IR 05000354/2011002
| ML111320528 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/12/2011 |
| From: | Arthur Burritt Reactor Projects Branch 3 |
| To: | Joyce T Public Service Enterprise Group |
| BURRITT, AL | |
| References | |
| IR-11-002 | |
| Download: ML111320528 (32) | |
Text
SUBJECT:
HOPE CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000354/201 1 002
Dear Mr. Joyce:
On March 31, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Hope Creek Generating Station. The enclosed inspection report documents the inspection results discussed on April 7,2011, with Mr. Perry and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings were identified. However, one licensee-identified violation that was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program (CAP). lf you contest this 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 l; the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident lnspector at the Hope Greek Generating Station.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's
"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 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://wurw.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).
Sincerely, r
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lJu" Arthur L. Burritt, Chief Projects Branch 3 Division of Reactor Projects Docket No: 50-354 License No: NPF-57 Enclosure: Inspection Report05000354/2411002 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ
SUMMARY OF FINDINGS
f R 0500035412011002; 01lO1l2O11 - 0313112011; Hope Creek Generating Station; Routine
Integrated Inspection Report.
This report covers a three-month period of inspection by resident inspectors, and announced inspections by a regional radiation specialist, an emergency preparedness inspector, and prolect engineers. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Findinqs No findings were identified.
Other Findinos One violation of very low safety significance, which was identified by PSEG, has been reviewed by the inspectors. Corrective actions taken or planned by PSEG have been entered into PSEG's CAP. This violation and its corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summarv of Plant Status The Hope Creek Generating Station operated at or near full power for the duration of the inspection period with the following exception. On March 18, operators shutdown the plant to conduct a planned maintenance outage. Operators commenced plant start-up on March 20 after completion of planned maintenance and full power was restored on March 22.
1. REACTORSAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness
1R01 Adverse Weather Protection
Evaluate Readiness for lmpendinq Adverse Weather Conditions a.
The inspectors completed one adverse weather protection sample. The inspectors reviewed PSEG's preparation activities for river grass intrusion conditions that may impact the station service water system. Inspectors assessed implementation of PSEG's grassing readiness plan through service water system walkdowns, corrective action program (CAP) reviews, and discussions with cognizant managers and engineers.
The documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
Equipment Aliqnment (71111.04 - 4 samples)1 R04
.1 PartialWalkdown
a. Inspection Scope
The inspectors completed three partialwalkdown inspection samples. The inspectors performed partial system walkdowns for the systems listed below to verify each system's operability when redundant or diverse trains and components were inoperable. The inspectors completed walkdowns to determine whether there were discrepancies in the system's alignment that could impact the function of the system, and therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, walked down system components, and verified that selected breakers, valves, and support equipment were in the correct position to support system operation. The inspectors also verified that PSEG had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the CAP. The documents reviewed are listed in the Attachment.
b.
a.
B, C, and D emergency diesel generators (EDGs) while the A EDG was out-of-service on January 3 High pressure coolant injection (HPCI) system while reactor core isolation cooling (RCIC) system was out-of-service on February 22 r Portions of the 500 kV system while 5015 offsite power line and control room indication and display system out-of-service on March 17 Findinqs No findings were identified.
Complete Walkdown lnspection Scope The inspectors performed one complete walkdown inspection of accessible portions of the B safety auxiliary cooling system (SACS). The inspectors used PSEG procedures and other documents to verify proper system alignment and functional capability. The inspectors independently verified the alignment and status of the B SACS valves, labeling, hangers and supports, and associated support systems. The walkdown also included checks that oil reservoir levels were normal, pump rooms and pipe chases were adequately ventilated, system parameters were within established ranges, and equipment deficiencies were appropriately identified. Documents reviewed are listed in the Attachment.
Findinqs No findings were identified.
Fire Protection (71111.05Q - 6 samples)b.
