IR 05000272/2023004
| ML24036A161 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/05/2024 |
| From: | Brice Bickett Division of Operating Reactors |
| To: | Mcfeaters C Public Service Enterprise Group |
| References | |
| IR 2023004 | |
| Download: ML24036A161 (1) | |
Text
February 5, 2024
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000272/2023004 AND 05000311/2023004
Dear Charles McFeaters:
On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Station, Units 1 and 2. On January 18, 2024, the NRC inspectors discussed the results of this inspection with David Sharbaugh, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Four findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Salem Nuclear Generating Station, Units 1 and 2.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Salem Nuclear Generating Station, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Brice A. Bickett, Chief Projects Branch 3 Division of Operating Reactor Safety
Docket Nos. 05000272 and 05000311 License Nos. DPR-70 and DPR-75
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000272 and 05000311
License Numbers:
Report Numbers:
05000272/2023004 and 05000311/2023004
Enterprise Identifier: I-2023-004-0033
Licensee:
Facility:
Salem Nuclear Generating Station, Units 1 and 2
Location:
Hancocks Bridge, NJ
Inspection Dates:
October 1, 2023 to December 31, 2023
Inspectors:
J. Dolecki, Senior Resident Inspector
E. Garcia, Resident Inspector
R. Clagg, Senior Project Engineer
G. Dipaolo, Senior Resident Inspector
B. Dyke, Operations Engineer
T. Fish, Senior Operations Engineer
R. Rolph, Senior Health Physicist
A. Turilin, Reactor Inspector
S. Veunephachan, Health Physicist
D. Werkheiser, Senior Reactor Analyst
Approved By:
Brice A. Bickett, Chief
Projects Branch 3
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Salem Nuclear Generating Station, Units and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.
Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71111.1
List of Findings and Violations
PSEG IWL Implementing Procedure not Followed Related to Salem Unit 2 Containment Electrical Penetration Room Location Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green FIN 05000272/2023004-01 Open/Closed
[H.7] -
Documentation 71111.08P The inspectors identified a finding of very low safety significance (Green) because PSEG staff did not implement Step 4.7.2 in their procedure OU-AA-335-018 for visual examinations of containment surfaces. Specifically, PSEG did not record indications as directed by the criteria in their procedure to support their conclusions regarding absence of distress or deterioration.
Failure to Promptly Identify and Correct Condition Adverse to Quality (CAQ) Results in Multiple Chiller Trips Due to Invalid Low Compressor Oil Level Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000272/2023004-02 Open/Closed
[H.13] -
Consistent Process 71111.12 Inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, because PSEG did not promptly identify and correct CAQs associated with the safety-related 13 Chiller. Specifically, troubleshooting and maintenance efforts regarding the 13 Chiller trips on September 27 and October 8, 2023, were not consistent with station procedures to promptly identify and correct prior to restoring the 13 Chiller to service. As a result, the 13 Chiller had repeat failures to perform its safety-related function when it tripped on October 8 and November 20, 2023, due to invalid low compressor oil level.
Failure to Implement Written Instruction for Sequence of Tagging Activities Affecting Reactor Coolant System (RCS) Vent Paths Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000272/2023004-03 Open/Closed
[H.5] - Work Management 71111.13 A self-revealed, Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 6.8.1.a, Procedures and Programs, was identified when PSEG failed to adequately implement documented instructions for tagging activities. Specifically, PSEG did not implement work instructions for the sequence of tagging activities associated with RCS vent paths to ensure TSs were not affected. As a result, one of the pressurizer power operated relief valves (PORV), 1PR1, was taken out of service prior to establishing another vent path resulting in only one remaining RCS vent path available to mitigate a potential pressure transient.
Failure to Implement and Maintain All Provisions of the Approved Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000272,05000311/2023004-04 Open/Closed
[H.2] - Field Presence 71152A The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Salem Nuclear Generating Station, Units 1 and 2, License Condition 2.C.5 and 2.C.10, "Fire Protection," for failing to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to identify a transient combustible was stored in a safety-related area and a transient combustible permit (TCP) was needed. As a result, from October 13 to October 19, 2023, a plastic bottle containing diesel fuel oil was stored inside the safety-related 12 diesel fuel oil transfer pump (DFOTP) room, unattended, and without an associated TCP.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at approximately 83 percent power in coastdown in preparation for the planned refueling outage 29 (S1R29). Unit 1 shutdown and entered S1R29 on October 7, 2023. On November 11, 2023, operators commenced reactor startup and the unit returned to rated thermal power on November 14, 2023. Unit 1 operated at or near rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures (work order (WO) 30375733).
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1, spent fuel pool cooling using alternate power source, October 17, 2023
- (2) Units 1 and 2, offsite electrical supply 13.8 kV and 4160 V during four station power transformer out of service and only one offsite source available, November 28, 2023
- (3) Units 1 and 2, emergency diesel generator (EDG) room drainage path and sumps, December 19, 2023
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) Unit 1, RCS inventory control during mid-loop (reduced inventory) operations, November 7, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 1, reactor coolant pump oil collection systems, October 8, 2023
- (2) Unit 1, diesel fuel oil storage area 84' elevation auxiliary building, FP-SA-1545, October 16, 2023 (Notification (NOTF) 20947226)
- (3) Unit 2, 4160 V switchgear 64' elevation auxiliary building, FP-SA-2531, October 30, 2023
- (4) Unit 2, relay room 100' elevation auxiliary building, FP-SA-2551, October 30, 2023
- (5) Unit 2, spent fuel and component cooling heat exchanger and pump area 84' elevation auxiliary building, FP-SA-2542, November 15, 2023
- (6) Unit 2, charging pump and spray additive tank area 84' elevation auxiliary building, FP-SA-2544, November 15, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated the on-site fire brigade training and performance during an announced fire drill on November 21, 2023.
- (2) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on December 8, 2023.
