SM-AA-300, Procurement Engineering Support Activities, Revision 5, step 4.1.1, item 3. PSEG captured this issue in NOTF 20798798.
PSEG also determined this was not the first SW pump to undergo internal coating delamination. In September of 2016, the 16 SW pump exhibited degraded IST, which resulted in planned corrective maintenance in March of 2017. Maintenance discovered the presence of foreign material internal to the pump and replaced the pump. In June of 2017, failure analysis of the removed pump identified the coating delamination (70192782-0030 and 70194122-0090). In May of 2017, 24 SW pump had a problem with the packing leakoff line during PMT from planned maintenance. In response, PSEG completed work group evaluation (WGE) 70194122 in June of 2017, which identified the same coating delamination as the previous 16 SW pump. PSEG determined the 24 SW pump issue was not a condition adverse to quality, because it was considered rework identified during PMT from planned maintenance. The inspectors verified this determination was in accordance with performance improvement job aid PIA-016, Examples of a Condition Adverse to Quality, Revision 0. The WGE did assign an equipment reliability (ER) strategy (70194122-0040) that resulted in changing the pump internals coating material to Inconel, but did not identify or evaluate the remaining SW pumps coated with chromium oxide. Following the 26 SW pump failed IST, PSEG performed a full extent of condition evaluation, and determined that the 21 SW pump was the one remaining pump installed in the plant with the chromium oxide coating. PSEG expedited the 21 SW pump replacement, and although the pump did exhibit degraded IST performance into the alert range prior to replacement, PSEG successfully replaced the pump prior to IST failure.
Corrective Actions: PSEG performed corrective maintenance to restore the 16 SW pump on March 21, 2017; 24 SW pump on May 27, 2017; 26 SW pump on April 6, 2018; and 21 SW pump on June 16, 2018. Additionally, PSEG performed ERE 70199758 and a failure analysis to evaluate the cause of the coating failure, wrote NOTF 20798798 to capture the deficient IEE in the CAP, and changed the coating material from chromium oxide to Inconel.
Corrective Action References: NOTFs 20798798 and 20793444, and ERE 70199518
Performance Assessment:
Performance Deficiency: The inspectors determined that not evaluating the SW pump internal coating material for form, fit and function as required by SM-AA-300, step 4.1.1, was a performance deficiency that was within PSEGs ability to foresee and correct, and should have been prevented.
Screening: This finding is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the coating material delaminated from the pump internals, which resulted in failed IST, inoperability and unavailability of the 26 SW pump as well as unavailability of the 16, 21 and 24 SW pumps to perform pump replacements.
Significance: The inspectors assessed the significance of the finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green), because the finding did not represent a loss of the SW system safety function, did not result in any loss of function beyond the Technical Specification allowed outage time, and did not result in the loss of any non-Technical Specification trains that were designated as high safety-significance in accordance with PSEGs maintenance rule program.
Cross-Cutting Aspect: This finding has a cross-cutting aspect of Problem Identification and Resolution, Evaluation, because PSEG did not thoroughly evaluate the chromium oxide coating delamination after it was identified in June of 2017 to have occurred on two pumps, to ensure that the resolutions addressed the cause and extent of condition prior to additional SW pump coating delaminations. Specifically, a WGE and an ER strategy were performed in response to two SW pump coating delamination issues, but neither product identified nor evaluated the SW pumps with the coating, and consequently did not ensure that the resolution addressed the cause and extent of condition. Although the inadequate IEE that approved the coating material was performed in 2011, which is outside of the nominal three-year current performance window as discussed in IMC 0310, the inspectors determined that the more recent missed opportunities in 2017 on the 16 and 24 SW pumps by PSEG were representative of current performance. (P.2)
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires that measures be established for the selection and review of materials for suitability of application. PSEG procedure SM-AA-300, Procurement Engineering Support Activities, Revision 5, step 4.1.1, item 3, requires the station to perform an IEE to document the acceptability of non-identical replacement items by evaluating form, fit, and function.
Contrary to this, from November 3, 2011, until June 21, 2018, IEE 80102443 was approved to make a non-identical replacement to the SW pump internals, but did not evaluate the use of a new coating material for suitability of application in a brackish river water environment.
