May 9, 2018 theres
SUBJECT: HOPE CREEK GENERATING STATION UNIT 1 – INTEGRATED INSPECTION REPORT 05000354/2018001
Implementing Procedures for Beyond Design Basis FLEX Mitigating Strategies Not Followed Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green FIN 05000354/2018001-01 Closed H.5 – Human Performance – WorkEach violation should be treated separately. Then fine or worst the hell out of them for each violation. Honestly, in this bundle all violations into one generic single violation system, you have no idea how many violation are in the industry. It is just not disciplining away from a chaotic and erratic site. It sends no messages to the other plants to keep these plants orderly.
The big inexpensive and flaw in the system the flex system should have been included into a licensing bases system.
These components are
Management 71152 A Green finding (FIN) was identified by the inspectors for multiple examples of PSEG not following the station specific procedures that implement the Salem and HCGS Final Integrated Plans for Beyond Design Basis FLEX Mitigating Strategies, EM-SA-100-1000 and EM-HC-100-1000, respectively. Specifically, since compliance with the FLEX order was met on November 10, 2016, PSEG did not follow the common PSEG fleet PM Process and diesel fuel oil testing program procedures, MA-AA-716-210, CY-AB-140-410, and SC.OP-LB.DF-0001 for the annual fuel oil sampling of FLEX equipment. In addition to this, between December 6, 2017, and March 8, 2018, PSEG did not follow site specific procedures for FLEX equipment unavailability and mitigation capability protection in accordance with these procedures, OP-HC-108-115-1001 and OP-SA-108-115-1001, Operability Assessment and Equipment Control Program. Description: PSEG is committed to comply with NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, and NRC Order on Mitigation Strategies, EA-12-049.
FLEX Equipment Preventive Maintenance
Section 11.5.2 of NEI 12-06 states, in part, that portable equipment that directly performs a FLEX mitigation strategy for the core, containment, or spent fuel pool (SFP) should be subject to maintenance and testing guidance provided in Institute of Nuclear Power Operations (INPO) AP 913, Equipment Reliability Process, to verify proper function. The maintenance program should ensure that the FLEX equipment reliability is being achieved. Standard industry templates (e.g., EPRI) and associated bases will be developed to define specific maintenance and testing.
In complying with NRC Order EA-12-049, PSEG implemented EM-HC-100-1000 and EM-SA-100-1000. In Sections 2.18.7 of these procedures it states that FLEX mitigation equipment is subject to initial acceptance testing and subsequent periodic maintenance and testing to verify proper function. FLEX diesel generators and pumps are in PSEG’s fleet common PM process, MA-AA-716-210, which defines periodic testing and maintenance and follows the PM template requirements in EPRI’s Preventive Maintenance Basis for FLEX Equipment – Project Overview Report (EPRI Report 3002000623), dated September 2013.
The inspectors reviewed a number of recent equipment and PM issues at PSEG associated with the HCGS, Salem, and fleet common FLEX diesel generators and pumps. During the review, the inspectors found that this equipment is scheduled per PSEG’s PM program and, in accordance with EPRI guidance, should be tested every 6 months and the fuel oil should be sampled every 12 months. Based on the inspector’s requests and questions related to the FLEX fuel oil cloud point and sample results, PSEG found that the initial fuel oil samples for all of the FLEX diesel generators and pumps were either never taken (at Salem) or not analyzed (at HCGS). Because of this, the inspectors determined that since compliance with the FLEX order was met on November 10, 2016, PSEG has not followed the common PSEG fleet PM Process and diesel fuel oil testing program procedures, MA-AA-716-210, CY-AB-140-410, and SC.OP-LB.DF-0001, for the annual fuel oil sampling of FLEX equipment.
FLEX Equipment Unavailability and Protection
Section 11.5.3 of NEI 12-06 states, in part, that the unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for the core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized. The unavailability of installed plant equipment is controlled by existing plant processes such as the technical specifications.
PSEG’s FLEX equipment allowable outage times and required actions for equipment unavailability are maintained in site specific operations procedures OP-HC-108-115-1001 and OP-SA-108-115-1001 in order to meet the requirements in NEI 12-06.
For the three site FLEX diesel pumps (H1FLX-10-P-500 (HCGS)); SCFLX-1FLXE18 (Salem); C1FLX-1FLXE42 (back-up common to Salem and HCGS), a loss of two of three represents a loss of a FLEX mitigation capability. OP-HC-108-115-1001 and OP-SA-108-115-1001 state, in part, that when installed equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability. The required beyond design basis (BDB)/FLEX equipment may be unavailable for 90 days provided that the site BDB/FLEX capability (N) is met. If the site BDB/FLEX capability is met but not protected for all of the sites’ applicable hazards (flood, earthquake, high winds from hurricane or tornado, or local intense precipitation), then the allowed unavailability is reduced to 45 days.
