IR 05000354/2020004

Integrated Inspection Report 05000354/2020004

ML21039A714
Person / Time
Site:	Hope Creek
Issue date:	02/09/2021
From:	Brice Bickett Division Reactor Projects I
To:	Carr E Public Service Enterprise Group
References
IR 2020004
Download: ML21039A714 (17)

Text

February 9, 2021

SUBJECT:

HOPE CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000354/2020004

Dear Mr. Carr:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station. On January 27, 2021, the NRC inspectors discussed the results of this inspection with Mr. Steve Poorman, 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: Brice A. Bickett Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000354 License No. NPF-57

Enclosure:

Inspection Report 05000354/2020004

Inspection Report

Docket Number: 05000354 License Number: NPF-57 Report Number: 05000354/2020004 Enterprise Identifier: I-2020-004-0016 Licensee: PSEG Nuclear, LLC Facility: Hope Creek Generating Station Location: Hancock's Bridge Inspection Dates: October 1, 2020 to December 31, 2020 Inspectors: J. Patel, Senior Resident Inspector D. Beacon, Resident Inspector E. Burket, Senior Reactor Inspector J. DeBoer, Reactor Inspector B. Fuller, Senior Operations Engineer T. Hedigan, Operations Engineer J. Rady, Emergency Preparedness Inspector A. Turilin, 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 Hope Creek 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 October 17, Hope Creek commenced a planned load reduction to approximately 70 percent RTP to perform a turbine valve testing and a control rod pattern exchange. Power was restored to 100 percent RTP on October 18. On November 17, the operators preemptively reduced power to 85 percent RTP due to a loss of normal power to 'A' reactor protection system bus and 'A' feedwater heater control panel. The station was returned to RTP on November 18. On November 20, Hope Creek commenced a down power to approximately 84 percent for a control rod pattern exchange, and returned to 100 percent RTP later the same day. On December 4, Hope Creek commenced a down power to approximately 83 percent for a control rod pattern exchange, and returned to 100 percent RTP later the same day. On December 18, Hope Creek commenced a down power to approximately 82 percent for a control rod pattern exchange, and returned to 100 percent RTP later the same day. 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 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 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) High pressure coolant injection system on October 8

(2) Reactor core isolation cooling system on November 17

(3) B emergency diesel generator on December 21

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) Station service water systems on December 9

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) B residual heat removal pump room on October 7

(2) Lower control equipment room on October 22

(3) Cable spreading room on October 22

(4) Turbine building electrical equipment mezzanine, room 1406, on November 18

(5) Fire pump house on December 23

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

The inspectors evaluated cable submergence protection in:

(1) Station service water cable vault MH-105 on December 18

71111.07T - Heat Sink Performance Triennial Review (IP Section 03.02)

The inspectors evaluated heat exchanger/sink performance on the following components from October 5 to 9, 2020 per Section 02.02b:

(1) 'B' emergency diesel generator jacket water heat exchanger, Closed loop, Section 02.02c

(2) 'B' residual heat removal heat exchanger, Closed loop, Section 02.02c

(3) Reactor core isolation cooling system lube oil heat exchanger, Closed Loop, Section 02.02c

(4) High pressure coolant injection system lube oil heat exchanger, Closed Loop, Section 02.02c

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on December 16, 2020

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on December 16, 2020.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

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 planned surveillance tests of reactor core isolation cooling system on November 17 and high pressure coolant injection system on December 9

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

(1) The inspectors observed and evaluated a crew of licensed operators in the plants simulator during a licensed operator examination on October 14

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 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) D emergency diesel generator backup differential relay (87B) failure follow-up on November 20

(2) Reactor manual control system constant voltage transformer premature failure follow-up on December 2

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Emergent work to address steam leak on B steam jet air ejector on October 29

(2) Planned elevated risk during Silver Run transmission line connection to Hope Creek 500kV bus section on November 3

(3) Planned inoperability of B service water train during maintenance on November 5

(4) Emergent work to address a spurious trip of a 480V bus that resulted in a half scram on November 19

(5) Planned inoperability of high pressure coolant injection system during maintenance on December 9

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

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

(1) Condensate storage tank and associated lines, valves, and missile shields on November 9

(2) F safety relief valve following an increase in tailpipe temperature on November 12

(3) D station service water strainer on November 20

(4) Reactor core isolation cooling system with trip unit light illuminating intermittently on November 24

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from December 14 to December 18, 2020.

