IR 05000272/2015008

IR 05000272/2015008 and 05000311/2015008, May 4, 2015 June 18, 2015, Salem Nuclear Generating Station, Units 1 & 2 - Problem Identification and Resolution

ML15202A314
Person / Time
Site:	Salem
Issue date:	07/21/2015
From:	Glenn Dentel Reactor Projects Branch 3
To:	Braun R Public Service Enterprise Group
DENTEL, GT
References
IR 2015008
Download: ML15202A314 (25)

Text

Mr. UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 July 21, 2015 Mr. Robert Braun President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038 SUBJECT: SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -

PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000272/2015008 AND 05000311/2015008

Dear Mr. Joyce:

On May 22, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an onsite inspection at your Salem Nuclear Generating Station (Salem). The results of the onsite portion of the inspection were discussed with Mr. John Perry, Site Vice President, and other members of your staff. In-office review continued after the conclusion of the onsite inspection, and a telephone exit was conducted on June 18, 2015, with Mr. Kevin Chambliss, Manager of Regulatory Affairs, and 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 NRC-identified finding of very low safety significance (Green).

The inspectors determined that this finding also involved a violation of NRC requirements. The NRC is treating this as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance. The NRC is also treating this violation as an NCV consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations in this report, 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

R. Braun -2-the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at Salem. In addition, if you disagree with the cross-cutting aspect assigned to the 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 Inspectors at Salem.

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 and 50-311 License Nos. DPR-70 and DPR-75

Enclosure:

Inspection Report 05000272/2015008 and 05000311/2015008 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-272, 50-311 License Nos.: DPR-70, DPR-75 Report Nos.: 05000272/2015008 and 05000311/2015008 Licensee: PSEG Nuclear LLC Facility: Salem Nuclear Generating Station Location: Hancocks Bridge, NJ Dates: May 4 - June 18, 2015 Team Leader: Anne DeFrancisco, Project Engineer Inspectors: Leonard Cline, Senior Project Engineer Adam Ziedonis, Resident Inspector Brian Lin, Project Engineer Approved by: Glenn Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

IR 05000272/2015008 and 05000311/2015008; 05/04/2015 - 06/18/2015; Salem Nuclear

Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution.

The inspectors identified 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 inspectors identified one finding of very low safety significance (Green)during this inspection and classified it as a non-cited violation (NCV). 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 December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated February 4, 2015. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

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 (CAP) at a low threshold, and prioritized issues commensurate with their safety significance. The inspectors concluded that PSEG adequately identified, reviewed, and applied relevant industry operating experience to Salem operations, and completed self-assessments and audits as required. PSEG adequately screened issues for operability and reportability, and generally performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that PSEG typically implemented corrective actions (CAs) that addressed problems identified in the CAP in a timely manner. However, the inspectors identified a violation of NRC requirements in the area of effectiveness of corrective actions.

Based on interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues through various available means.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR, Part 50, Appendix B, Criterion XVI, because PSEG did not assure that an identified condition adverse to quality was corrected. The condition adverse to quality was associated with improper maintenance of the 12 chiller which led to the chiller failure on August 23, 2014. Specifically, a procedure related to compressor rebuilds was not effectively updated to address the improper maintenance practice. PSEG entered this violation into the CAP as notification 20690927, has placed compressor rebuilds that would require use of this procedure on hold, and has purchased new compressors for contingent replacement pending completion of the compressor maintenance procedure changes.

The inspectors determined this performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating System cornerstone, and adversely affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, improper torqueing of the No. 4 discharge valve plate bolts for the 12 chiller caused the trip of that chiller on August 23, 2014, and, absent the procedural change, the vulnerability continued to exist for the occurrence of future improper torqueing and subsequent chiller failure. The inspectors determined that this finding screened to Green in accordance with IMC 0609,

Appendix A, because the finding did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time. The inspectors determined that this finding had a cross-cutting aspect in evaluation, because PSEG Root Cause 70169007 did not identify the improper torqueing of the discharge plate bolts as a condition adverse to quality. Consequently, PSEG assigned an action (ACIT) to address the problem, rather than a corrective action (CA) which, per LS-AA-125, requires additional reviews that verify the quality of completed corrective actions before closure. [P.2] (Section 4OA2.1.c(1))

Other Finding A violation of very low safety significance (Green), that was identified by the licensee, was reviewed by the inspectors. The issue has been entered into the licensees corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution (PI&R) 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 describe and implement PSEG's 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 various cornerstones of safety in the NRC's Reactor Oversight Process. The security cornerstone was not covered as part of the scope of this inspection because security issues at Salem and Hope Creek are addressed using the Hope Creek corrective action process. Based on this arrangement correction action process effectiveness under the security cornerstone at Salem was reviewed during the biennial PI&R inspection conducted at PSEGs Hope Creek station in February 2015. The results of this inspection are documented in IR 05000354/

2015008 (ML15085A348).