1 R05 Fire Protection - Tours
a. Inspection Scope
_
The inspectors completed six quarterly fire protection inspection samples. The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that combustibles and ignition sources were controlled in accordance with PSEG's administrative procedures; fire detection and suppression equipment was available for use; that passive fire barriers were maintained in good material condition; and that compensatory measures for out of service, degraded, or inoperable fire protection equipment were implemented in accordance with PSEG's fire plan. The areas toured are listed below with their associated pre-fire plan designator. The documents reviewed are listed in the
.
o FRH-11-533, Electrical Access Area o FRH-11-511, Diesel Fuel Oil Storage Tanks Area (A and C)
.
FRH-1 1-541, Class 1E Switchgear Rooms
.
FRH-1 1-423, Reactor Auxiliary Cooling System (RACS) Pumps & Heat Exchanger Area
. FRH-11-511, Diesel Fuel Oil Storage Tanks Area (B and D)
.
FRH-1 1-461, Standby Liquid Control (SLC) Room b.
Findinqs No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors completed one flood protection measures inspection sample. The inspectors reviewed selected risk-important plant design features and PSEG procedures intended to protect the plant and its safety-related equipment from internal flooding events. Specifically, the inspectors focused on internal flood mitigation features for the 54' elevation of the reactor building, which contains significant portions of the core spray (CS), residual heat removal (RHR), HPCI, RCIC, and reactor building sump systems, and the 77' elevation of the reactor building, which contains significant portions of the RHR, RACS and control rod drive systems. The inspectors reviewed flood analysis and design documents, including the updated final safety analysis report (UFSAR),engineering calculations, and abnormaloperating procedures. The inspectors observed the condition of wall penetrations, watertight doors, flood alarm switches, and drains to assess their readiness to contain flow from an internal flood in accordance with the design basis. The documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
1R1 1 Licensed Operator Requalification Prooram (71111.1 1Q - 1 sample)
a. Inspection Scope
The inspectors completed one quarterly licensed operator requalification program inspection sample. The inspectors observed a licensed operator annual requalification simulator scenario (SG-672) on January 31, 2011, to assess operator performance and training effectiveness. The scenario involved high vibrations on a reactor recirculation pump, a failed reactor protection system component, a steam leak on the RCIC system, and a reactor scram. The inspectors assessed simulator fidelity and observed the simulator instructors' critique of operator performance. The inspectors also observed control room activities with emphasis on simulator identified areas for improvement.
Documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
==1R12 Maintenance Effectiveness (71111JzQ - 2 samples) a.
lnspectiorr Scope==
The inspectors completed two maintenance effectiveness inspection samples. For the equipment performance issues listed below, the inspectors evaluated items such as:
appropriate work practices; identifying and addressing common cause failures; scoping in accordance with 10 CFR 50.65(b) of the Maintenance Rule; characterizing reliability issues for performance; trending key parameters for condition monitoring; charging unavailability for performance; classification and reclassification in accordance with 10 CFR 50.65(aX1) or (aX2); and appropriateness of performance criteria for structures, systems, and components (SSCs)/functions classified as (aX2) and/or appropriateness and adequacy of goals and corrective actions for SSCs/functions classified as (aX1).
The documents reviewed are listed in the Attachment.
. Drywell sump pump check valve
. B EDG bailey card failure b.
Findinqs No findings were identified.
1R13 Maintenance RiskAssessments and EmerqentWork Control
a. Inspection Scope
The inspectors completed five maintenance risk assessment and emergent work control inspection samples. The inspectors reviewed on-line risk management evaluations through direct observation and document reviews for the following five plant configurations:
o A EDG out-of-service for emergent maintenance during week of January 3
. C EDG and SACS valve 2496C planned maintenance during week of January 10
. B CS room cooler and B control room emergency filtration (CREF) planned maintenance during week of January 24
. B EDG and D circulating water pump out-of-service during week of February 14
. RCIC and 5023 offsite power line out-of-service during week of February 22 The inspectors reviewed the applicable risk evaluations, work schedules, and control room logs for these configurations to verify that concurrent planned and emergent maintenance and test activities did not adversely affect the plant risk already incurred with these configurations. PSEG's risk management actions were reviewed during shift turnover meetings, control room tours, and plant walkdowns. The inspectors also used PSEG's on-line risk monitor (Equipment Out of Service workstation) to gain insights into the risk associated with these plant configurations. Finally, the inspectors reviewed notifications documenting problems associated with risk assessments and emergent work evaluations. The documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
==1R15 Operabilitv Evaluations (71111
==
.15 - 5 samples)
a. Inspection Scope
The inspectors completed five operability evaluation inspection samples. The inspectors reviewed the operability determinations for the degraded or non-conforming conditions associated with the following systems:
. A EDG failed motor operated potentiometer o D EDG loose crankcase cover o R safety relief valve elevated tailpipe temperature o B EDG lube oil cooler leak
.