On February 19, 2018, PSEG documented NOTF 20787557 for the FLEX diesel back-up pump common to Salem and HCGS (C1FLX-1FLXE42) failure to start that was not returned to an available condition until March 8. A NOTF (20783115) dated December 6, 2017, 75 days earlier, documented a failure to start with the same common FLEX diesel pump. The inspectors noted that no actions were taken to resolve the December issue other than attempting to start the pump multiple times over 12 days until the pump started on December 18, 2017. At this point, PSEG declared the pump available without performing any corrective maintenance or documenting any basis for the pump being available. The inspectors questioned PSEG about the time period mentioned above and how PSEG’s BDB/FLEX capability was protected during that time for all of the applicable site hazards as all three pumps are located in outside FLEX storage areas at ground level. Because of this, the inspectors determined that PSEG did not follow site specific procedures for FLEX equipment unavailability and mitigation capability protection for this common diesel pump between December 6, 2017, and March 8, 2018 (92 days).
Based on all of the information above, the inspectors determined that there were multiple examples of PSEG not following the station specific procedures for FLEX Mitigating Strategies. Specifically, PSEG did not follow the common PSEG fleet PM Process and diesel fuel oil testing program procedures for the annual fuel oil sampling of FLEX equipment, or site specific procedures for FLEX equipment unavailability so that equipment issues were appropriately tracked and adequately protected to allow it to be unavailable for greater than 90 days when availability should have been limited to less than 45 days.
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Corrective Actions: PSEG’s corrective actions for the above issues included obtaining fuel oil samples from all the Salem, HCGS, and common FLEX equipment onsite and analyzing the samples to ensure the fuel oil quality remained adequate. PSEG also replaced the starting solenoid on the common FLEX diesel pump that failed to start and returned the pump to an available status on March 8, 2018, 92 days after it first became unavailable.
Corrective Action References: 20787557, 20783115, 60138024, 20787861, 20787862, 20787863, 20787879, 20787880, 20787881, 20787882, 20787883, 20787884, 20791977, 20791974, and 80122006. Performance Assessment:
Performance Deficiency: PSEG’s station specific procedures EM-SA-100-1000 and EM-HC-100-1000 implement the Salem and HCGS FLEX Mitigating Strategies, which includes FLEX equipment PM and unavailability. The inspectors determined that since January 2017, there were multiple examples of PSEG not implementing these procedures utilizing existing procedures for the PM process, diesel fuel oil testing or operability assessment and equipment control, and that this represented a performance deficiency.
Screening: The performance deficiency is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors also reviewed IMC 0612, Appendix E, “Examples of Minor Issues,” and found it was sufficiently similar to Example 3.k, in that significant programmatic deficiencies were identified that could have led to worse outcomes.
Significance: Issues identified concerning FLEX are evaluated through a cross-regional panel using IMC 0609, Appendix M, “Significance Determination Process Using Qualitative Criteria,” as informed by Appendix O, “Post Fukushima Mitigation Strategies Significance Determination Process (Orders EA-12-049 and EA-12-051)” (ML16055A351). The finding was determined to be of very low safety significance (Green) because the inspector answered “no” to the five questions in the draft Appendix O. Specifically, this condition was not associated with SFP level instrumentation required by NRC Order EA-12-051 and did not result in a complete loss of function to maintain or restore core cooling, containment pressure control/heat removal and/or SFP cooling capabilities.
Cross-Cutting Aspect: This finding has a cross-cutting aspect in the area of Human Performance, Work Management, because PSEG did not implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority and did not identify and manage the coordination of different Salem, HCGS and PSEG common work groups or job activities. Specifically, PSEG did not execute work activities associated with the FLEX fuel oil sampling or corrective maintenance activities on FLEX equipment that would ensure that equipment’s reliability and availability. (H.5) Enforcement: This finding does not involve enforcement action because no violation of regulatory requirements was identified. Because the finding does not involve a violation of regulatory requirements and has very low safety significance, it is identified as a finding.
Observation 71152 Annual Follow-up of Selected issues Review of Recent FLEX Equipment and Preventive Maintenance Issues
The inspectors noted the following observations during the review:
1. PSEG is inconsistent when conducting CAP screening for NOTFs involving FLEX equipment failures in accordance with procedure LS-AA-120, Issue Identification and Screening Process. NOTFs 20775917 and 20766130 for FLEX diesel generator (H1FLX-10-G-2026) and pump (H1FLX-10-P-500) failures to start were screened as significance level (SL) 4, a non-corrective action program condition (N-CAP), when similar failures to start of a FLEX diesel pump (C1FLX-1FLXE42) in NOTFs 20783115 and 20787557 were screened as SL3, a condition affecting regulatory compliance (CARC). NOTF 20788124 for the spare FLEX diesel generator (SCFLX-1FLXE10) low engine coolant temperature and determined it to be non-functional, but the NOTF was screened as SL4 instead of SL3.
2. PSEG did not have a process or procedure in place to ensure that the fuel oil used for outdoor FLEX equipment has the required fuel additives to ensure proper operation during cold weather operations. PSEG documented the inspector’s concern in NOTF 20786860.
3. PSEG did not quarantine and send out for failure analysis a failed FLEX component, the engine control module from a FLEX diesel generator (H1FLX-10-G-2026), identified in NOTF 20775917. PSEG has initiated NOTFs 20774397 and 20783803 to document delays and a lack of oversight in the failure analysis tracking process. PSEG has created corrective actions under orders 70196257 and 70197907 to revise ER-AA-230-1004, Failure Analysis Tracking and Reporting by April 2018.
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