(1) HC-17-055, 80119727, Diesel Vibration Design Control Package, dated April 10, 2017

(2) HC-17-065, HC.OP-EO.ZZ-0310, Alternate Injection Using Fire Water, dated April 26, 2017

(3) HC-17-108, HC.OP-GP-ZZ-0011, Placing Selected Instruments in the Tripped Condition, dated July 26, 2017

(4) HC-17-112, HC.OP-EP.5M-0001, Defeating Isolation Signals During Refuel Operations, dated August 3, 2017

(5) HC-17-085, 80120505, Locked containment isolation valve surveillance TS bases 3/4.6.1.1 change, dated June 20, 2017

(6) HC-17-132, 80120892, 250V Battery Analysis for HPCI, dated August 31, 2017

(7) HC-17-146, 80121132, HC HPCI/RCIC Pumps Uninsulated, dated October 19, 2017

(8) HC-17-154, 80121368, Install Valve Ready Light for RCIC Valves, dated November 8, 2017

(9) HC-18-003, 80120777, Replacement of HPCI Steam Admission Valve HIFD-FD-HV-F001, dated January 9, 2018

(10) HC-18-004, TCCP 4HT-18-001; 80121747, Defeat Trips from 6C FWH transmitter LT-1558C, dated January 17, 2018

(11) HC-18-029, 80121797, Changed Documented Position of AB-HV-F016 to Normally Closed, dated February 15, 2018

(12) HC-18-056, 80121897, Hope Creek Setpoint Calculations and PM extensions, dated April 5, 2018

(13) HC-18-155, HC.OP-AB.COOL-0005; HC.OP-AB.HVAC-0001, Total Loss of SSW, HVAC, dated December 10, 2018

(14) HC-19-085, 80125094, HC Diesel Volts, Freq, Watts Surveillance Tolerance Change, dated August 9, 2019

(15) HC-19-090, HC.OP-AB.ZZ-0001; HC.OP.BOP-0006, Transient Plant Conditions; Main Condenser Vacuum, dated August 20, 2019

(16) HC-19-107, HC.OP-GP.SM-0001, Defeating Isolation Signals during Shutdown Cooling Operations, September 16, 2019

(17) HC-19-140, HC.OP-AM-0024, Remote Operations of SRVs with RPV Injection, dated December 9, 2019

(18) H2020-015, 80125176, Hope Creek Generator Protection Relay Replacement, dated February 21, 2020

(19) H2020-074, HC.OP-SO.EA-0001(Q) Rev 42, HC.OP-AB.COOL-0001(Q) Rev 23, Station Service Water System Operation, Station Service Water abnormal procedure, dated June 23, 2020

(20) H2020-093, HC.OP-AB.CONT-0002(Q) Rev 15, Primary Containment abnormal procedure, dated September 22, 2020

(21) 80124591, NF-AA-310, HC SFP Thermal Management Measure Revision, dated September 26, 2019

(22) HC-17-121, HC.OP-ST.65-0007, Torus/Drywell Vacuum Breaker Monthly Test, dated August 14, 2017

(23) HC-18-139, 70203053 and 70203780, Work Control Documents Requiring 5059 Review, dated November 1, 2018

(24) HC-19-048, 80123228, SRV Accumulator Check Valve Testing, dated April 16, 2019

(25) 80122688, Hope Creek Control Room HVAC Veritak Controller Replacement, dated April 9, 2019

(26) H2020-055, HC.OP-SO.SN-0001(Q), Nuclear Pressure Relief and ADS Operation, dated May 7, 2020

(27) H2020-021, 80126374, Revise BC-0056 to determine maximum allowable leakage through F048B and 'B' RHR pump, dated February 27, 2020

(28) HC-18-024, HC.OP-SO.SE-0001 Rev 25, HC.OP-SO.SB-0001, Rev 35, NI System Operation, RPS Operation, dated February 13, 2018

71111.18 - Plant Modifications

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

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Design change for main control room emergency filtration system digital valve controllers on November 13

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

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

(1) Rosemount trip units replacement associated with the B main steam line low pressure isolation logic on October 15

(2) B control room emergency filtration following valve controller replacement on November 16

(3) High pressure coolant injection system following installation of signal isolators to allow mapping and monitoring of ramp generator signal converter and electric governor-magnetic signals to control room integrated display system on December 9