===71111.08P - Inservice Inspection Activities (PWR)
The inspectors verified that the RCS boundary, reactor vessel internals, risk significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from October 16, 2023 to October 26, 2023.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination (NDE) and welding activities were performed appropriately:
- (1) Ultrasonic Examination
- Manual ultrasonic testing of safety injection system, pipe to elbow weld, 10-SJ-1131-16 (NDE Report S1-UT-23-026)
- Manual ultrasonic testing of safety injection system, elbow to pipe weld, 10-SJ-1131-17 (NDE Report S1-UT-23-027)
Magnetic Penetrant Examination
- Magnetic particle testing of auxiliary feedwater system pipe weld, S1-30360524-FW6 Radiograph Examination
- Radiography testing of auxiliary feedwater system pipe welds S1-30360530-FW4 (11AF23) and S1-30360524-FW6 (13AF23)
Welding Activities
- Gas Tungsten Arc Welding (manual),o Auxiliary feedwater system, S1-30360530-FW4, class 2, 4 inch pipe to pipe butt weld for 11AF23 valve replacement o Auxiliary feedwater system, S1-30360524-FW6, class 2, 4 inch pipe to pipe butt weld for 13AF23 valve replacement
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
- NOTF 20946037 for the 13SJ144, Safety Injection Cold Leg Header Check Valve
- NOTF 20946236 for the 1RC900, Reactor Head Vent Isolation Valve
- NOTF 20946289 for the 1LL3599Z, 1A Reactor Vessel Level Head Hydraulic Sensor Bellows
- NOTF 20946343 for the 1CV2, Reactor Coolant Letdown Line to Regenerative Heat Exchanger Isolation Valve
- NOTF 20946385 for the 12SJ44, 12 Safety Injection Containment Sump Suction Stop Valve
PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04) (1 Sample)
The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:
(1)
- Eddy current examinations of inservice tubes in steam generators 11, 12, 13, and 14
- Secondary side visual examinations in steam generators 11, 12, 13, and 14
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exams administered July - September, 2023 and for the biennial written exams administered August - September, 2022.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered August - September, 2022.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification operating test administered the week of September 18, 2023.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the main control room during Unit 1 pre-refueling outage downpower and shutdown activities on October 6-7, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a Unit 2 simulator scenario that included a spurious start of the turbine-driven auxiliary feedwater pump, a steam generator tube leak, a main steam leak outside containment and upstream of the main steam isolation valves, and the failure of the containment sump discharge valves to close on November 29, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Units 1 and 2, chiller compressor oil subsystem due to multiple trips on low compressor oil level
- (2) Units 1 and 2, charging pump discharge check valves due to elevated back-leakage on 11 charging pump discharge check valve, 1CV47
- (3) Units 1 and 2, reactor coolant pump seal packages
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Safety-related relays
Aging Management (IP Section 03.03) (1 Sample)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
- (1) Unit 2, containment concrete wall, 78' elevation of auxiliary building, electrical penetration area (NOTF 20396338, WO 60152480)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 1, fire risk assessment and management actions for fire impairment due to open 1B EDG equipment hatch, October 9, 2023 (NOTF 20946153, Order 70231815)
- (2) Unit 1, emergent work on 11 reactor coolant pump due to indications of degraded #2 seal, October 9-20, 2023 (NOTF 20946062, WOs 60158667 and 60158668)
- (3) Unit 1, risk assessment and management actions for establishing RCS vent path using tagging activities, October 10, 2023 (NOTF 20946190/Order 70232828)
- (4) Unit 1, elevated shutdown risk (Yellow) due to lowered inventory in RCS during scheduled RCS drain-down and reactor pressure vessel head removal, October 10-13, 2023
- (5) Unit 1, emergent work on refueling water storage tank and surrounding piping due to discovery of resin suspected from spent fuel pool demineralizer vessel, during week of October 23, 2023 (NOTF 20947137, Order 70232105)
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, 13 chiller trip due to low oil level on multiple occasions and review of use of TS 3.0.4.b to permit mode change from Mode 5 to Mode 6 while chiller inoperable, October 10, 2023 (NOTF 20945673)
- (2) Unit 1, 1C EDG due to low level alarm for jacket water expansion tank, December 11, 2023 (NOTF 20953407)
- (3) Unit 1, EDGs due to 100' elevation room floor sump pump not available, December 18, 2023 (NOTFs 20502815 and 20939968)
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Salem Unit 1 refueling outage 1R29 activities from October 7 to November 15, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)
- (1) Unit 1, refueling water storage tank following discovery of resin and associated cleanup, October 20, 2023 (NOTF 20947137/WO 60158635)
===50245556 and 50246263)
- (3) Unit 1, safety injection throttling valve flow balance following the abandonment of the boron injection tank, November 1, 2023 (WOs 50235598 and 60144387)
- (4) Unit 1, 11 charging pump discharge check valve, 1CV47, following replacement to repair elevated back-leakage, November 4, 2023 (NOTF 20925834, Order 70232041, WO 60157605)
- (5) Unit 1, 11 reactor coolant pump following stuck seal injection inlet temperature thermocouple and continued operation without component inservice, November 6, 2023 (NOTF 20946725, Order 70232628)
- (6) Unit 1, pressurizer power operated relief valve following replacement of valve cage and plug assembly, November 14, 2023 (WO 30370107)
- (7) Unit 2, 22 component cooling heat exchanger following replacing degraded service water drain valve, 22SW124, November 20, 2023 (NOTF 20939787/WO 60158206)
Surveillance Testing (IP Section 03.01)===
- (1) Unit 1, S1.OP-ST.DG-0012, "1A Diesel Generator Endurance Run," October 2-3, 2023 (WO 50235182)
- (2) Unit 2, S1.OP-ST.CH-0003, "Inservice Testing Chilled Water Valves Modes 1-6,"
December 27, 2023 (WO 50245879)
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 1, S1.OP-ST.SJ-0001, "Inservice Testing - 11 Safety Injection Pump," October 5, 2023 (WO 50245297)
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) Unit 1, S1.OP-ST.CAN-0004(Q), "Containment Air Lock Local Leak Rate Test," November 10, 2023 (WO 30370898)
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) Units 1 and 2, SH.OP-PT.FLX-0480, "FLEX 480V Caterpillar Diesel Generators," October 6, 2023 (WO 30377891)
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazards Control and Work Coverage (IP Section 03.04) (1 Sample)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Reactor coolant pump lift and placement
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Shipment Preparation (IP Section 03.04)
- (1) The inspectors observed the preparation of radioactive shipment number 23-116 of dry active waste material, UN 2912 Radioactive Material, LSA-I.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1, October 1, 2022 through September 30, 2023
- (2) Unit 2, October 1, 2022 through September 30, 2023
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1, July 1, 2022 through June 30, 2023
- (2) Unit 2, July 1, 2022 through June 30, 2023
MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)
- (1) Unit 1, July 1, 2022 through June 30, 2023
- (2) Unit 2, July 1, 2022 through June 30, 2023
MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)
- (1) Unit 1, July 1, 2022 through June 30, 2023
- (2) Unit 2, July 1, 2022 through June 30, 2023
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1, October 1, 2022 through September 30, 2023
- (2) Unit 2, October 1, 2022 through September 30, 2023
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 1, 2022 through September 30, 2023
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) October 1, 2022 through September 30, 2023
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program (CAP) related to the following issues:
- (1) Identification of unpermitted diesel fuel oil (transient combustible) stored in 12 DFOTP room and comparative review of similar issue identified within NCV
===05000272,05000311/2023010-01, Failure to Adequately Control Transient Combustibles 71152S - Semi-annual Trend Problem Identification and Resolution
Semi-annual Trend Review (Section 03.02)===
- (1) Inspectors reviewed the CAP for potential adverse trends that might be indicative of a more significant safety concern.