North plant vent bypass flow splitter calibration failure The inspectors reviewed the technical adequacy of the operability determinations to ensure the conclusions were justified. The inspectors also walked down accessible equipment to verify the adequacy of PSEG's operability determinations. Additionally, the inspectors reviewed other PSEG identified safety-related equipment deficiencies during this report period and assessed the adequacy of their operability screenings. The documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
1R18 Plant Modifications
.1 Temporarv Modification
a. Inspection Scope
The inspectors completed a review of one temporary plant modification package for the drywell sump (DCP # 4HM-0024). The modification installed, and then removed closure springs in the sump check valves. The inspectors verified that the design bases, licensing bases, and performance capability of the drywell sump were not degraded by this temporary modification. The inspectors verified the post-modification testing was adequate to ensure the SSCs would function properly. The 10 CFR 50.59 evaluation associated with this temporary modification was also reviewed. The documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
b.
Permanent Modification Inspection Scope The inspectors completed a review of one permanent plant modification package for the North Plant Vent (DCP # 80096594). This review verified that the design bases, licensing bases, and performance capability of the system were not degraded by the modification. The inspectors verified the new configuration was accurately reflected in the design documentation, and that the post-modification testing was adequate to ensure affected SSCs would function properly. The 10 CFR 50.59 evaluation was reviewed. The inspectors also interviewed plant staff and reviewed issues entered into the CAP to assess PSEG's effectiveness in identifying and resolving problems associated with plant modifications. Documents reviewed are listed in the Attachment.
Findinqs No findings were identified.
Post-Maintenance Testinq (71111.19 - 6 samples)lnspection Scope The inspectors completed six post-maintenance testing inspection samples. The inspectors reviewed the post-maintenance tests for the maintenance items listed below to verify that procedures and test activities ensured system operability and functional capability following completion of maintenance. The inspectors reviewed applicable test procedures to verify that they tested all safety functions potentially affected by the associated maintenance activities. The inspectors verified that for each potentially affected safety function the acceptance criteria stated in the procedure was consistent with the UFSAR and other design documentation. The inspectors witnessed completion of the testing or reviewed the completed test results to confirm acceptance criteria were met and verified satisfactory restoration of all safety functions affected by the maintenance activities. The documents reviewed are listed in the Attachment.
o A EDG planned maintenance on February 2
. A CREF system planned maintenance on February 10 r B EDG planned maintenance on February 17
. RCIC pump planned maintenance on February 24 o B EDG Bailey card planned maintenance on March 24
. C RHR suction valve thermal overload bypass planned maintenance on March 25 Findinos No findings were identified.
1R20 Refuelinq and Outaqe Activities
a. Inspection Scope
PSEG conducted a planned maintenance outage from March 18 through March 21 to replace three safety relief valve pilot valves, troubleshoot and repair a problem with a drywell sump pump, and perform other planned maintenance activities. The inspectors monitored or observed the activities listed below to assess the adequacy of PSEG's outage controls:
e Portions of the shutdown and cooldown processes
.
Initial and final closeout walkdowns of selected areas of the drywell to check for unidentified leakage or other discrepant conditions
. Outage risk management
. Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the technical specifications (TS) when removing equipment from service;
. Decay heat removal operations r Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss
. Status and configuration of electrical systems to ensure compliance with TS r Activities that could affect reactivity
. Reactor start-up, including reactor criticality o Personnel fatigue management controls Documents reviewed are listed in the Attachment.
b.
Findinqs No findings were identified.
