ML17291B082

Supplemental Inspection Results

ML17291B082
Person / Time
Site:	Salem
Issue date:	10/18/2017
From:	Public Service Enterprise Group
To:	NRC Region 1
References
2017-011
Download: ML17291B082 (19)

Text

95001 Supplemental Inspection Results Salem Unit 2

NRC Team Members Nicole Warnek, Senior Allegation Coordinator, Region I Matt Hardgrove, Project Engineer Rich Barkley, PE, Senior Project Engineer

Required Inspection Areas Problem Identification Root Cause, Extent of Condition, and Extent of Cause Evaluation Corrective Actions

Overall Observations PSEG met the inspection objectives Documents reflect a significant effort by PSEG staff and consultants Committed to enhancing Equipment Reliability and CAP discipline Focused hardware changes to prevent recurrence of the 5 trips Equipment replacements to address relay aging and eliminate Single Point Vulnerabilities (SPVs)

2.01 a - Determine if PSEGs evaluations documented who identified the issue and the conditions under which it was identified Done for all 5 trips, but On the 1st trip, definitive cause could not be found for the 2H bus relay failing to isolate the shorted HD pump motor before the entire bus was lost

2.01b. Determine if PSEGs evaluations tell how long the issues existed and prior opportunities for identification Determined in each case Longest history/string of opportunities was with the CFCU (1999) 2nd was the Generator STV relay (2005)

The shortest (and most trying one) was the main transformer

2.01c. Determine if PSEGs evaluations document the plant specific risk consequences and compliance concerns associated with each issue Completed for all 6 RCEs Limited risk due to equipment involved Most equipment was on the non-nuclear, non-safety side of the plant All trips were uncomplicated Increased frequency does impact the PRA, but not to a significant degree

2.02a Inspection staff to determine if PSEG evaluated the issues using a systematic methodology to identify the root and contributing causes Multiple methodologies used Root and contributing causes identified Final RCEs reflected a lot of hard, thorough work Understand you went through multiple upgrades/revisions to get to here

2.02b Determine if PSEGs RCE was conducted to a level of detail commensurate with the significance of the issue Substantial detail Varied based on the complexity of the event Considerable effort went into the overall Adverse Trend root cause Again, we are looking only at the final products

2.02c Determine if PSEGs RCEs included a consideration of prior occurrences of the issue and knowledge of Operating Experience Considered in all 6 RCEs Prior occurrences varied by event (CFCU leak had the most, followed by the STV relay)

Some had little or no precedent (stator cooling water dripping on a relay)

Limited OE on most events due to their uniqueness

2.02d Determine if PSEGs RCEs address the extent of condition and extent of cause Considerable work completed in both areas Some labor-intensive inspections performed MPT internal inspections Containment penetration inspections, cleaning and repairs Some work outstanding Unit 1 MPT internal inspections

2.02e Determine if PSEGs RCEs appropriately considered safety culture components Most significant weaknesses were found in:

Problem Identification Decision-Making Leadership Safety Values and Actions Questioning Attitude Performance largely addressed by planned CAs Additional actions planned to address Decision-Making trait

2.03a Determine if PSEG specified appropriate corrective actions CAPRs/CRCAs specified in each case Equipment modifications:

CFCU bypass lines Relay conversions to digital SPV eliminations/mitigations Management Processes to focus on ER & CAP ER Scorecard & Heat Map LTAMs updated and ER strategies Causal Eval training (Engineers & MRC)

CA Change of Intent controls / CARB

2.03b Determine if PSEG prioritized CAs with consideration of risk significance and regulatory compliance Risk considered in the course of prioritizing work:

Single Point Vulnerability (SPV) eliminations Motor rewinds/refurbishments Significant progress to date on program/process/procedure changes Almost all will be complete by the end of 2017

2.03c Determine if PSEG established a schedule for implementing and completing the corrective actions Schedules laid out for all CAs - many are complete Many equipment CAs are long-term:

CFCU bypass lines - 2 cycles CFCU gaskets - 5 cycles Relay conversions - 2-3 cycles SPV - 2-3 cycles 25 kV monitoring equipment replacements - 2 cycles

2.03d Determine if PSEG developed quantitative and/or qualitative measures of success for determining the effectiveness of the CAs EFFRs planned Balance of qualitative versus quantitative measures based on the CA Many will not occur for awhile due to the need to complete modifications Interim EFFRs done where possible Questioned whether one of the EFFRs for the Adverse SCRAM trend would be practical (or possible) to implement

Notable Positive Observations Quality & Thoroughness of final evaluation products Substantial and meaningful corrective actions:

ER scorecards / heat map Hardware changes Component Engineering CAP training + discipline measures Issues captured reflect long-standing/ historical issues that have had an adverse impact on the site:

Equipment Reliability Material Condition CAP effectiveness (to a lesser extent)

Watch Areas Can CAP improvements/oversight be sustained given the industry direction is going the opposite direction?

CARB CA Intent revision process for evaluations Based on the sheer number of actions planned, can you ensure follow thru long-term? (Last 95001 follow-thru did not set a good example)

Can the station maintain the resource commitment and discipline necessary to sustain ER scorecard/heat maps long-term?

Next PI&R team in 2019 will follow-up

Wrap-Up Items Need to closeout LER on Main Power Transformer Will address assessment of why the CAs for the last 95001 on Unit 1 were ineffective & whats different this time Need to reference latest LER revision on HDP trip No proprietary information provided Questions?