INSPECTION RESULTS
PSEG IWL Implementing Procedure not Followed Related to Salem Unit 2 Containment Electrical Penetration Room Location Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green FIN 05000272/2023004-01 Open/Closed
[H.7] -
Documentation 71111.08P The inspectors identified a finding of very low safety significance (Green) because PSEG staff did not implement Step 4.7.2 in their procedure OU-AA-335-018 for visual examinations of containment surfaces. Specifically, PSEG did not record indications as directed by the criteria in their procedure to support their conclusions regarding absence of distress or deterioration.
Description:
The inspectors reviewed the licensees performance to address indications of potential degradation in the Salem Unit 2 concrete containment building exterior walls located inside the 78-foot electrical penetration room (Summary No. S2-910000, Component CON-S2-QUAD-000A-078). NRC regulations require the examination and monitoring of the containment building concrete under American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code,Section XI, Subsection IWL.
Aging of containment concrete at Salem is monitored by the existing ASME,Section XI, Subsection IWL, Aging Management Program (AMP B.2.1.29), which was enhanced to include the acceptance criteria guidance contained in American Concrete Institute 349.3R, per license renewal commitment 29, as delineated in the Salem Updated Final Safety Analysis (UFSAR). The inspectors reviewed AMP B.2.1.29 and observed that the Salem Unit 2 containment structure is susceptible to porosity and permeability due to leaching of calcium hydroxide. Additionally, the inspectors noted that Salem AMP B.2.1.29 states, in part, concrete surfaces that are suspected of deterioration and distress, based on General Visual examination, are subject to Detailed Visual examination to determine the magnitude and extent of deterioration and distress.
The inspectors reviewed previous IWL examination reports pertaining to the Unit 2 containment exterior walls in the 78-foot electrical penetration room from 2023, 2018, 2014, and 2010. The 2010 exam documented general pattern cracking (~0.020 inches), mortar patching loss/separation and efflorescence at seam as recordable indications. The 2023 exam identified efflorescence and surface map cracking in the grouted seam, as recordable indications. The inspectors noted that only the 2010 and 2023 reports documented indications of degradation in the subject area. The inspectors performed a walkdown of the subject area and observed cracks, including rectangular pattern cracks, efflorescence, and dark staining on the external surface of the containment concrete wall. The inspectors compared pictures of the area documented in the 2010 IWL exam report to the current condition documented in the 2023 IWL exam report and noted that the efflorescence and dark staining had apparently changed. The inspectors noted the photos were not sufficiently aligned to support age-based trending.
The PSEG implementing procedure for examinations of concrete containment surfaces at Salem is OU-AA-335-018, "Detailed and General VT-1 and VT-3 Visual Examination of ASME Class MC and CC Containment Surfaces and Components." Step 4.7.2 of this procedure directs PSEG staff to perform a general visual examination of all accessible areas to assess the general structural condition of containment. The step states the examination shall be performed in sufficient detail to identify areas of concrete deterioration and distress and that the indications shall be recorded in Attachment 5. The step includes some of the following acceptance criteria: Absence of leaching and chemical attack; passive cracks less than 0.015 inches in maximum width. The step further states that cracks should be characterized and documented as either passive or active and to include in the examination report the location, length, and width of the crack and whether the crack has evidence of water leakage, discoloration, or staining.
The inspectors reviewed PSEG staffs implementation of their procedure and completed periodic monitoring and documentation. The inspectors reviewed the IWL visual examination record completed on September 7, 2023, and noted that the exam data sheet (S2-VE-23-169) used Attachment 5 of procedure OU-AA-335-018. PSEG staff documented indication types "A. Cracks" and "Q. Efflorescence. The inspectors noted that PSEG did not characterize or size the cracks, and they did not document the staining around the cracks.
The inspectors also noted the licensee omitted indication type "F, Leaching or Chemical Attack" without a basis for distinguishing between efflorescence and leaching. Inspectors determined that while a comparison of photographs from 2010 to 2023 displayed apparent changes in chemical deposits, dark staining, and cracking, PSEG staff did not address the changes or the causes. Additionally, the inspectors observed PSEG staff did not track conditions and document their conclusions of each examination because there is no record (i.e., exam data sheet or procedural attachment) pertaining to this area for exams completed in 2014 and 2018. Furthermore, PSEG staff did not characterize cracks as passive or record measurements since 2010. Inspectors determined PSEG staff did not address whether there was evidence of water leakage which would support the presence of efflorescence.
Specifically, PSEG staff did not affirm by sample the composition of the deposits and associate the results with causes to support their conclusions. Consequently, the inspectors determined PSEG did not record indications as directed in their procedure to support their conclusions regarding absence of distress or deterioration of this Unit 2 containment location.
Corrective Actions: PSEG staff entered the issue into their CAP for assessment and resolution. PSEG conducted a chemical analysis of the efflorescence sample collected from the 78-foot elevation containment wall and concluded the results indicated that the concrete or mortar were not leaching.
Corrective Action References: NOTFs 20396338, 20948043, and 20951688
Performance Assessment:
Performance Deficiency: The inspectors determined the failure to follow Step 4.7.2 in their procedure OU-AA-335-018 for visual examinations of the Unit 2 containment surfaces was within PSEG's ability to foresee and correct, and is therefore a performance deficiency.
Specifically, PSEG did not record indications as directed by the criteria in their procedure to support their conclusions regarding absence of distress or deterioration.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors reviewed the guidance in IMC 0612, Appendix E, and determined this issue is similar to Example 5.d. Specifically, PSEG staff not following their procedure for IWL examinations resulted in not appropriately identifying, trending, and evaluating indications as directed by their procedure. The presence of cracking, staining, and deposits on the containment concrete, without identifying or evaluating the causes, could result in not identifying aging mechanisms that should be managed.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the issue was of very low safety significance (Green) because the performance deficiency did not result in an actual open pathway in the physical integrity of reactor containment, failure of containment isolation system, failure of containment pressure control equipment, failure of containment heat removal components, nor involve an actual reduction in function of hydrogen igniters in the reactor containment.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate, and up-to-date documentation. Specifically, the licensee did not document in their evaluation the causes of chemical deposits, staining, or consistently characterize crack sizes and apparent changes from previous exams during the 2023 IWL concrete examination to ensure that the causes were identified and addressed.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Failure to Promptly Identify and Correct Condition Adverse to Quality (CAQ) Results in Multiple Chiller Trips Due to Invalid Low Compressor Oil Level Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000272/2023004-02 Open/Closed
[H.13] -
Consistent Process 71111.12 Inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because PSEG did not promptly identify and correct CAQs associated with the safety-related 13 Chiller. Specifically, troubleshooting and maintenance efforts regarding the 13 Chiller trips on September 27 and October 8, 2023, were not consistent with station procedures to promptly identify and correct prior to restoring the 13 Chiller to service. As a result, the 13 Chiller had repeat failures to perform its safety-related function when it tripped on October 8 and November 20, 2023, due to invalid low compressor oil level.