Additionally, the inspectors attended Plan-of-the-Day, Station Ownership Committee (SOC), and Management Review Committee (MRC) meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, radiation protection, chemistry, and oversight programs.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, completed corrective and preventative maintenance work orders, completed surveillance tests, and periodic trend reports. The inspectors completed field walkdowns of various systems and components on site, including the auxiliary building ventilation system, the chilled water system, accessible portions of containment fan cooling unit support systems, the charging system, and a sample of various motor control centers that contained safety and non-safety related breakers. Additionally, the inspectors reviewed a sample of notifications written to document issues identified through internal self-assessments, audits, the operating experience program, and operator workarounds/burdens. 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 PI&R inspection completed in July 2013 (IR 05000272;311/2013008, ML13238A066). 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, maintenance rule functional failure determinations, and extent-of-condition and extent-of-cause reviews for selected problems to verify these processes adequately evaluated equipment operability, reporting of issues to the NRC, maintenance rule impacts, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed PSEGs completed corrective actions through documentation review, interviews, 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 PSEGs effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of notifications associated with previous NCVs and findings to verify that PSEG personnel properly evaluated and resolved these issues. In addition, the inspectors performed an expanded, five year corrective action review to evaluate PSEGs actions related to the Units 1 and 2 radiation monitor process channels, and the auxiliary building ventilation, chiller, and charging systems. Lastly, the inspectors performed a walkdown inspection on the reactor vessel level instrumentation, containment fan cooling unit service water valves, and control power breakers, focusing on the effectiveness of PSEGs processes for identifying and evaluating problems.

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 generally identified problems at a low threshold and entered them into the corrective action program as appropriate. The inspectors observed staff and supervisors at SOC and MRC meetings appropriately questioning and challenging notifications to ensure clarification and proper classification of the issues. Based on the samples reviewed, the inspectors determined that PSEG trended equipment, human performance, and programmatic issues, and generally entered identified problems into the CAP as appropriate. However, the inspectors identified one unresolved item (described in Section 4OA2.1.c(1)), and two observations regarding PSEGs problem identification (described below).

Entry of Conditions Adverse to Quality into the Corrective Action Program 10 CFR Part 50 Appendix B Criterion XVI requires in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, the inspectors identified several examples, between January and May of 2015, where PSEG did not initiate notifications for conditions adverse to quality until prompted by the NRC. These include:

(1) notification 20677723, after an equipment operator found an auxiliary feedwater storage tank nitrogen supply valve out of position;

(2) notification 20681597, after the 13 chiller control power breaker failed to close during testing; and,

(3) notifications 2066873, 20678037, 20677859, 20668732/20668490 regarding an adverse trend in the performance of various relief valves during refueling outage 1R23 testing. Although issues were not entered into the CAP in timely manner, none of these issues were considered more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because the impact of the untimely entries did not adversely impact the objective of the applicable cornerstone in each case.

Chiller Stainless Steel Cotter Pin Fatigue Condition Adverse to Quality Chiller stainless steel cotter pin fatigue failure vulnerability was not identified as a condition adverse to quality and assigned corrective actions in accordance with root cause procedure LS-AA-125-1001, in root cause 70169007. Specifically, the root cause evaluation identified that a previous causal evaluation conclusion on the cause of cotter pin fatigue failures was incorrect - in that the failed cotter pins had been stainless steel, and not carbon steel, as the previous evaluation had concluded. This called into question the current vulnerability of stainless steel cotter pins to repetitive fatigue failures. PSEG did not identify the fatigue failure mechanism of the stainless steel cotter pins as a condition adverse to quality (CAQ), and address the CAQ with formal, documented actions. The lack of formal, documented corrective actions to address the stainless steel fatigues failures was not more than minor, because it did not adversely affect the Mitigating Systems cornerstone objective of mitigating the effects of initiating events to prevent core damage. Specifically, other corrective actions to modify the chiller operating setpoints, and to address gasket leakby, were expected to minimize the likelihood of failure by cotter pin fatigue. In addition, new compressors, which include new stainless steel cotter pins, were installed in the chillers. PSEG initiated notification 20691006 to capture the stainless steel cotter pin fatigue failure vulnerability, and to document the intended corrective actions to address the issue.

