IR 05000354/2022010
| ML22075A182 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/16/2022 |
| From: | Glenn Dentel NRC/RGN-I/DORS |
| To: | Carr E Public Service Enterprise Group |
| Dentel G | |
| References | |
| IR 2022010 | |
| Download: ML22075A182 (14) | |
Text
March 16, 2022
SUBJECT:
HOPE CREEK GENERATING STATION - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000354/2022010
Dear Mr. Carr:
On March 3, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station and discussed the results of this inspection with Mr. Edward Casulli, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Hope Creek Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Hope Creek Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Digitally signed by Glenn T.
Dentel Glenn T. Dentel Date: 2022.03.16 14:20:23-04'00'
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000354 License No. NPF-57
Enclosure:
As stated
Inspection Report
Docket Number: 05000354 License Number: NPF-57 Report Number: 05000354/2022010 Enterprise Identifier: I-2022-010-0027 Licensee: PSEG Nuclear, LLC Facility: Hope Creek Generating Station Location: Hancocks Bridge, NJ Inspection Dates: February 14, 2022 to March 3, 2022 Inspectors: E. Dipaolo, Senior Reactor Inspector L. Dumont, Reactor Inspector D. Kern, Senior Reactor Inspector Approved By: Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection 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
Failure to Take Required Compensatory Action for Non-Functional Diesel-Driven Fire Pump (DDFP)
Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.21N.
Systems NCV 05000354/2022010-01 Identification 05 Open/Closed The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of the Hope Creek Generating Station Renewed Facility Operating License Condition 2.C(7), Fire Protection, for failure to implement and maintain in effect all provisions of the approved fire protection program (FPP) as described in the Final Safety Analysis Report for the facility. Specifically, test acceptance criteria for pump developed head to support functionality was not satisfied during pump flow testing on June 23, 2021, and PSEG failed to identify the condition and completely and accurately document the issue in the corrective action program. As a result, the required compensatory action for one non-functional fire pump was not implemented.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).
- (1) Fire Protection Water Supply System
- (2) High Pressure Coolant Injection System
- (3) Residual Heat Removal System, including Suppression Pool Cooling and Low Pressure Coolant Injection Modes
- (4) Fire Suppression System
Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
- (1) Control of Transient Combustible Material
Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)
The inspectors verified the following:
a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
b. The adequacy of the design modification, if applicable.
c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.
d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.
e. Post-fire safe shutdown operating procedures, such as abnormal operating procedures, affected by the modification were updated.
- (1) Revision 2 to HC-PRA-109, Hope Creek Probabilistic Risk Assessment Cable Selection Notebook
- (2) Order 80128357 Diesel Generator and Fuel Oil Storage Tank Rooms CO2 Systems Automatic to Manual Modification
INSPECTION RESULTS
Failure to Take Required Compensatory Action for Non-Functional Diesel-Driven Fire Pump (DDFP)
Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.21N.0 Systems NCV 05000354/2022010-01 Identification 5 Open/Closed The team identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of the Hope Creek Generating Station Renewed Facility Operating License Condition 2.C(7), Fire Protection, for failure to implement and maintain in effect all provisions of the approved fire protection program (FPP) as described in the Final Safety Analysis Report for the facility. Specifically, test acceptance criteria for pump developed head to support functionality was not satisfied during pump flow testing on June 23, 2021, and PSEG failed to identify the condition and completely and accurately document the issue in the corrective action program. As a result, the required compensatory action for one non-functional fire pump was not implemented.
Description:
During the review of HC.FP-ST.KC-0006(F), Fire Pump Capacity Test, completed on June 23, 2021, the team observed that the DDFP failed to meet the minimum required pump developed head (discharge pressure minus suction pressure) of greater than 119 pounds per square inch (psi) at 2500 gallons per minute (gpm). Actual pump developed head was recorded as 105 psi and pump speed was recorded as below the minimum recommended speed (1746 revolutions per minute versus 1750).
The DDFP was not declared non-functional despite the test acceptance criteria for required pump developed head not being satisfied. PSEG wrote a notification (NOTF) 20880344 to raise the pumps speed which was slightly lower than the recommended speed band during flow tests at 2500 gpm and 3750 gpm. PSEG stated in NOTF 20880344 that the pump was still operable and that the condition was not a functional failure. NOTF 20880344 did not contain any documentation that test acceptance criteria for pump developed head at 2500 gpm was not satisfied.
