IR 05000272/2023010
| ML23284A356 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/12/2023 |
| From: | Brice Bickett NRC/RGN-I/DORS |
| To: | Mcfeaters C Public Service Enterprise Group |
| References | |
| IR 2023010 | |
| Download: ML23284A356 (1) | |
Text
October 12, 2023
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000272/2023010 AND 05000311/2023010
Dear Charles McFeaters:
On August 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Salem Nuclear Generating Station, Units 1 and 2 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. 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 violation or the significance of the violation 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 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 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Digitally signed by Brice Brice A. A. Bickett Date: 2023.10.12 Bickett 09:47:06 -04'00'
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: DPR-70 and DPR-75 Report Numbers: 05000272/2023010 and 05000311/2023010 Enterprise Identifier: I-2023-010-0010 Licensee: PSEG Nuclear, LLC Facility: Salem Nuclear Generating Station, Units 1 and 2 Location: Hancocks Bridge, NJ Inspection Dates: August 14, 2023 to August 31, 2023 Inspectors: P. Cataldo, Senior Reactor Inspector E. Garcia, Resident Inspector D. Merzke, Senior Reactor Operations Engineer J. Schoppy, Senior Reactor Inspector Approved By: Brice A. Bickett, Chief Projects Branch 3 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Salem Nuclear Generating Station, Units 1 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.
List of Findings and Violations
Failure to Adequately Control Transient Combustibles Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.1] - 71152B NCV 05000272,05000311/2023010-01 Identification Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Salem Nuclear Generating Station, Unit 2, Technical Specification, Section 6.8.1, Procedures and Programs, for the licensees failure to implement requirements of the Fire Protection Program (FPP) procedure and to establish adequate guidance in the FPP. Specifically, the licensee did not control transient combustible materials in the 22 diesel fuel oil transfer pump (DFOTP) room in accordance with FPP procedure FP-AA-011, Control of Transient Combustible Materials, Revision 07 and this FPP contained instructions that approved transient combustible loading in the Unit 1 and Unit 2 DFOTP rooms in excess of that permitted in the fire hazard analysis (FHA) without engineering approval.
Additional Tracking Items
None.
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 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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the service water system. The corrective actions for a sampling of non-cited violations were evaluated as part of the assessment.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Problem Identification and Resolution Program Effectiveness: The inspectors determined that the licensee's problem identification and resolution program for Salem Units 1 and 2 was generally effective and adequately supported nuclear safety and security.
Assessment 71152B Identification The inspectors reviewed a sample of issues that have been processed through the licensee's problem identification and resolution program since the last biennial team inspection, including conditions adverse to quality, and NCVs of regulatory requirements. The team determined that, in general, the licensee identified issues and entered them into the corrective action program at a low threshold. However, the inspectors identified one finding of very low safety significance and two additional observations associated with the licensees control of transient combustible materials, which are documented below.
Assessment 71152B Prioritization and Evaluation Based on the samples reviewed, the inspectors determined that the licensees performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. In general, once a degraded or non-conforming issue was identified, the corrective action program was effective in directing equipment operability or functionality reviews. The licensee used a multi-discipline team consisting of department directors and managers to verify the corrective action notification categorization, evaluation method selection, and other actions adequately addressed the scope and significance of the documented issue.
Assessment 71152B Corrective Action Based on the samples reviewed, the inspectors determined that the licensee was generally effective in corrective action implementation. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems requiring the performance of a root cause evaluation or other causal evaluation methodologies were resolved in accordance with corrective action program requirements. The inspectors sampled assignments associated with violations that were identified previously by the NRC, and with licensee event reports. The inspectors determined that the corrective actions sampled were generally effective and timely.
Assessment 71152B Operating Experience Based on the samples reviewed, the inspectors determined that the licensees performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to Salem Units 1 and 2. When applicable, corrective action notifications were written, and actions were developed and implemented to prevent similar issues from occurring. Operating experience lessons-learned were communicated and incorporated into plant operations.
Assessment 71152B Self-Assessments and Audits Based on the samples reviewed, the inspectors determined that the licensees performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and quality assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold, and appropriately addressed by the licensee through the corrective action program.