(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, and potential impact on the safety conscious work environment.

Based on the sample of notifications reviewed, and the SOC and MRC meetings attended, the inspectors noted that the guidance provided by PSEGs corrective action program implementing procedures was sufficient to ensure consistency in the categorization of issues. Based on the inspected sample, operability and reportability determinations were performed when conditions warranted, and the evaluations supported the conclusion. Causal analyses generally appropriately considered the extent of condition associated with the problem, generic issues, and previous occurrences of the issue. However, in the area of evaluation, the inspectors identified one observation.

Containment Fan Cooler Unit (CFCU) Relay Failure On January 14, 2015, the 25 CFCU failed to start during the performance of surveillance testing. PSEG captured this issue in the corrective action program (CAP) under notification 20678550, and performed a maintenance rule functional failure cause determination (FFCDE) under order 70173690. FFCDE 70173690, step 9, determined that the cause of the 25 CFCU failure to start was attributed to excessive contact resistance that was introduced from a manufacturing defect. FFCDE 70173690, step 10, evaluated the extent of condition (EOC) for the January 14, 2015 relay failure and determined that most of the CFCU critical relays have been replaced recently as an extent of condition in accordance with (IAW) equipment apparent cause evaluation (EQACE) 70154315. The inspectors determined that this EOC was not appropriate to address the January 14, 2015, failure, because EQACE 70154315 was performed in response to a May 2013 failure of a CFCU control scheme relay of a different model type. The January 14, 2015, failed relay was actually a newer model relay that had been installed as a corrective action for the May 2013 failure and would have had a different extent of condition. ER-AA-310-1004-F1, Maintenance Rule Functional Failure Cause Determination (FFCDE), step 10, required documentation of the EOC associated with the Maintenance Rule Functional Failure. The inspectors concluded that due to this error the EOC documented in the FFCDE did not adequately determine the EOC associated with the January 14, 2015, relay failure and this was a performance deficiency. The inspectors determined this performance deficiency was not more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because the delay in the timeline for extent of condition corrective actions did not result in additional failures. In addition, at the time of inspection, the inspectors concluded that PSEGs planned corrective actions to address the vulnerability were reasonable to address the EOC going forward.

(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 corrective actions to address selected NRC NCVs and findings since the last problem identification and resolution inspection were adequate and timely. However, the inspectors identified one finding that was characterized as an NCV, in the area of corrective action implementation (described in section 4OA2.1.c(2)). Additionally, there was one licensee identified violation also related to corrective implementation (described in section 4OA7).

c. Findings

(1) Unresolved Item (URI) - Inadequate Maintenance Rule System Performance Criteria Selection

Introduction.

The inspectors identified a URI associated with inadequate Maintenance Rule Performance Criteria selection. Specifically, the inspectors determined that PSEG did not follow station procedures to: 1) determine that the number of maintenance preventable functional failures (MPFF) allowed per 10 CFR 50.65(a)(3) evaluation period was consistent with the assumptions in the probabilistic risk assessment (PRA); and 2)review and approve reliability performance criteria (PC) that was higher than the number of PRA-supplied basic event failures. The inspectors determined that additional information was needed to determine if these performance deficiencies were more than minor.

Description.

The inspectors performed a review of PSEGs Focused Area Self-Assessment (FASA) of the Maintenance Rule (MRule) Program, completed August 30, 2014, to determine if PSEG was appropriately assessing MRule program performance in accordance with LS-AA-126-1001, Self-Assessments. The purpose of PSEGs FASA was to ensure the MRule Program was implemented in accordance with 10 CFR 50.65, as well as PSEG program procedures. The inspectors noted that the MRule Program FASA met the requirements of LS-AA-126-1001, was sufficiently critical, identified several deficiencies that were entered into the CAP, and resulted in multiple recommendations. As a result of the FASA, PSEG determined that multiple structures, systems, and components (SSCs) in (a)(2) status had to be re-evaluated for (a)(1)status, due to those SSCs having had their Functional Failure Cause Determinations (FFCDE) and unavailability (UA) amounts incorrectly assessed in the past.

