IR 05000354/2012002
| ML12124A276 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/03/2012 |
| From: | Arthur Burritt Reactor Projects Branch 3 |
| To: | Joyce T Public Service Enterprise Group |
| BURRITT, AL | |
| References | |
| IR-12-002 | |
| Download: ML12124A276 (43) | |
Text
UNITED STATES May 3, 2012
SUBJECT:
HOPE CREEK GENERATING STATION UNIT 1 - NRC INTEGRATED INSPECTION REPORT 05000354/2012002
Dear Mr. Joyce:
On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Hope Creek Generating Station. The enclosed inspection report documents the inspection results, which were discussed on April 12, 2012, with Mr. J. Perry and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
No findings were identified during this inspection.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA Andrey Turilin Acting for/
Arthur L. Burritt, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No: 50-354 License No: NPF-57
Enclosure:
Inspection Report 05000354/2012002 w/Attachment: Supplemental Information
REGION I==
Docket No: 50-354 License No: NPF-57 Report No: 05000354/2012002 Licensee: PSEG Nuclear LLC (PSEG)
Facility: Hope Creek Generating Station Location: P.O. Box 236 Hancocks Bridge, NJ 08038 Dates: January 1, 2012 through March 31, 2012 Inspectors: F. Bower, Senior Resident Inspector J. Krafty, Acting Senior Resident Inspector - Salem A. Patel, Resident Inspector J. Schoppy, Senior Reactor Inspector S. Pindale, Senior Reactor Inspector R. Nimitz, Senior Health Physicist R. Montgomery, Project Engineer Approved By: Arthur L. Burritt, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000354/2012002; 01/01/2012 - 03/31/2012; Hope Creek Generating Station; Routine
Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
No findings were identified.
REPORT DETAILS
Summary of Plant Status
The Hope Creek Generating Station began the inspection period at or near full rated thermal power (RTP) where it generally remained until the end of the inspection period with the following exceptions:
- On January 26, 2012, operators reduced power to approximately 82 percent RTP to support chemistry sampling and fuel defect testing and the unit was returned to full power later the same day.
- On January 28, 2012, operators reduced power to approximately 60 percent RTP to support fuel defect power suppression testing. On January 30, 2012, following the completion of testing the unit was returned to full power.
- On January 30, 2012, the unit was returned to full power where it generally remained except for brief periods to support planned testing and rod pattern adjustments.
- On March 1, 2012, the plant entered end of cycle coast down and power was reduced to 88 percent to remove the 6C feedwater (FW) heater from service to support a return to full rated thermal power. During the power ascension that followed the removal of the 6C FW heater from service, an unplanned downpower occurred when the B reactor recirculation pump (RRP) tripped from approximately 92.5 percent RTP. The plant was stabilized at approximately 55 percent in single loop operation and the 6C FW heater was returned to service. On March 3, power was further reduced to 33 percent to support a restart of the B RRP for troubleshooting. On March 4, power was reduced to approximately 9 percent to support entry into the drywell for maintenance on the B RRP.
On March 5, the B RRP was returned to service, power ascension was begun, and full RTP was reached on March 8, 2012.