Assessment 71152B Safety-Conscious Work Environment To determine whether underlying factors exist that would produce a reluctance to raise nuclear safety concerns, the inspectors conducted interviews with employees from a cross-section of the organization, including the Operations, Maintenance, Engineering, Security, Chemistry, Radiation Protection, and Emergency Preparedness departments. The inspectors also interviewed the Employee Concerns Program coordinators, reviewed the Employee Concerns Program case log, and selected case files, and results of safety culture assessments and surveys. The inspectors did not identify issues that represented challenges to the free flow of information, nor any underlying factors that could produce a reluctance to raise nuclear safety concerns. Based on inspection interviews and insights obtained from safety culture and other relevant assessments, the conditions at Salem Units 1 and 2 were conducive to a Safety-Conscious Work Environment.
Failure to Adequately Control Transient Combustibles Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.1] - 71152B NCV 05000272,05000311/2023010-01 Identification Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Salem Nuclear Generating Station, Unit 2, Technical Specification, Section 6.8.1, Procedures and Programs, for the licensees failure to implement requirements of the Fire Protection Program (FPP) procedure and to establish adequate guidance in the FPP. Specifically, the licensee did not control transient combustible materials in the 22 diesel fuel oil transfer pump (DFOTP) room in accordance with FPP procedure FP-AA-011, Control of Transient Combustible Materials, Revision 07 and this FPP contained instructions that approved transient combustible loading in the Unit 1 and Unit 2 DFOTP rooms in excess of that permitted in the fire hazard analysis (FHA) without engineering approval.
Description:
During a walkdown of the 22 DFOTP room on August 15, 2023, the inspectors noted a small bucket positioned under the 22 DFOTP collecting diesel fuel oil as it continuously dripped out, approximately 10 diesel fuel oil-saturated absorbent wipes on the floor, and a full 5-gallon plastic bottle which was filled with diesel fuel oil transferred from the bucket. The inspectors identified that a transient combustible permit (TCP) was not posted in the area and provided their concerns to the sites Operations staff. The Operations staff initiated NOTF 20943636, emptied the 5-gallon plastic bottle of fuel oil, and generated TCP-S2-2023-272 for the 22 DFOTP room. The inspectors reviewed NOTF 20940261 and noted that the leak on the 22 DFOTP had been present since July 3, 2023. The inspectors reviewed TCP-S2-2023-272 and the sites FHA and identified that the TCP was non-conservative.
Specifically, the 22 DFOTP TCP approved 1,025,000 BTUs of transient combustibles for the room without an engineering evaluation; however, the FHA calculation for the 22 DFOTP room only allowed 500,000 BTUs. The inspectors reviewed licensee procedure FP-AA-11 and noted that up to 5,000,000 BTUs is allowed for the DFOTP room without engineering approval. The licensee initiated NOTF 20943936 to evaluate this issue. The licensee evaluation determined that up to 1,025,000 BTUs of transient combustibles was allowable for the DFOTP room. In addition, the extent-of-condition for the non-conservative values listed in FP-AA-11 also applied to the 11, 12, and 21 DFOTP rooms and this error most likely occurred during the implementation of FP-AA-011, Control of Transient Combustible Materials, Revision 3, which became effective on January 6, 2015.
The team also noted that the licensee had several opportunities to identify and correct the transient combustible deficiencies prior to NRC team identification. In particular, the station missed opportunities to identify the performance gaps during the frequent handling of the collected fuel oil (emptying the bucket and the 5-gallon poly bottle) by equipment operators since July 3, 2023, as well as daily fire protection operator walkdowns in the 22 DFOTP room.
Corrective Actions: The licensee initiated NOTF 20943636, emptied the 5-gallon plastic bottle of diesel fuel oil, and generated TCP-S2-2023-272. Following the inspectors identification of the non-conservative TCP, the licensee initiated NOTF 209433936 to revise the TCP and correct the non-conservative values listed in FP-AA-11.
Corrective Action References: NOTFs 20943636 and 20943936.
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to implement and maintain the FPP as identified in CC-AA-211, Fire Protection Program was a performance deficiency. Specifically, the licensee did not control transient combustible materials in the 22 DFOTP room as required by procedure FP-AA-011, because on August 15, 2023, the inspectors identified transient combustible materials were left unattended and without a TCP. In addition, the licensee did not maintain adequate guidance in procedure FP-AA-011, because on August 17, 2023, the inspectors identified this procedure had been revised to allow transient combustible loading in the Unit 1 and Unit 2 DFOTP rooms in excess of that permitted in the FHA without engineering approval.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, the as-found fire loading was not within the previously analyzed limit identified in the FHA, without engineering approval, resulting in the potential increase in the fire severity for risk significant fire areas (DFOTP rooms). This finding was also similar to an example described in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, Example 4j. Moreover, the Salem FHA specified a limit of 500,000 BTUs of transient combustible loading without engineering approval and the as-found transient combustible loading in the 22 DFOTP room on August 15 was over 1,000,000 BTUs without an approved 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 team assigned the category to fire prevention and administrative controls. The team determined that the safety significance of the finding was very low because based on the significance determination process (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. [Question 1.4.1-A was answered no based on the fact that the fire hazard classification for the area remained low-low (< 30 minutes) with the increased transient combustible loading (actual as-found loading) and the fire severity was bounded by the most limiting passive fire protection feature (1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> rated fire damper in the room).]
