IR 05000272/2013008
| ML13238A066 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/26/2013 |
| From: | Glenn Dentel Reactor Projects Branch 3 |
| To: | Joyce T Public Service Enterprise Group |
| DENTEL, GLENN T. | |
| References | |
| IR-13-008 | |
| Download: ML13238A066 (20) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ust 26, 2013
SUBJECT:
SALEM NUCLEAR GENERATING STATION UNIT NOS. 1 AND 2 -
NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000272/2013008 AND 05000311/2013008
Dear Mr. Joyce:
On August 1, 2013, the United States Nuclear Regulatory Commission (NRC) completed an inspection at your Salem Nuclear Generating Station, Unit Numbers 1 and 2. The enclosed report documents the inspection results, which were discussed on August 1 with John F. Perry, Site Vice President, and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and 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 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.
This report documents one self-revealing and one NRC-identified finding each of very low safety significance (Green). One of these findings was determined to be 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, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest this non-cited violation, 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 cross-cutting aspect assigned to any finding 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 Regional Administrator, Region I, and the NRC Resident Inspector at Salem Nuclear Generating Station.
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 Publicly 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/
Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos.: 50-272, 50-311 License Nos.: DPR-70, DPR-75
Enclosure:
Inspection Report 05000272/2013008 and 05000311/2013008 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-272, 50-311 License Nos.: DPR-70, DPR-75 Report Nos.: 05000272/2013008 and 05000311/2013008 Licensee: PSEG Nuclear LLC (PSEG)
Facility: Salem Nuclear Generating Station Units 1 and 2 Location: P.O. Box 236 Hancocks Bridge, NJ 08038 Dates: July 15 through July 19, 2013 July 29 through August 1, 2013 Team Leader: Steve Shaffer, Senior Project Engineer Inspectors: Phil McKenna, Resident Inspector Joe DeBoer, Project Engineer Stephanie Galbreath, Reactor Engineer Approved by: Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY
IR 05000272/2013008 and 05000311/2013008; July 15 through August 1, 2013, Salem Nuclear
Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified one finding in the area of effectiveness of problem identification and one finding in the area of effectiveness of corrective actions.
This NRC team inspection was performed by three regional inspectors and one resident inspector. The report documents two findings of very low safety significance (Green) identified during this inspection and classifies one of these findings as a non-cited violation. The significance of most findings is indicated by their color (i.e., greater than Green, or Green,
White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.
Problem Identification and Resolution The inspectors concluded that 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 and one finding, one in the area of effectiveness of problem identification and one 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 operations. In addition, based on those items selected for review, the inspectors determined that PSEG self-assessments and audits 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 any conditions that could have had a negative impact on the sites safety conscious work environment.
Cornerstone: Initiating Events
- Green.
The inspectors identified a Green finding (FIN) for PSEGs failure to evaluate the performance deficiency documented for FIN 2011004-02 in accordance with procedure LS-AA-1003, NRC Inspection Preparation and Response. Specifically, PSEG failed to initiate a notification to review FIN 2011004-02 and develop appropriate corrective actions. The original finding, FIN 201100402, was associated with untimely corrective actions for degraded reactor coolant pump motor cables. In addition to not addressing the performance deficiency, the failure to initiate a notification creates the potential for future untimely corrective actions in similar cases. This issue was entered into PSEGs corrective action program as notification 20616485.
This finding is more than minor because if left uncorrected the issue has the potential to lead to a more significant safety concern. Specifically, PSEG has not corrected the performance deficiency which resulted in untimely corrective actions with regards to FIN 2011004-02. If similar untimely corrective actions were taken on a safety system this could result in a more significant safety concern. 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, issued June 19, 2012, this finding is of very low safety significance (Green) because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and did not affect mitigation equipment. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because PSEG did not completely and accurately identify the issue for FIN 2011004-02. Specifically, PSEG did not initiate a notification to review FIN 2011004-02 to ensure corrective actions properly address the finding. P.1(a)
Cornerstone: Mitigating Systems
- Green.
A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion V,
Instructions, Procedures and Drawings, was identified because PSEG did not complete a change to a preventative maintenance requirement for the Switchgear and Penetration Area Ventilation (SPAV) fan motors in accordance with PSEG procedure MA-AA-716-210-1005,
Predefine Change Processing. PSEG failed to perform an adequate engineering review of the Preventative Maintenance Change Request (PMCR) when bearing replacements were deleted from the SPAV fan motor maintenance plans in September, 2009. This resulted in the bearing not being lubricated and subsequent failure of the 13 SPAV supply fan motor on February 4, 2013. PSEG entered the issue into the corrective action program as notification 20594424.