The inspectors reviewed the list of systems re-evaluated for (a)(1) status due to the FASA, as well as a listing of systems that remained in (a)(2) status and actual SSC performance data against the PC established under ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection. During this review the inspectors noted approximately 25 high safety significant systems (HSS) with reliability PC greater than two maintenance preventable functional failures (MPFFs). According to ER-AA-310-1003, Attachment 3, flowchart Process for Selecting Reliability Performance Criteria, HSS SSCs, with reliability PC greater than or equal to two MPFFs require SSC past performance documentation. Additionally, Attachment 1, steps 2.B.3 and 2.B.4, state that for HSS SSCs with high risk achievement worth (RAW) values, a reliability PC greater than or equal to zero or one MPFF requires SSC past performance documentation. The inspectors requested that PSEG provide past performance documentation for the HSS SSCs with reliability PC greater than two MPFFs. PSEG provided documentation of HSS SSC PC approval from 1997, when the MRule Program was first implemented by PSEG. The inspectors determined this documentation did not support the assigned PC, because it did not consider the last 18 years of SSC past performance.

The inspectors also reviewed ER-AA-310-1007, Maintenance Rule - Periodic (a)(3)

Assessment. Step 5.11.1.4 states Determine that the number of MPFFs allowed per evaluation period is consistent with the assumptions in the PRA. Contrary to ER-AA-310-1007, step 5.11.4, the last two periodic (a)(3) assessments performed by PSEG:

April 1, 2011 through September 9, 2012; and October 1, 2012 through June 30, 2014; did not verify that the number of MPFFs allowed per evaluation period was consistent with the assumptions in the PRA. Additionally, ER-AA-310-1003, step 4.3.2, states, in part, that Unless justified and approved by the Maintenance Rule Expert Panel, the number of MPFFs selected, as a Reliability PC, may not be higher than the PRA-supplied number of Functional Failures (FFs).

The inspectors then reviewed SC-MRULE-002, Maintenance Rule Performance Criteria Verification Following Salem SA112A PRA Update, subsequent to the most recent update performed in October 2014. The inspectors noted that to complete this verification, PSEG requantified the PRA model by changing the failure probabilities of the basic events to reflect the MRule PC. The result was a 98% increase in the Salem base core damage frequency (CDF) of 1.55E-05. The inspectors determined that this data was reflective of SSC reliability PC above the PRA-supplied number of basic event failures. As such, contrary to ER-AA-310-1003, step 4.3.2, the number of MPFFs selected as reliability PC was higher than the PRA-supplied number of FFs, and, based on the lack of documentation supplied by PSEG, the inspectors concluded this was not justified or approved by Maintenance Rule Expert Panel.

The inspectors determined that the failure to meet ER-AA-310-1007, step 5.11.4, and ER-AA-310-1003, step 4.3.2, was a performance deficiency. However, at the time of inspection, the inspectors did not have the information needed to determine the consequence of the performance deficiency. Information was needed to determine whether the performance deficiency was more than minor. Specifically, PSEG did not provide SSC past performance documentation for HSS SSCs with reliability PC greater than the PRA-supplied number of basic event failures in accordance with ER-AA-310-

and 3. The inspectors will use this information to determine whether the performance or condition of HSS SSCs was effectively controlled through the performance of appropriate preventive maintenance under 10 CFR 50.65(a)(2), and also to determine if those HSS SSCs being monitored under 10 CFR 50.65(a)(1) were assigned appropriate goals and monitoring when considered against the appropriate reliability PC threshold. This issue was determined to be a URI IAW Inspector Manual Chapter (IMC) 0612. (URI 05000272;311/2015008-01, Inadequate Maintenance Rule System Performance Criteria Selection)

(2) Failure to Correct a Condition Adverse to the Quality of the Chillers

Introduction.

The inspectors identified a Green NCV of 10 CFR, Part 50, Appendix B, Criterion XVI, because PSEG did not assure that an identified condition adverse to quality was corrected. The condition adverse to quality was associated with improper maintenance of the 12 chiller which led to the chiller failure on August 23, 2014.

Specifically, a procedure related to compressor rebuilds was not effectively updated to address the improper maintenance practice.

Description.

The chilled water system at Salem consists of three 50% capacity safety-related chillers per unit. The safety functions of the chilled water system are to remove sufficient heat loading from the emergency air conditioning units and emergency control air compressors under accident conditions, and remove sufficient heat loading from the main control room air condition units under normal operating conditions. Therefore, a trip of one of the safety-related chillers adversely affects the reliability of each of those units.