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, licensee personnel did not implement the corrective action program (CAP) with a low threshold for identifying transient combustibles in critical buildings.
Enforcement:
Violation: Salem Units 1 and Unit 2 Technical Specification 6.8.1, state, in part, written procedures shall be established, implemented, and maintained for implementing the Fire Protection Program. Salems FPP implementing procedure CC-AA-211, Fire Protection Program, Section 4.26.3 states, in part that the Operation Fire Protection Program for Salem is controlled by procedure FP-AA-011, Control of Transient Combustible Materials. FP-AA-011 Section 4.1, Transient Combustible Control General Requirements, step 4.1.3.2 requires a TCP for staging any flammable liquid or combustible liquid inside a safety-related or critical building. In addition, FP-AA-011 Attachment 4, Transient Combustible Fire Load Established Limits, states Transient combustible fire load limits have been established for safety-related areas/rooms within the Salem and Hope Creek Stations and are specified in the Fire Hazard Analysis of each station. Section A states Battery Rooms and Diesel Generator Control Rooms are permitted to have 500,000 BTUs in each room without engineering approval. Section B states All other fire areas are permitted to have 5,000,000 BTUs per fire area without Engineering approval.
Contrary to the above, from July 3, 2023, to August 15, 2023, PSEG failed to implement FPP requirements as stated in FP-AA-011. Specifically, PSEG allowed the storage of up to 5.5 gallons of diesel fuel oil (> 1,000,000 BTUs) in the DFOTP room, within a critical building, without a TCP. Further, from January 6, 2015, to August 17, 2023, PSEG failed to establish adequate guidance in FP-AA-011 to effectively implement the FPP requirements. Specifically, FP-AA-0 Section B, allowed the approval of transient combustible loading that exceeded that permitted in the FHA in the U1 and U2 DFOTP rooms without engineering approval.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Less than Adequate Attention to Detail on Plant Tours 71152B The inspectors identified a number of deficiencies that were not previously captured in the licensees CAP. Specifically, the inspectors performed walkdowns of accessible plant areas and identified multiple conditions that had not been entered into the licensees CAP. The inspectors determined that the licensees failure to promptly identify and correct the adverse conditions was a performance deficiency.
The inspectors reviewed the conditions on an individual basis and determined that each issue was of minor significance in accordance with Appendix B of NRC Inspection Manual Chapter IMC 0612. The licensee entered each issue into their CAP.
Observation: Adverse Trend in Transient Combustible Control 71152B In September 2022, PSEG identified a Fleet adverse trend in transient combustible compliance and performed a common cause evaluation, CCE 70225729, to evaluate the trend and initiate corrective actions. The inspectors reviewed the licensees transient combustible controls to determine the effectiveness of the corrective actions. The inspectors identified nine transient combustible control-related performance gaps. The inspectors noted that fire protection operators (FPOs) perform a daily walkdown of all safety-related and critical buildings at Salem looking for transient combustibles and verifying the adequacy of existing TCPs in accordance with procedure SC.FP-SV.ZZ-0058, Inspection of Class 1 Fire Doors and Safety-Related Areas for Transient Combustibles. The inspectors noted that FPOs initiated only two NOTFs during the period April 1, 2023, through August 16, 2023. The inspectors determined that the corrective actions for CCE 70225729 were not yet fully effective based on the inspectors identified issues during this inspection. The licensee initiated NOTF 20943614 to address the shortcoming regarding FPO documentation of transient combustible issues during their rounds.
