ML16040A345
| ML16040A345 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/09/2016 |
| From: | Ray Lorson Division of Reactor Safety I |
| To: | Davison P Public Service Enterprise Group |
| References | |
| Download: ML16040A345 (5) | |
See also: IR 05000354/2015007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
February 9, 2016
Paul J. Davison
Site Vice President - Hope Creek
P.O. BOX 236
HANCOCKS BRIDGE, NJ 08038
SUBJECT: RESPONSE TO DISPUTED NON-CITED VIOLATION HOPE CREEK
GENERATING STATION - COMPONENT DESIGN BASES INSPECTION
REPORT 05000354/2015007
Dear Mr. Davison:
We received your response [ADAMS No. ML15362A564] to our inspection report
05000354/2015007 [ADAMS No. ML15329A157] issued on November 25, 2015, concerning
activities conducted at your facility. In your response, you denied a Non-Cited Violation (NCV)
contained in the inspection report. Specifically, PSEG contends that the weaknesses identified
in the inspection report regarding classification, evaluation and corrective actions are not more
than minor in that PSEGs conclusion on operability and corrective actions were not impacted.
The NRC conducted a detailed review of your response and the applicable inspection guidance.
Region I staff who were not involved with the initial inspection effort performed this review. After
careful consideration of the bases for your denial of the NCV, we determined that the violation
and characterization of the finding were properly described in the inspection report. Specifically,
the inspection team identified that your staff failed to conduct operability determinations in
October 2013 following the improper installation of a service water system valve and a
subsequent event where the valve failed to operate due to a high torque condition. In response
to the inspection teams questions, your staff, with support from an external engineering
organization, performed an operability review and determined that the valve was able to perform
its safety function for a limited number of operating cycles. You subsequently scheduled a
maintenance activity to fully restore the valve during the October 2016 refueling outage. Our
review determined that this finding was appropriately characterized as more than minor as
there was a reasonable basis for questioning operability of the valve following the October 2013
events described above. We have provided a summary of our evaluation and conclusions as an
enclosure to this letter.
P. Davison 2
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its
enclosure and your December 24, 2015, response will be available electronically for public
inspection in the NRC Public Document Room or from the NRC's document system (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Raymond K. Lorson, Director
Division of Reactor Safety
Docket No. 50-354
License No. NPF-57
Enclosure: as stated
cc w/encl: Distribution via ListServ
SUMMARY
Non-Cited Violation (NCV)05000354/2015007-02
Restatement of the Violation:
The team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, because PSEG did not provide adequate work order instructions
for the installation of service water (SW) pump discharge isolation valve 2198C following
planned valve maintenance in October 2013. Specifically, the inadequate work order
instructions contributed directly to maintenance technicians installing the valve in the opposite
orientation compared to the intended orientation.
Licensee Response (Summary):
PSEG denies that the NRC identified any new information that impacted the licensees
conclusions regarding operability or corrective actions. The improper re-installation of the valve
EAHV-2198C was promptly identified by the licensee and entered in CAP, and the additional
analyses performed in response to NRC questions supported the licensees initial conclusions.
In addition, PSEG contends the identified weaknesses associated with the classification,
evaluation, and corrective actions of EAHV-2198C do not meet the threshold for more than
minor.
NRC Evaluation:
The NRC Region I staff performed an independent review of the documented NCV in Inspection
Report 05000354/2015007, using PSEGs basis for denial for comparison, and made the
following observations:
1) Notification (NOTF) 20626219 was initiated by the PSEG staff on October 22, 2013,
identifying the installation of valve 2198C 180 degrees different than when removed.
This NOTF was subsequently updated by the PSEG maintenance staff to reflect
inadequacies in the applicable Work Order (60112463-410) as compared to the valve
drawing (M-10-1) and the associated vendor manual. The NCV properly refers to
10 CFR 50, Appendix B, Criterion V, as the appropriate violation of regulatory
requirements.
2) The Component Design Bases Inspection (CDBI) report states (page 6) that there was
no documented evaluation of the impact of this misalignment and configuration error
prior to operations declaring the C SW pump operable following the 2198C maintenance
on October 23. As stated in the report and further clarified by interview with the
inspection team leader, PSEG did not complete an operability evaluation prior to
restoration of the C SW pump to service on October 23, 2013, in spite of the improper
installation of the outlet valve. Further, PSEG acknowledged this deficiency by initiating
NOTF 20705874 (also documented in the report). The inspection report (page 7)
identified a second instance where PSEG failed to properly assess a valve operational
anomaly, an unexpected high opening torque (compared to the valves weak link
analysis and Limitorque limits) and its potential adverse impact on system operability.