On August 23, 2014, Salem Unit 1, 12 chiller experienced a trip on low oil pressure.

Operators immediately entered Technical Specification limiting condition for operation (LCO) 3.7.10.A, which required restoration of 12 chiller to operable status within 14 days, or plant shutdown to Mode 3 if the chiller could not be restored. PSEG performed troubleshooting, replaced the compressor and restored the 12 chiller to operable status on August 29, 2015.

On September 17, 2014, PSEG approved the charter for Root Cause Evaluation (RCE)70169007, to investigate longstanding and recurring equipment problems in the chilled water system. The approved scope included the equipment failure analyses for three August 2014 chiller failures that included the August 23, 2014 failure. PSEG determined through this evaluation that the cause of the August 23, 2014, 12 chiller trip was maintenance technicians used an improper torque pattern when they re-torqued the chiller compressor No. 4 discharge valve plate. The improper torque pattern caused uneven torque on that plate that allowed plate movement, bolt failure, and eventually internal valve and piston damage that led to compressor failure. To address this cause PSEG ultimately created action tracking item (ACIT) No. 8 to revise the appropriate chiller maintenance procedures to provide more detailed steps to verify the required torque values for the compressor discharge valve plates. Among other items, the additional steps would require the technicians to record the torque applied to each bolt in the procedure step directly adjacent to the torque specified by the procedure. Recording these values in this step would more likely preclude technicians from failing to apply appropriate human performance tools (i.e., self-checking) when they applied the torque to the bolts.

The inspectors reviewed the completed changes for the affected procedures and identified that for procedure, SC.MD-CM.CH-0001, Acme Chiller Compressor Maintenance, Revision 21, the assigned action for ACIT No. 8 was not completed as directed. Specifically, the procedure was not updated to include sign-offs for the torque requirements for the discharge valve plate bolts. PSEG procedure LS-AA-120, Issue Screening and Identification Process, revision 13, step 4.6.3, states, in part, that ACIT final confirmations will document that the assigned action was completed as directed or describe the bases for why a different action or no action was taken. The inspectors determined that the ACIT No. 8 final confirmation was completed on March 25, 2015, but it did not include the required additional documentation to describe why the action was not taken as specified. The inspectors concluded that not completing the required procedure revision left the chillers susceptible to the cause of the August 23, 2014, failure, if and when the applicable maintenance was performed.

The inspectors also noted that PSEG did not identify the cause of the 12 chiller failure as a condition adverse to quality (CAQ) even though, as described above, the affected chillers performed safety-related functions and 10 CFR 50 Appendix B Criterion XVI states that CAQs include for example, a failure, malfunction, deficiency, deviation, defective material and equipment, or a nonconformance. Similarly, PSEG procedure, LS-AA-120, defined a CAQ as a failure, malfunction, deviation, and/or defective material and equipment associated with structures, systems and components. In accordance with the regulatory definition, and based on the results of PSEGs cause analysis, the inspectors concluded that the inadequate torque applied to the 12 chiller discharge plate was a CAQ. PSEG procedure LS-AA-125, Corrective Action Program, revision 8, required that a corrective action (CA) be assigned to track completion of corrective actions for a CAQ. The inspectors determined this was important because LS-AA-125 required additional reviews for completing and closing a CA that were not required to close an ACIT. Specifically, closure of a CA required peer review and Department Head approval, as well as department corrective action program coordinator (CAPCO) closure review of the final confirmation for completion of the CA. The inspectors concluded that these additional reviews would likely have prevented the inadequate corrective action for the chiller failure, and therefore, not assigning a CA to track completion of the chiller maintenance procedure changes resulted in the inadequate corrective action.

Analysis.

The inspectors determined that inadequately implementing procedure changes specified to address the condition adverse to quality was a performance deficiency. The inspectors determined this performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating System cornerstone, and adversely affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, improper torqueing of the No. 4 discharge valve plate bolts for the 12 chiller caused the trip of that chiller on August 23, 2014, and, absent the procedural change, vulnerability continued to exist for the occurrence of future improper torqueing and subsequent chiller failure. The inspectors determined that this finding affected the Mitigating Systems cornerstone in accordance with IMC 0609, Attachment 4, because the safety-related function of the chillers is to provide cooling for main control room ventilation and the emergency air compressors. The inspectors determined that this finding screened to Green in accordance with IMC 0609, Appendix A, because the finding did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time.

