Basically the maintenence rule is a voluntary bureaucratic system defining the rules of necessary plant maintenence and documentation. It is another process done under the sheets away from public scrutiny.
***Everyone is confused with, throwing worthless documents at a problem over and over again equates to actually fixing the problem. If it is still broke, just throw a powerless document at it.
Again, if we had a real NRC, the agency would bark once about "interfacing system functions". It would scare the pants off Hope Creek. I think this all is fraud and falsification, not documenting maintenence rule functional failures.
Everyone is confused with, throwing worthless documents at a problem over and over again equates to actually fixing the problem...
February 2, 2016
SUBJECT: HOPE CREEK GENERATING STATION UNIT 1 – INTEGRATED INSPECTION REPORT 05000354/2015004
Maintenance Rule Program Implementation
The inspectors have identified multiple examples of PSEG’s failure to evaluate the impact of an equipment issue on interfacing systems, including:
· In September 2013, the inspectors identified that PSEG failed to evaluate the impact of a failure of a feedwater crosstie valve on the feedwater sealing functions for the reactor core isolation cooling system and HPCI system. This observation resulted in the creation of a new feedwater system maintenance rule function and subsequent maintenance preventable functional failure classification that would not have been otherwise counted. (NOTF 20619913)
· In May 2014, the inspectors identified that PSEG failed to evaluate safety relief valve setpoint failures under all applicable interfacing system functions. The condition was evaluated for the automatic depressurization system functions, but not for the main steam functions. (NOTF 20650346)
· In August 2015, the inspectors identified that PSEG failed to evaluate the loss of the 10B431 480VAC (alternating current) 1E motor control center (MCC) as a Maintenance Rule functional failure of the interfacing 1E 480VAC system.
This is the third instance identified in three years of PSEG failing to evaluate the impact of equipment issues on interfacing systems. This observation resulted in the assignment of a maintenance preventable functional failure to the 480VAC 1E MCC system that would not have been otherwise counted. (NOTF 20702217)
Along with the items described above, during 2015, the inspectors and the NRC PI&R team inspectors observed multiple other examples of PSEG’s failure to evaluate the impact of an equipment issue on interfacing systems. These repetitive observations related to deficiencies with PSEG’s interfacing system maintenance rule screening resulted in PSEG creating a maintenance rule panel consisting of the maintenance rule program coordinator and engineers that performs an independent, periodic review of issues identified in the CAP to ensure all appropriate screenings are assigned. The inspectors determined that the corrective action implemented to address the issue was reasonable to resolve the identified deficiencies. The inspectors determined all the issues above screened to minor in accordance with IMC 0612, Appendix E, because the systems’ preventive maintenance still demonstrated effective control of system equipment performance as provided in paragraph (a)(2) of the maintenance rule.
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