05000272/FIN-2017003-02
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Finding | |
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Title | Violation of Containment Integrity Technical Specification |
Description | The inspectors identified a Green non-cited violation (NCV) of Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.6.1.1, Containment Integrity,when PSEG did not ensure that the APD backup CIVs, associated with penetrations required to be closed during accident conditions, were unisolated intermittently under appropriate administrative controls. Specifically, manual CIVs associated with the APD sampling system were opened and left continuously open for 27 days, under tagging instructions that would have resulted in an actual open penetration outside of containment during certain design basis accidents and PSEG had not evaluated the adequacy of the tagging instruction to ensure radiological dose consequences would remain in conformance with the licensing basis. PSEG entered this issue in the Corrective Action Program (CAP) as notifications (NOTFs) 20751423 and 20777663. Technical Specification (TS) compliance was restored on January 4, 2017, when PSEG restored the normal air APD sample valve configuration. This issue was more than minor since it was associated with the configuration control attribute of the Barrier Integrity cornerstone and adversely impacted its objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide release cause by accidents or events. Using Appendix H, the inspectors determined this finding was of very low safety significance, or Green, because this was a Type B finding (Section 4.0), involving small diameter lines that were not important to large early release frequency (LERF), as described in Table 4.1. The finding had a cross-cutting aspect in the area of Human Performance, Work Management, in that the organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, the planned tagging instructions for control of the back-up sampling valves did not ensure the work activity was controlled and executed in accordance with TS. [H.5] |
Site: | Salem |
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Report | IR 05000272/2017003 Section 1R15 |
Date counted | Sep 30, 2017 (2017Q3) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | P Finney A Ziedonis R Barkley T Fish J Furia F Bower |
Violation of: | Technical Specification |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Salem - IR 05000272/2017003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Salem) @ 2017Q3
Self-Identified List (Salem)
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