After inspector questioning of the test results, PSEG wrote NOTF 20897899 on February 23, 2022. PSEG concluded that no notification was written to document that the pumps true discharge pressure (i.e., pump developed head) did not meet the test acceptance criteria to demonstrate functionality. PSEG appropriately declared the DDFP non-functional but available and issued Fire Impairment PFIP-HC-2021-031 to track the required implemented compensatory measure for a non-functional fire pump (i.e., within 7 days, provide a backup fire pump). PSEG planned corrective maintenance to adjust the DDFPs speed and re-perform the fire pump capacity test.
Corrective Actions: On February 23, 2022, PSEG declared the DDFP non-functional but available, and issued fire protection impairment permit FPIP-HC-2021-021 track the requirement to restore the DDFP to a functional status or provide a backup fire pump within seven days.
Corrective Action References: NOTFs 20880344, 20897899, 20898182 and 20898243.
Performance Assessment:
Performance Deficiency: The team determined that PSEGs failure to identify and properly document that the DDFP was non-functional as demonstrated by testing was a performance deficiency that was reasonable within PSEGs ability to foresee and correct. Specifically, test acceptance criteria for pump developed head to support functionality was not satisfied during pump flow testing on June 23, 2021, and PSEG failed to identify the condition and completely and accurately document the issue in the corrective action program. As a result, the required compensatory measure for one non-functional fire pump was not implemented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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. Specifically, the capability of the DDFP was not ensured because the required pump developed head to support functionality was not demonstrated during flow testing on June 23, 2021. In addition, this finding is more than minor because it was similar to Example 2.a of IMC 0612, Appendix E, Examples of Minor Issues. Specifically, when identified, the licensee had to initiate actions required by the procedure and the time period specified had been exceeded.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection Significance Determination Process. Appendix F was applicable in this case because the finding was associated with fire water supply systems. This issue screened as Green in Step 1.4.3 because adequate fire water capacity was still available for protection of equipment important to safe shutdown in the most limiting location onsite. The motor-driven fire pump was functional, and the Salem fire water system was capable of supplying the Hope Creek Generating Station by opening the crosstie valve between the two sites fire water systems.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, although the required acceptance criteria for pump developed head at the flowrate of 2500 gpm was not satisfied, PSEG did not identify the issue completely and accurately in the corrective action program for resolution.
Enforcement:
Violation: Hope Creek Generating Station Renewed Facility Operating License Condition 2.C(7), Fire Protection, requires, in part, that PSEG Nuclear, LLC shall implement and maintain in effect all provisions of the approved FPP as described in the Final Safety Analysis Report for the facility. Updated Final Safety Analysis Report, Section 9.5.1.4.2, Operational Testing and Inspection, Revision 14, requires equipment out of service, including fire suppression, detection, and barriers, will be controlled through the administrative program and appropriate remedial actions taken. FP-HC-004, Actions for Inoperable Fire Protection-Hope Creek Station, Revision 7, identifies actions to be taken when a fire protection system or component, or related equipment at Hope Creek Generating Station is determined to be non-functional. Attachment 1, Actions Criteria, V. Fire Water Supply Inoperable, Case 1, requires that with one fire pump non-functional, provide a backup fire pump within seven days.