- Between March 12, 2012, and March 24, 2012, Hope Creek reduced power as necessary to remove the 4C, 5C, 6B and 6C FW heaters from service in support of end-of-cycle coastdown. In each instance, the plant was returned to full RTP later the same day. At the end of the inspection period, Hope Creek was at 98 percent RTP in end-of-cycle coastdown.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed PSEGs preparation activities for river grass intrusion conditions that may impact Hope Creeks service water system between March 12 and 26, 2012. The inspectors assessed implementation of PSEGs grassing readiness plan through service water system reviews, corrective action program (CAP) reviews, and discussions with cognizant plant personnel. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
- B residual heat removal (RHR) system while A RHR system was out-of-service on January 4, 2012
- A and B emergency diesel generators (EDGs), switchgear, and 1E Logic Panels while D filtration, recirculation and ventilation system fan was out-of-service on January 26, 2012
- B control room emergency filtration system while A control room emergency filtration system was out-of-service on February 8, 2012 The inspectors selected these systems based on their risk-significance for the current plant configuration or following realignment. The inspectors reviewed applicable procedures, system diagrams, the updated final safety analysis report (UFSAR),technical specifications (TSs), work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On January 9 and 10, 2012, the inspectors performed a complete system walkdown of accessible portions of the B and D core spray (CS) systems to verify the equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment lineup procedures, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether PSEG staff had properly identified equipment issues and entered them into the CAP for resolution with the appropriate significance characterization. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure PSEG appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that PSEG controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
- FRH-II-512, Battery Rooms
- FRH-II-563, Control Area HVAC Equipment Rooms
- FRH-II-533, Electrical Access Area
- FRH-II-542, Control Equipment Mezzanine
- FRH-II-551, Battery Rooms and Cable Chases
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation
a. Inspection Scope
The inspectors observed an unannounced fire brigade drill scenario conducted on February 22, 2012, that involved a fire in the turbine lube oil tank room (1314). The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that PSEG personnel identified deficiencies; openly discussed them in a self-critical manner at the post-drill debrief; and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:
- Proper wearing of turnout gear and self-contained breathing apparatus
- Proper use and layout of fire hoses
- Employment of appropriate fire-fighting techniques
- Sufficient fire-fighting equipment brought to the scene
- Effectiveness of command and control
- Search for victims and propagation of the fire into other plant areas
- Smoke removal operations
- Utilization of pre-planned strategies
- Adherence to the pre-planned drill scenario
- Drill objectives met The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with PSEGs fire-fighting strategies.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, the site internal flooding analysis, and plant procedures to verify that the PSEGs flooding mitigation plans and equipment are consistent with the design requirements and the risk analysis assumptions. The inspectors also reviewed the CAP to determine if PSEG identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on: the C CS pump room (4116); the C RHR pump room (4114); the high pressure coolant injection (HPCI) pump room (4111); and the reactor core isolation cooling (RCIC) pump room (4110) areas to verify the adequacy of penetration seals located below the flood line, watertight door seals, floor drain line check valves, and room level alarms.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Requalification Activities Review by Resident Staff
a. Inspection Scope
The inspectors observed licensed operator simulator training on February 21, 2012, which included a loss of the main turbine electronic hydraulic control system that was followed by an electrical fire and an anticipated transient without a scram. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by licensed operations personnel. Additionally, the inspectors assessed the ability of the operations personnel and the training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed reactivity manipulations associated with fuel defect power suppression testing on January 28, 2012. On March 1, 2012, the inspectors observed control room activities during the initial phase of End-of-Cycle FW temperature reduction plan. The inspectors observed the planned power reduction to 88 percent, the removal from service of the 6C FW heater, and portions of the subsequent power ascension.
During these control room observations, the inspectors assessed the adequacy of:
procedure use, crew communications, human performance tool use, supervisory oversight, and coordination of activities between work groups to verify that PSEGs established expectations and standards were met.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed CAP documents (notifications), maintenance work orders (orders), and maintenance rule basis documents to ensure that PSEG was identifying and properly evaluating performance problems within the scope of the maintenance rule. As applicable, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by PSEG staff was reasonable; for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2); and the inspectors independently verified that appropriate work practices were followed for the SSCs reviewed. Additionally, the inspectors ensured that PSEG staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
- B EDG lube oil strainer high differential pressure (Notification 20546788)
- A safety auxiliary cooling system (SACS) (Notification 20545124)
- Functional failure of the rod position indication system (RPIS) (Notification 20544170)
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that PSEG performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance. As applicable for each activity, the inspectors verified that PSEG personnel performed risk assessments as required by 10 CFR 60.65(a)(4) and applicable station procedures, and that the assessments were accurate and complete. When PSEG performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.
