IR 05000354/2013007

IR 05000354-13-007; January 28 February 15, 2013; Hope Creek Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution

ML13091A134
Person / Time
Site:	Hope Creek
Issue date:	04/01/2013
From:	Daniel Schroeder Reactor Projects Branch 3
To:	Joyce T Public Service Enterprise Group
schroeder, dl
References
IR-13-007
Download: ML13091A134 (32)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ril 1, 2013

SUBJECT:

HOPE CREEK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000354/2013007

Dear Mr. Joyce:

On February 15, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Hope Creek Generating Station. The enclosed report documents the inspection results discussed with John 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 of very low safety significance (Green). Both findings were determined to involve violations of NRC requirements.

However, because of the very low safety significance and because they have been entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a written 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 Senior Resident Inspector at Hope Creek Generating Station. In addition, if you disagree with the cross-cutting aspects assigned to the findings 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 Senior Resident Inspector at Hope Creek Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 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 Agencywide Documents Access Management 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/

Daniel L. Schroeder, Chief Projects Branch 1 Division of Reactor Projects Docket No.: 50-354 License No.: NPF-57

Enclosure:

Inspection Report 05000354/2013007 w/Attachment: Supplemental Information

REGION I==

Docket No.: 50-354 License No.: NPF-57 Report No.: 05000354/2013007 Licensee: PSEG Nuclear LLC Facility: Hope Creek Generating Station Location: Hancocks Bridge, NJ Dates: January 28 through February 1, 2013 February 11 through February 15, 2013 Team Leader: Richard Barkley, PE, Senior Project Engineer Inspectors: Joseph Schoppy, Senior Reactor Inspector Tracey Ziev, Project Engineer Sherlyn Ibarrola, Resident Inspector, Hope Creek Approved by: Daniel L. Schroeder, Chief Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000354/2013007; January 28 - February 15, 2013; Hope Creek Generating Station;

Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified two findings in the area of the effectiveness of prioritization and evaluation of issues.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The inspectors identified two non-cited violations of very low safety significance (Green) during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. Cross-cutting aspects associated with findings are determined using IMC 0310, Components Within the Cross-Cutting Areas. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

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. Notwithstanding, the inspectors identified two non-cited violations in the area of corrective action effectiveness, both associated with the control room ventilation chilled water system.

The inspectors concluded that, in general, PSEG adequately identified, reviewed, and applied relevant industry operating experience to Hope Creek operations. In addition, based on those items selected for review, the inspectors determined that PSEGs self-assessments and audits were thorough, probing, and self-critical.

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: Barrier Integrity

Green.

A self-revealing, Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, was identified because PSEG failed to perform maintenance on the A control room air conditioning train in accordance with the documented procedure steps. Specifically, PSEG personnel failed to follow the maintenance procedure as written by stopping and restarting the A control room ventilation train prior to completing the monitoring period and obtaining the tuning parameters required by the procedure. PSEGs corrective actions included entering this issue into its corrective action program as notification 20575256, conducting an apparent cause investigation, restoring the system to an operable status, conducting a training needs analysis, and revising the maintenance procedure.

This finding is more than minor because it is associated with the human performance attribute of the barrier integrity cornerstone, and affected the cornerstone objective maintaining the radiological barrier functionality of the control room. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency represents a degradation of only the radiological barrier function provided for the control room.

This finding has a cross-cutting aspect in the area of human performance, work control because PSEG did not appropriately control work activities by incorporating actions to address the need for work groups to communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance. Specifically, maintenance personnel did not communicate to operations personnel that the maintenance activity was not completed or that the A control room ventilation should not be stopped and restarted H.3(b) [Section 4OA2.1.c.(1)].

Green.

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI,

Corrective Action, because PSEG failed to promptly correct a design deficiency in the control room chilled water circulating low flow pump trip logic. Specifically, PSEG failed to take timely action to develop and implement a modification to add a 10 second time delay to the pump trip logic. PSEGs corrective actions included entering this issue into their corrective action program as notification 20567269, conducting an apparent cause investigation, and developing and implementing design change packages to modify the low flow control room air conditioning chilled water circulating pump trip logic.

This finding is more than minor because it is associated with the systems, structures, and components (SSC) and barrier performance attribute of the barrier integrity cornerstone, and affected the cornerstone objective of maintaining the radiological barrier functionality of the control room. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency represents a degradation of only the radiological barrier function provided for the control room.