Specifically, the IEE evaluated the pump bearing and bushing material change, and further stated that a chrome oxide coating would be applied to the pump shaft and various pump internals by a different vendor, to harden the pump internals due to new bearing material.
However, the chrome oxide spray coating material was not evaluated for form, fit, and function in its service environment.
Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observations 71152 Semi-Annual Trends The inspectors evaluated a sample of condition reports generated over the past two quarters to identify trends (either NRC-or licensee-identified) that might indicate the existence of a more significant safety issue, and to identify potential adverse trends in systems, structures and components (SSCs). The inspectors determined that, in most cases, the issues were appropriately evaluated by PSEG staff and appropriately resolved. The inspectors noted three examples of trends that were important to safety:
Notification Significance Screening
PSEG nuclear oversight department (NOS) identified an adverse trend associated with the significance level screening of NOTFs. NOTFs are documents used by PSEG to identify an issue or a problem at the station, as described in LS-AA-120, Issue Identification and Screening, Revision 17. Five significance levels are use in the significance screening process. Levels 1 through 3 fall under the scope of the corrective action program (CAP), and levels 4 and 5 are considered Non-CAP (N-CAP).
In May of 2017, NOS identified several examples of NOTFs that documented issues associated with safety-related equipment, but were subsequently screened with an N-CAP significant level (NOTF 20764651). Additional follow-up reviews by NOS in August of 2017 (20773330), February of 2018 (20787256), and May of 2018 (20793644), have identified continued challenges in the screening of NOTFs as CAP issues versus N-CAP issues. In response, PSEG completed WGE 70194087 in June of 2017, which determined the station was applying too narrowly a focus on the impact of the safety function when screening NOTFs that document issues with safety-related equipment. PSEG also re-reviewed over 2000 NOTFs, re-screened over 350 NOTFs, rolled out additional guidance to station NOTF screening committees. In addition, PSEG has performed subsequent revisions to LS-AA-120, Issue Identification and Screening, to improve definitions and guidance with examples of issues at each significance level in CAP, as well as examples of N-CAP items.
The inspectors have also questioned PSEG on a sampling of NOTF significance screenings, including August 2017 (20774380), November 2017 (20782853 and associated NCV 05000272/2017004-01 [ML18039A899]), and February 2018 (20786093). The inspectors determined that PSEG was taking adequate actions to correct this adverse trend.
Status Control and Human Performance Events
PSEG identified an adverse trend in the areas of status control and human performance events. In June of 2018, PSEG documented an adverse trend in operations department human performance events (20796617), including a 2B EDG trip on reverse power during post maintenance testing, a station air compressor automatic start on low air header pressure during maintenance, and a service water valve mispositioned during tagging for planned maintenance. In February of 2018, PSEG initiated common cause evaluation 70198988, in response to a negative trend of status control events in 2017, including steam generator nitrogen sparging containment isolation valves (CIVs) that were left open during plant startup (NCV 05000272/2018001-03 [ML18134A260]), and a mispositioned main generator hydrogen vent valve that caused a loss of hydrogen pressure in the main generator and subsequent unplanned downpower to 47 percent (IR 05000272/311/2017004 [ML18039A899], Summary of Plant Status and Section 4OA3.1). PSEG has taken several action in response to this adverse trend, including issuing several station communications, establishing a cross-discipline status control committee, establishing a status control excellence plan, assigning an action to perform an annual status control CCE that incorporates industry benchmarking, issuing status control cards to all personnel that work in the plant for use during pre-job briefs, and performance of a self-assessment to evaluate station procedures and administrative processes governing configuration control. The inspectors noted that several of the status control events inherently involved a failure to follow procedure, but did not specifically select items from this trend review for additional inspection based on the low safety significance (other than the NCV referenced above). The inspectors determined that PSEG was taking adequate actions to correct this adverse trend.