The inspectors reviewed the scope of maintenance work to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
- A RHR and 10K107 service air compressor out-of-service for preventive maintenance on January 1 - 7, 2012 (Orders 50092134 and 60097371)
- A CS loop out-of-service for preventive maintenance on January 9 - 11, 2012 (Orders 50132287 and 60086989)
- Emergent inoperability of the HPCI system January 11 - 23, 2012 (Order 60100684)
- Emergent inoperability of the control RPIS January 25 - 26, 2012 (Notification 20544170)
- A RHR and A SACS out-of-service for preventive maintenance on February 1, 2012
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
- A standby liquid control (SLC) pump non-conforming condition due to insufficient thread engagement on SLC pump discharge relief valve outlet flange (Order 80105757)
- Step change in offgas Xenon ratio (Notification 20543906)
- Increase in water content in HPCI lube oil system (Order 60100187)
- Degraded RCIC jockey pump due to flow blockage (Order 80101359)
- Reactor building exhaust fan trip and loss of secondary containment (Notification 20544775)
The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and UFSAR to PSEGs evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by PSEG. The inspectors determined, where appropriate, compliance with assumptions in the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors completed a review of one temporary plant modification package for the RRP differential overcurrent protection (TCCP No. 4HT-12-004) to determine whether the modifications affected the safety functions of systems that are important to safety.
The temporary configuration change package (TCCP) defeats the differential overcurrent trip for the B recirculation motor/generator set power to the B recirculation pump motor by jumpering the A, B, and C phase current transformers. The TCCP also removed the differential overcurrent trip relay from the multi-trip circuit. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
- A CS pump after pump suction relief valve replacement on January 1, 2012 (Order 50056020)
- C SACS pump after motor replacement on January 12, 2012 (Order 30163690)
- RPIS after data receiver card replacement on January 25 - 30, 2012 (Order 60101039-0020)
- B EDG recirculation fan after F-V-412 fan flow switch replacement on February 17, 2012 (Order 60093646)
- RCIC jockey pump after discharge piping replacement on March 31, 2012 (Order 60101431)
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and PSEG procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
- HC.OP-ST.KJ-0001, A EDG inservice test on January 3, 2012
- HC.OP-IS.BC-0004, D RHR Pump (DP202) inservice test on January 24, 2012
- HC.OP-DL.ZZ-0026, Drywell floor drain leakage monitoring during February 6 -
9, 2012
- HC.OP-ST.KJ-0014, A EDG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance test on February 1, 2012
- HC.OP-IS.BJ-0001, HPCI surveillance test on March 9, 2012
- HC.IC-FT.SE-0032, Nuclear Instrumentation System, Divisions 1 & 3 - Channel E Average Power Range Monitor, Single Loop Operations from March 2 - March 27, 2012
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors evaluated PSEGs conduct of a focused area routine emergency drill on February 23, 2012, to identify any weaknesses and deficiencies in the classification and notification activities. The inspectors observed emergency response operations in the Hope Creek technical support center to determine whether the event classification and notification were performed in accordance with procedures. The inspectors also attended the facility post-drill critique to compare inspector observations with those identified by Hope Creek emergency response organization personnel in order to evaluate the adequacy of PSEGs critique and to verify whether PSEG staff were properly identifying weaknesses and entering them into the CAP.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstone: Radiation Safety - Public and Occupational
2RS1 Access Control to Radiologically Significant Areas
a. Inspection Scope
The inspectors reviewed selected activities, and associated documentation, in the areas listed below. The evaluation of PSEGs performance was against criteria contained in 10 CFR Part 20, applicable TSs, and applicable station procedures.
Inspection Planning
The inspectors reviewed performance indicators (PIs) for the Occupational Exposure cornerstone. The inspectors also reviewed the results of recent radiation protection program audits and assessments and any reports of operational occurrences, related to occupational radiation safety since the last inspection.
Radiological Hazard Assessment The inspectors reviewed plant operations to identify any significant new radiological hazards for onsite workers or members of the public. The inspectors assessed the potential impact of the changes and monitoring, as appropriate, to detect and quantify the radiological hazards.