Description:
Salem Units 1 and 2, TS 3.7.10, requires the chilled water system loops to be operable dependent on a configuration of their two chilled water pumps and three chillers.
PSEG operators enter a 14-day action statement when one required loop is inoperable.
Salems Units 1 and 2 chilled water systems provide safety-related cooling during normal and emergency operating conditions to the emergency control air compressors and various air conditioning units.
PSEG uses their CAP, as implemented by LS-AA-120, Issue Identification and Screening Process, and LS-AA-125, Corrective Action Program, in combination with procedure MA-AA-716-004, Conduct of Troubleshooting, to identify and correct the undesired conditions and CAQs that is the direct cause of a plant system, component, or sub-component failure or degradation.
PSEG staff declared the 13 Chiller inoperable and entered troubleshooting trips due to low compressor oil level on both September 27 and October 8, 2023 (NOTF 20945673).
Following each trip, PSEG staff determined the low compressor oil level was invalid because there was no evidence of an oil leak and oil level was visible in the upper sight glass. As such, following each trip, PSEG initiated an investigation of the failure modes using vendor documentation to refute the listed potential failures such as a malfunctioning float low compressor oil level switch, LLS565, faulty wiring and circuitry, and/or faulty oil separator components. Following the September 27, 2023 trip, during approximately 10-minute iterative test runs, although oil level was maintaining at a level within the upper site glass, the chiller initially tripped again on low oil level and during another run identified an abnormality where the LLS565 contacts opened for 10 seconds but then reset. Subsequent test runs showed the LLS565 contact maintained closed. PSEG made the decision to exit troubleshooting after completing one troubleshooting log and to perform operability testing. PSEG performed a satisfactory test of the 13 Chiller and declared the 13 Chiller operable on September 30, 2023. Within the operability determination, PSEG operators noted that the likely cause to be sticking of the LLS565 in a lower than actual state but the testing conducted during troubleshooting demonstrated the LLS565 was now free. PSEG did not remove the LLS565 for bench testing or repair.
Following the October 8, 2023 trip, PSEG focused troubleshooting on replacing the LLS565.
PSEG staff evacuated and isolated the compressor, replaced the LLS565 with the new part ordered following the September 27, 2023 trip, and added compressor oil up to half the level of the upper sight glass. PSEG generated NOTF 20945883 to quarantine the part that was removed to perform testing and to send out for failure analysis. PSEG performed a satisfactory test of the 13 Chiller and declared the 13 Chiller operable on October 13, 2023.
During investigation, PSEG identified the compressor oil level monitoring guidance within vendor documentation was incorrect (NOTF 20946603). Specifically, PSEG determined the LLS565 actuates at a higher level than previously understood, at a location somewhere between the upper and lower sight glass instead of at somewhere in the middle of the lower sight glass.
PSEG performed Work Group Evaluation 70231922 to determine the cause of the September 27 and October 8, 2023, 13 Chiller trips. PSEG stated the direct cause was due to the information captured in NOTF 20946603, which stated an incorrect compressor oil level listed in the vendor documentation for the LLS565 trip setpoint. Inspectors determined this conclusion was not supportable based on the evidence and documentation. Specifically, the wrong LLS565 trip setpoint in the vendor documentation could not have caused the 13 Chiller trips because, in part, oil level was not observed to be at a level below the upper sight glass following each trip and during the September 27-30 and October 8-13, 2023 troubleshooting, there was abnormal indications of the LLS565 during the September 27-30, 2023 troubleshooting, and only the 13 Chiller tripped due to invalid low compressor oil level.
Inspectors noted PSEG initially suspected the LLS565 to be the cause and pursued failure analysis but hand manipulation of the LLS565 lowered suspicions that was the cause so failure analysis was not pursued.
On November 20, 2023, PSEG again declared the 13 Chiller inoperable and entered troubleshooting following a trip due to low compressor oil level (NOTF 20951141). PSEG staff again determined it was an invalid low compressor oil level because there was no evidence of an oil leak and oil level was visible in the upper sight glass. PSEG removed the LLS565 and performed bench testing which showed evidence the float was sticking near the bottom demonstrating this was the likely failure mechanism. PSEG performed a satisfactory test of the 13 Chiller and declared the 13 Chiller operable on November 22, 2023.
Inspectors determined that, based on a review of the documents referenced above, PSEG staff failed to identify the CAQ prior to restoring the 13 Chiller to service on September 30 and October 13, 2023. Inspectors determined PSEG did not appropriately use MA-AA-716-004 to identify with high confidence the failed plant system, component, or sub-component failure or degradation corresponding to the invalid compressor oil level trips on September 27 and October 8, 2023, and correct the problem, as required by Sections 4.3 and 4.5. Following each 13 Chiller trip, only one simple troubleshooting log was completed. Inspectors determined that although PSEG staff identified there was an issue with the functionality of the compressor oil subsystem, PSEG did not appropriately investigate and refute these components that are designed to maintain adequate compressor oil level and provide a valid output of low compressor oil level to the protective circuitry during chiller operation.
Specifically, inspectors determined PSEGs troubleshooting was limited and focused on only a portion of the compressor oil subsystem and failed to disprove, for example, the compressor internals or the components within the oil separator-to-compressor line.
Inspectors also noted that PSEG staff has not provided a technical basis to how the LLS565 can get hung up in a lower state while oil level is observable in the upper sight glass. Even in the case PSEG staff observed abnormal functioning of LLS565 during testing following the September 27, 2023 trip, including an additional trip and an approximately 10 second actuation of the circuit, inspectors identified PSEG did not consider this an abnormality thus the 13 Chiller was not removed from service as required by S1.OP-SO.CH-0001, Chilled Water System Operation. Then following the October 8, 2023 trip, inspectors determined PSEG staffs troubleshooting was not a systematic use of the troubleshooting process because it was focused directly on the LLS565 without investigating other components within the compressor oil subsystem. Also, inspectors identified that the trips had only occurred on the 13 Chiller without any observed impact to the other four same-model chillers. Lastly, inspectors noted PSEG staff did not initiate actions to gather field data or to address the degraded condition in the interim, such as an adverse condition monitoring plan or temporary change configuration, to manage the risk and further investigate. Collecting field data through non-intrusive techniques or otherwise, as stated by Section 4.3, could have proved or disproved failure modes. Inspectors determined the testing and monitoring was relatively short-duration (less than 60-minute test runs and a couple days of monitoring) and did not include enhancement to monitor more frequently, such as through camera feed.