Contrary to the above, from June 23, 2021, until February 23, 2022, the DDFP was non-functional and PSEG failed to implement the required compensatory action with one fire pump non-functional as required by FP-HC-004.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 3, 2022, the inspectors presented the triennial fire protection inspection results to Mr. Edward Casulli, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Corrective Action 20383166
Documents 20472006
20820914
20821021
20821328
20824280
20825247
20827633
20828777
20832162
20834984
20843939
20844163
20844304
20854420
20856382
20863830
20882576
20883940
20886423
20891695
Corrective Action 20869865
Documents 20897251
Resulting from 20897314
Inspection 20897315
20897561
20897657
20897659
20897675
20897677
20897741
Inspection Type Designation Description or Title Revision or
Procedure Date
20897743
20897899
20898071
20898072
20898073
20898077
20898078
20898088
20898100
20898182
20898186
20898243
20898248
20898288
20898331
20898355
20898358
20898371
20898374
20898376
20898424
Drawings E-6108-0 RHR System Suction Cooling Outboard Isolation Valve 11
Electrical Diagram
M-51-1 Sht. 2, RHR System P&ID 45
M-51-1, Sht. 1, RHR System P&ID 52
M-55-1 High Pressure Coolant Injection P&ID 40
Engineering 70210392-0010 Fire Watch Change for EDG & DFOST Room CO2 11/22/2019
Changes Systems in Manual Operation
80128357-0200 Converting from Automatic to Manual Carbon Dioxide Fire 10/29/2021
Suppressions Systems
Design Hope Creek DC Short Circuit Analysis 0
Equivalent
Change Package
Inspection Type Designation Description or Title Revision or
Procedure Date
80128453
Engineering BJ-0024 Failure of High Reactor Level Turbine Trip 2
Evaluations E-26 Breaker to Fuse and Fuse to Fuse Coordination for 0
Appendix R
H-1-BCXXMEE- Engineering Evaluation of Low Pressure Section of 0
2-3 Residual Heat Removal System and Core Spray System
Piping Subject to Spurious Valve Actuation Due to a
Design Basis Fire and Resultant Reactor Coolant Leakage
during Power Operation
Order 70216626- Generic Letter 86-10 Evaluation for Loss of Automatic
0010 Start of Fire Pumps at Hope Creek
Miscellaneous CC-AA-211 Fire Protection Program 6
HC-PRA-104 Hope Creek Generating Station Fire Probabilistic Risk 5
Assessment-Summary, Quantification, and Uncertainty
Notebook
HC-PRA-106 Hope Creek Generating Station Fire Probabilistic Risk 3
Assessment-Human Reliability Analysis
HC-PRA-109 Hope Creek Generating Station Fire Probabilistic Risk 2
Assessment-Cable Selection Notebook
HC.ER-PS.FP- Hope Creek Fire Protection Report-Safe Shutdown 0
0001-A3 Analysis, Appendix 3
HC.FP-ST.KC- Electric Motor Driven Fire Pump Operability Test 12/14/2021
0002(F)
HC.FP-ST.KC- Fire Pump Capacity Test 03/28/2020
0006(F) and
06/24/2021
HC.FP-ST.KC- Diesel Driven Fire Pump Operability Test 01/11/2022
0009(F)
NC.DE-PS.ZZ- Programmatic Standard for Fire Protection 3
0001(Q)
NFPA 20-1974 Standard for the Installation of Centrifugal Fire Pumps
NUREG-1048, Hope Creek Generating Station Safety Evaluation Report April 1986
Supplement 5
PM 660-0051-02 Installation and Operating Instructions for King-Knight 05/02/1980
Inspection Type Designation Description or Title Revision or
Procedure Date
Engine Driven Fire Pump Control Panel Model FP68D
SH-PBD-AMP- GALL Program XI.M27-Fire Water System 2
XI.M27
Updated Final 25
Safety Analysis
Report
VTD 430049 - EPU TR T0611 - Appendix R/Fire Protection November
Volume 2 2006
Procedures CA-AA-112 Temporary Configuration Changes 18
CA-AA-211 Fire Protection Program 6
FP-AA-001 Control of Transient Combustible Material 7
FP-AA-014 Fire Protection Training Program 5
HC.ER-PS.ZZ- Hope Creek Fire Protection Safe Shutdown Analysis 0
0517 Manual Action Feasibility Analysis
HC.FP-SO.KC- Fire Protection Water Suppression Systems Operation 11
0001(F)
HC.FP-ST.KC- Electric Motor Driven Fire Pump Operability Test 9
0002(F)
HC.FP-ST.KC- Diesel Driven Fire Pump Operability Test 23
0009(F)
HC.OP-AB.FIRE- Fire - Spurious Operation 2
0001
HC.OP- Control Room Environment 12
AB.HVAC-0002
HC.OP-IO.ZZ- Shutdown from Outside Control Room 41
0008
LS-AA-128 Regulatory Review of Proposed Changes to the Approved 3
OP-AA-102-106 Operator Response Time Program 0
OP-HC-102-106- Hope Creek Master List of Timed Actions 7
F1
Self- Order 80129471 2021 Hope Creek Fire Protection Focused Area Self- 11/26/2021
Assessments Assessment
Work Orders 50209970
Inspection Type Designation Description or Title Revision or
Procedure Date
215994
221406
225538
11