IR 05000272/2017008

Problem Identification and Resolution Inspection Report 05000272/2017008 and 05000311/2017008

ML17289A946
Person / Time
Site:	Salem
Issue date:	10/13/2017
From:	Fred Bower Reactor Projects Branch 3
To:	Sena P Public Service Enterprise Group
References
IR 2017008
Download: ML17289A946 (19)

Text

B. Hanson UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713 October 13, 2017 Mr. Peter P. Sena, III President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038 SUBJECT: SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -

PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000272/2017008 AND 05000311/2017008

Dear Mr. Sena:

On September 1, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial problem identification and resolution inspection at your Salem Nuclear Generating Station (Salem), Units 1 and 2. The NRC inspection team discussed the results of this inspection with you, Mr. Charles McFeaters, Salem Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. .

The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRCs Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Fred L. Bower, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 50-272 and 50-311 License Nos. DPR-70 and DPR-75 Enclosure:

Inspection Report 05000272/2017008 and 05000311/2017008 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

SUMMARY

Inspection Report (IR) 05000272/2017008 and 05000311/2017008; 08/14/2017 - 09/01/2017;

Salem Nuclear Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution (PI&R). No findings were identified.

This NRC team inspection was performed by three resident inspectors and one regional inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

Problem Identification and Resolution The inspectors concluded that PSEG was effective in identifying, evaluating, and resolving problems. PSEG personnel identified problems, entered them into the corrective action program (CAP) at a low threshold, and prioritized issues commensurate with their safety significance. The inspectors concluded that corrective actions (CAs) for identified deficiencies were generally timely and adequately implemented however, a trend regarding untimely CAs was identified. The inspectors concluded that PSEG appropriately identified, reviewed, and applied relevant industry operating experience (OE) to Salem operations, and completed self-assessments and audits as required. PSEG adequately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition (EOC), generic issues, and previous occurrences.

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

No findings were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of PI&R as defined by Inspection Procedure (IP) 71152. All documents reviewed during this inspection are listed in the to this report.

.1 Assessment of CAP Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that describe and implement PSEG's CAP at Salem. To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and CA implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, CA, and PSEG procedure LS-AA-125, CAP.

For each of these areas, the inspectors considered risk insights from Salems risk analysis and reviewed notifications (NOTFs) selected across various cornerstones of safety in the NRC's Reactor Oversight Process. The security cornerstone was not covered as part of the scope of this inspection because security issues at Salem and Hope Creek are addressed using the Hope Creek CAP. Based on this arrangement, CAP effectiveness under the security cornerstone at Salem was reviewed during the biennial PI&R inspection conducted at PSEGs Hope Creek station in February 2017.

The results of that inspection are documented in IR 05000354/2017008 (ML17094A365).

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

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, completed corrective and preventative maintenance work orders (WOs), completed surveillance tests, and periodic trend reports. The inspectors completed field walkdowns of various systems and components on site, including the control room ventilation system, accessible portions of the chemical volume control system (CVCS), safety injection system, auxiliary feedwater system, service water (SW) strainers, and emergency diesel generators (EDGs). Additionally, the inspectors reviewed a sample of NOTFs written to document issues identified through internal self-assessments, audits, the OE program, and operator workarounds/burdens. The inspectors completed this review to verify that PSEG entered conditions adverse to quality into their CAP, as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of NOTFs issued since the last NRC biennial PI&R inspection completed in May 2015 (IR 05000272;311/2015008, ML15202A314). The inspectors also reviewed NOTFs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate CAs to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, maintenance rule (MR) functional failure determinations, and EOC and extent-of-cause reviews for selected problems to verify these processes adequately evaluated equipment operability, reporting of issues to the NRC, MR impacts, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed PSEGs completed CAs through documentation review, interviews and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed 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 PSEGs effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of NOTFs associated with previous NCVs and findings to verify that PSEG personnel properly evaluated and resolved these issues. In addition, the inspectors performed an expanded, five-year CA review to evaluate PSEGs actions related to the Units 1 and 2 SW strainers, CVCS and control room ventilation system.

The inspectors reviewed the CAs from root cause evaluation (RCE) 70171797 that remained incomplete at the conclusion of the Salem Unit 1 IP 95001, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area, inspection (IR 05000272/2015009, ML15258A467) for a White NRC Unplanned Manual Scrams per 7,000 Hours Critical performance indicator (PI). The inspectors reviewed the CAs to provide assurance that the completed CAs for risk significant performance issues were sufficient to address the root and contributing causes and prevent recurrence.