Corrective Actions: PSEG replaced the low compressor oil level switch (LLS565) following both the October 8 and November 20, 2023, 13 Chiller trips. Following the November 20, 2023, 13 Chiller trip, PSEG decided to send out both LLS565s for failure analysis.
PSEG initiated a revision to S1(2).OP-DL.ZZ-0006, "Primary Plant Logs," to change operator readings from SAT/UNSAT to logging specific compressor oil level.
PSEG initiated a design change package to evaluate removal of LLS565 as a chillers protective actuation circuit function.
Corrective Action References: NOTFs 20945673, 20946181, 20945883, 20946804, 20946603, 20951141, and 20954410
Performance Assessment:
Performance Deficiency: The inspectors determined the failure to promptly identify and correct a CAQ after the 13 Chiller tripped was within PSEG's ability to foresee and correct and is therefore a performance deficiency. Specifically, after the 13 Chiller tripped on September 27 and October 8, 2023, due to an invalid low compressor oil level, PSEG failed to identify and correct the failure, malfunction, deficiency, defective item, or non-conformance within the compressor oil subsystem that performs the safety-related function to maintain the 13 Chiller operable.
Screening: The inspectors determined the performance deficiency was 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. Inspectors used Example 4.f of IMC 0612, Appendix E, Examples of Minor Issues, effective November 2023, in the determination that this performance deficiency is more than minor. Specifically, inadequate repairs to the 13 Chiller on September 27-30 and October 8-13, 2023, prevented the system from performing its safety-related function on October 8-13 and November 20-22, 2023, respectively.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened to Green (very low safety significance) because the probabilistic risk assessment functionality of this multi-train system was restored prior to the TS allowed outage time in each instance.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Inspectors determined PSEG did not effectively use troubleshooting through the systematic approach outlined in MA-AA-716-004 to identify and repair the likely failure mode associated with the invalid low compressor oil level or incorporate risk management tools to mitigate potential unknowns.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to ensure that CAQs, such as deviations and non-conformances, are promptly identified, and corrected.
Contrary to the above, from September 27 to November 20, 2023, PSEG did not promptly identify and correct a CAQ, a failure, malfunction, deficiency, defective item, or non-conformance, within the compressor oil subsystem of the safety-related 13 Chiller.
Specifically, PSEG did not promptly identify and correct the condition within the compressor oil subsystem that generated an invalid low compressor oil level trip actuation on September 27, October 8, and November 20, 2023.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Implement Written Instruction for Sequence of Tagging Activities Affecting Reactor Coolant System (RCS) Vent Paths Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity
Green NCV 05000272/2023004-03 Open/Closed
[H.5] - Work Management 71111.13 A self-revealed, Green finding and associated non-cited violation (NCV) of TS 6.8.1.a, Procedures and Programs, was identified when PSEG failed to adequately implement documented instructions for tagging activities. Specifically, PSEG did not implement work instructions for the sequence of tagging activities associated with RCS vent paths to ensure TSs were not affected. As a result, one of the pressurizer power operated relief valves (PORV), 1PR1, was taken out of service prior to establishing another vent path resulting in only one remaining RCS vent path available to mitigate a potential pressure transient.
Description:
When Salem Unit 1's RCS temperature of at least one cold leg is less than 321F and the reactor head vessel is installed, operators rely upon overpressure protection systems to ensure a potential pressure transient does not exceed established limits. TS 3.4.9.3, Overpressure Protection Systems, requires either two pressurizer PORVs or a RCS vent of greater than or equal to 3.14 square inches. To meet this requirement for low temperature over pressurization (LTOP) protection, Salem either keeps the two PORVs open or utilizes a 4-inch diameter vent path through the RCS vent connection valve, 1PS59.
On October 10, 2023, Salem Unit 1 was in Mode 5 with RCS drain-down on-going to remove the reactor pressure vessel head. Operators credited the two PORVs, 1PR1 and 1PR2, as the RCS vent paths for LTOP protection in accordance with TS 3.4.9.3. At 2:19 p.m., while performing concurrent outage tagging evolutions for the Unit 1 pressurizer and RCS vent connection valve, 1PS59, 1PR1 was de-energized in the closed position. Because the other planned RCS vent path, 1PS59, had not been established yet this resulted in entry to TS 3.4.9.3, action b, which requires the RCS to be vented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The redundant PORV, 1PR2, remained available/energized and open. Within approximately five minutes after receiving an unexpected overhead alarm for the loss of power to the 1PR1, the main control room operators had contacted the field operators and had power restored to the 1PR1 and opened the valve. Operators subsequently exited the TS action statement. PSEG generated NOTF 20946190 to capture the event.
Inspectors reviewed NOTF 20946190 and other documents associated with the tagging activities of 1PR1 and 1PS59. PSEG was taking action to tag the DC power to the solenoid valves for the 1PR1 and 1PR2 (de-energize and close the valves) in conjunction with opening the 1PS59, which would become the new relief path. However, correct control of the tagging sequence was not utilized to ensure LTOP protection via the RCS vent path through 1PS59 was established prior to isolating the 1PR1 and 1PR2. PSEG identified that the communications with the personnel involved were held at separate times and there was no discussion of the order of tagging manipulations. PSEG also identified the refueling outage work schedule initially had the 1PS59 work activity scheduled for completion prior to the 1PR1 work activity.
Inspectors determined PSEG staff did not properly perform Section 4.3 of OP-AA-109-115, "Safety Tagging Operations," with the authorization and hanging of the 1PS59 and 1PR1 tags. Specifically, the inspectors identified the 1P59 tagging activity was authorized on October 10, 2023, at 1:14 p.m., while the 1PR1 tagging activity was authorized on October 10, 2023, at 1:15 p.m., although the 1PS59 tagout was released 1-minute earlier and the 1PS59 tagout was not complete in the field. Inspectors determined the authorization of these two tagging activities did not include an adequate review of the plant configuration to prevent TS impact, which resulted in personnel in the field not being appropriately briefed to ensure the tagging activities sequence were controlled and TSs were not impacted.
Operators subsequently de-energized the 1PR1 in accordance with the tagout at 2:19 p.m.
As such, during the 1PR1 tagout authorization process described in Section 4.3, operators failed to identify the impact to plant operations or TSs during the reviews, approvals, and pre-job briefs. Specifically, inspectors determined that the 1PR1 tagging was authorized and hung without operators in the control room, work control center, or in the field identifying the 1PS59 tagging was not complete and the valve was still closed.
