IR 05000354/2020003
| ML20308A403 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 11/04/2020 |
| From: | Brice Bickett Reactor Projects Branch 3 |
| To: | Carr E Public Service Enterprise Group |
| References | |
| IR 2020003 | |
| Download: ML20308A403 (15) | |
Text
November 4, 2020
SUBJECT:
HOPE CREEK NUCLEAR GENERATING STATION - INTEGRATED INSPECTION REPORT 05000354/2020003
Dear Mr. Carr:
On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Nuclear Generating Station. On October 7, 2020, the NRC inspectors discussed the results of this inspection with Mr. Thomas Agster, Acting Plant Manager and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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 No 05000354 License No. NPF-57
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Hope Creek Nuclear Generating Station, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
The Hope Creek Generating Station (Hope Creek) began the inspection period at approximately 100 percent rated thermal power (RTP). On August 28, a planned load reduction to approximately 70 percent RTP was conducted, to perform a control rod pattern exchange and maintenance on various balance-of-plant components. Power was restored to approximately 100 percent RTP on August 29. The station remained at or near 100 percent RTP 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 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 and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted. As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. 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 some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated stations readiness to cope with external flooding on August 3 through August 5
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) A and B divisions station service water system during work on reactor auxiliary cooling system heat exchanger header supply valve on July 27 (2)
'C' residual heat removal (RHR) system while 'A' RHR was out of service for maintenance on July 29
- (3) A and C core spray system on September 8
- (4) D emergency diesel generator fuel oil system with G fuel oil transfer pump out of service for testing on September 17
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) Reactor building north motor control center area and elevator machine room on July 6
- (2) High pressure coolant injection pump and turbine room, and electrical equipment room on July 27
- (3) Control area HVAC equipment rooms 5602 and 5630 on July 30
- (4) B and D emergency diesel generator rooms on August 13
- (5) D residual heat removal pump room on August 26
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated fire brigade performance during a tabletop drill exercise on September 1
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 a planned load reduction to perform a rod pattern adjustment and planned maintenance activities on August 28 and 29
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a crew of licensed operators in the plant's simulator during a licensed operator requalification training on August 17
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Control area ventilation system for Maintenance Rule (a)(1) status on September 24
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Emergent work to address D filtration, recirculation, and ventilation system fan, D emergency diesel generator recirculation fan, and control area ventilation fan trips on August 6
- (2) Planned high risk lift of a loaded spent fuel dry cask storage transfer canister on August 11
- (3) Planned inoperability of reactor core isolation cooling system during in-service testing on August 21
- (4) Planned inoperability of D core spray during maintenance on September 24
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Reactor protection system following panel 10C609 relay contact cycling on July 23
- (2) D emergency diesel generator following a recirculation fan trip on August 20
- (3) FLEX diesel generator output breaker as-found trip settings nonconforming to calculation of record on August 11
- (4) Standby liquid control system following squib continuity and heat trace temperature indication issues on September 3
- (5) High pressure coolant injection system with steam admission valve leak-by occurring following surveillance runs on September 22
- (6) A1 safety and turbine auxiliary cooling system heat exchanger service water outlet motor operated valve thermal overload failure on September 22
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) D residual heat removal pump following planned maintenance on July 21
- (2) Reactor core isolation cooling system level 2 actuation and level 8 steam supply isolation relays following replacement on July 24
- (3) A control room ventilation system installation of new damper controller on August 6
- (4) Reactor manual control system following transformer replacement on August 19
- (5) D and E safety relief valve automatic depressurization system auxiliary relays following replacement on September 16
- (6) D core spray following valve maintenance on September 25
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) HC.OP-IS.BD-0001, reactor core isolation cooling system quarterly test on August 20
- (2) HC.OP-IS.BC-0003, B residual heat removal pump quarterly test on September 11
- (3) HC.OP-ST.KJ-0004, emergency diesel generator 1DG400 operability test on September 14
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) HC.OP-IS.BJ-0101, high pressure coolant injection system valves in-service test on July 8
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Simulator training evolution for licensed operators, with associated emergency preparedness drill and exercise performance criteria, on August
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated radiological protection-related instructions to plant workers.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material.
- (1) Observed licensee surveys of potentially contaminated material leaving the RCA
- (2) Observed workers exiting the RCA
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.
- (1) Observed workers during removal of spent fuel transfer cask from spent fuel pool. This work involved work in high radiation areas, neutron radiation areas, contaminated areas and dose gradients?
- (2) Observed workers performing radiological instrument response checks in high dose fields
- (3) Observed workers performing radiological instrument calibrations in high dose fields
- (4) Observed worker briefings for entry into high radiation areas and contaminated areas
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Observed TIP room controls. This was a very high radiation area.
- (2) Observed high radiation area key control inventory
- (3) Observed worker briefings and reviewed radiation work permits for entry into high radiation areas
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices including the licensee's TEDE ALARA reviews for TORUS repair work completed in October of 2019.
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 through a review of the licensee's 10 CFR Part 61 review for 2019.
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 including the neutron energy response of dosimeters.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments for actual internal exposures:
- (1) Bioassay and dose assessment for an individual that had a potential internal exposure dated April 20, 2020. The individual was determined to have external contamination.
