IR 05000272/2019011
| ML19294A155 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/18/2019 |
| From: | Glenn Dentel Engineering Region 1 Branch 2 |
| To: | Carr E Public Service Enterprise Group |
| Dentel G | |
| References | |
| IR 2019011 | |
| Download: ML19294A155 (10) | |
Text
ber 18, 2019
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000272/2019011 AND 05000311/2019011
Dear Mr. Carr:
On September 13, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Station, Units 1 and 2 and discussed the results of this inspection with Rick DeSanctis, Salem Operations Director and other members of your staff.
The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Salem. 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 at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000272 and 05000311 License Nos. DPR-70 and DPR-75
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000272 and 05000311 License Numbers: DPR-70 and DPR-75 Report Numbers: 05000272/2019011 and 05000311/2019011 Enterprise Identifier: I-2019-011-0018 Licensee: PSEG Nuclear, LLC Facility: Salem Nuclear Generating Station, Units 1 and 2 Location: Hancocks Bridge, NJ 08038 Inspection Dates: August 19, 2019 to September 13, 2019 Inspectors: A. Patel, Senior Reactor Inspector (Team Lead)
C. Hobbs, Reactor Inspector D. Kern, Senior Reactor Inspector Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at Salem Nuclear Generating Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Missing Preventive Maintenance for Environmental Qualification Program Components Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N Systems NCV 05000311,05000272/2019011-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, because PSEG did not schedule and perform equipment replacement preventive maintenance (PM) as required by station procedures to maintain qualification components within the Environmental Qualification (EQ) program scope.
Specifically, twenty-one components did not have scheduled PMs and three of these had exceeded their qualified life.
Additional Tracking Items None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
===71111.21N - Design Bases Assurance Inspection (Programs)
The inspectors evaluated Environmental Qualification program implementation through the sampling of the following components:
Select Sample Components to Review - Risk Significant/Low Design (Inside/Outside Containment) (IP Section 02.01) ===
- (1) Unit 1, 12 Main Steam & Turbine Bypass Steam Generator Main Steam Drain Valve Solenoid Valve (S1MS-1SV279) [solenoid operated pilot valve, position indication switch, wire splice, power cable]
- (2) Unit 1, 11 Safety Injection Pump Cross Over Motor Operated Valve Motor (S1SJ-11SJ113-MTRY) [motor operated valve, limit switch, terminal block, wire splice, power cable]
- (3) Unit 1, 13 Auxiliary Feedwater Flow Differential Pressure Transmitter (S1AF-1FA1095) [transmitter, instrument cable]
- (4) Unit 1, 1CC215 Component Cooling Valve Open Limit Switch (S1CC-1CC215-LS1)
[solenoid operated valve, limit switch, terminal block, wire splice, power cable]
- (5) Unit 2, 21 Service Water Accumulator Injection Line Isolation Valve (S2SW-2SV1742)
[position indication switch, wire splice, power cable]
- (6) Unit 2, 21 Residual Heat Removal Pump Motor (S2RHR-2RHR1-MTRD) [pump motor, wire splice, power cable]
Select Sample Components to Review - Primary Containment (Inside Containment) (IP Section 02.01) (2 Samples)
- (1) Unit 1, 1PR3 Reactor Coolant Pressurizer Safety Relief Valve Close Limit Switch (S1RC-1PR3-LS2) [limit switch, terminal block, wire splice, power cable]
- (2) Unit 2, Emergency Core Cooling System Recirculation Sump Level Switch (S2SJ-2LD20255) [level switch, wire splice, power cable]
INSPECTION RESULTS
Missing Preventive Maintenance for Environmental Qualification Program Components Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N Systems NCV 05000311,05000272/2019011-01 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because PSEG did not schedule and perform equipment replacement preventive maintenance (PM) as required by station procedures to maintain qualification components within the Environmental Qualification (EQ) program scope. Specifically, twenty-one components did not have scheduled PMs and three of these had exceeded their qualified life.
Description:
10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, established testing and maintenance requirements to ensure certain equipment was qualified for its application and would meet its specified performance requirements when subjected to design basis event conditions predicted to be present when it must perform its safety function up to the end of its qualified life. Salem EQ Program procedures, including component EQ Binders, established installation and maintenance requirements to ensure equipment covered by 10 CFR 50.49 remains qualified.
CC-AA-203, EQ Program, Revision 9, requires station personnel to schedule and perform preventive maintenance activities required by the EQ Program to maintain component environmental qualification.
The inspectors requested work history documentation to determine the age of solenoid valve S1MS-1SV279 and to verify PMs were established to replace the solenoid valve prior to the end of its 23.99 year qualified life as specified by EQ-SA-017E, EQ Binder for Automatic Switch Company (ASCO) Solenoid Valve Model NP8321 Series, Revision 3. PSEG found that replacement PMs were not scheduled for S1MS-1SV279 or its two similar valves on Unit 2. However, each valve remained within its qualified life. Valves S1MS-1SV279, S2MS-2SV279, and S2MS-2SV288 would reach the end of qualified life on November 2, 2021, February 9, 2020, and February 2, 2020, respectively. Prior to the inspectors inquiry, no activity was in place to schedule or perform the required equipment replacements prior to exceeding their qualified life.