This finding does not have a cross-cutting aspect associated with it because, although the performance deficiency occurred within the last three years, the performance characteristic associated with the untimely corrective action for this deficiency is not indicative of PSEGs current performance. PSEG demonstrated improved performance in response to trips of the A control room ventilation in June and July 2012 caused by chilled water pump low flow by taking timely corrective action to develop and implement a design change package for the modification to the low flow trip logic that had been identified in 2011. PSEG also identified an additional deficiency in the low flow trip logic and took timely action to correct it in mid-2012. Additionally, since PSEG identified that a modification to the low flow pump trip logic was necessary, PSEG has implemented a new station process in the fall of 2012, ER-AA-2001-1001, Evaluation of Equipment Reliability Strategies, to evaluate the timeliness, effectiveness, and mitigating actions of proposed strategies developed for equipment reliability based on risk significance. Based on demonstrated improved performance in recent months as well as this new station process, which would have increased the priority and accelerated the implementation of these modifications, it is unlikely that this performance deficiency would occur again under similar circumstances.

[Section 4OA2.1.c (2)]

Other Findings

None.

REPORT DETAILS

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 PSEGs corrective action program at Hope Creek. To assess the effectiveness of the corrective action program (CAP), 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 corrective action documents 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 (SOC), and Management Review Committee (MRC) meetings during which corrective actions were discussed in detail. 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 plant areas, including the emergency diesel generator (EDG) rooms, service water (SW) intake, safety auxiliaries cooling system (SACS) rooms, high pressure coolant injection (HPCI) system, residual heat removal (RHR) pump rooms, core spray rooms, torus room, remote shutdown panel room, main control room, and the cable spreading rooms. They walked down selected systems in these areas, such as the control room heating, ventilation and air conditioning (HVAC)system, the service water intake structure (SWIS) heating and ventilation systems, and the primary containment instrument gas system. The inspectors verified that conditions adverse to quality identified through this review, internal self-assessments, audits, emergency preparedness drills, and operating experience were entered into the CAP as appropriate. 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 (NOTFs) issued since the last NRC biennial Problem Identification and Resolution inspection completed in January 2011. The inspectors selected NOTFs for review that encompassed the full range of evaluations, including root cause evaluations (RCEs),apparent cause evaluations (ACEs), Work Group Evaluations (WGEs) and common cause evaluations (CCEs). NOTFs that were assigned lower levels of significance that did not include formal cause evaluations were also reviewed by the inspectors to ensure they were appropriately 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 (CAs) to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, Maintenance Rule functional failure evaluations, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of problems. The inspectors also observed several MRC meetings during which PSEG managers reviewed completed ACEs, as well as selected corrective action assignments.

(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 cause of the problems. The inspectors also reviewed a sample of corrective actions for NOTFs greater than five years old, and determined whether appropriate interim actions were in place and that the basis for not completing the specified CAs was well supported. The inspectors reviewed NOTFs for adverse trends and repetitive problems to determine whether CAs were effective in addressing the broader issues. The inspectors reviewed PSEGs timeliness in implementing CAs and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of NOTFs associated with selected non-cited violations, findings, and licensee event reports to verify that PSEG personnel properly evaluated and resolved these issues. In addition the corrective action review was expanded to five years to evaluate PSEGs actions related to the performance of the Control Room and SWIS ventilation systems.

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 identified problems and entered them into the corrective action program at a low threshold. PSEG staff at Hope Creek initiated approximately 30,000 Notifications between January 2011 and December 2012. The inspectors observed supervisors and managers at the Plan-of-the-Day, SOC, and MRC meetings appropriately questioning and challenging NOTFs 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 NOTFs. 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 significant issues or concerns that had not been appropriately entered into the corrective action program for evaluation and resolution. In response to NRC questions and minor equipment observations identified by the inspectors during plant walkdowns, PSEG personnel promptly initiated a number of NOTFs and/or took prompt action to address the issues.

(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 NOTFs for operability and reportability, categorized them 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 impacts on the safety conscious work environment.

Based on the considerable sample of NOTFs reviewed, the inspectors noted that the guidance provided by PSEGs corrective action program implementing procedures appeared sufficient to ensure consistency in the 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 two findings of more than minor significance involving issues with the control room ventilation system.

These findings are documented in Section 4OA2.1.c. The inspectors also noted three observations regarding PSEGs corrective action program:

Service Water Intake Structure (SWIS) Heating and Ventilation System Performance Monitoring and Evaluation The inspectors identified instances where PSEGs reliability monitoring and evaluation of SWIS heating and ventilation system performance was inconsistently implemented.