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 at a low threshold and entered them into the CAP as appropriate with minor exceptions noted below. The inspectors observed staff and supervisors at SOC and MRC meetings appropriately questioning and challenging NOTFs to ensure clarification and proper classification of the issues. Based on the samples reviewed, the inspectors determined that PSEG trended equipment, human performance, and programmatic issues, and entered identified problems into the CAP as appropriate. In general, the inspectors did not identify any issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. The inspectors identified several examples of degraded material condition and housekeeping observations during the course of the inspection which were all of minor safety significance. In response, PSEG personnel promptly initiated NOTFs and took immediate action to address the observations.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that PSEG appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem, however, one notable exception regarding the quality of equipment performance tracking in the MR program was identified. PSEG screened NOTFs for operability and reportability, categorized the NOTFs by significance, and assigned actions to the appropriate department for evaluation and resolution. The NOTF screening process considered human performance issues, radiological safety concerns, repetitiveness, and potential impact on the safety conscious work environment (SCWE).

Based on the sample of NOTFs reviewed, and the SOC and MRC meetings attended, the inspectors noted that the guidance provided by PSEGs CAP implementing procedures was sufficient to ensure consistency in the categorization of issues. Based on the inspected sample, operability and reportability determinations were performed when conditions warranted, and the evaluations supported the conclusion. In general, causal analyses appropriately considered the EOC associated with the problem, generic issues, and previous occurrences of the issue. The inspectors noted a significant amount of management involvement and oversight of the CAP fundamental functions to ensure adequate and consistent disposition of issues. Additionally, in the area of evaluation, the inspectors identified one observation regarding the quality of equipment performance tracking in the MR program.

Maintenance Rule Evaluation of Degraded Equipment Performance Title 10 CFR 50.65(a)(1) requires, in part, that if system performance has not been effectively controlled through preventive maintenance, goals-based performance monitoring shall be established, and CA shall be taken when the goals are not met. The inspectors identified examples where PSEG did not adequately monitor the performance of several MR (a)(1) systems against pre-established goals and did not promptly assure that adequate CAs were assigned to meet pre-stablished goals to address conditions adverse to quality associated with safety-related systems monitored under 10 CFR 50.65. Specific examples to support this observation include:

The team reviewed the current (a)(1) MR status for the CVCS system and identified multiple deficiencies. Specifically, Salem did not appropriately update the (a)(1)monitoring goals for the 13 and 23 charging pumps with the most recent MR expert panel approved goals that were established in June 2016. Additionally, the inspectors identified that during the period from February through April 2017, PSEG had accumulated 1013 and 416 hours0.00481 days <br />0.116 hours <br />6.878307e-4 weeks <br />1.58288e-4 months <br /> of unavailability on the 13 and 23 charging pumps, respectively. Although the accumulated unavailability time exceeded the June 2016 MR (a)(1) monitoring goal of 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> for both pumps, a NOTF was not initiated to document the condition until August 2017. Therefore, the inspectors determined that PSEG did not appropriately monitor the charging pumps performance against the established MR (a)(1) goals from June 2016. In addition, the inspectors identified that PSEG failed to promptly identify and reevaluate the MR (a)(1) monitoring goals after the unavailability goal had been exceeded in April 2017.

PSEG recognized the untimely evaluation and documented the issue into NOTF 20774012.

The inspectors reviewed the fuel handling building (FHB) ventilation system MR status and identified that the MR (a)(1) monitoring plan established in July 2015 had not been reevaluated by the MR expert panel since the MR (a)(1) monitoring period had ended in February 2017. In addition, the inspectors identified multiple NOTFs documenting deficient material and performance conditions that were not captured or included for the outstanding expert panel review of the (a)(1) monitoring period.

PSEG confirmed the inadequate and untimely evaluation of the FHB ventilation systems MR status and documented the issues in NOTFs 20774246, 20774330, and 20773016. An EOC review was also performed under NOTF 20773016 and similar issues were identified with the monitoring and evaluation of conditions associated with the SW system.

The inspectors determined that a performance deficiency (PD) existed because PSEG did not adequately monitor the performance of systems against established goals in accordance with 10 CFR 50.65(a)(1). Specifically, PSEG did not monitor the actual performance of the CVCS and FHB systems against the established unavailability and unreliability goals established by the MR program. The inspectors determined that the PD was minor in accordance with Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, because PSEG had maintained the systems in MR (a)(1) monitoring status and had established and implemented corrective actions to address the degraded systems performance.