1R22 Surveillance Testino
a. Inspection Scope
The inspectors completed six surveillance testing (ST) inspection samples. The inspectors witnessed performance of andior reviewed test data for the risk-significant STs listed below to verify that the SSCs tested satisfied TSs, UFSAR, and procedure requirements. The inspectors verified that test acceptance criteria were clear, demonstrated operational readiness, and were consistent with design documentation; that test instrumentation had current calibrations and the correct range and accuracy for the application; and that tests were performed as written with applicable prerequisites satisfied. Upon ST completion, the inspectors confirmed that equipment was returned to the status specified to perform its safety function. The documents reviewed are listed in the Attachment.
o A RHR pump inservice test on January 4
. HPCI quarterly surveillance test on February 8
. Reactor water cleanup isolation on SLC initiation test on February 16
. RCIC inservice test on February 24
.
B CS pump surveillance test on March 14
.
B SLC pump inservice test on March 27 b.
Findinqs No findings were identified.
1EP2 Alert and Notification Svstem (ANS) Evaluation
a.
lnspection Scope An onsite review of the Salem and Hope Creek ANS was conducted to assess current maintenance and testing practices. During the inspection, the inspectors reviewed ANS maintenance and testing procedures, maintenance and test records, and the updated Salem and Hope Creek ANS design report to ensure PSEG's compliance with design report commitments for system maintenance and testing. A sample of condition reports (CRs) pertaining to the ANS was reviewed for causes, trends, and corrective actions.
The inspectors interviewed the ANS System Manager to discuss system performance and upgrades. The inspection was conducted in accordance with NRC lnspection Procedure 71114, Attachment 2. Planning Standard, 10 CFR 50.47(bX5), and the related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b.
Findinos No findings were identified.
1EP3 Emerqencv Response Orqanization (ERO) Staffino and Auomentation Svstem
a. Inspection Scope
The inspectors conducted a review of Salem and Hope Creek's augmentation staffing requirements and the process for notifying and augmenting the ERO. This was performed to ensure the readiness of key PSEG staff to respond to an emergency event and ensure PSEG's ability to activate their emergency facilities in a timely manner. The inspectors reviewed the Salem and Hope Creek Emergency Plan, duty rosters, and augmentation reports. The inspectors also reviewed a sampling of ERO responders training records to ensure training and qualifications were up to date. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 3.
Planning Standard, 10 CFR 50.47(b)(2), and related requirements of 10 CFR 50, Appendix E, were used as reference material.
b.
Findinos No findings were identified.
1EP4 Emerqencv Action Level (EAL) and Emerqencv Plan Chanoes
a.
lnspection Scope Since the last NRC inspection of this program area, PSEG implemented various changes to the Salem and Hope Creek Emergency Plan and implementing procedures.
PSEG had determined that, in accordance with 10 CFR 50.54(q), any change made to the Emergency Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Emergency Plan, and that the Emergency Plan continued to meet the standards in 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. The inspectors reviewed all EAL changes. A sample of Emergency Plan changes, including the changes to lower-tier implementing procedures, was evaluated for any potential decreases in effectiveness of the Salem/Hope Creek Emergency Plan. However, this review by the inspectors was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 4. The requirements in 10 CFR 50.5a(q) were used as reference criteria.
b.
Findinqs No findings were identified.
1EPs Correction of Emerqencv Preparedness Weaknesses (71114.05 - 1 sample)
a. Inspection Scope
The inspectors reviewed a sampling of self-assessment procedures and reports to assess PSEG's ability to evaluate their emergency preparedness performance and program. The inspectors reviewed a sampling of CRs from April 2009 through March 2011 initiated by PSEG at Salem and Hope Creek from drills, self-assessments, and audits. The inspectors also reviewed 10 CFR 50.54(t) audit reports and nuclear oversight audits. This inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 5. Planning Standard, 10 CFR 50.41(b)(14), and the related requirements of 10 CFR 50, Appendix E, were used as reference criteria.
b.
Findinqs No findings were identified.
lEPO Drill Evaluation (71114.06 - 1 sample)
a. Inspection Scope
The inspectors completed one drillevaluation inspection sample. The inspectors observed emergency plan response actions at the simulated control room and the technical support center during an emergency preparedness drill on March 2, 2011.