PSEG entered the issue into their corrective action program as notifications 20830411 and 20832938. PSEG performed an initial extent-of-condition review and identified eighteen additional EQ components whose required replacement PMs had not been generated or scheduled. Three of the affected installed components (Unit 2 hydrogen analyzer sensors S2CBV-2XA3358 & S2CBV-2XA3359, Unit 2 pressurizer pressure transmitter circuit card S2RC-2PT474) were already beyond their qualified life. The Unit 2 hydrogen analyzer sensors were originally qualified to June 2016 and the Unit 2 pressurizer pressure transmitter circuit card were originally qualified to March 2018. PSEG performed detailed engineering analysis and determined qualified life for the three overdue components could be extended until the next opportunity to perform the associated equipment replacement PMs. The inspectors determined the analysis was reasonable.
PSEGs initial review determined the most likely cause was a work control database conversion that occurred in 1999. PSEG also plans on reviewing other work orders not associated with EQ as a further extent-of-condition review.
Corrective Actions:
PSEG entered the issue into their corrective action program, performed detailed engineering analysis, and determined qualified life for the three overdue components could be extended until the next opportunity to perform the associated equipment replacement PMs.
PSEG determined none of the twenty-one components were currently beyond their revised qualified life and all remained qualified. Work control staff initiated action to schedule the twenty-one replacement PMs for performance prior to exceeding their revised qualified life. The inspectors reviewed the three EQ PM deferral evaluations and determined they were reasonable. Additionally, PSEG initiated action to assess the programmatic impact of this issue, verify scheduling of non-EQ PMs, and to assess applicability to Hope Creek Nuclear Generating Station.
Corrective Action References: Notifications 20830411 and 20832938
Performance Assessment:
Performance Deficiency: Preventive maintenance work orders required to maintain equipment qualification were not generated, scheduled, and/or performed for twenty-one EQ components. Three of these components were beyond their qualified life and required engineering evaluations to support extending qualified life and EQ PM deferrals. The remaining eighteen components had not exceeded their qualified life. The deficiency occurred in 1999 when the station converted to a new work control system. The extent-of-condition may also extend to non-EQ components.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. With no replacement PMs scheduled, twenty-one installed EQ components (serving various systems on both Salem Units 1 and 2) would likely have exceeded their qualified life and may not have reliably performed their designated safety function during and following design basis events. Additionally, the deficiency was similar to NRC IMC 0612, Appendix E, Examples of Minor Issues (examples 3.j and 3.k), in that it was programmatic impacting twenty-one EQ components. This could adversely affect the reliability of mitigating systems and complicate operator response to prevent undesirable consequences to a design basis event.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations, Exhibit 2, Mitigating Systems Screening Questions. The performance deficiency affected the qualification of Mitigating Systems cornerstone components. The inspectors determined that this finding was a deficiency affecting the design or qualification of mitigating structures, systems, or components, where the structures, systems, or components maintained their operability or functionality.
Therefore, the inspectors determined the finding to be of very low safety significance (Green).
Specifically, for the twenty-one above mentioned components, operability and qualification was subsequently demonstrated through a technical evaluation which extended the EQ life and/or rescheduling the EQ replacement PM to an earlier date.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The inspectors determined the central cause of the issue occurred when the station converted to a new work control system in 1999, and did not represent present licensee performance.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures. Salem EQ Program procedures, including component EQ Binders, established installation and maintenance requirements to ensure equipment covered by 10 CFR 50.49 remains qualified. CC-AA-203, EQ Program, Revision 9, requires station personnel to schedule and perform preventive maintenance activities required by the EQ Program to maintain component environmental qualification. Various component-specific EQ binders identify additional EQ replacement PMs and their required frequency.
Contrary to the above, from approximately June 2016 to September 13, 2019, station personnel did not accomplish procedures to generate, schedule, and perform PM work orders required to maintain equipment qualification for three EQ components (Unit 2 hydrogen analyzer sensors S2CBV-2XA3358 & S2CBV-2XA3359 and Unit 2 pressurizer pressure transmitter circuit card S2RC-2PT474). The components were in service beyond their qualified life and required engineering evaluations to support extending EQ preventive maintenance activities. In addition, eighteen other components including ASCO solenoid valves S1MS-1SV279, S2MS-2SV279, and S2MS-2SV288 were not scheduled for preventive maintenance before their end of qualified life. The deficiency occurred when the station transitioned to a new work control system. PSEG entered the issue into their corrective action program as notifications 20830411 and 20832938.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On September 13, 2019, the inspectors presented the design basis assurance inspection (programs) inspection results to Rick DeSanctis, Salem Operations Director and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N Calculations EQ-SA-008A Namco Controls, Limit Switch Model EA180 Series Revision 2
EQ-SA-013 Crosby Position Indicator Model DSC-C-65628 Revision 1
EQ-SA-017E Automatic Switch Company Solenoid Valve Model NP8321 Revision 3
Series
S-C-SDC-1419 Salem Generating Station Environmental Design Criteria Revision 5
Corrective Action 20831352
Documents 20831354
Resulting from 20831549
Inspection 20831550
20831552
20831553
20831555
20831561
20831564
20831591
20832007
20832461
20832525
20832547
20832938
20834011
Drawings 231405 Penetration Area No. 12 & 22 Main Steam Panels 683-1B Revision 26
through 689-1B, and 832-1B
Procedures EQ-SA-017D Environmental Qualification Binder For Automatic Switch Revision 2
Company Solenoid Valve Model NP8316 Series
Work Orders 920717009
951021001
951021003
7