(3) Effectiveness of Corrective Actions Although the inspectors concluded that CAs for identified deficiencies were generally timely and adequately implemented, an adverse trend regarding untimely CAs was identified. For significant conditions adverse to quality (SCAQ), PSEG identified corrective actions to prevent recurrence. The inspectors concluded that CAs to address selected NRC non-cited violations (NCVs) and findings since the last PI&R inspection were generally adequate and timely. However, as described below, the inspectors identified a trend in untimely CAs for known degraded conditions and two observations related to CA closure and effectiveness.

Untimely Corrective Actions Trend The team identified numerous examples where PSEG did not complete timely CAs to address conditions adverse to quality for known degraded conditions. The degraded conditions had NOTFs written and had CAs proposed or WOs generated, however, the completion of CAs was delayed. The most notable examples that support this trend include the following:

A nitrogen leak from the 23 SJ Accumulator to the containment atmosphere was identified in 2014 and required weekly operator action to maintain operability of the system. The condition was appropriately classified as an operator burden, but PSEG had not completed troubleshooting to identify the source of the leak and implement repair activities at the time of this inspection. Salem captured the untimely completion of the CAs to eliminate this operator burden in NOTF 20773482.

PSEG identified failures of Unit 2 pressurizer heater bundles in 2000. The initial CAs planned to abandon-in-place the failed safety-related heater bundles since adequate margin existed to perform the safety function. In 2011, Westinghouse Technical Bulletin 11-8 identified a concern that intergranular stress corrosion cracking of failed heater bundles, which, could impact reactor coolant system pressure boundary integrity, and interim compensatory measures were recommended until heater bundle replacements could be performed. PSEG implemented the recommended compensatory interim actions and established CAs to replace the heater bundles.

The inspectors identified that the CAs to replace the failed heater bundles had been incorrectly placed on hold which delayed implementation of the CAs. Salem captured the untimely CA observation under NOTF 20773617.

The team reviewed the CAs associated with NRC NCV 2015004-04. The finding documented an inadequate post-maintenance test (PMT) after a reactor trip channel was discovered inoperable following the calibration of a nuclear instrument. PSEG established CAs to change the calibration and PMT procedures before their next use. The inspectors observed that 20 of the 45 procedure revisions had not been completed at the time of the inspection. In addition, the inspectors identified that a small population of the unrevised procedures were used to perform instrument calibrations. In response to questions by the inspectors, Salem appropriately reviewed the impact of the use of the unrevised procedures on the associated instruments, and determined that no challenges to operability existed due to separate previously implemented corrective action to record enhanced operator log readings of the associated instrumentation. The observation regarding untimely CAs to revise the calibration procedures was captured in CAP under NOTF 20773280.

The inspectors determined that not performing timely CAs for known degraded conditions in accordance with 10 CFR Part 50, Appendix B, Criterion XVI was a PD.

PSEG entered NOTF 20773955 into the CAP to address the untimely corrective actions trend. The inspectors determined the PD was minor because the failure to perform timely CAs did not impact the operability or availability of inservice components.

Corrective Action Closure Review for NRC Findings The team reviewed root cause evaluation (RCE) 70184454, which evaluated the 22 steam generator feed water pump trip during the Unit 2 startup on February 16, 2016.

The team reviewed the CA closure documentation requirements of LS-AA-1003, NRC Inspection Preparation and Response, Section 4.3, which required Salem to initiate a NOTF to ensure Salems response and CAs properly addressed the finding or violation and captured the response in the closeout documentation. The inspectors identified that the NOTF had been written, however, the action to review Salems CAs had not been completed. The inspectors identified six additional examples of NRC findings or violations where the response NOTF specified in LS-AA-1003 had not been written or the response actions had not been completed. PSEG performed a prompt EOC review and determined a total of 20 NRC findings or violations did not have their LS-AA-1003 reviews completed. PSEG documented the issue under NOTF 20774281.

The inspectors identified that not performing the CA closure review specified in the self-imposed standard, LS-AA-1003, was a PD that could leave Salem vulnerable to not fully addressing all aspects of NRC findings or violations. Specifically, the inspectors review of RCE 70184454 determined that the CAs did not directly address the associated cross-cutting aspect. However, the inspectors concluded that Salem developed and implemented adequate CAs to identify and correct the cause of the feed water pump trip, and the associated cross cutting aspect did not require additional CAs.

The review of the six additional NRC-identified examples yielded similar conclusions.

Therefore, for the examples that were inspected, the inspectors determined that the PD was minor because there was no significant impact to the accuracy or completeness of PSEGs CAs.

