IR 05000272/2024010
| ML24137A106 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/16/2024 |
| From: | Glenn Dentel NRC/RGN-I/DORS |
| To: | Mcfeaters C Public Service Enterprise Group |
| References | |
| IR 2024010 | |
| Download: ML24137A106 (1) | |
Text
May 16, 2024
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - FIRE PROTECTION TEAM INSPECTION REPORT 05000272/2024010 AND 05000311/2024010
Dear Charles McFeaters:
On April 25, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Station, Units 1 and 2, and discussed the results of this inspection with Richard J. DeSanctis, Jr., Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
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 or severity 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, Glenn T. Dentel, Chief Engineering Branch 2 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: 05000272/2024010 and 05000311/2024010
Enterprise Identifier: I-2024-010- 0027
Facility: Salem Nuclear Generating Station, Units 1 and 2
Location: Hancocks Bridge, NJ
Inspection Dates: April 08, 2024 to April 25, 2024
Inspectors: J. Ayala, Senior Reactor Inspector B. Pinson, Senior Reactor Inspector J. Tifft, Reactor Inspector
Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team 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
Inadequate Control of Transient Combustible Material Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.2] - 71111.21N.
NCV 05000272,05000311/2024010- 01 Evaluation 05 Open/Closed The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of the Salem Unit 1 License Condition 2.C.(5) and Unit 2 License Condition 2.C.(10), for failure to implement and maintain in effect all provisions of the approved fire protection program (FPP) as described in the Final Safety Analysis Report for the facility.
Specifically, on April 13, 2024, the inspectors identified bulk transient combustible material (wood dunnage) stored on the roof of the safety-related Auxiliary Building. PSEG's FPP prohibits the storage of bulk combustible materials adjacent to safety-related buildings.
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.
REACTOR SAFETY
===71111.21N.05 - Fire Protection Team Inspection (FPTI)
Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
- (1) Fire Prevention/Barriers - Dampers and Door
- (2) Fire Protection Detection
- (3) Fire Suppression - Halon System
- (4) Turbine Driven Auxiliary Feedwater System
Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (1) Control of Transient Combustible Materials
- (2) Fire Brigade Training, Drills, and Qualifications
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
The inspectors verified the following:
a.
Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
b.
The adequacy of the design modification, if applicable.
c.
Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d.
The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
e.
Post-fire SSD operating procedures, such as abnormal operating procedures, affected by the modification were updated.
- (1) Modification Package 80111049 - Salem Unit 1 Chiller Replacement
- (2) Modification Package 80124609 - Salem 1B and 1D Vital Inverters Replacement
INSPECTION RESULTS
Inadequate Control of Transient Combustible Material Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.2] - 71111.21N.0 NCV 05000272,05000311/2024010- 01 Evaluation 5 Open/Closed The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of the Salem Unit 1 License Condition 2.C.(5) and Unit 2 License Condition 2.C.(10), for failure to implement and maintain in effect all provisions of the approved fire protection program (FPP) as described in the Final Safety Analysis Report for the facility.
Specifically, on April 13, 2024, the inspectors identified bulk transient combustible material (wood dunnage) stored on the roof of the safety - related Auxiliary Building. PSEG's fire protection program prohibits the storage of bulk combustible materials adjacent to safety -
related buildings.
Description:
On April 13, 2024, the inspectors performed a walkdown of the roof of the safety -
related Auxiliary Building. The inspectors observed several piles of wood dunnage and a transient combustible permit (TCP) for wood in the amount of 1,159,200,000 B ritish Thermal Units (BTU s). The TCP was initially issued in August 2020 and had been extended every six months. The TCP expired on February 16, 2024, therefore, the licensee had transient combustible material without an active TCP.
The team reviewed the licensee's response to Appendix A (B.2) to Branch Technical Position (BTP) APCSB 9.5 - 1. Appendix A (B.2) to BTP APCSB 9.5-1, requires that Effective administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety related buildings or systems during operation or maintenance periods. The licensee's response to the BTP states Procedure FP-AA- 011 includes measures to control the use of combustibles within the station, and to minimize the fire hazards presented by their use. Bulk storage of combustible materials is prohibited inside or adjacent to safety related buildings or systems. SC.ER-PS.FP- 0001-A2, Salem Fire Protection Report - Fire Hazards Analysis lists the Auxiliary Building as safety-related.
Procedure FP-AA- 011, Control of Transient Combustible Material, defines bulk combustibles of Class A materials as equal to or greater than 118,950,000 BTUs. While this definition of bulk storage does not appear to have a clear basis and is potentially non-conservative, the transient combustible permit issued in August 2020 for 1,159,200,000 BTUs exceeded the licensee's definition of bulk material.
