I guess my information was wrong. Now a non dependable source. Had to run it to ground to the best of my ability. You lose credibility during a operation like this.
R1ALLEGATION RESOURCE R1ALLEGATION.RESOURCE@nrc.gov
Update June 11
Maybe Allegations wasn't keeping the inspections in the LOOP. Maybe the inspectors answered me off the cuff without thinking. They assumed the Site had a part 21 procedure, but never checked.
Update June 7
I don't know why I didn't do this first. The Hope Creek NRC's admin assistant relayed from the inspectors saying they "do" have a part 21 procedure. But they are too busy to talk to me.
Maybe it is a new procedure?
Update: The Allegation official was the team leader in the below chiller inspection. The licensee had a horrendous repeated problem with trying to solve this part 21 issue and failed to report this to the NRC. It would be a NRC automatic reflex response to check out the part 21 procedure or any other similar botched issue in the plant. I accused the team leader, now a Allegation official...they should have picked up the missing procedure, they didn't do their job. It looks to me like you were protecting PSEG by not violating them on the missing part 21 procedure. This is preliminary information. This is the strange NRC's response. I expected them to either say Hope Creek has a part 21 procedure or not. Bet you the lawyers were involved?
"I led the biennial Problem Identification and Resolution team inspection in my role as a qualified reactor inspector. It was not related to my current position in the Allegation/Enforcement team.
Happy to talk more about the Part 21 observation documented in my inspection report. Note that it is 2.5 years old, and I am not aware of the current status of any Part 21 procedures."
Does this blurt from the inspection report indicate the missing Part 21 procedure...the missing and late reportability issue?
Regarding Part 21. PSEG has no part 21 procedure.Temperature Switch Potential Part 21 Issue Notification (NOTF) 20626121 documented an October 2013 trip of the ‘A’ main control room chiller. PSEG performed an apparent cause evaluation (ACE) and determined that the trip was due to the bearing oil temperature switch momentarily pegging high. The ACE cited electromagnetic interference (EMI) as the most likely cause, and the switch was sent to a vendor for failure analysis. In an August 2014 report, the vendor confirmed EMI as a likely cause of the switch failure. The ACE included an action item (ACIT) to evaluate the switch for Part 21 reportability, if EMI was found to be the cause and was determined to be within the switch specifications. This ACIT was initially due in January 2015, but, at an MRC meeting attended by the inspection team in late January 2015, the due date was extended to June 2015. The inspectors noted that, if the issue were ultimately determined to warrant reporting under 10 CFR Part 21, the station would have 60 days from the time of discovery to submit the required Part 21 report.The inspectors determined that Hope Creek has not taken timely action to determine whether the temperature switch EMI issue is reportable under the Part 21 process. As of the time of the inspection, it had been 16 months since the switch initially failed, and six months since the failure analysis report was received, and the station had not yet determined if the switch had operated within its design, or if the failure constituted a deviation or non-conformance subject to the Part 21 process. The inspectors determined the performance deficiency was minor, because the issue is most likely not required to be reported under 10 CFR 21. Specifically, the inspectors noted that the vendor’s failure analysis determined the switch was only subject to EMI at levels below those typically present in the nuclear power plant environment, and below the levels that NRC requires electrical components to be designed and tested to NRC Regulatory Guide 1.180, “Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems.”
A NRC Allegations employee recently led the NRC team who inspected Hope Creek surrounding a Part 21 issues. They had other part 21 issues.
Why didn't the employees force PSEG to write the procedure. This indicates safety culture problems and intimidations...
General Provisions
§ 21.1 Purpose.
The regulations in this part establish procedures and requirements for implementation of section 206 of the Energy Reorganization Act of 1974. That section requires any individual director or responsible officer of a firm constructing, owning, operating or supplying the components of any facility or activity which is licensed or otherwise regulated pursuant to the Atomic Energy Act of 1954, as amended, or the Energy Reorganization Act of 1974, who obtains information reasonably indicating: (a) That the facility, activity or basic component supplied to such facility or activity fails to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order, or license of the Commission relating to substantial safety hazards or (b) that the facility, activity, or basic component supplied to such facility or activity contains defects, which could create a substantial safety hazard, to immediately notify the Commission of such failure to comply or such defect, unless he has actual knowledge that the Commission has been adequately informed of such defect or failure to comply.
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