The inspectors determined that the performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone, and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Specifically, because PSEG failed to investigate a difference in bearing type documented in a 1998 NRC commitment letter and the SPAV fan motor material master, they did not resolve conflicting information on the type of bearing installed in the SPAV fan motors before a preventive maintenance change to delete periodic bearing replacements took effect. This resulted in bearing and fan motor failure. The inspectors evaluated the finding in accordance with IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations (IMC 0609A). The inspectors determined that the finding was of very low safety significance (Green) because the deficiency did not affect the design or qualification; did not represent a loss of system safety function; did not screen as potentially risk significant due to external initiating events; and SPAV fans are not designated as high safety-significance in the licensees maintenance rule program. There is no cross-cutting aspect assigned because the performance deficiency is not indicative of current performance. Specifically, the performance deficiency involves an issue that occurred greater than three years ago and is not indicative of current performance.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described PSEG corrective action program at Salem. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these 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. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed notifications selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.
- (1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the charging system, safety injection system, emergency diesel generators and the intake structure.
Additionally, the inspectors reviewed a sample of notifications written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that PSEG entered conditions adverse to quality into their corrective action program as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of notifications issued since the last NRC biennial Problem Identification and Resolution inspection completed in July 2011. The inspectors also reviewed notifications that were assigned lower levels of significance that did not include formal cause evaluations to ensure that 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 the issues.
- (3) Effectiveness of Corrective Actions The inspectors reviewed PSEGs completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also 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 non-cited violations 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 PSEG actions related to the component cooling water system.
b.
Assessment
- (1) 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 typically identified problems and entered them into the corrective action program at a low threshold. PSEG staff at Salem initiated approximately 36,000 notifications between July 2011 and July 2013. The inspectors observed supervisors at the Plan-of-the-Day, Station Ownership Committee, and Management Review Committee meetings appropriately questioning and challenging condition reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that PSEG trended equipment and programmatic issues, and appropriately identified problems in notifications. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In general, inspectors did not identify any issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, PSEG personnel promptly initiated notifications and/or took immediate action to address the issues.
However, the inspectors identified one example of more than minor significance where Salem personnel were not effective in problem identification. This finding is documented in Section 4OA2.1.c.
- (2) 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.
Based on the sample of notifications reviewed, the inspectors noted that the guidance provided by PSEGs corrective action program implementing procedures was sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.
However, the inspectors identified one example of more than minor significance where Salem personnel were not effective in prioritization and evaluation. This finding is documented in Section 4OA2.1.c.
- (3) 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 most corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective with one exception documented below.
c. Findings
- (1) Failure to Evaluate Performance Deficiency for FIN 2011004-02
Introduction.
The inspectors identified a Green Finding (FIN) for PSEGs failure to adequately evaluate the performance deficiency for NRC FIN 2011004-02. Specifically, PSEG failed to initiate a notification to review FIN 2011004-02 and develop appropriate corrective actions per procedure LS-AA-1003, NRC Inspection Preparation and Response. The original finding, FIN 201100402, was associated with untimely corrective actions for degraded reactor coolant pump motor cables. In addition to not addressing the performance deficiency, the failure to initiate a notification creates the potential for future untimely corrective actions in similar cases.
Description.
On November 9, 2011, PSEG was issued a Green self-revealing finding (FIN 2011004-02) because PSEG did not ensure long-term corrective action options for the reactor coolant pump motor lead cables were completed timely and effectively in accordance with their corrective action program procedure (see NRC Inspection report 05000272,311/2011004). As part of the biennial Problem Identification and Resolution inspection (71152B), inspectors reviewed corrective actions taken in response to past NRC findings and violations. The inspectors identified that PSEG had not written a notification to address the performance deficiency for FIN 2011004-02.
PSEG procedure LS-AA-1003, NRC Inspection Preparation and Response, Step 4.3.2, states once the inspection report is issued, a notification is required to be generated.
During the licensee focused area self-assessment conducted in preparation for this inspection, PSEG identified that contrary to procedure, no notifications were written for FIN 2011004-02, and initiated notification 20608327. Inspectors reviewed the notification and determined that the licensee recommended no corrective actions and closed the notification to trend. The inspectors added value by identifying the performance deficiency for FIN 2011004-02 was still not evaluated and therefore no corrective actions have been taken. The intent of LS-AA-1003 is to ensure that station response and corrective actions properly address all findings and/or violations. PSEG did not take corrective actions to properly address FIN 2011004-02 and did not meet procedure LS-AA-1003. PSEG initiated notification 20616485 to address the concern.