Corrective Actions: After receiving an alarm in the main control room for loss of power to 1PR1, operators re-energized 1PR1 and opened the valve. To evaluate the activities surrounding the event, PSEG performed a Safety Human Performance Response in accordance with OP-AA-106-101-1001, Event Response Guidelines. PSEG also categorized the event as a maintenance rule functional failure.
Corrective Action References: NOTF 20946190
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to implement documented instructions for the sequence of tagging instructions was within PSEGs ability to foresee and correct and is therefore a performance deficiency. Specifically, inspectors determined PSEG staff did not adequately implement OP-AA-109-116, Section 4.3, when the 1PR1 was authorized and hung because the impact to the RCS vent path configuration and the LTOP TS was not identified.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the implementation of the tagging activities rendered the 1PR1 incapable of responding to a LTOP event and manual operator action was required to close the breaker to restore power to the valve.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix G, Shutdown Safety SDP. Based on consultation with regional senior risk analysts, this finding is characterized as Green (very low safety significance). Specifically, although the finding involved LTOP because one PORV was rendered unavailable, the inspectors determined that the finding did not require a quantitative assessment. The licensee had the functional ability to establish an alternate core cooling path in the event of a loss of residual heat removal based on the licensees conclusion that the venting capability of the remaining PORV was still functionally available and able to sustain an overpressure event during the plant conditions of low temperature. Additionally, the RCS was not water solid and the licensee had adequate controls in place to prevent a high pressure safety injection or reactor coolant pump start.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, PSEG staff failed to identify and manage the risk of the overlapping tagging activities prior to executing the work activities.
Enforcement:
Violation: Salem Unit 2, TS 6.8.1(a), Procedures and Programs, requires in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in Regulatory Guide 1.33, Appendix A, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 1.c, includes administrative procedures for equipment control (e.g., locking and tagging). PSEG established procedure OP-AA-109-115, Safety Tagging Operations, to, in part, meet this requirement.
Contrary to the above, on October 10, 2023, PSEG failed to implement the sequence of tagging activities affecting the RCS vent paths. Specifically, during the 1PR1 tagging activities to authorize and hang the tags, PSEG staff did not verify the status of the other tagging activity involving the RCS vent paths and did not identify the other RCS vent path through 1PS59 had not yet been opened. As a result, one PORV, 1PR1, was taken out of service (closed) prior to establishing another RCS vent path.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71111.13 This violation of very low safety significance was identified by the licensee and has been entered into the licensee CAP and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Salem Units 1 and 2 Renewed Facility Operating Licenses (DPR-70 and DPR-75),
Conditions 2.C.5 and 2.C.10, Fire Protection, respectively, state, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR. The UFSAR, Section 9.5.1, Fire Protection, states, in part, that the use of combustibles materials at Salem Generating Station is controlled by station procedures. Salem Units 1 and 2, License Condition 2.C.5, requires the licensee to implement and maintain in effect all provisions of the approved fire protection program. The licensee established procedure FP-AA-002, "Fire Protection Impairment Program," to, in part, meet this requirement and to identify fire impairments and to specify and establish compensatory measures as necessary.
Contrary to the above, on October 9, 2023, from approximately 12:15 a.m. to 09:30 a.m.,
PSEG failed to implement FP-AA-002 to identify a fire impairment and establish compensatory measures. Specifically, the 1B EDG outside hatch was found open, which rendered the fixed fire protection suppression system non-functional, without establishing an hourly fire watch as required.
Significance/Severity: Green. Based on consultation with regional senior reactor analysts and using IMC 0609, Appendix F, "Fire Protection Significance Determination Process," the inspectors characterize this finding as Green (very low safety significance). Specifically, using Appendix F, Step 1.4.2, Fixed Fire Protection Systems, and considering the unit was shutdown, it was determined the finding screened to Green because the non-functional fixed fire protection suppression system related to the 1B EDG did not adversely affect the ability to protect safe shutdown equipment since the unit was in Mode 5 (a safe shutdown condition)and all three EDGs were still available.
Corrective Action References: 20946153
Failure to Implement and Maintain All Provisions of the Approved Fire Protection Program Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000272,05000311/2023004-04 Open/Closed
[H.2] - Field Presence 71152A The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Salem Nuclear Generating Station, Units 1 and 2, License Condition 2.C.5 and 2.C.10, "Fire Protection," for failing to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to identify a transient combustible was stored in a safety-related area and a transient combustible permit (TCP) was needed. As a result, from October 13 to October 19, 2023, a plastic bottle containing diesel fuel oil was stored inside the safety-related 12 diesel fuel oil transfer pump (DFOTP) room, unattended, and without an associated TCP.
Description:
Salem Units 1 and 2, License Conditions 2.C.5 and 2.C.10, respectively, require the licensee to implement and maintain in effect all provisions of the approved fire protection program as described by the UFSAR. The UFSAR, Section 9.5.1, "Fire Protection," states, in part, that the use of combustibles materials is controlled by station procedures. PSEG implements and maintains several procedures to govern the fire protection program including FP-AA-011, Control of Transient Combustible Material, to ensure the proper handling of transient combustible material inside a safety-related or critical building.
Salem has two safety-related DFOTPs per unit that are shared by the three emergency diesel generators for the unit. The pumps support diesel operation by transferring fuel oil from the diesel fuel oil storage tanks to the diesel fuel oil day tanks. The transfer pumps are necessary to supply the TSs required minimum volume of diesel fuel oil.
On October 16, 2023, inspectors identified a plastic bottle containing diesel fuel oil stored inside the 12 DFOTP room without an associated TCP and communicated this concern to the licensee. On October 19, 2023, the inspectors identified that the plastic bottle remained in the 12 DFOTP room. The inspectors notified operations staff and observed the removal of the plastic bottle. The inspectors reviewed work order history and identified the plastic bottle had been in place without a TCP since October 13, 2023, following work on the 12 DFOTP. FP-AA-011, Control of Transient Combustible Materials, Step 4.1.3, states, in part, that a TCP is required prior to staging any flammable liquid or combustible liquid in a safety-related or critical building.