- (2) Bioassay and dose assessment for an individual that had a potential internal exposure dated October 19, 2019. The individual was determined to have external contamination.
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (8 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Radwaste Sample Station Area Radiation Monitor, H0SD -0SDRE-6639 Spent fuel pool storage area radiation monitor H1SD -1SDRE-6607 New fuel storage area radiation monitor H1SP -1SPRE-4813A New fuel storage area radiation monitor H1SP -1SPRE-4813B TIP room radiation detector H1SD -1SDRE-6640A Noble gas effluent monitor RY-4873B Noble gas effluent monitor flow element FE-4873A/B Radioactive waste liquid effluent monitor RE-4861 (2)
(3)
(4)
(5)
(6)
(7)
(8)
Calibration and Testing Program (IP Section 03.02) (15 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Canberra Multi-Channel Analyzer, Model GC2518, Detector 1-S/N 04047758
- (2) Fastscan whole body counter at the PSEG Processing Center
- (3) Eberline RM14 number H6088
- (4) Eberline RM14 number H6092
- (5) Ludlum 2360 number S312718
- (6) Ludlum 2360 number S312728
- (7) Ludlum 9 number H316383
- (8) Ludlum 9 number S316388
- (9) Eberline E520 number S1175
- (10) Mirion telepole number S6610-023
- (11) Mirion telepole number S6610-064
- (12) Mirion telepole number S6610-074
- (13) Eberline RO2E number 2721
- (14) Eberline RO2E number 2824
- (15) Eberline AMS4 number S12968
Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Liquid radioactive waste effluent monitor number RE-4861
- (2) Noble gas effluent monitor and flow element numbers RY-4873B and FE-4873A/B
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS07: High Pressure Injection Systems (IP Section 02.06)===
- (1) July 1, 2019 - June 30, 2020
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) July 1, 2019 - June 30, 2020
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) July 1, 2019 - June 30, 2020
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) July 1, 2019 - June 30, 2020
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Review of corrective actions associated with notification 20833732 to address the extent of cause for C emergency diesel generator jacket water pump seal failure on August 25
- (2) Pellet-Cladding Interaction related fuel failures in fuel cycle 22 (Root Cause Evaluation: 70202192)
INSPECTION RESULTS
Observation: Pellet-Cladding Interaction related fuel failures in fuel cycle 22 (Root Cause Evaluation: 70202192)71152 The inspectors reviewed PSEG's evaluation and corrective actions associated with Pellet-Cladding Interaction (PCI) related fuel failures that were identified in the previous fuel cycle (fuel cycle 22) which ended in the Fall of 2019. PCI is a degradation mechanism that occurs when fuel pellets within the fuel rod swell and contact the fuel cladding. PCI related fuel leaks occur due to stress-corrosion cracking of the fuel cladding. In a new fuel rod, there is a gap between the fuel pellet and the fuel cladding. As the fuel pellet is irradiated, it expands and the gap closes, putting the fuel pellet in direct contact with the fuel cladding. This stress is highly dependent on the rate of change of local power, which is the basis for establishing fuel conditioning or PCI rules, thresholds, and ramp rates to control the rate of local power change during the fuel cycle.
During the months of June and July 2018, elevated Offgas readings at Hope Creek identified the presence of fuel defects in operating fuel cycle. Immediate corrective actions taken by PSEG, at that time, included conducting Power Suppression Testing (PST) which resulted in the full insertion of three control rods at core locations 22-31, 30-39, and 38-31 to suppress reactor power in these areas of the core. Additional corrective actions included convening a Failed Fuel Monitoring Team (FFMT) to meet on a regular basis over the course of the remaining months of fuel cycle 22, and adoption of an Adverse Condition Monitoring Plan (ACMP) to increase the frequency of Offgas and Reactor Coolant System chemistry samples.
Following completion of the final PST on July 20, 2018, Offgas radioactivity readings were generally low, with no additional fuel failure indications. Reactor Coolant System activity never increased above background levels for the remainder of the fuel cycle, indicating the fuel defects had been successfully suppressed by insertion of the above control rods. PSEG completed a Root Cause Evaluation (RCE) in September 2018, that concluded the cause of the fuel failures was PCI related based on their symmetrical location in the core, and the timing of the appearance of the fuel failures following the first rod sequence exchange of the fuel cycle, which involved fully withdrawing the control rods in core locations 22-31, 30-39, and 38-31 from the core.
PSEG completed a Refueling Outage (RFO) in November 2019. As part of the extent of condition corrective actions, in-mast sipping was performed on all fuel assemblies in the core.
Two fuel bundles that were in core locations 22-31 and 38-31 were determined to contain fuel rod cladding failures. Visual examination confirmed the four fuel assemblies in core location 30-39 did not contain failed fuel. In addition, visual examination confirmed pin-hole size leaks in GNF-2 fuel assemblies YLL690 and YLL692 that are consistent with PCI. Both fuel assemblies were discharged to the spent fuel pool during the RFO. For the reactor startup in November 2019, PSEG utilized more conservative legacy ramp rate rules that had previously been in place before the startup in May 2018. Following incorporation of more conservative ramp rate restrictions during the reactor startup and power ascension in November 2019, no fuel failures have been discovered in the current Hope Creek fuel cycle (fuel cycle 23) to date.