Salem Unit 1 - IP 95001 Supplemental Inspection - CAs to Prevent Recurrence The inspectors reviewed the CAs to prevent recurrence (CAPR) from the RCE for Salem Unit 1s IP 95001 supplemental inspection (IR 05000272/2015009, ML15258A467) dated September 15, 2015, and found that all of the CAPRs had been completed in the CAP.

The inspectors identified that the CAs had been implemented as intended or the intent of the CA had been changed through MRC. However, PSEGs effectiveness review of the CAs determined that the CAPRs were inadequate since a White NRC PI for unplanned SCRAMs per 7,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> was repeated on Salem Unit 2 approximately one year later.

Therefore, PSEG closed the effectiveness review to the new RCE (70187925) which will address both the deficiencies that resulted in the Unit 2 White PI and the CAP deficiencies that lead to ineffective CAPRs for the previous Unit 1 White PI. The inspectors did not identify any additional issues of concern with PSEGs assessment and determined that the proposed actions to address the deficiencies in RCE 70187925 were adequate. The new RCE and actions were inspected in accordance with IP 95001 during the Salem Unit 2 supplemental inspection that was conducted onsite beginning on September 11, 2017. The results of this supplemental inspection are expected to be documented in IR 05000311/2017011 within 45 days from the exit meeting that was conducted on September 15, 2017.

c. Findings

No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of NOTFs associated with review of industry OE to determine whether PSEG appropriately evaluated the OE information for applicability to Salem and took appropriate actions, when warranted. The inspectors also reviewed evaluations of OE documents associated with a sample of NRC generic communications to ensure that PSEG adequately considered the underlying problems associated with the issues for resolution via their CAP.

b. Assessment The inspectors determined that PSEG considered industry OE information for applicability, and used the information to identify and prevent similar issues when appropriate. The inspectors determined that OE was appropriately applied, and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors identified one observation where PSEG had not fully evaluated and implemented actions for industry OE. Specifically, a revision was made to Westinghouse Technical Bulletin 11-8 regarding intergranular stress corrosion cracking on pressurizer heater bundles which had not been entered into the CAP or evaluated in accordance with the standards in PSEG procedure LS-AA-115, OE. PSEG entered the issue into the CAP under NOTF 20774141. Although the revised bulletin had not been entered into the CAP, the inspectors determined that the new revision did not contain significant changes to the compensatory actions or recommended CA and, therefore, the issue was determined to be minor.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the CAP, 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 CAP, when appropriate, and whether PSEG initiated CAs to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment Based on the inspected sample, the inspectors concluded that self-assessments, audits, and other internal PSEG assessments were critical, thorough and effective in identifying performance 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 CAP for evaluation. Based on the inspected sample, the inspectors concluded that Salem implemented CAs associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of SCWE

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the SCWE at Salem.

Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the PSEG ECP coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the ECP files to ensure that PSEG entered issues into the CAP when appropriate in accordance with EI-AA-101, ECP.

b. Assessment During interviews with the inspectors, Salem staff expressed a willingness to use the CA 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 CA program and the ECP. Based on these limited interviews and review of selected ECP files, the inspectors did not identify any examples of an unacceptable SCWE or significant challenges to the free flow of information related to nuclear safety.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On September 1, 2017, the inspectors presented the inspection results to Mr. Peter Sena, Chief Nuclear Officer, Mr. Charles McFeaters, Site Vice President and other members of PSEGs staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

K. Caampued, System Engineer

T. Cachaza, Regulatory Assurance

M. Cocking, Fire Protection Program Superintendent

P. Essner, Instrumentation and Controls Engineer

A. Garcia, System Engineer

W. Hardgrave, Senior Reactor Operator

M. Hassler Sr., RP Manager

G. Klotz, Maintenance Rule

F. Leeser, Technical Training Manager

T. Lighty, Maintenance Rule Program Manager

D. Maxey, Senior Reactor Operator

T. Muholland, Acting Operations Director

K. Palmer, CAP Program Manager

C. Partridge, Maintenance Support Superintendent

J. Plefka, Chemistry Technician

F. Possessky, CAP Program Specialist

M. Richers, Manager, Design Engineering

S. Rund, Manager, System Engineering

J. Shelton, Chemistry Manager

T. Swanson, Fire Protection Manager

J. Tutterow, System Engineer

J. Van Namee, Chemistry Technician

W. Wikoff, Engineering Technical Specialist

L. Wu, System Engineer

A. Zang, System Engineer

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

None.