IR 05000272/2020001

Integrated Inspection Report 05000272/2020001 and 05000311/2020001

ML20128J321
Person / Time
Site:	Salem
Issue date:	05/07/2020
From:	Brice Bickett Reactor Projects Branch 3
To:	Carr E Public Service Enterprise Group
References
IR 2020001
Download: ML20128J321 (19)

Text

May 7, 2020

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000272/2020001 AND 05000311/2020001

Dear Mr. Carr:

On March 31, 2020, 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 Mr. David Sharbaugh, Plant Manager and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. One of these findings 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 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 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, X /RA/

Signed by: NRC-PIV Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000272 and 05000311 License Nos. DPR-70 and DPR-75

Enclosure:

Inspection report 05000272/2020001 AND 05000311/2020001

Inspection Report

Docket Numbers: 05000272 and 05000311 License Numbers: DPR-70 and DPR-75 Report Numbers: 05000272/2020001 and 05000311/2020001 Enterprise Identifier: I-2020-001-0030 Licensee: PSEG Nuclear, LLC Facility: Salem Nuclear Generating Station, Units 1 and 2 Location: Hancocks Bridge, NJ 08038 Inspection Dates: January 01, 2020 to March 31, 2020 Inspectors: J. Hawkins, Senior Resident Inspector M. Hardgrove, Resident Inspector D. Kern, Senior Reactor Inspector S. Wilson, Senior Health Physicist Approved By: Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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

FLEX Auxiliary Feedwater Pump Oil Unacceptable Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems FIN 05000272,05000311/2020001-01 Challenge the Open/Closed Unknown A Green finding was identified by the inspectors for PSEG not following their procedures for the implementation of Salems Final Integrated Plans for Beyond Design Basis FLEX Mitigating Strategies, EM-SA-100-1000. Specifically, PSEG did not follow their preventive maintenance (PM) process procedures for the periodic inspection and maintenance of the FLEX Auxiliary Feedwater (AFW) pumps.

Inadequate Corrective Action for Vital Instrument Bus Inverter Failure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71152 Systems NCV 05000272,05000311/2020001-02 Evaluation Open/Closed A self-revealing Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, was identified because PSEG did not adequately implement, in part, procedure LS-AA-125, Corrective Action Program (CAP), requirements to address a condition adverse to quality (CAQ) in a timely manner associated with previous equipment failures. Specifically, PSEG did not implement adequate or timely corrective actions (CAs) to address vital instrument bus (VIB)inverter failures that were the result of vendor preventive maintenance (PM)recommendations, or equivalent strategy, not being incorporated into their PM program. As a result, PSEG experienced multiple failures of the VIB inverters in 2019, causing multiple entries into short duration Technical Specification Limiting Conditions of Operations and VIB inverter inoperability.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On February 25, 2020, the unit was tripped from 20 percent power due to equipment challenges with a steam generator tube leak. A reactor startup was commenced on March 26, 2020, and the unit reached rated thermal power on March 28, 2020. The unit remained at or near rated thermal power for the remainder of the inspection period.

Unit 2 began the inspection period at rated thermal power. The unit 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/readingrm/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. From January 1 - March 19, 2020, the inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Common, mitigating system performance index (MSPI) auxiliary feedwater pump on January 24

(2) Unit 1, midloop operations with steam generator nozzle dams installed and decay heat-pressurizer vent path on March 10

(3) Unit 2, service water walkdown with 25 service water pump out for maintenance on January 13

(4) Unit 2, chill water system during 11 chiller replacement on January 16

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) Common, 1FP30 cross-tie valve failed to open on January 13

(2) Unit 1, chiller room during hot work for 11 chiller replacement on February 12

(3) Unit 1, IFP126 and IFP161 FP deluge header leak on March 3

(4) Unit 2, diesel generator area during 2B emergency diesel generator run on January 6

(5) Unit 2, diesel generator area (FP-SA-2555) Elevation 100' on February 25

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1, 13 TDAFW pump enclosure 84' elevation on January 20

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 1, spent fuel pool heatup rate analysis on March 4