(4) A emergency diesel generator lube oil keep warm following installation of jumpers to bypass a failed heater on December 17

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) HC.OP-IS.EG-0002, 'B' safety and turbine auxiliary cooling system pump in-service test on October 13

(2) HC.OP-ST.KJ-0002, emergency diesel generator 1BG400 operability test on November 9

(3) HC.OP-ST.KJ-0001, emergency diesel generator 1AG400 operability test on December 2

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(1) The inspectors evaluated PSEG's maintenance and testing of the alert and notification system common to Salem and Hope Creek on September 28 - October 2, 2020, for the period of January 2019 through September 2020

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of PSEG's Emergency Preparedness Organization common to Salem and Hope Creek on September 28 - October 2, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes onsite on September 28 - October 2, 2020

• Evaluation No.: 2019-36, NC.EP-EP.ZZ-0202, Operations Support Center Activation and Operations, Revision 27

• Evaluation No.: 2019-44, NC.EP-EP.ZZ-0903, Opening of Emergency Operations Facility, Revision 5

• Evaluation No.: 2019-48, EP-AA-120-1007, Maintenance of Emergency Response Organization, Revision 8

• Evaluation No.: 2020-26, Emergency Plan Section 7, Emergency Communications, Revision 17 This evaluation does not constitute NRC approval.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

(1) The inspectors evaluated the maintenance of PSEG's emergency preparedness program common to Salem and Hope Creek on September 28 - October 2, 2020, for the period of January 2019 through September

OTHER ACTIVITIES - BASELINE

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

EP01: Drill/Exercise Performance (IP Section 02.12) ===

(1) January 1, 2019 to June 30, 2020 (common to Salem and Hope Creek)

EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)

(1) January 1, 2019 to June 30, 2020 (common to Salem and Hope Creek)

EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) January 1, 2019 to June 30, 2020 (common to Salem and Hope Creek)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) Unit 1 (October 1, 2019 - September 30, 2020)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) Unit 1 (October 1, 2019 - September 30, 2020)

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed PSEG's corrective action program for potential adverse trends that might be indicative of a more significant safety issue.

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) Corrective actions associated with apparent cause evaluation 70211890 for the loss of power to C feedwater heater panel and apparent cause evaluation 70212840 for loss of 5015 transmission line during the week of December

INSPECTION RESULTS

Observation: Semiannual Trend Review 71152 The inspectors performed a semi-annual review of site issues to identify trends that might indicate the existence of more significant safety concerns. As part of this review, the inspectors included repetitive or closely-related issues documented by PSEG in their corrective action program (CAP) database, trend reports, major equipment problem list, system health reports, and maintenance or CAP backlog. The inspectors determined, in general, PSEG was appropriately identifying, evaluating, and resolving issues and potential trends. Most notably, PSEG documented an area of concern (notification 20866895) related to a potential negative trend in equipment reliability due to multiple temporary losses of spent fuel pool cooling. The inspectors reviewed each of the following occurrences and assessed PSEG's timeliness in addressing the causes and the actions taken to reduce the likelihood of interruption to spent fuel pool cooling.

• On April 17, the in service A fuel pool cooling and cleanup (FPCC) pump tripped due to a grid voltage perturbation that caused voltage to drop below the motor seal-in circuit limit (20849865);

• On July 24, the in service 'A' FPCC pump tripped due to a faulty thermal overload relay (20856016);

• On October 3, the in service 'B' FPCC pump tripped on a low flow signal when the fuel pool filter demineralizer was isolated from a loss of power to the filter demineralizer panel, creating a low flow condition on the running pump (20860137); and

• On October 29, the A FPCC pump tripped when an operator inadvertently opened the incorrect breaker, causing a loss of power to fuel pool filter demineralizer panel and isolating fuel pool filter demineralizer. This resulted in a low flow condition on the running A FPC pump, and the pump tripped on low flow (20863335).

In response, PSEG addressed each of these events individually, including the performance of prompt investigations, human performance review boards, and an apparent cause evaluation (ACE). The inspectors reviewed these documents and determined that three of the four occurrences of FPCC pump tripping were attributed to the existing vulnerabilities that challenged the safety performance of FPCC system.