This condition was identified during troubleshooting of valve 2198C on October 27,
2013, but no corresponding operability evaluation was documented.
1
Enclosure
3) The teams observations documented in the report and highlighted in 2) above, form the
basis for the inspection teams conclusion that the NRC added value to a licensee-
identified finding or violation. The absence of an operability evaluation, for either of the
above referenced conditions, was documented as a weakness in the licensees
classification, evaluation, or corrective action (page 9) and was the basis for the team to
conclude there was a reasonable doubt of operability, with respect to the valve being
able to function under all design basis conditions. In order to conclude that the valve
was operable and to answer questions from the inspection team, PSEG performed an
operability determination for the issue of the valve being installed in the wrong
orientation (NOTF 20705874), performed a technical evaluation to determine that the
valve actuator was capable of opening the valve under all required design basis
conditions based upon actual measured data (NOTF 20704783), and contracted with
Kalsi Engineering to perform an H4BC gear box torque analysis for the valve actuator.
This team conclusion was documented in the Analysis Section of the inspection report
(page 9-10) in reference to the basis for the observations (and underlying performance
deficiency) being more than minor. The team cites Example 3.j of IMC 0612,
Appendix E, as justification of the more than minor determination.
4) PSEGs Basis for Denial did not address the Appendix E more than minor example
referenced in the CDBI inspection report. Rather, PSEG stated that the weaknesses
identified by the team regarding classification, evaluation and corrective action were not
more than minor. Further, PSEG contends that the additional analyses performed in
response to NRC team questions did not change the original operability determination
outcome. Neither the subjective contention of the weaknesses being minor nor the final
determination of operability being maintained provide a sufficient basis for denial. The
NRC determined that the Appendix E example established the basis for determining that
this performance deficiency was of more than minor significance.
5) In the Basis for Denial, PSEG opines that the CDBI teams challenge of the operability
impact of the above conditions was unfounded without knowledge of the actual operating
conditions of the system (system alignment, flowrates, and valve differential pressure
were not recorded and were unknown). PSEG contends that without knowing actual
system operating conditions, data cannot be extrapolated with any certainty. The NRC
considers that the uncertainties associated with the valve operating parameters highlight
the reason why PSEG was required to perform an operability determination following
improper installation of the valve and its failure to operate due to a high torque condition.
6) Additionally, PSEG took exception to the observation in the inspection report that the
maintenance work instructions lacked sufficient detail. On page 6 of the inspection
report, the inspection team noted that PSEG maintenance personnel identified and
documented in NOTF 20626219, that the desired orientation of the 2198 valve was not
specified in valve drawing M-10-1 or in the vendor manual. The inspection team also
noted that the work order contained several diagrams which depicted the wrong valve
orientation. The NRC determined that the maintenance work instructions given to the
maintenance staff lacked sufficient detail to ensure that the valve was installed in the
proper orientation.
For the above reasons, the staff concludes that the violation occurred as described in Inspection
Report 05000354/2015007.
2
Enclosure
P. Davison 2
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its
enclosure and your December 24, 2015, response will be available electronically for public
inspection in the NRC Public Document Room or from the NRC's document system (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Raymond K. Lorson, Director
Division of Reactor Safety
Docket No. 50-354
License No. NPF-57
Enclosure: as stated
cc w/encl: Distribution via ListServ
DISTRIBUTION:
DDorman, RA (R1ORAMail) FBower, DRP PKrohn, DRS
DLew, DRA (R1ORAMail) RBarkley, DRP JKulp, DRS
MScott, DRP (R1DRPMail) MDraxton, DRP WCook, DRS
JColaccino, DRP (R1DRPMail) JHawkins, DRP, SRI JSchoppy, DRS
RLorson, DRS (R1DRSMail) SHaney, DRP, RI JBrand, DRS
BSmith, DRS (R1DRSMail) COtt, DRP, AA CSantos, RI, OEDO
RidsNrrPMHopeCreek RidsNrrDorlLpl1-2
DOCUMENT: G:\DRS\Engineering Branch 2\PSEGCDBINCVChallengeJan2016.docx
ADAMS ACCESSION NUMBER: ML16040A345
SUNSI Review Non-Sensitive Publicly Available
OFFICE RI/DRS RI/DRS RI/DRS
NAME WCook JKulp RLorson
DATE 02/08/2016 02/08/2016 02/09/2016
OFFICIAL RECORD