The inspectors verified that emergency classification declarations and notifications were completed in accordance with 10 CFR 50.72,10 CFR 50, Appendix E, and the Hope Creek emergency plan implementing procedures. Documents reviewed are listed in the
.
b.
Findinqs No findings were identified.
RADIATION SAFETY
Radiation Safety - Public and Occupational
2RS1 Radiolooical Hazard Assessment and Exposure Controls
a. Inspection Scope
Radioloqical Hazard Assessment The inspectors determined that, since the last inspection, there have been no changes to plant operations that may result in a significant new radiological hazard for onsite workers or members of the public.
The inspectors reviewed the last two radiological surveys from selected plant areas.
The inspectors verified that the thoroughness and frequency of the suryeys was appropriate for the given radiological hazard.
The inspectors conducted walkdowns of the facility, including radioactive waste processing, storage, and handling areas, to evaluate material and potential radiological conditions.
The inspectors selected radiologically risk-significant work activities that involved exposure to radiation. The inspectors verified that appropriate pre-work surveys were performed to identify and quantify the radiological hazard and to establish adequate protective measures. The inspectors evaluated the radiological survey program to determine if hazards were properly identified, including the following:
.
ldentification of hot particles
. The presence of alpha emitters
. The potential for airborne radioactive materials, including the potentialfor the presence of transuranics and/or other hard-to-detect radioactive materials;
. The hazards associated with work activities that could suddenly and severely increase radiological conditions
. Severe radiation field dose gradients that can result in non-uniform exposures of the body The inspectors selected air sample survey records and verified that samples were collected and counted in accordance with PSEG procedures. The inspectors observed work in potential airborne areas and verified that air samples were representative of the breathing air zone. The inspectors verified that PSEG had a program for monitoring levels of loose surface contamination in areas of the plant with the potential for the contamination to become airborne.
b.
a.
2RS2 The inspectors reviewed radiation work permits (RWPs) used to access high radiation
areas and identified what work control instructions or control barriers had been specified.
lnstructions to Workers The inspectors selected containers holding non-exempt licensed radioactive materials that may cause unplanned or inadvertent exposure of workers and verified that they were labeled and controlled. The inspectors verified that allowable stay times or permissible dose for radiologically significant work under each RWP was clearly identified. The inspectors verified that electronic personal dosimeter (EPD) alarm setpoints were in conformance with survey indications and plant policy.
The inspectors selected occurrences where a worker's EPD noticeably malfunctioned or alarmed. The inspectors verified that workers responded appropriately to the off-normal condition. The inspectors verified that the issue was included in the CAP and dose evaluations were conducted as appropriate.
Problem ldentification and Resolution The inspectors verified that problems associated with radiation monitoring and exposure controlwere identified by PSEG at an appropriate threshold and were properly addressed for resolution in their CAP. In addition, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems that involved radiation monitoring and exposure controls. The inspectors also verified that PSEG was assessing the applicability of operating experience to their plants.
Findinqs No findings were identified.
Occupational As Low As Reasonablv Achievable (ALARA) Planninq & Controls (71124.02)
Inspection Scope Verification of Dose Estimates and Exposure Trackinq Svstems The inspectors selected ALARA work packages and reviewed the assumptions and basis for the Fall 2010 refueling outage (RFO16) collective exposure estimate for reasonable accuracy. The inspectors reviewed the applicable procedures to determine the methodology for estimating exposures from specific work activities and the intended dose outcome. The inspectors selected the following work packages for review:
o Drywell nozzle exams r Reactor disassembly
. Reactor reassembly
. B RHR heat exchanger repairs
. Scaffold activities The inspectors verified that for the selected work activities PSEG had established measures to track, trend, and if necessary, reduce occupational doses for ongoing work activities. The inspectors verified that trigger points or criteria were established to prompt additional reviews and/or additional ALARA planning and controls.
The inspectors also evaluated PSEG's method of adjusting exposure estimates, or re-planning work when unexpected changes in scope or emergent work were encountered to confirm that adjustments to exposure estimates were based on sound radiation protection and ALARA principles.
b.