The inspectors toured and conducted walk-downs of radiological controlled areas (RCA)and reviewed radiological surveys from selected plant areas (e.g., refueling floor, reactor buildings, radioactive processing building, and turbine building), to verify that the thoroughness and frequency of the surveys were appropriate for the given radiological hazard. The inspectors also evaluated material conditions and potential radiological conditions. The inspectors made independent radiation measurements to verify radiological conditions.
The inspectors evaluated the radiological survey program to determine if it included:
identification of discrete particles, the presence of alpha emitters, the potential for airborne radioactive materials, potential changes in radiological conditions, and non-uniform exposures of the body.
The inspectors selectively reviewed and discussed air sample survey records associated with various work activities to verify that samples were representative of breathing zone and collected and counted in accordance with procedures.
Instructions to Workers The inspectors toured the RCAs and reviewed labeling of containers of radioactive materials to verify labeling was consistent with requirements and was informative to workers.
The inspectors reviewed various documents including radiation work permits (RWP), as low as is reasonably achievable (ALARA) reviews, and radiological surveys used to access high radiation areas (HRAs) to identify work control instructions or control barriers specified, use of stay times or permissible dose, and appropriate electronic personal dosimeter alarm set-points.
Contamination and Radioactive Material Control The inspectors observed locations where PSEG monitors potentially contaminated material leaving the RCA, and inspected the methods used for control, survey, and release from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use to verify that it was performed in accordance with plant procedures and the procedures were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site. The inspectors selectively evaluated the radiation monitoring instrumentation sensitivity for the types of radiation present.
The inspectors reviewed PSEGs criteria for the survey and release of potentially contaminated material. The inspectors verified that there was guidance on how to respond to an alarm that indicated the presence of radioactive material.
The inspectors reviewed PSEGs procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters including application of alarm set-points based on the instruments typical sensitivity. The inspectors also discussed alarm set-points and typical detection capabilities with cognizant PSEG personnel.
The inspectors selected risk significant sources from PSEGs inventory records to verify sources were accounted for. The inspectors verified transactions involving nationally tracked sources and reporting.
Radiological Hazards Control and Work Coverage The inspectors toured the facility and reviewed ongoing work and evaluated ambient radiological conditions (e.g., radiation levels or potential radiation levels). The inspectors verified the existing conditions were consistent with posted surveys, RWPs, and worker briefings.
The inspectors conducted selective inspection of posting and physical controls for HRAs and very high radiation areas (VHRAs), to verify conformance with the Occupational PI.
The inspectors evaluated down-posting of areas from HRAs.
Risk-Significant HRA and VHRA Controls The inspectors selectively discussed with the Radiation Protection Manager, supervisors, and technicians the controls and procedures for high-risk HRAs and VHRAs and procedural changes since the last inspection. The inspectors discussed methods employed by PSEG to provide control of VHRA access including potential reduction in the effectiveness and level of worker protection (e.g., use of lock boxes).
The inspectors discussed with health physics supervisors, controls for special areas that had the potential to become VHRAs during certain plant operations including controls to ensure that an individual was not able to gain unauthorized access to the VHRA.
Radiation Worker Performance The inspectors toured radiological controlled areas and observed radiation worker performance with respect to stated radiation protection work requirements to determine if performance reflected the level of radiological hazards present.
The inspectors selectively reviewed radiological problem reports since the last inspection to identify human performance errors and determine if there were any observable patterns. The inspectors discussed corrective actions for identified concerns with PSEG personnel.
Problem Identification and Resolution The inspectors verified that problems associated with radiation monitoring and exposure control were being identified by PSEG at an appropriate threshold and were properly addressed for resolution in their CAP. The inspectors discussed corrective actions for identified concerns.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
Inspection Planning
The inspectors reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current exposure performance and exposure challenges. The inspectors determined the plants 3-year rolling average collective exposure.