The inspectors noted that PSEG conducts daily walkdowns of safety-related areas by multiple departments including fire protection, operations, and security staff. One such walkdown is performed using fire protection procedure SC.FP-SV.ZZ-0058(Q), Inspection of Class 1 Fire Doors and Safety Related Areas for Transient Combustibles. This procedure establishes an inspection for control of transient combustible materials and verification that each unlocked class 1 fire door is closed as required. Attachment 1 of the procedure is an Area Inspection Check Sheet the PSEG fire protection staff member initials that they completed the walkdown. Attachment 3 is the Fire Hazard Identification Report where fire prevention deficiencies can be noted from the walkdown, such as uncontrolled or unauthorized transient combustibles. The inspectors identified that Attachment 1 was signed off as completed for October 12 through October 19, 2023, and that the plastic bottle was not noted on the
3. The inspectors also noted that on October 19, 2023, the 12 DFOTP room was then being
protected as required by OP-AA-108-116, Protected Equipment Program. The inspectors reviewed OP-AA-108-116 and noted that Step 4.3.1.3 states, Prior to establishing boundaries around protected equipment the following actions must be completed: Complete an area walkdown for any scaffolding, TP&L, transient combustibles, etc. that could interfere with the equipments ability to perform.
Based on previous challenges in this area, inspectors observed that PSEG has initiated actions to raise awareness to the importance of transient combustible controls to the staff through signage, informational pamphlets, and fleet safety messages. However, at this time, inspectors determined these corrective actions have not been fully effective.
Corrective Actions: PSEG removed the plastic bottle from the room. PSEG revised procedure FP-AA-011, Control of Transient Combustibles, to provide improved guidance on when a TCP is needed and added a requirement for transient combustibles controlled by a TCP.
Corrective Action References: 20947226, 20953891
Performance Assessment:
Performance Deficiency: The inspectors determined the failure to implement and maintain all provisions of the approved fire protection program was within PSEGs ability to foresee and correct and is therefore a performance deficiency. Specifically, PSEG personnel did not identify transient combustible material stored unattended in a safety-related room and they did not identify that a TCP was required.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, during several walkdowns and absent NRC intervention, PSEG personnel did not identify diesel fuel oil was stored in a critical building, the 12 DFOTP room, unattended, and without a TCP.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using Appendix F, 1, Fire Protection SDP Phase 1 Worksheet, the inspectors assigned the category to fire prevention and administrative controls. The inspectors determined that the safety significance of the finding was very low because based on the SDP qualitative screening question (Step 1.4.1) related to fire prevention and administrative controls, the finding does not increase the likelihood of a fire, delay detection of a fire, or result in a more significant fire than previously analyzed such that the credited safe shutdown strategy was adversely impacted.
Cross-Cutting Aspect: H.2 - Field Presence: Leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Deviations from standards and expectations are corrected promptly. Senior managers ensure supervisory and management oversight of work activities, including contractors and supplemental personnel.
Specifically, while corrective actions are being implemented, supervisory actions have not resulted in consistent implementation of standards in the field by station personnel.
Enforcement:
Violation: Salem Units 1 and 2 Renewed Facility Operating Licenses (DPR-70 and DPR-75),
Conditions 2.C.5 and 2.C.10, Fire Protection, respectively, state, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR. The UFSAR, Section 9.5.1, "Fire Protection," states, in part, that the use of combustibles materials at Salem Generating Station is controlled by station procedures. Salem established FP-AA-011, Control of Transient Combustible Material, to, in part, meet this requirement.
Contrary to the above, from October 13 to 19, 2023, PSEG staff failed to identify and control transient combustibles. Specifically, following the performance of maintenance on the 12 DFOTP on October 13, 2023, PSEG staff failed to identify the transient combustible material being left behind unattended. During several subsequent walkdowns, PSEG staffed failed to identify the unattended transient combustible material and that a TCP was required. The transient combustible was ultimately removed on October 19, 2023, after inspectors informed operators multiple times.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend Review 71152S The inspectors reviewed PSEGs CAP for trends that might be indicative of a more significant safety issue. The inspectors verified that PSEG was evaluating issues for potential trends; however, inspectors identified a trend regarding the significance level screening of CAP NOTFs in accordance with LS-AA-120, Issue Identification and Screening Process.
Specifically, inspectors identified multiple instances where issues were inappropriately screened as not CAQ (i.e., non-CAP).
10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that CAQs are promptly identified and corrected. PSEG uses procedure LS-AA-120 to identify issues and screen those issues within a tiered approach, with a CAQ being significance level 2. LS-AA-120 defines a CAQ, in part, as an all-inclusive term used in reference to any of the following:
failures, malfunctions, deficiencies, defective items, and non-conformances. LS-AA-120 further states a non-conformance is a deficiency in characteristic, documentation, or procedure that renders the quality of a SSC or activity unacceptable or indeterminate.
Inspectors reviewed a sample of NOTFs to assess the adherence to LS-AA-120 and 2, "Notification Level." Inspectors noted recent NOTFs documenting concerns where PSEG did not appropriately screen the deficiency as a CAQ. Specifically, inspectors identified the following:
(NOTF 20946190) Unit 1 pressurizer PORV, 1PR1, inadvertently de-energized on October 10, 2023. This NOTF documents the closure and loss of power to the 1PR1.
Inspectors determined this represents a condition describing a deficiency in a safety-related component where there was a loss of configuration control, which is an example of a CAQ as described in LS-AA-120.
(NOTF 20946153) 1B EDG room equipment hatch open without a firewatch in place identified on October 9, 2023. The NOTF documents that the required compensatory measure of an hourly firewatch was not in place with the suppression system non-functional due to the open hatch. Inspectors determined this represents a condition describing a deficiency in the safety-related EDG room regarding performance of work to maintain and operate that equipment, which is an example of a CAQ as described in LS-AA-120.
(NOTF 20948688) Degraded 11 RCP seal injection inlet thermocouple identified on November 13, 2023. This NOTF documents a thermocouple was rendered non-functional during the safety-related 11 RCP seal replacement work window (WO 60158667) resulting in not having seal injection inlet temperature indications to the control room. Inspectors determined this represents a deficiency describing a defective component and deficiencies in performance of work or other activities to maintain and operate safety-related equipment, which is an example of a CAQ as described in LS-AA-120.
Based on the above examples, inspectors determined PSEG staff did not appropriately follow LS-AA-120 to evaluate the deficiency against the definition of CAQ and the examples provided within Attachment 2. Inspectors identified that each of these issues had gone through management review prior to concluding on the non-CAP screen. However, in each of the cases described, the inspectors determined the corrective actions were adequate.
These examples were independently evaluated in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined the issues were not of more than minor significance.
PSEG captured this observation in NOTF
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 18, 2024, the inspectors presented the integrated inspection results to David Sharbaugh, Site Vice President, and other members of the licensee staff.
- On October 26, 2023, the inspectors presented the Unit 1 inservice inspection results to Dave Sharbaugh, Site Vice President, and other members of the licensee staff.