The inspectors reviewed the conditions on an individual basis and determined that the performance aspects of each issue were of minor significance in accordance with Appendix B of NRC Inspection Manual Chapter IMC 0612. The licensee entered each issue into their CAP.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 31, 2023, the inspectors presented the biennial problem identification and resolution inspection results to David Sharbaugh, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Calculations S-C-AF-MDC- Auxiliary Feedwater Hydraulic Analysis Revision 3D
0445
71152B Corrective Action NOTF No. 20765853
Documents 20879280
20883034
20885063
20887328
20890580
20906357
20907279
20925047
20927308
71152B Corrective Action NOTF No. 20943394
Documents 20943401
Resulting from 20943417
Inspection 20943418
20943419
20943514
20943547
20943559
20943560
20943561
20943562
20943584
20943598
20943599
20943602
20943608
20943614
20943636
20943682
20943736
20943739
20943745
Inspection Type Designation Description or Title Revision or
Procedure Date
20943746
20943749
20943772
20943774
20943775
20943779
20943780
20943799
20943817
20943830
20943833
20943836
20943838
20943839
20943855
20943856
20943858
20943859
20943866
20943919
20943920
20943932
20943934
20943936
20943969
20943973
20943975
20944010
20944012
20944013
20944064
20944085
20944110
20944167
20944168
20944169
Inspection Type Designation Description or Title Revision or
Procedure Date
20944170
20944171
20944178
20944179
20944253
20944256
20944259
20944260
20944261
20944262
20944421
20944423
71152B Miscellaneous LER 22-01-00 Salem Unit 2 Reactor Trip and Safety Injection
71152B Miscellaneous S1.OP-ST.DG- 1B Diesel Generator Surveillance Test 07/10/2023
0002
71152B Miscellaneous S1.OP-ST.DG- 1C Diesel Generator Surveillance Test 08/14/2023
0003
71152B Miscellaneous S2.OP-PT.SW- Service Water Fouling Monitoring Room Coolers 05/27/2023
0005
71152B Miscellaneous S2.OP-ST.DG- 22 Fuel Oil Transfer System Operability Test 08/09/2023
0005
71152B Miscellaneous SC.FP-SV.ZZ- Inspection of Class 1 Fire Doors and Safety-Related Areas 08/07 -
0058 for Transient Combustibles 08/20/2023
71152B Procedures IT-AA-3007 Cyber Security Monitoring Tool Response and Review Revision 4
71152B Procedures LS-AA-1003 NRC Inspection Preparation and Response Revision 18
71152B Procedures LS-AA-1006 NRC Cross-Cutting Analysis and Trending Revision 4
71152B Procedures LS-AA-126 Self-Assessment / Benchmarking Revision 20
71152B Procedures OP-AA-102-103 Operator Workaround Program Revision 3
71152B Procedures OP-AA-102-103- Operator Burdens Program Revision 2
1001
71152B Procedures RP-AA-500-103 10 CFR Part 37 Material Accountability Program Revision 0
71152B Procedures S2.OP-DL.ZZ- U2 Primary Plant Log Revision 25
0006-F1
71152B Procedures S2.OP-ST.SJ- High Head ECCS Check Valve Testing in Modes 1-3 Revision 5
22
71152B Procedures SC.FP-SV.ZZ- Inspection of Class 1 Fire Doors and Safety-Related Areas Revision 22
Inspection Type Designation Description or Title Revision or
Procedure Date
0058 for Transient Combustibles
71152B Procedures SC.OP-AB.ZZ- Adverse Environmental Conditions Revision 3
0001
71152B Procedures SY-AA-101-112 Searching Personnel, Vehicles, Packages and Cargo Revision 34
71152B Procedures WC-AA-106 Work Screening and Processing Revision 25
71152B Self-Assessments NOS-EP-23-001 2023 Emergency Preparedness Assessment 03/2023
71152B Self-Assessments NOS-HPC-22-02 Emergency Plan, Procedures, Facilities, and Interfaces Audit 04/2022
Report
71152B Self-Assessments NOSA-HPC-23- Materials Management and Procurement Engineering Audit 03/14/2023
(80133660) Report
71152B Self-Assessments NOSA-SLM-21- Radiation Protection Audit Report 09/27 -
10/7/2021
71152B Self-Assessments NOSA-SLM-21- Salem Operations, Operations Training, and FRC Audit 12/02/2021
Report
71152B Self-Assessments NOSA-SLM-22- Maintenance Audit Report 03/31/2022
(80131058)
71152B Self-Assessments NOSA-SLM-22- Chemistry, Radwaste, Effluent and Environmental Monitoring 05/16 -
Audit Report 06/01/2022
71152B Self-Assessments NOSA-SLM-22- Engineering Programs Audit Report 10/04/2022
(80132330)
71152B Self-Assessments NOSA-SLM-22- Surveillance and Test Programs Audit Report 11/30/2022
71152B Work Orders Order No. 50232315
219767
220086
220273
220800
222264
224677
227130
80134208
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