The inspectors evaluated and determined the site-specific trends in collective exposures using various methods such as plant historical data, including outage work activity dose, evaluation of ALARA data, and source term data.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA including the processes used to estimate and track exposures from specific work activities.
Radiological Work Planning The inspectors obtained from PSEG a list of work activities ranked by actual or estimated exposure that were planned for the next outage and selected work activities of the highest exposure significance. These included reactor disassembly, reactor cavity decontamination, suppression pool work, scaffolding, in-service inspection, control rod drive work, and valve work.
The inspectors reviewed ALARA work activity plans and evaluations, exposure estimates, and exposure mitigation requirements. The inspectors determined if PSEG reasonably grouped the radiological work into work activities, based on historical precedence, industry norms, and/or special circumstances.
The inspectors verified that PSEGs planning identified appropriate dose mitigation features; considered, commensurate with the risk of the work activity, alternate mitigation features; and defined reasonable dose goals. As applicable, the inspectors verified that the ALARA assessments had taken into account decreased worker efficiency from use of respiratory protective devices.
The inspectors determined if work planning considered the use of remote technologies (such as teledosimetry, remote visual monitoring, and robotics) as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors verified the integration of ALARA requirements into work procedure and RWP documents.
Verification of Dose Estimates and Exposure Tracking Systems The inspectors selected various ALARA work packages and reviewed the assumptions and bases for the collective exposure estimate for reasonable accuracy. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures for specific work activities and the intended dose outcome. The inspectors also reviewed approvals by the station ALARA committee as applicable.
Source Term Reduction and Control The inspectors used PSEG records to determine the historical trends and current status of significant tracked plant source term known to contribute to elevated facility aggregate exposure. The inspectors discussed the outage Chemistry Plan and long term plans for source term reduction (e.g., Cobalt reduction). The inspectors discussed contingency plans for potential changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry. The inspectors discussed source term reduction efforts including system flushing and use of additional demineralization and filtration systems.
Problem Identification and Resolution The inspectors verified that problems associated with ALARA planning and controls were being identified by PSEG at an appropriate threshold and were properly addressed for resolution in their CAP. The inspectors discussed corrective actions for identified ALARA concerns with the health physics staff.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
Inspection Planning
The inspectors selectively reviewed the plant UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. The inspectors also reviewed the UFSAR for overview of the respiratory protection program and a description of the types of devices used.
The inspectors reviewed procedures for maintenance, inspection, and use of respiratory protection equipment including procedures for air quality maintenance and breathing air quality sampling.
The inspectors reviewed the reported PIs to identify any related to unintended dose resulting from personnel intakes of radioactive materials.
Engineering Controls The inspectors evaluated the use of selected ventilation systems to control airborne radioactivity. The inspectors discussed procedural guidance for use of installed plant systems to verify system use during high-risk activities. The inspectors discussed verification of plant ventilation systems during reactor cavity work.
The inspectors evaluated PSEGs use of decision criteria for evaluating levels of hard-to detect airborne radionuclides.
Use of Respiratory Protection Devices The inspectors selected three individuals qualified to use respiratory protection devices, and verified that they were qualified (by training and medical certification) to use the devices.
Self-Contained Breathing Apparatus for Emergency Use The inspectors selected three individuals on control room shift crews to determine if control room operators were trained and qualified in the use of self-contained breathing apparatus. The inspectors verified that appropriate mask sizes and types were available for use in the control room.
The inspectors entered the control room and selected on-shift operators to verify that they had no facial hair that would interfere with the sealing of the mask to the face and that required vision correction devices were available that did not penetrate mask sealing surface.
Problem Identification and Resolution The inspectors reviewed and discussed problems associated with the control and mitigation of in-plant airborne radioactivity to evaluate PSEGs identification and resolution in their CAP.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
Inspection Planning
The inspectors reviewed available radiation protection program audits related to internal and external dosimetry or corrective action documents to gain insights into overall PSEG performance in the area of dose assessment.