Findinqs No findings were identified.
2RS3 ln-Plant Airborne Radioactivitv Control and Mitiqation
a. Inspection Scope
Inspection Planninq The inspectors reviewed the plant's final safety analysis report (FSAR) to identify areas of the plant designed as potential airborne radiation areas including the associated ventilation and/or airborne monitoring instrumentation. The inspectors reviewed the FSAR, TSs, and emergency planning documents for an overview of the respiratory protection program and to identify the location and quantity of respiratory protection devices stored for emergency use. The inspectors reviewed the reported Pls to identify any related to unintended dose resulting from intakes of radioactive materials.
Enqineerinq Controls: Permanent and Temporarv Ventilation The inspectors verified that PSEG used ventilation systems, in lieu of respiratory protection devices, to control airborne radioactivity. The inspectors reviewed procedural guidance for use of installed plant systems and verified that the systems were used, to the extent practicable, during high-risk activities. The inspectors selected installed ventilation systems, used to mitigate the potentialfor airborne radioactivity, and verified that ventilation airflow capacity, flow path, and filter/charcoal unit efficiencies were consistent with maintaining concentrations of airborne radioactivity in work areas below the concentrations of an airborne area to the extent practicable.
The inspectors selected temporary ventilation system setups (high-efficiency particulate air) used to support work in contaminated areas and verified that the use of these systems was consistent with PSEG procedural guidance and ALARA.
Enqineering Controls: Airborne Monitoring Protocols The inspectors selected installed systems to monitor and warn of changing airborne concentrations in the plant. The inspectors verified that alarm and setpoints were sufficient to prompt PSEG/worker action to ensure that doses were maintained within the limits of 10 CFR ParI20 and ALARA. The inspectors verified that PSEG had established trigger points for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides.
Problem ldentification and Resolution The inspectors verified that problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by PSEG at an appropriate threshold and were properly addressed for resolution in their CAP.
b.
Findinqs No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (Pl) Verification
a. Inspection Scope
The inspectors reviewed PSEG's program for gathering, evaluating and reporting information for the Pls listed below. The inspectors used the definitions and guidance contained in Nuclear Energy Institute 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, to assess the accuracy of PSEG's collection and reporting of Pl data.
Cornerstone: Initiatinq Events
. Unplanned scrams per 7000 critical hours
. Unplanned scrams with complications
. Unplanned power changes per 7000 critical hours The inspectors reviewed the data reported for these Pls for the period January 1 through December 31, 2010. The records reviewed included Pl data summary reports, licensee event reports, monthly operating reports, and operator narrative logs. The inspectors verified the accuracy of the Pls and discussed the results with the system engineers responsible for data collection and evaluation.
Cornerstone: Emeroencv Preparedness
. Drill and Exercise Performance o ERO Drill Participation o ANS Reliability For the Pls listed above, to verify the accuracy of the reported data, the inspectors reviewed the Pl data, supporting documentation, and the information PSEG reported, from the second quarter through the fourth quarter of 2010.
b.
Findinos No findings were identified.
4OA2 Problem ldentification and Resolution (71152 - 1 annual sample)
.1 Routine Review of ltems Entered into the CAP
a. Inspection Scope
As required by lP 71152, ldentification and Resolution of Problems, and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of all items entered into PSEG's CAP. This was accomptished by reviewing the description of each new notification and attending management review committee meetings.
b.
Findinqs No findings were identified.
Annual Sample: EDG Equipment Reliabilitv lssues Inspection Scope The inspectors performed an in-depth review of PSEG's corrective actions for recent and long-standing EDG equipment reliability issues associated with the EDG preventative maintenance (PM) program. PSEG initiated an apparent cause evaluation (ACEXOrder
Recent equipment issues that PSEG determined to be related to the PM program included jacket water leaks, lube oil keep warm heaters, Bailey card control failures, voltage regulator issues and breaker trips. Documents reviewed are listed in the
.
Findinos and Observations No findings were identified.