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during the Unit 1 downpower to 20% to trip reactor following 14 steam generator tube leak on February 25

(2) The inspectors observed and evaluated licensed operator performance in the Control Room during the Unit 1 Startup of reactor following manual reactor trip for loss of 11 MG set on March 26

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator re-qualification training on January 21

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) Common, station blackout emergency diesel generator battery failure on January 8

(2) Common, flex auxiliary feedwater pump oil issues on January 20

(3) Common, chiller motor magnetic shading rings on February 3

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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, yellow shutdown risk for equipment hatches and 11 chiller replacement following forced outage for 14 steam generator tube leak on February 27

(2) Unit 1, drain down of reactor coolant system (RCS) to reactor flange for forced outage following 14 steam generator leak on March 2

(3) Unit 1, midloop operations with orange risk for start up following 14 steam generator tube leak forced outage on March 14

(4) Unit 2, 2B emergency diesel generator jacket water leak on January 6

(5) Unit 2, main turbine valve testing interval exceeding frequency on January 6

(6) Unit 2, spent fuel pit heat exchanger 2CC34 outlet relief valve on January 21

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (10 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Common, FLEX auxiliary feedwater pump unacceptable oil on January 14

(2) Common, containment fan cooling unit bearings PC-4 versus PC-2 on January 27

(3) Common, 12 & 22 service water pumps stiffener plates nonconforming on March 23

(4) Unit 1, 250 volt DC batteries degraded prior to scheduled replacement and performance discharge (capacity) tests on January 8

(5) Unit 1, decay heatup rate when in midloop with steam generator nozzle dams and no core alternations on March 10

(6) Unit 1, 1RR8-pressurizer safety loop drain seal leak on March 10

(7) Unit 1, reactor vessel level instrumentation system train A & B sensor CAL005 valves on March 24

(8) Unit 2, reactor head vent valves nonconforming due to Part 21 issue on February 3

(9) Unit 2, 2B emergency diesel generator R9 cylinder leak during loaded run on February 4

(10) Unit 2, replacement steam generators low temperature post-weld heat treatment on February 4

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Common, service water pump discharge header modification with stiffener addition on January 31

(2) Unit 2, implementation of Taverage (end of the cycle) coastdown to refueling outage on March 22

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)

The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:

(1) Common, 1FP30 fire protection header cross tie valve on February 3

(2) Unit 1, containment spray add tank safety relief values replacement of 1CS12, 1CS13, 1CS26 on January 7

(3) Unit 1, 1PS1 large packing leak on March 12

(4) Unit 2, 24 containment fan cooling unit service water supply valve 24SW58 failed closed stroke time on January 8

(5) Unit 2, 21 safety injection pump 2SJ1 motor clean, inspection, megger and breaker replacement on January 28

(6) Unit 2, 22 service water pump discharge head stiffener installation on January 30

(7) Unit 2, 22 auxiliary building supply fan on February 3

(8) Unit 2, 23 chiller not initiating pump down sequence on February 13

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the forced maintenance outage for Unit 1 following 14 steam generator tube leak from February 26 to March 28

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1, 1A emergency diesel generator monthly surveillance testing, S1.OP-ST.DG-0001 on February 24

(2) Unit 2, 2A emergency diesel generator monthly surveillance testing,

S2.OP-ST.DG-0001 on February 24 Inservice Testing (IP Section 03.01) (2 Samples)

(1) Unit 1, containment ventilation valves modes 5 & 6 inservice testing on March 3

(2) Unit 2, 22 auxiliary feedwater pump inservice testing on January 8

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) The inspectors observed an emergency preparedness drill on February

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) Unit 1 steam generator secondary side in-service inspection. Continuous radiation protection technician coverage involved due to the generator being >1000 mrem/hr at 30 centimeters inside the access opening.

(2) Unit 1 steam generator eddy-current inspection and remote monitoring. Significant contamination, dose exposure, and airborne radioactive contamination monitoring.