Specifically, the inspectors identified two instances where component unavailability were not accounted for in Maintenance Rule (MR) system monitoring for the HVAC system for one of the station service water (SSW) pump rooms. The inspectors also identified that the traveling water screen motor room supply fans were incorrectly categorized as having high safety significance (HSS) in 2010, but did not have performance monitoring criteria consistent with other HSS systems. They also identified that while the Maintenance Rule function of the SWIS HVAC system is to maintain appropriate design temperatures within the intake structure and the traveling screen motor rooms, the temperature in these spaces is not tracked other than during periodic walk downs by system engineers. Moreover, low temperature alarms in these spaces were not set at temperatures consistent with the temperature operating band for these areas as listed in the UFSAR.

The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. Because engineering ultimately determined that traveling water screen ventilation supply fan (BV558) that was previously found to be degraded, was a low safety significance component, and none of the identified deficiencies would have caused the system to exceed a Maintenance Rule performance criterion, the inspectors determined that the issues were of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. PSEG documented these issues noted above in notifications 20594140, 20594723, and 20594733.

Maintenance Rule Functional Failure Evaluations While the inspectors noted that MR functional failure evaluations were being performed in accordance with PSEGs MR procedure AA-301-1004, Maintenance Rule -

Performance Monitoring, they observed that the quality and technical basis for some of these evaluations varied such that some functional failures were not recorded. For example, contrary to PSEGs MR procedure, the inspectors observed several cases where maintenance or operations personnel error that occurred while performing maintenance were not listed as MR functional failures, or equipment failures were not recorded as functional failures because the equipment was not called upon to meet its MR function at the time of the failure. The issues appeared to stem from the inconsistent implementation of this procedure in identifying and evaluating functional failures. These functional failures involved equipment such as the control room and service water ventilations systems.

The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. Because none of the identified deficiencies would have caused the system to exceed a maintenance rule performance criterion, the inspectors determined that the issues were of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. PSEG noted the issues observed by the inspectors and issued Notifications 20594380, 20595752, and 20595883 to address this matter.

Conformance With Station Processes Regarding Rework and CAP Documentation The inspectors identified examples where PSEG staff did not complete documentation in conformance with station processes. For example, the inspectors noted that as part of the rework documentation process, MA-AA-716-232, Station Rework Reduction Process, personnel were only filling out the rework codes, not the full template information required by the procedure. While this template was begun several years ago as an initiative to reduce rework, the process was found to be redundant to the corrective action process and was not consistently implemented. In recent months, PSEG decided to discontinue this process, but this procedure still directed this template be completed.

A second example involves PSEG CAP procedure (LS-AA-125), which was not consistently being followed for Action Items, or ACITS, which are meant to address performance improvements versus corrective actions. Specifically, the inspectors noted that some corrective actions did not contain documentation on why an ACIT was changed, or not completed, while in other cases ACITS were assigned when corrective actions would have been required by the procedure.

The inspectors independently evaluated this observation for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. Since PSEG had initiated or taken actions to correct identified deficiencies via ACITS in the examples noted by the inspectors, and the rework issues noted were addressed via the stations existing corrective action process (versus via the documentation templates), the inspectors determined that these documentation issues were of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy. PSEG noted the issues observed by the inspectors and issued Notifications 20581399, 20582305, and 20595651 to address this observation.

(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 the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective.

c. Findings

(1) Failure to Perform Maintenance on the A Control Room Air Conditioning System in Accordance With the Procedure

Introduction:

A self-revealing, Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified because PSEG failed to perform maintenance on the A control room air conditioning train in accordance with the documented procedure steps. Specifically, PSEG personnel failed to follow the maintenance procedure as written by stopping and restarting the A control room ventilation train prior to completing the monitoring period and obtaining the tuning parameters required by the procedure.

Description:

On September 6, 2012, PSEG placed the A control room ventilation train in service to support a 48-month tuning preventive maintenance activity on the A control room air conditioning. Maintenance personnel made the decision to stop the tuning procedure, HC.IC-DC.ZZ-0349(Q), at step 5.30 (which requires a monitoring period),remove the test equipment, and complete the tuning procedure the next day.

Maintenance communicated to the control room operators that the test equipment could be removed. However, they failed to communicate that there was more tuning to perform to obtain the proper parameters, and that the procedure had not been completed. Control room operators removed the A control room ventilation train from service for removal of test equipment. Following removal of the equipment, operations restarted the A control room ventilation. Nine minutes later, the A control room chilled water pump tripped because the proper tuning parameters had not been set. The trip of the A chilled water pump caused an automatic trip of the A control room emergency filtration system. At that time, control room operators entered Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.2.1 for the A control room emergency filtration being inoperable, and TS LCO 3.7.2.2 for the A control room air conditioning being inoperable.