Main Control Room Ventilation Outside Air Intake Radiation Monitors (R1Bs)
On October 17, 2017, PSEG identified an adverse trend of R1B issues (20778575), whereby some issues resulted in control area ventilation (CAV) system actuation from the normal ventilation damper alignment (i.e., normal mode) to the safety mode of operation, and other issues consisted of an abnormal rising trend in detector radiation levels (i.e., counts)discovered by operators prior to system actuation. PSEG determined that several of the issues were caused by degraded detector mylar shielding, which is designed to shield ambient light from the detector. In response to the trend, PSEG took credit for actions performed under ERE 70196422, completed on November 8, 2017. The ERE identified the direct cause to be attributed to degraded mylar, and took actions to correct the direct cause.
PSEG further attributed the cause of the degraded mylar to be discrete particulates entering the ventilation intake and impacting the mylar. The inspectors noted the ERE treated this as a prevention item, which does not require an assigned corrective action, and created an enhancement action (70196422, operation 80) for engineering to evaluate alternate duct designs to shield the detector from discrete particles.
From November 28, 2017, to June 10, 2018, the inspectors noted an apparent trend of five additional R1B failures that either resulted in an unplanned shift in CAV mode, or the R1B being declared inoperable due to rising counts. Each of the five failures were corrected and the R1Bs were returned to service. PSEG identified the apparent trend through the Plant Health Committee (PHC) review process, and discussed the trend at a PHC meeting on June 11, 2018. PHC determined that no further action was required, based on the low risk screening of the R1Bs in accordance with ER-AA-2001-1003, Equipment Reliability Risk Management Process. The inspectors independently reviewed each of the five failures, including PSEGs corrective maintenance, and did not identify any causes that were common to the five failures. The inspectors noted the enhancement action assigned under ERE 70196422 has been open since November 7, 2017.
In the case of each of the three observations above, the inspectors determined there was no new performance deficiency identified.
EXIT MEETINGS AND DEBRIEFS
Inspectors verified no proprietary information was retained or documented in this report.
- On May 4, 2018, the inspectors presented the Evaluations of Changes, Tests and Experiments inspection results to Mr. Charles V. McFeaters, Site Vice President, and other members of PSEG staff.
- On May 25, 2018, the inspector presented the radiation safety inspection results to Mr. S. Howe, Radiation Protection Manager, and other members of the licensee staff.
- On July 10, the inspectors presented the quarterly resident inspector inspection results to Mr. Charles McFeaters, Salem Vice President, and other members of the PSEG staff.
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
Procedures
OP-AA-108-107-1001, Response to Grid Emergencies and ESOC / ER&T Interface, Revision 5
71111.04 - Equipment Alignment
Procedures
S1.OP-DL.ZZ-0003, Control Room Log - Modes 1-4, Revision 84
S1.OP-SO.CC-0002, 11 and 12 Component Cooling Heat Exchanger Operation, Revision 32
S1.OP-SO.CC-0003, Inservice Testing - 13 Component Cooling Pumps, Revision 25
Condition Reports
20793557
20786124
20797325
Drawings
205334-SIMP, Unit 2 Safety Injection Simplified P&ID, Revision 2
Miscellaneous
Additional Reading Sheet associated with 20786124, Dated 06/13/2018
NC.DE-AP.ZZ-0002, Equal Signal Pressure / Control of Valves SW122 and SW127, Revision 0