Further, FP - AA- 011 states that TCP duration is limited to 60 days for online work and 90 days for outage work, and for longer term projects work dates can be for the duration of the approved project. The Class A bulk material was not removed after completion of the work and remained in a stored condition between work activities contrary to the licensees BTP B.2 response. Additionally, FP-AA- 011 states that if a TCP exceeds g reater than six months, the job supervisor should document the condition for an evaluation by engineering as a permanent plant change. This evaluation was never performed. This permit was extended every six months without this evaluation until it expired on February 16, 2004. The wood dunnage remained on the roof in a stored condition and without an evaluation past this expiration.
This issue is similar to NCV 05000311, 05000272/2019004- 01, where inspectors also observed bulk storage of wood dunnage on the roof of the Auxiliary Building. The licensee promptly removed the material from the roof. The licensee subsequently reintroduced the wood dunnage eight months later and failed to remove it upon completion of the work activities.
Corrective Actions: Upon identification by the inspectors, PSEG extended the TCP. On April 14, 2024, the licensee removed the wood dunnage from the roof of the safety-related Auxiliary Building. The licensee entered the issue into the corrective action program as Notification (NOTF) 20963353.
Corrective Action References: 20962374, 20963352, 20963353
Performance Assessment:
Performance Deficiency: The team determined that PSEG's failure to implement and maintain all provisions of the approved FPP was within PSEGs ability to foresee and correct; and is, therefore, a performance deficiency. Specifically, PSEG personnel did not identify bulk transient combustible material on the roof of the safety-related Auxiliary Building. As a result, the licensee stored bulk transient material when not in use for specific work activities from August 2020 to April 14, 2024.
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, bulk combustible material was stored on the unrated roof of a safety-related structure.
Additionally, this finding is similar to example 4.j described in IMC 0612, Appendix E, Examples of Minor Issues. Specifically, the amount of transient combustibles present in the area exceeded the maximum load limit allowed by the FPP procedure and the material remained in a stored condition following completion of the work activities.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors determined this finding to be under the Fire Prevention and Administrative Controls category, in accordance with Table 1.2.1, Finding Categories. In accordance with step 1.3.1-A, a low degradation rating was assigned. Therefore, the inspectors determined the finding is of very low safety significance (Green).
Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, after promptly removing the wood dunnage from the roof in 2019, PSEG reintroduced the wood dunnage and did not evaluate the significance of the amount of wood dunnage in the TCP and did not remove the material after completion of the work that led to bulk combustibles being stored adjacent to a safety-related building.
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 Updated Final Safety Analysis Report.
The Updated Final Safety Analysis Report, Section 9.5.1, "Fire Protection," states, in part that The Salem Fire Protection Program is described in several documents: [including] A program description which establishes the basis for the fire protection programThe report also provides a comparison to Appendix A of BTP APCSB 9.5-1. BTP-APCSB 9.5-1 Appendix A (B.2), states, in part that Effective administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety related buildings or systems during operation or maintenance periods. SC-ER-PS.FP-0001-A6, Salem Fire Protection Report - General, states the licensee's response to BTP-APCSB 9.5-1, Appendix A (B.2), in part, as Bulk storage of combustible materials is prohibited inside or adjacent to safety related buildings or systems.
Contrary to the above, from August 2020 to April 14, 2024, the licensee stored bulk combustible material adjacent to the safety-related Auxiliary Building. Specifically, the licensee issued a TCP approving transient combustibles (wood dunnage) that exceeded the licensees definition of bulk material and the material was not removed after completion of the work but rather remained in a stored condition between work activities.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Very Low Safety Significance Issue Resolution Process: Acceptance Criteria for 71111.21 Halon System Surveillance N.05 This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.
Description:
PSEG's halon system design includes four banks (Units 1 and 2 main banks, each with a reserve bank). Each bank is comprised of eight cylinders. Halon is the main suppression system for the R elay Room. PSEG procedure FP-AA- 005, Fire Protection Surveillance and Periodic Test Program, states, in part that the Relay Room halon system shall be demonstrated operable at least once per 6 months by verifying the combined volume of a bank of halon storage tanks' weight (2480 pounds by design) to be at least 95 percent of full charge weight (2356 pounds) for each main and reserve bank.
Procedure S1(2).FP-SV.FS- 0066, Relay Room Halon Cylinders Volume and Pressure Check, implements this surveillance and acceptance criteria. Per this procedure, each halon cylinder is weighed, and the aggregate weight of the cylinders is compared to the minimum required total halon amount listed in FP-AA- 005.
National Fire Protection Association (NFPA) 12A (1980), the code of record for the system, states in S ection 1-11.1.6 that each individual cylinder should be checked for a loss of more than five percent and if any fall below that, the individual cylinder shall be refilled or replaced.
The vendor manual for the system, 172432, Ansul Halon 1301 Fire Suppression Systems, also recommends testing each individual cylinder.