Analysis.
The inspectors determined that PSEGs failure to evaluate the performance deficiency from FIN 2011004-02 was a new performance deficiency that was within PSEGs ability to foresee and correct. This performance deficiency is more than minor because if left uncorrected the issue has the potential to lead to a more significant safety concern. Specifically, PSEG has not corrected the performance deficiency which resulted in untimely corrective actions with regards to FIN 2011004-02. If untimely corrective actions were taken in a similar issue which involved a safety system, this could result in a more significant safety concern. 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, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because it did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and did not affect mitigation equipment.
This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because PSEG did not completely and accurately identify the issue for FIN 2011004-02. Specifically, PSEG did not initiate a notification to review FIN 2011004-02 to ensure corrective actions properly address the finding. P.1(a)
Enforcement.
This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Since this finding does not involve a violation and is of very low safety significance, it is identified as a FIN [05000311/2013008-01],
Failure to Evaluate Performance Deficiency for an NRC finding.
- (2) 13 Switchgear and Penetration Area Ventilation Supply Fan Motor Bearing Failure
Introduction.
A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified because PSEG did not complete a change to a preventative maintenance requirement for the SPAV fan motors in accordance with PSEG procedure MA-AA-716-210-1005, Predefine Change Processing. PSEG failed to perform an adequate engineering review of the PMCR when bearing replacements were deleted from the SPAV fan motor maintenance plans in September, 2009. This resulted in the bearing not being lubricated and subsequent failure of the 13 SPAV supply fan motor on February 4, 2013.
Description.
The function of the SPAV fans is to supply the switchgear and penetration areas of the plant, including safety-related switchgear, with cool, filtered air during all modes of operation. On February 4, 2013, at 12:25 pm, the 13 SPAV supply fan was discovered in a stopped condition by the control room operator. At the time of the discovery, the 12 SPAV supply fan was being restored to service after maintenance.
With the two SPAV supply fans out of service, the probability risk analysis (PRA) was calculated as red by the shift manager. It was later determined that the 13 SPAV fan had tripped between 8:00 and 8:30 am on February 4, 2013, based on a main control room board walkdown by the nuclear control operator (NCO) who had validated the 13 SPAV fan in service during the morning board walkdown. Further evaluation by the Salem PRA engineer concluded that PRA was yellow primarily based on the actual time that the 12 and 13 SPAV fans were out of service. The 12 SPAV supply fan was returned to service at 12:30 pm on February 4, 2013. The 13 SPAV supply fan was repaired and returned to service on February 15, 2013. PSEG entered the issue into the corrective action program as notification 20594424.
PSEG investigated the cause of the failed fan motor and found that the installed bearing was different then the bearing on the material master for the fan motor. The installed bearing was an open bearing instead of a double shielded bearing as listed on the material master. Double shielding bearings do not require any lubrication per PSEGs lubrication plan, so no lubrication was specified for the SPAV fan motor bearings. Since the bearing was open, the grease eventually expelled from the bearing and caused a direct failure.
In 1995, PSEG conducted a controlled shutdown of Salem Unit 1 due to simultaneous failures of the 12 and 13 SPAV supply fans. During the investigation of this issue, PSEG determined that a contributing factor to the SPAV fan failures was a lack of a preventative maintenance program for the fan motors. The LER submitted for this event committed to implement recurring preventative maintenance tasks to replace the SPAV fan motors on a regular schedule as would be appropriate for double shielded bearings.
In a 1998 Summary of Revised Regulatory Commitments letter to the NRC, PSEG discussed that the SPAV fan motors were replaced with new motors fitted with open/single shielded bearings and that the preventative maintenance requirements were determined to be periodic lubrication and vibration monitoring.
PSEG completed an apparent cause evaluation (ACE) 70149975 on March 7, 2013, and determined that a preventative maintenance scope change in 2009 to delete motor bearing replacement was implemented before supporting predictive technologies were fully implemented and validated. PSEG had planned to conduct online Baker Box testing in addition to the already occurring vibration monitoring of the motor bearings.
PSEG also concluded that inadequate vibration data collection was an apparent cause of the bearing failure. The vibration monitoring points on the 13 SPAV fan motor were improperly placed such that they allowed the warning signs of the bearing failure to go undetected. PSEG could not determine how the bearing replacement preventative maintenance was deleted from the SPAV motor maintenance plans, but assumed that it was during the timeframe that the material master for the SPAV motors was changed to show double shielded bearings were installed.