The inspectors reviewed the most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report for PSEGs dosimetry.
The inspectors reviewed PSEG procedures associated with dosimetry operations, including issuance/use of external dosimetry (routine, multi-badging, extremity, neutron, etc.), assessment of internal dose (operation of whole body counter, assignment of dose based on derived air concentration hours, urinalysis, etc.), and evaluation of and dose assessment for radiological incidents. The inspectors evaluated implementation of dose determination by use of effective dose equivalent for external exposure (EDEX). The inspectors evaluated procedure guidance for personnel monitoring.
External Dosimetry The inspectors evaluated the use of personnel dosimeters that require processing, to verify NVLAP accreditation. The inspectors determined if PSEG uses a correction factor to address the response of the electronic dosimeter (ED) as compared to its NVLAP accredited dosimeter for situations when the ED must be used to assign dose.
Internal Dosimetry The inspectors selectively evaluated the routine whole body counting program, including use of passive monitoring provided for detection and measurement of intakes of radioactive materials.
The inspectors evaluated the minimum detectable activity (MDA) of PSEGs instrumentation used for passive whole body counting to determine if the MDA was adequate to determine the potential for internally deposited radionuclides sufficient to prompt additional investigation.
Special Dosimetric Situations The inspectors reviewed PSEGs program to inform workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for declaring a pregnancy.
The inspectors reviewed PSEGs methodology for monitoring external dose in situations in which non-uniform fields are expected or large dose gradients could exist (e.g., diving activities) to verify that PSEG established criteria for determining when alternate monitoring techniques (i.e., use of multi-badging or determination of effective dose EDEX using an approved method) were to be implemented. The inspectors selectively reviewed use of multi-badging (e.g., diving).
Problem Identification and Resolution The inspectors selectively reviewed corrective action documents to verify that problems associated with occupational dose assessment were being identified by PSEG at an appropriate threshold and were properly addressed for resolution in their CAP.
b. Findings
No findings were identified.
2RS5 Radiation Monitoring Instrumentation
a. Inspection Scope
Inspection Planning
The inspectors reviewed the plant UFSAR to identify radiation instruments associated with monitoring area radiological conditions including airborne radioactivity, process streams, effluents, materials/articles, and workers.
The inspectors obtained a list of in-service survey instrumentation including air samplers and small article monitors (SAMs), along with instruments used for detecting and analyzing workers external contamination (personnel contamination monitors (PCM)) and workers internal contamination (portal monitors, whole body counters, etc.), including neutron monitoring instrumentation to determine whether an adequate number and type of instruments are available to support operations.
The inspectors selectively reviewed procedures that govern instrument source checks and calibrations. The inspectors review the calibration and source check procedures for adequacy.
Walkdowns and Observations The inspectors selected various portable radiological survey instruments in use and checked calibration and source check stickers for currency, and to assess instrument material condition and operability.
The inspectors walked down portable area radiation monitors and continuous air monitors to determine whether they were appropriately positioned relative to the radiation source(s) or area(s) they were intended to monitor. The inspectors compared monitor response (via local or remote indication) with actual area conditions for consistency.
The inspectors selected portal monitors, PCMs, and SAMs and verified that the periodic source checks were performed in accordance with PSEG procedures.
Calibration and Testing Program The inspectors reviewed alarm set-point data for various personnel and equipment monitors at the radiological controlled area exit to verify that the alarm set-point values were reasonable under the circumstances to ensure that licensed material was not released from the site.
Calibration and Check Sources The inspectors discussed PSEGs 10 CFR Part 61 waste stream report to determine if the calibration sources used were representative of the types and energies of radiation encountered in the plant.