PSEG's ACE 70212840 for the April 17th event documented the cause of the pump trip as an undervoltage transient to its 480V motor control center (MCC) starter. The MCC starter for the FPCC pump uses an auxiliary contact for a seal-in circuit that does not allow automatic re-energization of the starter when voltage is restored. The MCC seal-in circuit uses a Motor Malfunction Detector (MMD) card in Bailey logic, so when the 480V MCC bus detected an undervoltage condition the MMD card energized the trip relay resulting in loss of the control power which could not be automatically restored. PSEG determined that this seal-in circuit configuration was a vulnerability that tripped the FPCC pump and did not allow the motor starter to automatically reenergize upon restoration of power.

Similarly, the inspectors noted that the two FPCC pump trips that occurred in October were due to vulnerability in system operation. Specifically, when the power was lost to a non-safety related fuel pool filter demineralizer, it isolated and resulted in a low flow condition on the running FPCC pump. As a result, the pump tripped on a low flow signal. The inspectors also noted that the FPCC system has an additional non-safety related trip signal for low level in the skimmer surge tank that can trip the safety related FPCC pump. These non-safety related portions of the FPCC system presented vulnerabilities in the FPCC system because failure of it could impact the safety function of the FPCC system.

In response to the area of concern notification, PSEG generated multiple actions to address these vulnerabilities. To address the seal-in circuit design, PSEG developed a design change to modify the FPCC pump circuit to prevent pump trips during voltage perturbations. PSEG also initiated a process in their Plant Health Issue tracking database (LCM H-20-0219) to develop a strategy and implement a modification to eliminate FPCC pump low flow and low skimmer surge tank level trips to prevent spurious trips of the pumps and trips following filter demineralizer flow path isolation. Additionally, PSEG generated a procedure revision request to operate the FPCC system with two pumps in service and to establish filter demineralizer bypass flow such that the pumps would continue to operate following a loss of the filter demineralizer flow path.

The inspectors determined PSEGs overall response to the issue was commensurate with the safety significance and included appropriate corrective actions. The inspectors determined PSEGs corrective actions were reasonable and timely to evaluate and correct the conditions. The inspectors did not identify any performance deficiencies based on the review.

Observation: Follow-up on Corrective Actions from Apparent Cause Evaluation 71152 for the Loss of 5015 Transmission Line Events The inspectors reviewed PSEGs apparent cause evaluation (ACE) 70212840 and corrective actions associated with the 500kV transmission line (5015 line) transients that occurred on April 17 and 18, 2020. The scope of the ACE was to determine and evaluate why the plant response on April 17th and April 18th was different for each event. PSEG determined the momentary loss of the 5015 line was the initiating event for both transients, however, it was the ground fault on the line that caused the 500kV breakers to trip and isolate the 5015 line. These ground faults were on different phases of the line resulting in different equipment being affected during each transient. On April 17th, the 5015 line was lost due to a C phase ground fault and on April 18th, the line was lost due to an A phase ground fault.

PSEG conducted a thorough technical review of both transients, including a detail review of data from the station fault recorder and electrical schematics. PSEG analyzed systems that were affected by these electrical transients and determined that there is a distinction between what equipment was affected by a certain phase ground fault. On April 17th, most of the equipment impacted, including A fuel pool cooling pump, have their control power derived from two of three phases of their associated 480V motor control centers (MCCs), of which one of those phases corresponded to the faulted C phase on 5015 line. As a result, the control power circuit for those components experienced an undervoltage condition causing the trip relay to drop out, deenergizing the MCC starter for those components. Additionally, PSEG identified that the MCC starter for these components uses an auxiliary contact for a seal-in circuit which by design did not allow automatically reenergizing the starter when voltage was restored. PSEG concluded other equipment that was affected during both transients utilizes three phase power or has control power fed from both A and C phases. PSEGs ACE identified two condition report corrective actions (CRCAs) to address the apparent cause, which were to develop an equipment reliability strategy and to implement a circuit modification for the MCC loads that tripped to prevent future trips. Additionally, PSEGs ACE identified some non-CAP action tracking items (ACITs) to improve performance and make enhancements, which included an action request to revise standard operating procedure for electrical system operation.

