IR 05000354/2022010

Triennial Fire Protection Inspection Report 05000354/2022010

ML22075A182
Person / Time
Site:	Hope Creek
Issue date:	03/16/2022
From:	Glenn Dentel Division of Operating Reactors
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, 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

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

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 Aspect Report Section Mitigating Systems Green NCV 05000354/2022010-01 Open/Closed

[P.1] -

Identification 71111.21N.

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 Aspect Report Section Mitigating Systems

Green NCV 05000354/2022010-01 Open/Closed

[P.1] -

Identification 71111.21N.0 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

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21N.05

Corrective Action

Documents

20383166

20472006

20820914

20821021

20821328

20824280

20825247

20827633

20828777

20832162

20834984

20843939

20844163

20844304

20854420

20856382

20863830

20882576

20883940

20886423

20891695

Corrective Action

Documents

Resulting from

Inspection

20869865

20897251

20897314

20897315

20897561

20897657

20897659

20897675

20897677

20897741

Inspection

Procedure

Type

Designation

Description or Title

Revision or

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

Electrical Diagram

M-51-1

Sht. 2, RHR System P&ID

M-51-1,

Sht. 1, RHR System P&ID

M-55-1

High Pressure Coolant Injection P&ID

Engineering

Changes

210392-0010

Fire Watch Change for EDG & DFOST Room CO2

Systems in Manual Operation

11/22/2019

80128357-0200

Converting from Automatic to Manual Carbon Dioxide Fire

Suppressions Systems

10/29/2021

Design

Equivalent

Change Package

Hope Creek DC Short Circuit Analysis

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

80128453

Engineering

Evaluations

BJ-0024

Failure of High Reactor Level Turbine Trip

E-26

Breaker to Fuse and Fuse to Fuse Coordination for

Appendix R

H-1-BCXXMEE-

2-3

Engineering Evaluation of Low Pressure Section of

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-

0010

Generic Letter 86-10 Evaluation for Loss of Automatic

Start of Fire Pumps at Hope Creek

Miscellaneous

CC-AA-211

Fire Protection Program

HC-PRA-104

Hope Creek Generating Station Fire Probabilistic Risk

Assessment-Summary, Quantification, and Uncertainty

Notebook

HC-PRA-106

Hope Creek Generating Station Fire Probabilistic Risk

Assessment-Human Reliability Analysis

HC-PRA-109

Hope Creek Generating Station Fire Probabilistic Risk

Assessment-Cable Selection Notebook

HC.ER-PS.FP-

0001-A3

Hope Creek Fire Protection Report-Safe Shutdown

Analysis, Appendix 3

HC.FP-ST.KC-

0002(F)

Electric Motor Driven Fire Pump Operability Test

2/14/2021

HC.FP-ST.KC-

0006(F)

Fire Pump Capacity Test

03/28/2020

and

06/24/2021

HC.FP-ST.KC-

0009(F)

Diesel Driven Fire Pump Operability Test

01/11/2022

NC.DE-PS.ZZ-

0001(Q)

Programmatic Standard for Fire Protection

NFPA 20-1974

Standard for the Installation of Centrifugal Fire Pumps

NUREG-1048,

Supplement 5

Hope Creek Generating Station Safety Evaluation Report

April 1986

PM 660-0051-02

Installation and Operating Instructions for King-Knight

05/02/1980

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Engine Driven Fire Pump Control Panel Model FP68D

SH-PBD-AMP-

XI.M27

GALL Program XI.M27-Fire Water System

Updated Final

Safety Analysis

Report

VTD 430049 -

Volume 2

EPU TR T0611 - Appendix R/Fire Protection

November

2006

Procedures

CA-AA-112

Temporary Configuration Changes

CA-AA-211

Fire Protection Program

FP-AA-001

Control of Transient Combustible Material

FP-AA-014

Fire Protection Training Program

HC.ER-PS.ZZ-

0517

Hope Creek Fire Protection Safe Shutdown Analysis

Manual Action Feasibility Analysis

HC.FP-SO.KC-

0001(F)

Fire Protection Water Suppression Systems Operation

HC.FP-ST.KC-

0002(F)

Electric Motor Driven Fire Pump Operability Test

HC.FP-ST.KC-

0009(F)

Diesel Driven Fire Pump Operability Test

HC.OP-AB.FIRE-

0001

Fire - Spurious Operation

HC.OP-

AB.HVAC-0002

Control Room Environment

HC.OP-IO.ZZ-

0008

Shutdown from Outside Control Room

LS-AA-128

Regulatory Review of Proposed Changes to the Approved

Fire Protection Program

OP-AA-102-106

Operator Response Time Program

OP-HC-102-106-

F1

Hope Creek Master List of Timed Actions

Self-

Assessments

Order 80129471

21 Hope Creek Fire Protection Focused Area Self-

Assessment

11/26/2021

Work Orders

209970

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

215994

221406

225538