Problem Identification and Resolution The inspectors selectively reviewed corrective action documents associated with radiation monitoring instrumentation to determine if PSEG identified issues at an appropriate threshold and placed the issues in their CAP for resolution. In addition, the inspectors evaluated the appropriateness of the corrective actions for a selected sample of problems documented by PSEG that involve radiation monitoring instrumentation.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
.1 Initiating Events Performance Index (3 samples)
a. Inspection Scope
The inspectors reviewed PSEG submittal of the following Hope Creek initiating events PI results for the period of January 1, 2011 through December 31, 2011:
- Unplanned (automatic and manual) scrams per 7,000 critical hours
- Unplanned Power Changes per 7,000 critical hours
- Unplanned Scrams with Complications To determine the accuracy of the PI data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed Hope Creeks monthly operating reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Safety System Functional Failures (1 sample)
a. Inspection Scope
The inspectors sampled PSEGs submittals for the Safety System Functional Failures PI for Hope Creek for the period from July 1, 2011, through December 31, 2011. To determine the accuracy of the PI data reported during those periods, inspectors used definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed PSEGs licensee event reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that PSEG entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the CAP and periodically attended management review committee meetings.
b. Findings
No findings were identified.
.2 Annual Sample: Feedwater Temperature Reduction
a. Inspection Scope
On September 14, 2011, the NRC issued Amendment No. 190 to the Hope Creek Generating Station (HCGS) Renewed Facility Operating License (FOL) to allow HCGS to operate at a reduced FW temperature for purposes of extending the normal fuel cycle.
The amendment also allows operation with FW heaters out-of-service at any time during the operating cycle. In addition, the amendment revised TS surveillance requirements related to testing of the oscillation power range monitors (OPRMs). PSEG developed design change package (DCP) 80100455 to evaluate and implement this modification.
PSEG used their CAP to control and track the various evaluations, procedure changes, operator training activities, and corrective action notifications for identified potential problems associated with this DCP. On March 1, 2012, PSEG implemented the first phase of their planned FW temperature reduction to extend current cycle operation at rated RTP to delay the onset of the power coastdown period prior to the April 2012 refueling outage.
The inspectors reviewed PSEGs associated apparent cause evaluations (ACEs),simulator scenarios, independent assessments, implementation plans, and short- and long-term corrective actions. The inspectors also reviewed a sample of operator narrative logs, completed OPRM surveillance tests, operating and abnormal procedures, operator training material, industry operating experience, and maintenance work orders to assess the adequacy of PSEGs corrective actions to ensure alignment with the HCGS FOL and TSs. The inspectors performed several walkdowns of the associated control room FW, OPRM, 3D Monicore, and Safety Parameter Display System instrumentation to independently assess PSEGs design control, TS and FOL compliance, the material condition, procedure adequacy, potential operator challenges, and configuration control. The inspectors also discussed the DCP and OPRM performance with reactor engineers, reactor operators, and senior reactor operators to assess their awareness and knowledge level, to assess the DCP training effectiveness, and to obtain plant performance and trend data. The inspectors reviewed a sample of DCP and OPRM related issues that PSEG entered into the CAP to verify PSEGs threshold for identifying issues and to evaluate the effectiveness of corrective actions.
In addition, the inspectors reviewed corrective action notifications written on issues identified during the inspection to verify adequate problem identification and incorporation of the problem into the CAP.
b. Findings and Observations
No findings were identified.
The inspectors concluded that PSEG had taken timely and appropriate action in accordance with TS requirements, the HCGS FOL, surveillance and operating procedures, and PSEGs CAP. The inspectors determined that PSEGs associated technical evaluations and independent reviews were sufficiently thorough and based on appropriate analyses, sound engineering judgment, and relevant operating experience.
PSEGs assigned corrective actions, which included various procedure revisions and operator training, were aligned with the identified causal factors, adequately tracked, appropriately documented, and completed as scheduled. Based on the documents reviewed, control room walkdowns, and operator interviews, the inspectors noted that PSEG personnel identified problems and entered them into the CAP at an appropriate threshold.