The inspectors determined PSEGs overall response to the issue was commensurate with the safety significance and included appropriate corrective actions. The inspectors determined actions planned were reasonable to address the apparent cause. However, the inspectors identified that PSEG did not appropriately document these actions in the corrective action program (CAP). PSEG uses the SAP application as part of their CAP program to ensure corrective actions are implemented correctly as identified in evaluations and are completed in a timely manner. PSEGs CAP procedure LS-AA-125, Corrective Action Program, Revision 28, requires CRCAs are created in SAP for any planned action necessary to restore a condition adverse to quality that is not tracked in an approved process. The procedure also requires any non-CAP ACITs are created in SAP. Contrary to the procedure requirements, PSEG did not create CRCAs and ACITs from their ACE in SAP, and they were not tracked in an approved process. Upon further review, PSEG provided documentation to the inspectors that demonstrated the two CRCAs were completed, although not consistent with PSEG CAP requirements, within the due dates established in the ACE.

This issue was determined to be a minor performance deficiency because it was related to PSEGs implementation of the CAP. Specifically, PSEG did implement the two CRCAs to address the condition adverse to quality within due dates established by the ACE. Therefore, this performance deficiency was determined to be of minor significance in accordance with the IMC 0612, Appendix B, and Appendix E. Consequently, this issue was not subject to enforcement action in accordance with the NRCs enforcement policy. PSEG entered this issue into their CAP as notification

EXIT MEETINGS AND DEBRIEFS

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

• On October 2, 2020, the inspectors presented the Emergency Preparedness Program Inspection results to Thomas Agster, Senior Director - Maintenance, and other members of the licensee staff.

• On October 9, 2020, the inspectors presented the Heat Sink Inspection results to Mr. Ed Casulli, Site Vice President and other members of the licensee staff.

• On December 18, 2020, the inspectors presented the Evaluations of Changes, Tests, and Experiments Inspection results to Mitchell Dior, Senior Director of Hope Creek Engineering and David Mannai, Senior Director of Regulatory Affairs and Nuclear Oversight and other members of the licensee staff.

• On January 27, 2021, the inspectors presented the integrated inspection results to Mr. Steve Poorman, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.07T Corrective Action 20803119 PROCEDURE HC.OP-IS.BD-0001 REV REQUEST 08/31/2018

Documents 20803120 PROCEDURE HC.OP-IS.BJ-0001 REV REQUEST 08/31/2018

Drawings M-56-1 HPCI Pump Turbine Revision 34

Miscellaneous PJ610Q-0067 Vendor Technical Document for RCIC pressure reducing valve 01/28/2011

Model RV186 (RCIC valve H1FC-1FCPCV-F015)

PN1-E51-C002- Vendor Technical Document - RCIC Turbine Manual 06/14/2002

0054(001)

Work Orders 30228954 PM Lube HPCI Oil Sys CLN/OIL Change 10/22/16

203251 Residual Heat Removal System RHR Heat Exchanger Flow 10/16/2019

Measurement - 18 month

220397 Reactor Core Isolation Cooling Pump - OP203 - Inservice 08/20/2020

Test

221021 HPCI Main and Booster Pump Set - 0P204 and 0P207 - 09/16/2020

Inservice Test

222365 Emergency Diesel Generator 1BG400 Operability Test 09/16/2020

222558 Reactor Core Isolation Cooling Pump - OP203 - Inservice 12/03/2020

Test

222777 HPCI Main and Booster Pump Set - 0P204 and 0P207 - 12/15/2020

Inservice Test

71111.17T Corrective Action 20867389

Documents 20867390

Resulting from 20867392

Inspection

Procedures LS-AA-104-1000 50.59 Resource Manual Revision 9

71114.02 Miscellaneous Design Report Final 2005 REP-10 Design Review Report for PSEG Salem Revision 1

and Hope Creek Generating Stations

71114.03 Corrective Action 20861144

Documents 20861168

Resulting from

Inspection

Miscellaneous On-Shift Staffing Hope Creek and Salem Generating Station On-Shift Staffing Revision 0

Report Analysis Report

Inspection Type Designation Description or Title Revision or

Procedure Date

PSEG Nuclear PSEG Nuclear Emergency Plan dated April 8,

LLC - EP 2020

71114.04 Procedures EP-AA-120-1001 10 CFR 50.54(q) Change Evaluation Revision 5

71114.05 Corrective Action 20861175

Documents 20861333

Resulting from 20861334

Inspection

Procedures EP-AA-121-1003 Equipment Important to Emergency Response - Work Revision 5

Prioritization

15