(3) Unit 1 refueling operations in containment High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Unit 1 containment building sump locked high radiation area

(2) Unit 1 steam generator primary manways locked high radiation area

(3) Unit 1 steam generator secondary hand-holes locked high radiation area

(4) Unit 1 Fuel transfer tunnel very high radiation area

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1)

• Control room envelope ventilation and filtration

• Fuel storage ventilation and filtration

• Auxiliary building ventilation and filtration

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) The inspectors observed the storage and use of portable vacuum systems and temporary ventilation systems.

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1)

• The inspectors evaluated the licensees use of respiratory protection devices.

• The inspectors evaluated the licensee's qualification program for respiratory protection users.

• The inspectors evaluated the licensee's fit-testing program.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments for actual internal exposures:

(1) No internal dose assessments were performed for the inspection period.

(2) The inspectors reviewed the licensee's screening method for screening intakes.

The inspectors reviewed the whole body counts for two individuals that met the screening monitor alarm setpoint on initial (arrival) screening.

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Neutron dose tracking and monitoring for at-power containment entries

(2) Use of multi-pack dosimetry for reactor disassembly and reactor cavity decontamination

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1, January 1, 2019 - December 31, 2019

(2) Unit 2, January 1, 2019 - December 31, 2019 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (2 Samples)

(1) Unit 1, January 1, 2019 - December 31, 2019

(2) Unit 2, January 1, 2019 - December 31, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)

(1) Unit 1, January 1, 2019 - December 31, 2019

(2) Unit 2, January 1, 2019 - December 31, 2019

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Required Preventive Maintenance (PM) Not Generated, Scheduled, and/or Performed for 21 Environmental Qualification (EQ) Program Components (NCV

05000272,05000311/2019011-01) 71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)

(1) Unit 1, 14 steam generator tube leak on February 25

(2) Unit 1, manual trip of reactor during startup following loss of 11 MG Set with 12 MG Set out of service on March

INSPECTION RESULTS

FLEX Auxiliary Feedwater Pump Oil Unacceptable Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.11] - 71111.15 Systems FIN 05000272,05000311/2020001-01 Challenge the Open/Closed Unknown A Green finding was identified by the inspectors for PSEG not following their procedures for the implementation of Salems Final Integrated Plans for Beyond Design Basis FLEX Mitigating Strategies, EM-SA-100-1000. Specifically, PSEG did not follow their preventive maintenance (PM) process procedures for the periodic inspection and maintenance of the FLEX Auxiliary Feedwater (AFW) pumps.

Description:

PSEG is committed to comply with NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, and NRC Order on Mitigation Strategies, EA-12 049. Section 11.5.2 states that portable equipment that directly performs a FLEX mitigation strategy for the core, containment, or spent fuel pool should be subject to the maintenance and testing guidance provided in INPO AP 913, Equipment Reliability Process, to verify proper function. The maintenance program should ensure that the FLEX equipment reliability is being achieved. Standard industry templates (e.g., EPRI) and associated bases will be developed to define specific maintenance and testing. In complying with NRC Order EA-12-049, PSEG implemented EM-SA-100-1000. Section 2.18.7 states that FLEX mitigation equipment is subject to periodic maintenance and testing to verify proper function.

The FLEX AFW pumps are scoped into PSEGs PM process, ER-AA-210, which defines periodic testing and maintenance and follows the PM template requirements in EPRIs Preventive Maintenance Basis for FLEX Equipment - Project Overview Report (EPRI Report 3002000623), dated September 2013.

The FLEX AFW Pumps are used in Phase 2 of the FLEX Mitigating Strategies as described in EM-SA-100-1000. These pumps are primarily used to supply water to the steam generators for reactor core cooling and heat removal after the turbine driven AFW (TDAFW)pump becomes unavailable and can also be used to provide cooling water to the spent fuel pool and backup the FLEX charging pumps. On December 30, 2019, the inspectors performed a walk down of the three FLEX AFW pumps noting discoloration and separation of the oil inside the bubblers of all three pumps. PSEG documented this condition in NOTF 20842868 and initiated actions to sample and analyze the oil from all three pumps (60145349). On January 14, 2020, PSEG documented that each of the oil samples were found unacceptable.

