05000272/FIN-2011007-03
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Finding | |
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| Title | Failure to Identify and Correct a Condition Adverse to Quality Affecting the CREACS Expansion Joints |
| Description | The team identified a finding of very low safety significance (Green) involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because PSEG did not identify and correct a condition adverse to quality. Specifically, PSEG did not identify and correct the degraded condition of the Unit 1 and Unit 2 control room emergency air conditioning system (CREACS) common suction expansion joints because they did not implement appropriate preventive maintenance (PM) per their performance-centered maintenance (PCM) template. PSEG placed the finding and the associated issues in its corrective action program. In response to the identified control room envelope (eRE) breach, operators promptly entered TS 3.7.6 and initiated mitigation actions. PSEG affected prompt repairs, performed an appropriate post maintenance test, declared the CRE fully operable, and exited the TS limiting condition for operation action statement. The finding is more than minor because it is associated with the barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the control room operators from radionuclide releases caused by accidents or events. The finding was evaluated in accordance with IMC 0609, Attachment 4, Table 4a for the containment barrier. Since the finding had the potential to impact more than the radiological barrier function, a Region 1 Senior Reactor Analyst (SRA) performed a Phase 3 analysis. The SRA determined that the dominant sequence involved a sufficient degradation of the CREACS barrier that would allow sufficient in-leakage to force an evacuation of the control room during a fire or toxic gas event. The areas with the degradation were in room 15615 and 25615 for Units 1 and 2, respectively. The SRA evaluated these areas and determined that the potential impact due to in-leakage through the degraded barrier from fire and toxic gas would be negligible. The SRA also reviewed the results of recent CRE in-leakage testing conducted in September 2010. The condition of the expansion joint tearing and wear could reasonably be assumed to have existed during the September testing. This testing also confirmed that the total inleakage in these areas was small. Based on the above factors, the SRA determined the finding was of very low safety significance (Green). The team determined that this finding has a cross-cutting aspect in the area of Human Performance, Work Control Component, because PSEG did not plan work activities to support long-term equipment reliability by ensuring that maintenance scheduling was more preventive than reactive. Specifically, PSEG did not implement appropriate PMs on the CREACS filter expansion joints necessitating several reactive corrective maintenance activities. (IMC 0310, Aspect H.3( |
| Site: | Salem  |
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| Report | IR 05000272/2011007 Section 1R21 |
| Date counted | Mar 31, 2011 (2011Q1) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | R Montgomery K Mangan G Skinner J Schoppy D Orr L Doerflein C Edwards |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Salem - IR 05000272/2011007 | |||||||||||||||||||||||||||||
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Finding List (Salem) @ 2011Q1
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