While PSEG is meeting the intent of the vendor manual and NFPA 12A by testing the weight of each individual cylinder, the last performance of the surveillance on March 30, 2024, identified that nine cylinders were below the 95 percent threshold. At least two cylinders in each of the four banks were identified as being below the 95 percent requirement. The surveillance determined that all four banks with weight aggregated met the licensees current acceptance criteria. While current operability requirements for the system are being met, PSEG is not meeting the maintenance requirements in the code of record by delaying when cylinders are refilled or replaced. Additionally, this surveillance procedure is designed such that cylinders will not be refilled or replaced until the halon system is inoperable, putting the system potentially in a state of inoperability without compensatory measures until it is discovered during the next surveillance.
Licensing Basis: NFPA 12A (1980) is the code of record for the halon system. Section 1-11.1.6, states that, At least semiannually, the agent quantity and pressure of refillable containers shall be checked. If a container shows a loss in net weight of more than 5 percentit shall be refilled or replaced.
Salem's FPP, SC.ER -PS.FP-0001-A6, lists NFPA 12A as used as guidance in the design of the Fire Protection Systems.
PSEG staff stated that an NRC -approved licensing action to add fire protection to the Technical Specification and subsequently remove them in accordance with the provisions of Generic Letter 86-10, accepted the licensee determination that halon cylinder recharging is required when the bank weight drops below 95 percent weight. Specifically, license amendment request, LCR 90- 15, dated August 2, 1991, and approved in NRC Safety Evaluation Report, dated January 5, 1993, approved the surveillance requirement language used in the licensee's procedure and states the requirement for demonstrating operability as:
At least once per 6 months by verifying the Halon storage tank weight to be at least 95% of full charge weight. The team determined that the use of the word "tank" was ambiguous, and documentation reviewed did not provide clarity as to whether "tank weight" as approved in the original Technical Specification meant an individual cylinder weight or a bank of cylinders weight.
Significance: For the purpose of the VLSSIR process, the inspectors screened the issue of concern through IMC 0612, Issue Screening, and determined the issue of concern would likely be greater than minor. The issue was also screened through IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP and determined that the issue of concern would screen as very low safety significance (Green).
Technical Assistance Request: No Technical Assistance Request was processed in support of this issue.
Corrective Action Reference: PSEG entered the issue into the corrective action program as Notification
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 25, 2024, the inspectors presented the fire protection team inspection results to Richard J. DeSanctis, Jr., Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Corrective Action 20869122
Documents 20869240
20869325
20869326
20869555
20869738
20869865
20869921
20869940
20896791
20896792
20935386
20929205
20951416
20953224
Corrective Action 20933110
Documents 20957132
Resulting from 20957245
Inspection 20957335
20962006
20962009
20962010
20962011
20962219
20962251
20962345
20962347
20962374
20962414
20962552
20962632
20962789
Inspection Type Designation Description or Title Revision or
Procedure Date
20962830
20962932
20963349
20963352
20963353
20963569
Miscellaneous 619495 Announced Fire Drill Scenario - Salem Unit 2 Condensate 03/11/2024
Polisher
619627 Announced Fire Drill Scenario - Salem U1 78' Electrical 03/21/2024
NLR-N90202 Request for Amendment 08/02/1991
(LCR 90-15)
NLR-N92107 Supplement to Request for Amendment 09/30/1992
(LCR 90-15)
Transient Aux Building Roof 04/11/2024
Combustible
Permit 30278101
Procedures CC-AA-211 Fire Protection Program Revision 6
FP-AA-005 Fire Protection Surveillance and Periodic Test Program Revision 6
FP-AA-011 Control of Transient Combustible Material Revision 8
FP-SA-003 Actions for Non-functional Fire Protection - Salem Station Revision 8
LS-AA-120 Issue Identification and Screening Process Revision 24
OP-SA-102-106-Master List of Timed Actions Revision 7
F1
S1.OP-AR.ZZ-Overhead Annunciators Window A Revision 59
0001
S2.OP-AB.CR-Control Room Evacuation Due to Fire in the Control Revision 36
0002(Q) Room, Relay Room, 460/230V Switchgear Room, or 4kV
Switchgear Room
S2.OP-AR.ZZ-Overhead Annunciator - Window A Revision 62
0001
SC-ER-PS.FP-Salem Fire Protection Report - General Revision 1
0001-A6
SC.ER-PS.FP-Salem Fire Protection Report - Fire Hazard Analysis Revision 1
Inspection Type Designation Description or Title Revision or
Procedure Date
0001-A2
SC.ER-PS.FP-Salem Fire Protection Report - Safe Shutdown Analysis Revision 2
0001-A3
Work Orders 80111049 Salem Unit 1 Chiller Replacement Revision 7
80124609 Salem 1B and 1D Vital Inverters Replacement Revision 1
10