S-1-CC-MDC-1817, Component Cooling System Thermal-Hydraulic Analysis - Unit 1,
Revision 9
S-2-CC-MDC-1692, Component Cooling System Thermal-Hydraulic Model - Unit 2, Revision 7
71111.05 - Fire Protection
Procedures
FP-AA-011, Control of Transient Combustible Material, Rev. 6
Miscellaneous
FP-SA-2543-F1, U2 Auxiliary Feed pump & Letdown Heat Exchange Area, Rev. 0
SC.ER-PS-0001-A2, Salem Fire Barrier Deviations, Rev. 0
71111.06 - Flood Protection Measures
Condition Reports
20715168
20775834
20747706
20780808
Drawings
205246, Demineralized Water - Restricted Areas, Sheet 1, Revision 45
Maintenance Orders/Work Orders
60137110
60133992
71111.11 - Licensed Operator Requalification Program
Procedures
EP-SA-111-130, Salem EAL Wall Chart - All Modes, Revision 2
EP-SA-111-131, Salem EAL Wall Chart - Hot Conditions (RCS > 200^F), Revision 1
OP-SA-102-106-F1, Master List of Times Actions, Revision 1
S2.OP-AB.LOAD-0001, Rapid Load Reduction, Revision 19
S2.OP-AB.RC-0001, Reactor Coolant System Leak, Revision 14
S2.OP-AB.PZR-0001, Pressurizer Heater Malfunction, Revision 18
Miscellaneous
ACM 2017-009, 2PR2 PORV Leakage, Revision 1
S-ESG-1802, Simulator Training Scenario
71111.12 - Maintenance Effectiveness
Condition Reports (*initiated in response to inspection)
20799133*
20793581
20791632
20796561
20795909
20793974
20793476
20793465
20793116
20793429
20793065
Maintenance Orders/Work Orders
200387
70085974
70088447
200400
70196614
Miscellaneous
NUMARC 87-00, Revision 0
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Condition Reports (*initiated in response to inspection)
20790904*
20790976*
20789818*
20791273*
20792515*
20792839*
20792707*
20792716*
20792717*
20793378*
71111.15 - Operability Determinations and Functionality Assessments
Condition Reports (*initiated in response to inspection)
20792430*
20792989
20792822*
20792575
20793249*
20793752
20792250
29792581
20794055
20794044
20797741
20758900
20768856
20768866
20762932
20760469
20796523
20799781
20798222
20798223
20798968
20796701*
20799780
20765041
20799448
20796648
20796970
20797131
20797136
20797561
20797569
20797570
20797571
20797573
20797572
20797574
20797772
20797773
20797774
20797775
20797776
20797777
20799051*
20798741
20796231
20793326
20792935
20793992
20793991
Drawings
205447, Units 1 and 2 Service Water Intake Yard Duct Runs Pipe Tunnel Conduit and Trays,
Revision 37, Sheet 1
211750, Units 1 and 2 Class 1 Tanks and Pipe Tunnel, Sheet 1, Revision 7
219562, Units 1 and 2 Class 1 Tanks and Pipe Tunnel, Sheet 1, Revision 10
219563, Service Water Piping to Auxiliary Building, Revision 23
Maintenance Orders/Work Orders
60138533
60138438
203517
203277
60139321
60132502
70192913
70199153
289992
289993
288527
60139163
200981
Miscellaneous
ACM 2018-005, Salem Unit 2 RAP Tunnel North Manhole Opening Missile Shield Removed,
Revision 0
Event Notification 53438, Tornado Missile Vulnerabilities
ND.DE-TS.ZZ-1014, Technical Standard: Instrument Piping and Tubing Design Requirements,
Revision 4
Operability Evaluation 2018-003, 21 Service Water Pump, Revision 0
Operability Evaluation 2018-004, Non Conformances due to Tornado Missile Vulnerability,
Revisions 0 and 1
SC.IC.CC.NIS-023, NIS Source Range/Intermediate Range N36 Channel Calibration, Revision
71111.17 - Evaluations of Changes, Tests and Experiments
Procedures
1-EOP-LOCA-3, Transfer To Cold Leg Recirculation, Revision 31
LS-AA-104, 50.59 Review Process, Revision 6
LS-AA-104-1000, 50.59 Resource Manual, Revision 8
LS-AA-104-1006, PSEG Nuclear 50.59 Training and Qualification, Revision 3
S1.OP-SO.CC-0001, Component Cooling System Operation, Revision 20
S1.OP-SO.SW-0005, Service Water System Operation, Revision 41
Condition Reports (*initiated in response to inspection)