The inspectors reviewed how the PMCR to remove the bearing replacement from the maintenance plan was implemented. PSEG procedure MA-AA-716-210-1005, Predefine Change Processing discusses the procedure for the deletion of existing preventative maintenance. Step 5 of Attachment 3 of this procedure is the engineering review of a PMCR that involves critical components. The purpose of this section is to ensure adequate technical rigor is applied in the PMCR process by reviewing all of the applicable data from various source documents that can affect the preventative maintenance scope or frequency. Step 5.E of the procedure requires review of the applicable commitments and industry documents. In the case of the SPAV fan motors it was not noted that there was conflicting information between the type of bearing PSEG had committed to in their 1998 commitment letter and the type of bearing listed on the material master. As part of the corrective action for the difference in bearing types on the material master, PSEG has corrected the material master for SPAV fan motors to require single shielded bearings.
Analysis.
The inspectors concluded that the failure of PSEG to complete an adequate engineering review on the PMCR which deleted the bearing replacement requirement for the SPAV fan motors was a performance deficiency and was within PSEGs ability to foresee and correct. The inspectors determined that the performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone, and it 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 failed to investigate a difference in bearing type documented in the 1998 NRC commitment letter and the SPAV fan motor material master, they did not resolve conflicting information on the type of bearing installed in the SPAV fan motors before a preventive maintenance change to delete periodic bearing replacements took effect. This resulted in bearing and fan motor failure.
The inspectors evaluated the finding in accordance with IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations (IMC 0609A). The inspectors determined that the finding was of very low safety significance (Green) because the deficiency did not affect the design or qualification; did not represent a loss of system safety function; did not screen as potentially risk significant due to external initiating events; and SPAV fans are not designated as high safety-significance in the licensees maintenance rule program.
There is no cross-cutting aspect assigned because the performance deficiency is not indicative of current performance. Specifically, the performance deficiency involves an issue that occurred greater than three years ago and is not indicative of current performance.
Enforcement.
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires in part, that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings and shall be accomplished in accordance with these instructions, procedures and drawings. Procedure MA-AA-716-210-1005, Predefine Change Processing, Step 5.E, requires review of the applicable commitments and industry documents. Contrary to the above, PSEG did not accomplish a change to a preventative maintenance requirement for the SPAV fan motors in accordance with step 5.E of procedure MA-AA-716-210-1005, Predefine Change Processing. Specifically, PSEG failed to investigate a difference in bearing type documented in their 1998 NRC commitment letter as required by Predefine Change Processing when conducting an engineering review of a PMCR for a critical component.
As a result, the existence of conflicting information on what type of bearing was installed in the SPAV fan motors was not resolved and the preventative maintenance item of changing out the SPAV fan motor bearings was deleted which would have caught the degraded condition of the 13 SPAV fan motor before the motor failed in February, 2013.
Because this issue is of very low safety significance (Green) and PSEG entered the issue into the corrective action program as notification 20594424, this violation is being treated as an NCV consistent with the NRC Enforcement Policy. NCV
[05000272/2013008-02,] 13 Switchgear and Penetration Area Ventilation Supply Fan Motor Bearing Failure due to Deletion of Preventative Maintenance Requirement
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of notifications associated with review of industry operating experience to determine whether PSEG appropriately evaluated the operating experience information for applicability to Salem and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that PSEG adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b. Assessment The inspectors determined that PSEG appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs.
c. Findings
No findings 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 PSEG entered problems identified through these assessments 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.
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 were knowledgeable in the subject and 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 then 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 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 coordinator 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 Employee Concerns Program files to ensure that PSEG entered issues into the corrective action program when appropriate.
b. Assessment During interviews, Salem 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 Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On August 1, 2013, the inspectors presented the inspection results to John F. Perry, Site Vice President 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:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- T. Cachaza, Regulatory Assurance
- K. Coville, Performance Improvement Manager
- J. Garecht, Work Management Manager
- K. Grover, Engineering Director
- K. King, Design Engineering
- B. Ohmert, Component Maintenance Optimization Engineer
- D. Price, Maintenance Superintendent
- D. Raymond, Nuclear Equipment Operator
- G. Rich, Chemistry Engineer
- B. Rivel, Nuclear Equipment Operator
- B. Stewart, Senior Reactor Operator
- S. Swenson, Manager Plant Engineering
- L. Wagner, Plant Manager
- R. Wegner, Maintenance
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
- 05000311/2013008-01 FIN Failure to Evaluate Performance Deficiency for FIN 2011004-02
- 05000272/2013008-02 NCV 13 Switchgear and Penetration Area Ventilation Supply Fan Motor Bearing Failure due to Deletion of Preventative Maintenance Requirement