PSEGs evaluations (WGE 70211238, TEs 70211302, and 70211766) found that the most likely cause of the unacceptable oil was residual water left in the bearing reservoirs during initial installation (November 2015). PSEG found that the presence of water in lubricating oil can cause oxidation to increase tenfold, resulting in premature aging of the oil. If the oil in the FLEX AFW pump reservoir were to emulsify because of mixing, the effects would age the lubricant by a factor of 100. This emulsified oil could cause the operating temperature to be higher. Typically, this type of oil has a useful life of 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (at 180F) and 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> at 220F with no water present. However, with the amount of water found in the FLEX AFW pump oil, the useful life is reduced to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> (at 180F) and 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (at 220F).

PSEG concluded that if the water and oil emulsified, the FLEX AFW pumps would have operated for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, which would provide time for operator intervention, as this condition would be evident during a walkdown of the equipment.

The inspectors reviewed these conclusions and noted the following:

• For a previous water in oil issue on an important to safety pump, PSEG confirmed that the viscosity is the primary indication of the lubricating ability of the oil.

Excessive water content in oil will cause the oils viscosity to either increase or decrease. Deviations of >10 percent in viscosity in either direction are immediately detrimental to the oils ability to reduce friction, cool, and clean the moving components of the associated equipment. (PSEG order 70173676)

• VTD 903037, FLEX AFW pump,Section VI Care and Maintenance, A. Lubrication -

Bearings, 2. States that Under normal operating conditions, a good grade of oil will be suitable for 6 months to one year between changes, as long as it is free of contaminants. A small sample of oil should be drained from the bearing housing periodically. Any cloudiness, turbidity, discoloration or presence of solids is evidence of contamination, and the oil should be changed immediately. The inspectors found no periodic sampling of the oil occurred or was planned since 2015, and, also verified the pump casing internals were not made of corrosion resistant material (cast iron).

• PSEG order 80112509-0010 for the FLEX AFW and charging pump PM states that the basis for these new MPs (maintenance plans) is contained in NEI order EA-12-06 and NRC order EA-12-049 regulations. The PM program associated with these regulations is required to be in place by November 1, 2014. The EPRI template for this equipment was consulted. Per this order, a six month MP was created to inspect the pumps condition, but the six month inspection never noted oil or water in the pump oil bubblers.

• PSEG procedure SC.OP-PM.FLX-0001, FLEX Standby Equipment Status Checks, 1, FLEX AFW and CV Status Verification, acceptance criteria 3 states pump bearing oil levels satisfactory. This is a monthly status check to verify the oil level in the pump bubblers, but this check never identified degraded oil in the bubblers.

• Surface rust on the shafts of all three pumps. PSEG documented and evaluated this in TE 70211766. PSEGs corrective actions will monitor rust on the pump shafts by adding inspections of the shaft to the existing six month PM.

Based on the information above, the inspectors determined that PSEG did not follow EM-SA-100-1000. Specifically, PSEG did not follow their PM process procedures for the periodic inspection and maintenance of the FLEX AFW pumps which raised reasonable doubts about the likeliness that the FLEX AFW pumps would function when called upon.

Corrective Actions: PSEGs corrective actions involved replacing the oil in all three FLEX AFW pumps and creating periodic MPs that ensure that the oil in the pumps is sampled.

Corrective Action References: 70211238, 70211302, 70211739, and 70211766.

Performance Assessment:

Performance Deficiency: The inspectors determined that PSEG did not follow EM-SA-100-1000. Specifically, PSEG did not follow their PM process procedures for the periodic inspection and maintenance of the FLEX AFW pumps which was a performance deficiency that was within their ability to foresee and correct, and which should have been prevented.

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.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for at Power, Exhibit 2 -Mitigating Systems Screening Questions, Section E for Flexible Coping Strategies (FLEX). The finding screened to Green, very low safety significance, because it did not involve aspects credited for the sole purpose of satisfying the requirements of Orders EA-12-051 (Spent Fuel Pool Instrumentation) and/or EA-13-109 (Containment Venting), and it did not involve deficient procedures, training, and/or other programmatic aspects or a failure, unavailability, or degradation of equipment that resulted in a complete loss of the ability to maintain or restore core cooling or containment capabilities for an exposure period greater than the out of service time allowed in the licensees FLEX final integrated plan.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because PSEG did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.