The inspectors determined that this finding had a cross-cutting aspect in the area of problem identification and resolution, evaluation [P.2], because PSEGs evaluation for the cause of the 12 chiller low oil pressure trip did not ensure that the identified resolutions addressed the cause. Specifically, PSEG Root Cause 70169007 did not identify the improper torqueing of the discharge plate bolts as a condition adverse to quality. Consequently, PSEG assigned an action (ACIT) to address the problem, rather than a corrective action (CA) which, per LS-AA-125, require additional reviews that verify the quality of completed corrective actions before closure.

Enforcement.

10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, between March 25 and May 19, 2015, PSEG measures did not assure that an identified condition adverse to quality associated with the performance of safety-related chiller maintenance was corrected. Specifically, PSEG determined that the cause of the 12 chiller trip on August 23, 2014, was improper torque of the No. 4 discharge valve plate during a compressor rebuild on May 8, 2014.

PSEG entered this violation into the CAP as notification 20690927, has placed compressor rebuilds that would require use of this procedure on hold, and has purchased new compressors for contingent replacement pending completion of the compressor maintenance procedure changes. This violation is being treated as an NCV, consistent with section 2.3.2 of the Enforcement Policy. (05000272;311/2015008-02, Failure to Correct a Condition Adverse to the Quality of the Chillers)

.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 (OE) to determine whether PSEG appropriately evaluated the operating experience information for applicability to Salem and took appropriate actions, when warranted. The inspectors also reviewed evaluations of OE 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.

b. Assessment The inspectors determined that PSEG adequately considered industry OE information for applicability, and used the information to identify and prevent similar issues when appropriate. The inspectors determined that OE was adequately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.

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 Based on the inspected sample, the inspectors concluded that self-assessments, audits, and other internal PSEG assessments were adequate to meet program requirements.

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 then entered into the corrective action program for evaluation. Based on the inspected sample, the inspectors concluded that 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 May 22, 2015, the inspectors presented the inspection results to Mr. John Perry, Site Vice President, and other members of the Salem staff. Following additional inspection activities, the inspectors conducted an exit meeting over the telephone on June 18, 2015 with Mr. Kevin Chambliss, Manager of Regulatory Affairs, and staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

4OA7 Licensee-Identified Violation

The following violation of very low security significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for disposition as an NCV.

10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to the above, PSEG did not establish measures to assure that a condition adverse to the quality related to safety-related chillers was promptly corrected. Specifically, PSEG determined that previous corrective actions for chiller operating temperature setpoint overlap, which were directed in several previous CAP evaluations that were completed between 2009 and 2013, were not implemented in a timely manner. This caused excessive chiller cycling and load sharing and prolonged and cyclic operation at low load conditions, which caused component fatigue and compressor damage. In response to this issue, PSEG completed a root cause evaluation and established corrective actions to develop and install a chiller operating setpoint design change package. The inspectors determined that this finding screened to Green in accordance with IMC 0609, Appendix A, because the finding did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time. This issue is tracked in the corrective action program under RCE 70169007.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Perry, Site Vice President

L. Wagner, Plant Manager

B. Booth, Regulatory Affairs Manager

K. Chambliss, Regulatory Affairs Manager

T. Cachaza, Regulatory Affairs

F. Possessky, Regulatory Affairs

J. Racer-DeSanctis, Performance Improvement Manager

R. DeKnight, Operations Director

S. Taylor, Radiation Protection Manager

R. Truhan, Nuclear Oversight

P. Duke, Regulatory Affairs

D. Schuman, Employee Concerns Program Manager

P. Essner, Engineering

A. Zhang, Engineering

J. Giunta, Engineering

M. Pennington, Engineering

J. Thompson, Procurement Engineering Manager

H. Balian, Engineering

C. Beeson, Engineering

S. Boesch, Engineering

S. Bowers, Engineering

L. Oberembt, Engineering

B. Ohmert, Engineering

J. Hargrave, Operations

P. Martino, Maintenance Director

G. Delp, Maintenance

NRC Personnel

P. Finney, Senior Resident Inspector, Salem

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened

05000272;311/2015008-01 URI Inadequate Maintenance Rule System Performance Criteria Selection (Section 4OA2.1.c.(1))

05000272;311/2015008-02 NCV Failure to Correct a Condition Adverse to the Quality of the Chillers (Section 4OA2.1.c.(2))