PSEG performed an evaluation and identified gaps in PM strategy and scope, the application of the PCM template, and inadequate work planning. PSEG initiated corrective actions to address each gap. The inspectors reviewed the evaluation and PSEG's completed and proposed corrective actions and determined that PSEG adequately evaluated and was addressing the identified causes of the EDG equipment reliability issues through PM program improvements.
Event Follow-up (71153 - 1 sample)
(Closed) Licensee Event Report (LER) 05000354/2010-003-00, RHR Shutdown Cooling Suction Relief Valve Missed Surveillance In December 2009, a PSEG self assessment discovered a missed surveillance test for l BCPSV-4425, the RHR shutdown cooling common suction relief valve. l BCPSV-4425 is an American Society of Mechanical Engineers (ASME) Class 1 valve, but had been improperly grouped with Class 2 and 3 valves. The valve was last tested on October 25, 2007, and is required to be tested every 24 months. As such, this discovery constituted a missed surveillance. PSEG performed a risk assessment in accordance with TS 4.0.3 to justify delaying the surveillance test until the following refueling outage, and concluded there was no significant increase in risk as a result of the delay.
On November 1, 2010, PSEG completed the test and determined that the as-found lift setpoint for l BCPSV-4425 was unsatisfactory. The valve did not open within the required actuation pressure setpoint tolerance of +/- 3 percent. l BCPSV-4425 opened above the required pressure band. PSEG determined that the apparent cause for the l BCPSV-4425 test failure was corrosion bonding/bridging of the pilot disc. The failed relief valve was replaced with a fully tested spare. The enforcement aspects of this finding are discussed in Section 4OA7. This LER is closed.
.2 a.
40A3 4OAO Meetinqs. includino Exit On April 7, 2011, the inspectors presented inspection results to Mr. J. Perry and other members of his staff. The inspectors asked PSEG whether any materials examined during the inspection were proprietary. No proprietary information was identified.
4C.A7 Licensee-ldentified Violations The following violation of very low safety significance (Green) was identified by PSEG and is a violation of NRC requirements that meets the criteria of Section 2.3.2 of the NRC Enforcement Policy for being dispositioned as a NCV:
Hope Creek TS 6.8.4.i, "lnseryice Testing Program," requires the inservice testing of ASME Code Class 1,2, and 3 components in accordance with the ASME Boiler and Pressure Vessel Code. ASME Code requires that l BCPSV-4425, the RHR shutdown cooling common suction relief valve, a Class 1 valve, be tested every 24 months and that it open within a lift setpoint of +/- 3o/o of the specified code safety valve lift setting.
Contrary to this requirement, on November 1, 2010, PSEG identified that l BCPSV-4425 opened above the +/- 3% acceptable range. Since the valve was last tested on October 25,2007, this constituted a failed late surveillance test. PSEG entered this issue into their CAP as notification 20484572. This licensee-identified NCV is of very low safety significance based on a Phase 1 SDP screening, because the relief valve lifted below the maximum rating of the piping. Thus, the condition resulted in the inoperability of the valve, but did not result in a loss of system safety function.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- J. Perry, Hope Creek Site Vice President
- L. Wagner, Hope Creek Plant Manager
- E. Carr, Operations Director
- E. Casulli, Shift Operations Superintendent
- K. Chambliss, Work Management Director
- P. Duca, Senior Engineer, Regulatory Assurance
- D. Bush, System Engineer
- L. Davis, System Engineer
- M. Gaffney, Regulatory Assurance Manager
- L. Gorecki, System Engineer
- C. Johnson, Senior Engineer
- F. Jones, System Engineer
- K. Knaide, Engineering Director
- W. Kopchick, Plant Engineering Manager
G. Lichty Technical Specialist
- F. Mooney, Maintenance Director
- S. Peterkin, Radiation Protection Support Superintendent
- A. Shabazian, Maintenance Rule Coordinator
- G. Siefert, Design Engineer
- H. Trimble, Radiation Protection Manager
- A. Whatley, System Engineer
- D. Burgin, Corporate Emergency Preparedness Manager
LIST OF ITEMS
OPENED, GLOSED, AND DISCUSSED
Closed
- 05000354/201 0-003-00 LER RHR Shutdown Cooling Suction Relief Valve Missed Surveillance (Section 4OA3.1)