The Hope Creek fuel vendor completed an analysis in April of 2020 that predicted PCI related fuel failures in the same locations that were observed visually during the fall 2019 RFO. In contrast to the results of the original RCE completed in September 2018, the two fuel failures were not in GE-14 fuel assemblies as was originally suspected but were in the newer GNF-2 fuel assemblies. The fuel vendor analysis showed that the localized tensile stresses placed on the cladding in the GNF-2 were higher than in the GE-14 fuel, and the locations where the fuel defects were observed visually, had the highest stresses in the fuel cycle following the June 11, 2018 rod sequence exchange, which fully withdrew the control rods in core locations 22-31 and 38-31. The fuel vendor analysis further confirmed that the fuel cycle 22 fuel failures were in fact PCI related and provided quantitative results on the lower ramp rates that would have been required to prevent the fuel failures from happening.
Following completion of the fuel vendor analysis, PSEG revised the original RCE completed in September 2018. Additional corrective actions taken by PSEG in May 2020 include a major revision of NF-AA-440, BWR Fuel Conditioning, which added a set of ramp rate rules that are more restrictive than the ramp rate rules provided by the fuel vendor in November 2017, and that were utilized in the May 2018 reactor startup. This was done after recognition that the Hope Creek core design is unique compared to the majority of BWRs in the United States, in that it is operated on 18-month versus 24-month fuel cycles. The shorter fuel cycle leads to higher localized nodal power in fuel assemblies during the first rod sequence exchange. In addition, during the April 2018 RFO, a Margin Uncertainty Recovery (MUR) power uprate was completed which raised reactor power approximately 1.5 percent higher above the Original Licensed Thermal Power. This power uprate contributed to maximum nodal powers and maximum fuel assembly powers that were discovered to be toward the upper end of known industry ranges as a result of the fuel vendor analysis.
A Green, Non-Cited Violation of Technical Specification 6.8.1, Procedures and Programs was issued in the Hope Creek Integrated Inspection report on November 14, 2018. (See Inspection Report #: 05000354/2018003 and ADAMS ACCESSION NUMBER:
ML18319A072). This violation addresses the underlying performance deficiency of procedural inadequacies in NF-AA-440, BWR Fuel Conditioning which led to PCI related fuel failures in Hope Creek fuel cycle 22. This inspection sample reviewed corrective actions taken by PSEG since this violation was issued. The inspectors reviewed the revised root cause investigation, revisions made to multiple Nuclear Fuels procedures, the fuel vendor analysis report, and the fuel examination results following the fall 2019 RFO. The inspectors determined that the evaluation and corrective actions taken by PSEG since November 2018 are adequate and commensurate with the safety significance of the PCI related fuel failures which occurred in Hope Creek fuel cycle 22. No performance deficiencies were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 6, 2020, the inspectors presented the RP Rad Hazards Control and Radiation Monitoring Instrumentation Inspection Debrief inspection results to Steve Poorman, Plant Manager and other members of the licensee staff.
- On August 13, 2020, the inspectors presented the Radiological inspection debrief for remote inspections including inspection procedures 71124.03 (In-plant Airborne Radioactivity Control and Mitigation), and 71124.04 (Occupational Dose Assessment)inspection results to Hal Trimble, Radiation Protection Manager and other members of the licensee staff.
- On September 2, 2020, the inspectors presented the 2018 PCI related fuel failures inspection results to Steve Poorman, Hope Creek Plant Manager and other members of the licensee staff.
- On October 7, 2020, the inspectors presented the integrated inspection results to Mr. Thomas Agster, Acting Plant Manager and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ALARA Plans
RWP 1, Task
4710, Attachment
TEDE ALARA Evaluation Screening Worksheet for Pre-
outage Equipment Pit Work
08/06/2020
Procedures
Respiratory Protection Program
Revision 10
Procedures
Dosimetry Issue, Usage, and Control
Revision 13
Methods for Estimating Internal Exposure from In-vivo and
In-vitro Bioassay Data
Revision 7
Procedures
NC.RS-TI.ZZ-
0592(Q)
RADIATION PROTECTION INSTRUMENTATION (RPI)
LABORATORY CALIBRATION AND QUALITY CONTROL
Revision 3
Corrective Action
Documents
20797726,
20800087,
20800756
202192, Root
Cause
Evaluation, Hope
Creek Cycle 22
Failed Fuel,
Revision 1
Engineering
Evaluations
HCP.6-0316
Hope Creek Cycle 22 Projection to End of Cycle
Revision 0
Procedures
Issue Identification and Screening Process
Revision 22
Reload Control Procedure
Revision 16
Reload Risk Management Assessment Instructions
Revision 3
BWR Control Blade Lifetime Management
Revision 2
BWR Fuel Conditioning
Revision 16
Adverse Condition Monitoring Plan 18-001: Cycle 22 Failed
Fuel Monitoring Plan
Revision 5