20768892
20769000
20769002
20770247
20774261
20784396
20793321
20793479*
20793480*
20793579*
20793585*
20793589*
20793590*
20793592*
20793593*
Maintenance Orders/Work Orders
70062808
70183596
70195291
70195979
70183596
80120385
80121786
Miscellaneous
LR-N17-0080, Salem CTE Summary Report of Changes Tests, and Experiments, 4/14/17
LTR-SEE-16-236, Downstream Effects Evaluation of an Inadvertent Actuation of the Reactor
Coolant Pump Shutdown Seal at Salem Units 1 and 2, 2/7/17
NOSA-SLM-17-07, Salem Engineering Design Control Audit Report, 6/28/17
Salem 50.59 Performance Self-Assessment, 4/12/18
SNGS Unit 1 Amendment No. 316 to Facility Operating License, Renewed License No. DPR-70
SNGS Unit 2 Amendment No. 297 to Facility Operating License, Renewed License No. DPR-75
S-C-CAV-MDC-2320, Evaluation of the Control Area Ventilation System During Chilled Water
System Chiller Replacement, Revision 2
S-C-CH-MDC-2319, Hydraulic Evaluation of Salem Units 1 and 2 Chilled Water Systems to
Support Reduced Chiller Availability, Revision 2
SGS-TRM, SNGS Units 1 and 2 Technical Requirements Manual, Revision 0
SGS-UFSAR, Revision 29
TR-FSE-14-1-P, Use of Westinghouse SHIELD Passive Shutdown Seal for FLEX Strategies,
Revision 1
VTD 320832, Emergency Operating Procedure Setpoint Document, Revision 16
71111.19 - Post Maintenance Testing
Procedures
S2.OP-ST.CH-0004, Chilled Water System - Chillers, Revision 23
Condition Reports (*initiated in response to inspection)
20793466
20797457*
2797367*
20799000*
Maintenance Orders/Work Orders
203942
202240
200903
70156720
60138959
Miscellaneous
PMT of Failed IR NI 2N36, Completed on May 9, 2018
71111.20 - Refueling and Other Outage Activities
Procedures
OP-AA-108-114, Post Transient Review, Revision 5
OP-SA-108-114-1001, Post-Trip Data Collection Guidelines - Salem, Revision 4
S2.OP-AB.RCP-0001, Reactor Coolant Pump Abnormality, Revision 22
S2.OP-IO.ZZ-0008, Maintaining Hot Standby, Revision 16
Condition Reports
20796928
20793014
20794354
20792574
20793987
20793944
20793813
20793989
20793988
20796661
20796639
20796566
20796564
20795287
20795892
20795893
20795894
20795895
20793977
20793979
20796650
20796651
20796652
20796654
20793714
20794037
20793844
20794056
20794360
20794421
20798152
20798151
Drawings
218920, 11 and 12 RCPs and Loops, Revision 26
203525, Units 1 and 2 Control Rooms Recorder Panels 1RP4 and 2RP4, Revision 41
Maintenance Orders/Work Orders
60138585
71111.22 - Surveillance Testing
Condition Reports
20781952
20793466
20793084
Maintenance Orders/Work Orders
202723
201642
201611
71114.06 - Drill Evaluation
Procedures
S2.OP-AB.GRID-0001, Abnormal Grid, Revision 21
S2.OP-AB.LOAD-0001, Rapid Load Reduction, Revision 19
Condition Reports (*initiated in response to inspection)
20789869*
20793157*
20791381
20791372
20791371
20791369
20791370
20791428
20791368
20791012
20790997
20789820
20790913
20790906
20790967
20790968
20790969
20790970
20790858
20790323
20791147
20789844
20790038
20790703
20790009
20790594
20790595
20790627
Drawings
205203, Unit 1 Main, Reheat and Turbine Bypass Steam, Sheet 1, Revision 78
Miscellaneous
S18-01, Emergency Drill Scenario
S18-01, Emergency Drill Critique Report
71152 - Problem Identification and Resolution
Condition Reports (*initiated in response to inspection)
20791323*
20790980*
20791015*
20791418*
20793152*
20793247*
20793250*
20793811*
20796886*
20798999*
20799212*
71153 - Follow-Up of Events and Notices of Enforcement Discretion
Condition Reports (*initiated in response to inspection)
20794421*
Miscellaneous
Post-Trip Data Collection, Completed on May 7, 2018
Post Transient Review, Completed on May 7, 2018
TSO 2018-015, Units 1 and 2 RCP Stator Winding Alternate Indications, dated 05/10/2018