The apparent cause investigation into the trip of the A control room ventilation train determined that the cause of the trip was inappropriate stopping and subsequent restart of the chiller prior to obtaining the parameters required by the procedure. The procedure used for the tuning preventive maintenance, HC.IC-DC.ZZ-0348(Q) 32SM Chilled Water Temperature Controller, contains a note indicating that adjustments should be monitored over a full day of operation. After the monitoring period, the procedure contains steps to shut down the control room air conditioning, remove the test equipment, and to return the control room air conditioning to service. Maintenance personnel failed to follow this procedure during A control room air conditioning tuning by having A control room air conditioning stopped, removing the test equipment, and having A control room air conditioning restarted prior to the monitoring period and completing the tuning adjustments.

Analysis:

The inspectors determined that the failure to follow the maintenance procedure as written for maintenance on the A control room air conditioning train was a performance deficiency that was reasonably within PSEGs ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the human performance attribute of the barrier integrity cornerstone, and affected the cornerstone objective of maintaining the radiological barrier functionality of the control room. Specifically, PSEG personnel caused control room ventilation A train to become inoperable for several hours when they stopped and restarted A control room ventilation prior to completing the maintenance procedure.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency represents a degradation of only the radiological barrier function provided for the control room.

This finding has a cross-cutting aspect in the area of human performance, work control because PSEG did not appropriately control work activities by incorporating actions to address the need for work groups to communicate and coordinate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance. Specifically, maintenance personnel did not communicate to operations personnel that the maintenance activity was not completed or that the A control room ventilation should not be stopped and restarted H.3(b).

Enforcement:

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with those procedures. Contrary to the above, on September 6, 2012, PSEG failed to conduct maintenance on the A control room air conditioning in accordance with the documented procedure. Specifically, PSEG failed to follow procedure DC.ZZ-0348(Q) as written by stopping and restarting the A control room ventilation prior to completing the procedure.

PSEGs corrective actions included entering this issue into their corrective action program as NOTF 20575256, conducting an apparent cause investigation, restoring the system to an operable status, conducting a training needs analysis, and revising the maintenance procedure. Because this violation was of very low safety significance (Green), and PSEG entered the issue into their corrective action program (NOTF 20575256), this violation is being treated as an NCV, consistent with section 2.3.2 of the NRCs Enforcement Policy. (NCV 05000354/2013007-01, Failure to Conduct Maintenance on the CR HVAC System in Accordance with a Procedure)

(2) Failure to Promptly Correct a Design Deficiency in the Control Room Chilled Water System

Introduction:

The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because PSEG failed to promptly correct a design deficiency in the control room chilled water circulating low flow pump trip logic.

Specifically, PSEG failed to take timely action to develop and implement a modification to add a 10 second time delay to the pump trip logic.

Description:

On July 7, 2011, A train control room ventilation tripped due to the A control room air conditioning chilled water circulating pump tripping on low flow. The apparent cause evaluation performed for this event determined the cause of the trip was a design deficiency in the protective logic for the pump. The evaluation identified the control room chilled water circulating low flow pump would trip if a low flow signal was received 20 seconds or more after the pump start, but the desired protective logic was to trip 10 seconds after the low flow signal was received to prevent unnecessary trips in response to momentary indicated low flow. PSEG developed a corrective action to present the proposed logic modification to the Plant Health Committee, and in January 2012, the Plant Health Committee approved the modification. Following approval, PSEG did not take timely action to develop or implement a design change package for the modification.

On June 25 and July 1, 2012, the A train control room ventilation tripped due to the A control room air conditioning chilled water circulating pump tripping on low flow. The work group evaluation for these trips noted that an action had been developed in the fall of 2011 to add a 10 second time delay to the pump trip logic as the result of a corrective action for previous trips, and developed a corrective action to obtain funding for the modification. On July 7 and July 10, 2012, the A chilled water circulating pump tripped on low flow again. The apparent cause evaluation for the July 10 trip identified the cause to be that the system was subject to trips due to momentary indicated low flow, and a contributing cause was the low flow trip set point was set too close to the normal flow, based on an outdated calculation. PSEG developed a corrective action to change the low flow setpoint. As a result of the trips in June and July 2012, PSEG developed and implemented a temporary configuration change package to change the low flow setpoint in July 2012 on the A train and September 2012 on the B train. PSEG then developed and implemented a design change package to add the 10 second time delay for the chill water pump trip on low flow in September 2012 on the A train and November 2012 on the B train.