- On December 19, 2023, the inspectors presented the Unit 2 IWL FIN inspection results to Tammy Morin, Manager Station Compliance, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
20947466
Focused Area Self-Assessment to Withstand Climate-Driven
Events
10/24/2023
20948873
2CBV37-1 and 38-1 Unit 2 Outer Penetration Dampers Not
Fully Closing
11/13/2023
Corrective Action
Documents
Resulting from
Inspection
20953136
SW Control House Roof Plug Leak
2/05/2023
Corrective Action
Documents
Resulting from
Inspection
20947226
Poly Bottle in 12 DFOTP Room
10/16/2023
20947855
Transient Combustibles and TCPs in 'Fire in a(4) Areas'
Identified
10/30/2023
20947883
Fire Impairment to 2FP229 Hose Station Not Included in a4
Evaluation
11/02/2023
20950500
Performance of Fire Protection Procedure SC.FP-SV.ZZ-
0058 Failed to Note Fire Impairment to Fire Door C8-2 (CC
Hx Room)
11/16/2023
20950845
Fire Plan for 84' Auxiliary Building 22 CC Hx Room Does Not
Accurately Reflect Actual Plant Layout
11/16/2023
Procedures
Fire Drill Performance
S1(2).OP-
AB.FIRE-0001
71111.08P Corrective Action
Documents
234570
234644
20396338
20948043
20951688
Miscellaneous
ACI 201.1R
Guide for Conducting a Visual Inspection of Concrete in
Service
07/2008
ACI 349.3R
Evaluation of Existing Nuclear Safety-Related Concrete
Structures
01/01/1996
NDE Reports
S2-VE-23-169!
Salem Unit 2 ASME IWL (Class CC) Containment Concrete
10/12/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Visual Examination Report for Component CON-S1-QUAD-
VE-10-047/048
Salem Unit 2 ASME IWL (Class CC) Containment Concrete
Visual Examination Record for Summary 910000
04/22/2010
VEN-14-020 to
VEN-14-027
Containment IWL General Visual Examination
08/26/2014
VEN-18-004
Salem Unit 2 ASME IWL (Class CC) Containment Concrete
Visual Examination Report
11/01/2018
VT-09-236
Visual Examination of IWL (VT-3C) for Component CON-S2-
QUAD-000D-078 (Summary 910000)
10/20/2009
Work Orders
50071724
Salem Unit 2 Class CC Visual Examination Data Sheet
06/07/2005
Corrective Action
Documents
20734280
20-year Struthers Dunn Relays Replacement Strategy
07/07/2016
20874992
Adverse Trend - Struthers Dunn Relay
04/13/2021
20945673,
20951141
Chiller Tripped on Low Compressor Oil Level
20946603,
231922
Chiller Vendor Manual Oil Level Information Inaccurate
10/13/2023
20947063,
20947064,
20946591
Relays Requiring Adjustment After Inspection During 1R29
Refueling Outage
Engineering
Evaluations
232041
1CV47 Unexpected Damage Seat and Disk
2/12/2023
Procedures
Relay Testing
Shipping Records 4501255467
Purchase Order to Replace Compressor Oil Level Switch
09/29/2023
Work Orders
60158580
Troubleshooting Investigation of 13 Chiller Trip on Low
Compressor Oil Level on 10/8/2023
10/11/2023
Corrective Action
Documents
20946153
Failure to Identify Fire Impairment and Perform Hourly
Firewatches as a Result of 1B EDG Equipment Hatch Being
Open
10/09/2023
Procedures
Fire Protection Impairment Program
OP-AA-106-101-
1001
Event Response Guidelines
OP-AA-106-101-
1001
Event Response Guidelines
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
30370268
1B EDG Work Window
10/09/2023
30370865
Remove Blank Flange of 1PS59
10/10/2023
Tagout S1C-
PZR/PRT 1R29
Tagout of Unit 1 Pressurizer, Including PORV, 1PR1
10/10/2023
Corrective Action
Documents
20945883
Chiller Tripped on Low Oil Level
10/08/2023
20946255
Shutdown Safety Review Board Conducted Review of TS 3.0.4.b Risk Assessment to Permit Change to Mode 6 and
Allow Movement of Irradiated Fuel
10/09/2023
Work Orders
60158580
Troubleshoot 13 Chiller Trip Due to Low Oil Level
09/28/2023
Corrective Action
Documents
20906357,
30360524
13AF23 Failed Reverse Flow IST Per S1.OP-ST.AF-0005,
Section 4.9, 4" Valve Replaced in Fall 2023 RFO
20941657,
20941658
Main Steam Turbine Governor Valve, 14MS29, Actuator
Controls Found Degraded
10/25/2023
20946853
Fleet Trend in Missed Firewatches
10/15/2023
20947222
FM Discussed in BIT Piping During Demolition Activities
10/20/2023
20947643
Incorrect FME Area Designation for Unit 1 RWST Entry and
Inspection
10/27/2023
20948611
1R29 Trend in Safety and HU Issues
11/13/2023
20948629
RCP Standpipe Alarming Every 31 Minutes, Possibly Due
to #3 Seal Hung Up and/or Clogged RCDT Piping Line
11/06/2023
20948672
Initial Inverse Count Rate Ratio Not Taken by Reactor
Engineering During Startup
11/11/2023
20948812
Wrong Revision of Troubleshooting Logs Used
11/13/2023
20950445
Area of Concern - S1R29 RP Gaps in Behaviors
11/13/2023
20950828
Area of Concern - S1R29 Reactor Engineering Gaps in
Behaviors
11/15/2023
Procedures
Unit Restart Review
S1.OP-IO.ZZ-
0005
Minimum Load to Hot Standby
Work Orders
600155151
UT of Unit 1 Thermal Shield Support Block Bolts at AZ. 292
Found Failed
10/17/2023
Corrective Action
Documents
20921531
FLEX8 Fuel Level Below 900 Gallons
11/22/2022
20945951
1R Cylinder on 1A EDG Fuel Leak
10/03/2023
20948498,
Unit 1 100' Airlock Inner Door Failed LLRT
11/09/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
20948779
Operability
Evaluations
S-23-002
RCP Seal Inlet Temperature Indication Operability and
Technical Decision Making Process
11/03/2023
Procedures
S1.OP-ST.DG-
0003
1C Diesel Generator Surveillance Test
S1.OP-ST.SJ-
0016
High Head Cold Leg Throttling Valve Flow Balance
Verification
SC.MD-CM.RC-
0004
PR1, PR2, and CV2 Valves Overhaul/Repacking
Work Orders
30363012,
30376657
1-year PM - FLEX8 RICE Inspection
Corrective Action
Documents
20946846
Diesel Fuel Oil Transfer Pump Will Not Stop in AUTO
10/15/2023
Corrective Action
Documents
Resulting from
Inspection
20947226
Poly Bottle Found in 12 Diesel Fuel Oil Transfer Pump Room
10/16/2023
Corrective Action
Documents
20948688,
20946190,
20946153,
20945883,
20948043