Specifically, individuals involved with creating PM activities for FLEX equipment and performing frequent checks of the equipment did not recognize and plan for the latent issues with the oil and the inadequate performance of the periodic PM. [H.12]

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Inadequate Corrective Action for Vital Instrument Bus Inverter Failure Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.2] - 71152 Systems NCV 05000272,05000311/2020001-02 Evaluation Open/Closed A self-revealing Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, was identified because PSEG did not adequately implement, in part, procedure LS-AA-125, Corrective Action Program (CAP), requirements to address a condition adverse to quality (CAQ) in a timely manner associated with previous equipment failures. Specifically, PSEG did not implement adequate or timely corrective actions (CAs) to address vital instrument bus (VIB)inverter failures that were the result of vendor PM recommendations, or equivalent strategy, not being incorporated into their PM program. As a result, PSEG experienced multiple failures of the VIB inverters in 2019, causing multiple entries into short duration Technical Specification Limiting Conditions of Operations and VIB inverter inoperability.

Description:

Each Salem Unit has four VIB inverters that provide a reliable source of uninterruptible 115 VAC power during normal plant operations to the safety-related VIBs. In NRC Inspection Report 2017004 (ML18039A899), the inspectors reviewed a failure of the 1A VIB inverter and determined that PSEG did not fully evaluate and address vendor recommendations from a 2010 bulletin to replace capacitors in the inverters every seven to eight years due to the potential for inverter failures during loading. The inspectors found that PSEG had reviewed the bulletin but failed to justify not incorporating the recommendations into the PM program, which could have prevented the failure of the 1A VIB inverter.

Recently, Salem has experienced more VIB inverter failures, including:

• On January 24, 2019, the 2D VIB inverter failed due to a logic power supply (LPS)card failure. PSEG found (ERE 70205493) that the recommendations in the 2010 Cyberex bulletin were not appropriately addressed and had a PM replaced the LPS before 7 years, this failure may have been prevented.

• On October 24, 2019, PSEG determined the 1C VIB inverter failed due to an LPS card failure from electrical overstress or aging (ERE 70209949; 6.5 years old).

The inspectors reviewed PSEGs CAs from FIN 2017004-05 (ERE 70191881; ACE 70192996) and found no CA or action (ACIT) that addressed evaluating the 2010 bulletin to ensure that the appropriate vendor recommendations or replacement strategy had been incorporated into the sites PM program. The inspectors noted a missed opportunity to correct the 2017 issue when PSEG reviewed the 2010 bulletin and documented NOTF 20776326 on October 2, 2017. PSEG's review generated a PM change request (PCR 70196825) to change the maintenance strategy for the LPS cards from a 12 to 6-year replacement frequency due to the extensive industry experience and the internal maintenance history but was not approved and incorporated before the recent failures occurred.

PSEGs CAP procedure, LS-AA-125, Section 2.7 states that a condition report corrective action (CRCA) is an action to restore or address the cause of a CAQ. Section 1.1.1.2 states that CAs fix or minimize the consequence of the unacceptable condition to acceptable levels. This procedure also defines extent of condition (EOC) as the extent to which the actual condition exists with other equipment. Section 4.2.3.2, Station Management Review Committee Requirements, states to review completed CAP products to ensure EOC is appropriate to the significance and risk presented by the originating issue.

Based on the above, the inspectors determined that PSEGs review and implementation of the corrective action program from the 2017 issue did not correct the adverse condition and incorporate the appropriate vendors recommendations from the 2010 bulletin or supportable maintenance replacement strategy for VIB into the PM program.

Corrective Actions: PSEGs CAs included repairing the failed inverters and replacing the LPS cards. PSEG also approved changes to the PM strategy for the LPS cards, increasing the frequency of replacement from 12 to 6 years. PSEG also evaluated the 2010 bulletin to ensure all the PM recommendations were incorporated into the VIB inverter PM strategy.