Analysis:

The inspectors determined that failure to take prompt corrective action for the design deficiency in the low flow trip logic for the control room chilled water circulating pumps was a performance deficiency that was reasonably within PSEGs ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the SSC and barrier performance attribute of the barrier integrity cornerstone and affected the cornerstone objective to maintain the radiological barrier functionality of the control room. Specifically, failure to take timely corrective action to develop and implement a modification to add a 10 second time delay to the pump trip logic caused inoperability of the A train control room ventilation on several occasions.

In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency represents a degradation of only the radiological barrier function provided for the control room.

This finding does not have a cross-cutting aspect associated with it because, although the performance deficiency occurred within the last three years, the performance characteristic associated with the untimely corrective action for this deficiency is not indicative of PSEGs current performance. PSEG demonstrated improved performance in response to trips of the A control room ventilation in June and July 2012 caused by chilled water pump low flow by taking timely corrective action to develop and implement a design change package for the modification to the low flow trip logic that had been identified in 2011. PSEG also identified an additional deficiency in the low flow trip logic and took timely action to correct it in mid-2012. Additionally, since PSEG identified that a modification to the low flow pump trip logic was necessary, PSEG has implemented a new station process in the fall of 2012, ER-AA-2001-1001, Evaluation of Equipment Reliability Strategies, to evaluate the timeliness, effectiveness, and mitigating actions of proposed strategies developed for equipment reliability based on risk significance.

Based on demonstrated improved performance in recent months as well as this new station process, which would have increased the priority and accelerated the implementation of these modifications, it is unlikely that this performance deficiency would occur again under similar circumstances.

Enforcement:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, following a July 2011 trip of a train of the CR HVAC system, PSEG failed to take prompt corrective action for an identified design deficiency in the low flow trip logic for the A control room air conditioning chilled water circulating pumps. Specifically, PSEG failed to develop and implement a modification to add a 10 second time delay to the pump trip logic, which was specified as a corrective action in the ACE for the July 2011 pump trip.

PSEGs corrective actions included entering this issue into their corrective action program as notification 20567269, conducting an apparent cause investigation, and developing and implementing design change packages to modify the low flow control room air conditioning chilled water circulating pump trip logic. Because this violation was of very low safety significance (Green), and PSEG entered the issue into their corrective action program (20567269), this violation is being treated as an NCV, consistent with section 2.3.2 of the Enforcement Policy. (NCV 05000354/2013007-02, Failure to Take Timely Corrective Action for an Identified Design Deficiency with the CR HVAC System)

.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 Hope Creek 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 Hope Creek 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 Hope Creek 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 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 and functional area self-assessment 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 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. 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 Hope Creek. 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 Manager 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 also reviewed select Employee Concerns Program files to ensure that PSEG entered issues into the corrective action program when appropriate.

b. Assessment During interviews, PSEG 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 February 15, 2013, the inspectors presented the inspection results to John Perry, Site Vice President and other members of the Hope Creek staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Perry, Site Vice President

E. Carr, Plant Manager

W. Kopchick, Operations Director

J. Kandasamy, Work Management Director

K. Knaide, Engineering Director

F. Mooney, Maintenance Director

J. Clancy, Corrective Action Program Coordinator

S. Simpson, Regulatory Assurance Manager

R. Chan, Nuclear Oversight Manager

F. Possessky, Performance Improvement Manager

P. Bonnett, Senior Engineer, Regulatory Assurance

H. Trimble, Radiation Protection Manager

D. Boyle, Operations Supervisor

B. Fulker, Nuclear Oversight Supervisor

D. Kelly, Radiation Protection CAPCO

K. Master, Chemistry CAPCO

D. Rogozenski, Operations CAPCO

D. Bush, System Engineer

S. Connelly, System Engineer

M. Conroy, Program Engineering

R. Cummins, System Manager

Y. Ghotok, System Engineer

T. Gingerich, System Engineering

C. Johnson, Program Engineering

D. Kabachinski, Emergency Preparedness

S. Kozink, Operations

J. Molner, Manager, Emergency Preparedness

T. Morin, Regulatory Assurance

P. Pino, System Engineering

A. Simkins, System Engineering

R. Smith, System Engineering

S. Thomassen, Emergency Preparedness

K. Torres, System Manager, System Engineering

K. Wichman, System Engineer

NRC Personnel

D. Schroeder, Chief, DRP Branch 1, Region I

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000354/2013007-01 NCV Failure to Conduct Maintenance on the CR HVAC System in Accordance with the Procedure

05000354/2013007-02 NCV Failure to Take Timely Corrective Action for an Identified Design Deficiency with the CR HVAC System