.3 Annual Sample: Inadequate Corrective Actions Associated with a Known Degraded
Condition/Preventive Maintenance Evaluation Backlog
a. Inspection Scope
The inspectors performed an in-depth review of PSEGs cause analysis and corrective actions associated with a May 12, 2011, failure of a service air compressor check valve after several completed preventive maintenance (PM) tasks had identified corrosion and rust on the valve internals. PSEG had not changed the PM frequency of the degraded check valve or evaluated the use of materials less susceptible to corrosion. Specifically, about a year prior to the failure, a PM change request had been submitted to evaluate changing the PM frequency, however, the request was not evaluated and had been maintained in a relatively large change request backlog.
The inspectors assessed PSEGs extent of condition review and the prioritization and timeliness of corrective actions to determine whether they were appropriately identifying, characterizing, and correcting problems associated with the May 12, 2011, incident when the check valve failure resulted in a service and instrument air system transient.
In addition, the inspectors interviewed station personnel and reviewed selected PM evaluations that were completed in order to reduce the backlog to assess the effectiveness of PSEGs corrective actions. The inspectors reviewed relevant procedures, corrective action notifications, and PM backlog related documents to verify PSEG reduced the PM change request backlog to a manageable level.
b. Findings and Observations
No findings were identified.
The inspectors determined that PSEGs overall response to the issue was commensurate with the safety significance, was timely, and included appropriate corrective actions such as evaluating items in the backlog to develop or modify PM activities as appropriate. Additionally, the inspectors determined that the actions taken were reasonable to resolve the issue and that PSEG had appropriately prioritized the backlog reduction effort. Further, the inspectors determined, based upon review of a selected sample of completed PM evaluations, PSEG appropriately performed various PM frequency analyses and made appropriate changes as indicated in the associated evaluations.
.4 Annual Sample: Review of the Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of the existing operator workarounds, operator challenges, operator burdens, disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in PSEG procedures OP-AA-102-103, Operator Work-Around Program, and OP-AA-102-103-1001, Operator Burdens Program.
The inspectors reviewed Hope Creeks process to identify, prioritize, and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and observed the Hope Creek plant operations review committees safety review of the fourth quarter 2011 cumulative impact assessment of operator burdens. The inspectors also toured the control room to review current operator burdens and ensure the items were being addressed on a schedule consistent with their relative safety significance.
b. Findings and Observations
No findings were identified.
The inspectors observed that Hope Creek had not identified any current operator workarounds providing an obstacle to safe plant operations and there were two operator challenges providing an obstacle to normal plant operations. These operator challenges and identified operator burdens were entered into the corrective action program for correction at an appropriate threshold. Additionally, the inspectors noted that the aggregate impacts of operator burdens are assessed quarterly in accordance with OP-AA-102-103-1001 for impact on: personnel safety, plant trips and transients, operator procedure performance, radiological concerns, reactivity events, and environmental concerns.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel and compared the event details with criteria contained in Inspection Manual Chapter 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified PSEG made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed PSEGs follow-up actions related to the events to assure that PSEG implemented appropriate corrective actions commensurate with their safety significance.
- HPCI system declared inoperable on January 11, 2012, and was retracted on January 13, 2012 (Event # 47585)
- HPCI system declared inoperable on March 14, 2012 (Event # 47745)
- An unplanned power reduction to approximately 55 percent RTP on March 1, 2012, due to a differential over-current trip of the B RRP (Notification 20549229)
b. Findings
No findings were identified.
4OA6 Meetings, including Exit
On April 12, 2012, the inspectors presented inspection results to Mr. J. Perry and other members of his staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
PSEG Personnel
- J. Perry, Hope Creek Site Vice President
- D. Lewis, Hope Creek Plant Manager
- E. Carr, Operations Director
- K. Knaide, Work Management Director
- W. Kopchick, Engineering Director
- F. Mooney, Maintenance Director
- P. Duca, Senior Engineer, Regulatory Assurance
- M. Gaffney, Regulatory Assurance Manager
- H. Trimble, Radiation Protection Manager
- D. Boyle, Operations Support Manager
- J. Krall, Reactor Engineering Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
NONE