Corrective Action References: 70205493 and 70209949

Performance Assessment:

Performance Deficiency: The inspectors determined that PSEG not implementing adequate or timely CAs to address VIB inverter failures that were the result of vendor PM recommendations not being incorporated into the PM program was a performance deficiency within their ability to foresee and correct and which should have been prevented.

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. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found this issue was similar to Example 13.a for Service Life, in that if left uncorrected, the issue had the potential to lead to a more significant safety concern.

Specifically, operating the VIB LPS cards beyond the documented time period for replacement could cause more failures and potential unavailability of the VIB inverters.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated December 20, 2019, and determined this finding was of very low safety significance (Green) because Yes was not answered to any of the screening questions.

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. The inspectors determined that this finding had a cross-cutting aspect in Problem Identification and Resolution, Evaluation, because PSEG did not thoroughly evaluate the identified CAQ in 2017 to ensure that the resolutions addressed the causes and extent of conditions commensurate with their safety significance. [P.2]

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the above, from February 8, 2018, until January 17, 2020,PSEG did not adequately implement, in part, procedure LS-AA-125, Corrective Action Program (CAP),requirements to correct a condition adverse to quality (CAQ) in a timely manner associated with previous vital instrument bus (VIB) inverter failures. Specifically, PSEG did not promptly implement a VIB inverter replacement strategy into its PM program that was appropriate or consistent with vendor recommendations and site operating experience which contributed to additional failures.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Evaluation and Corrective Action to Address Missed Environmental 71152 Qualification (EQ) Component Preventive Maintenance The inspectors selected the non-cited violation (NCV) for preventive maintenance (PM) not performed or scheduled for environmentally qualified (EQ) components as an annual sample because the central cause of the performance deficiency had the potential to also adversely affect non-EQ safety-related components. Inspection scope included review of issue documentation and prioritization, causal evaluation, corrective actions for the affected 21 EQ components, and assessment of the extent-of-condition for non-EQ components.

The inspectors concluded PSEG staff appropriately documented the NCV in the corrective action program, evaluated the issue and initiated corrective actions which addressed the cause of the condition adverse to quality in a timely manner, commensurate with its safety significance. Following inspectors' interactions, actions to evaluate and perform missed PMs for non-EQ components, as part of the extent-of-condition review, were documented in the corrective action program and were in progress at the time of this inspection (notifications 20845110 and 20845224). The inspectors concluded the delay in evaluating whether non-EQ PMs were missed was minor, because the cause of the NCV was not directly applicable to non-EQ PMs and the inspectors did not identify adverse impact on the reliability and availability of non-EQ equipment.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 16, 2020, the inspectors presented the RP Inspection debrief for In-Plant Airborne Radioactivity and Occupational Dose Assessment; inspection procedures (71124.03 and IP 71124.04) inspection results to Mr. David Sharbaugh, Plant Manager and other members of the licensee staff.

• On March 31, 2020, the inspectors presented the integrated inspection results to Mr. David Sharbaugh, Plant Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71124.03 Corrective Action 20843335 Notification for neutron dose omission from an individuals January 9,

Documents dose record. 2020

Procedures RP-AA-443 Quantitative Respirator Fit Testing Revision 9

RP-AA-825 Maintenance, Care and Inspection of Respiratory Protective Revision 6

Equipment

71124.04 Corrective Action 20832555 Notification for lost dosimeter September

Documents 12, 2019

Self-Assessments Technical Support Hope Creek/Salem Nuclear Generating Stations Passive Revision 00

Document No. Internal Monitoring Evaluation

15-103

Technical Support Passive Monitoring Sensitivity Study at Salem/Hope Creek Revision 00

Document No. Nuclear Generating Station

18-096

71152 Corrective Action 20830411

Documents 20832938

20834440

Corrective Action 20845110

Documents 20845224

Resulting from

Inspection

Procedures WC-AA-111 Work Management - Predefine Process Revision 9

16