IR 05000354/2023004

Integrated Inspection Report 05000354/2023004

ML24032A134
Person / Time
Site:	Hope Creek
Issue date:	02/01/2024
From:	Brice Bickett Division of Operating Reactors
To:	Mcfeaters C Public Service Enterprise Group
References
IR 2023004
Download: ML24032A134 (1)

Text

February 1, 2024

SUBJECT:

HOPE CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000354/2023004

Dear Charles McFeaters:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station. On January 17, 2024, the NRC inspectors discussed the results of this inspection with Robert DeNight, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

No NRC-identified or self-revealing findings were identified during this inspection.

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. 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Brice A. Bickett, Chief Projects Branch 3 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:

05000354/2023004

Licensee:

PSEG Nuclear, LLC

Facility:

Hope Creek Generating Station

Location:

Hancocks Bridge, NJ

Inspection Dates:

October 01, 2023 to December 31, 2023

Inspectors:

J. Patel, Senior Resident Inspector

J. Bresson, Resident Inspector

G. Dipaolo, Senior Resident Inspector

N. Eckhoff, Health Physicist

R. Rolph, Senior Health Physicist

S. Veunephachan, Health Physicist

Approved By:

Brice A. Bickett, Chief

Projects Branch 3

Division of Operating Reactor Safety

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

Shutdown Margin Not Within Limits Required by Technical Specification Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000354/2023004-01 Open/Closed Not Applicable 71153 A self-revealing Severity Level IV non-cited violation (NCV) of Technical Specification (TS)3.1.1 was identified when PSEG determined the shutdown margin (SDM) was less than required by the TS. Specifically, due to the reduced reactivity worth of the two control rod blades (CRBs), the calculated SDM for the current fuel cycle (Cycle 25) was lower than expected, and less than required by TS during the early part of the fuel cycle, about 24 days into the fuel cycle that began on October 25, 2022.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000354/2023-002-00 LER 2023-002-00 for Hope Creek Generating Station,

Shutdown Margin Less Than Expected Resulting in a Condition Prohibited by Technical Specifications 71153 Closed

PLANT STATUS

The Hope Creek Generating Station began the inspection period at rated thermal power. On October 17, 2023, operators reduced the units power to 94 percent due to 'R' safety relief valve pilot stage leakage; and continued to reduce power to 90 percent until October 20, 2023. On October 21, 2023, the operators shutdown the unit to commence a maintenance outage to replace the pilot valve on the 'R' safety relief valve. Operators returned the unit to rated thermal power on October 27, 2023.

On December 11, 2023, operators reduced the units power to 70 percent in response to an electrohydraulic control fluid leak on the #4 turbine control valve to perform repairs. On December 14, 2023, in response to challenges encountered during the restoration from the leak repair, the unit automatically shutdown from approximately 88 percent power. Operators returned the unit to rated thermal power on December 20, 2023. On December 27, operators commenced a shutdown to address operational challenges with the #4 turbine control valve and to perform repairs. Operators returned the unit to rated thermal power on December 29, 2023, and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed onsite portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 19, 2023.

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 following indication of the high-pressure coolant injection turbine steam supply isolation, F001, valve seat leakage, October 18, 2023

(2) Diesel control building structure walkdown, November 14, 2023

(3) Reactor core isolation cooling, December 14, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Electrical access area in pre-fire plan FP-HC-3543, November 27, 2023

(2) Diesel fuel oil storage tanks area in FP-HC-3511, December 11, 2023

(3) Motor control center area in FP-HC-3424, December 14, 2023

(4) Condenser bay and turbine control valves in FP-HC-3134, December 16, 2023

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the control diesel building, 130' elevation, on November 13, 2023.

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 annual requalification results for the annual operating exam completed on October 13, 2023.

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 reactor shutdown for the maintenance outage on October 21, 2023.

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

(1) The inspectors observed and evaluated licensed operator performance in the simulator during a licensed operator requalification examination on October 4, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1)

'D' emergency diesel generator room recirculation fan motor trips, week of November 27, 2023

(2) Source range monitors downscale failure following startup, December 4, 2023

(3) Review of licensee's periodic assessment to ensure the effectiveness of maintenance strategies, week of December 18, 2023

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) Fast acting solenoid and servo valve replacement associated with the #4 turbine control valve, December 15-17, 2023

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) Planned maintenance outage to replace pilot stages of 'R' and 'L' safety relief valves, October 22-24, 2023

(2) Planned maintenance on 500kv Red Lion (5015) transmission line and inoperability of

'A' emergency diesel generator, week of October 30, 2023

(3) Elevated aggregated risk based on planned maintenance activities, November 27, 2023

(4) Unplanned down power to repair #4 turbine control valve electrohydraulic control oil leak, week of December 11, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

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

(1) Missed surveillance test for the anticipated transient without scram-recirculation pump trip functional test and performance of risk assessment for operability, October 12, 2023

(2) B-K-400 chiller condenser and evaporator plugged tubes affecting design margin, October 12, 2023 (3)

'A' emergency diesel generator jacket water keep-warm heater out of service due to blown fuse, October 16, 2023 (4)

'R' safety relief valve following the pilot stage temperature drop indicating pilot stage leak, October 17, 2023

(5) Jet pump operability during reactor restart, October 25, 2023

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated the maintenance outage to replace the pilot valve on 'R' and 'L' safety relief valves after an indication of the pilot stage leakage from October 21-24, 2023.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:

Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)

(1)

'R' and 'L' safety relief valves following pilot valve replacement, October 22-23, 2023 (2)

'A' emergency diesel generator jacket water pressure switch circuit troubleshooting, October 30, 2023

(3) MasterPact circuit breaker inspection and preventative maintenance, November 10, 2023 (4)

1. 00 service air compressor 1st/2nd stage intercooler replacement, November 14, 2023

(5) Reactor pressure channel B21-N678A instrumentation following channel calibration and relay replacement, November 28, 2023

(6) Turbine control valve functional test following fast acting solenoid and servo valve replacement, December 18, 2023

(7) Electrohydraulic control system following leak repair on #4 turbine control valve, December 14, 2023

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) HC.OP-ST.BF-0001, "Control Rod Drive Exercise," October 22, 2023

(2) HC.OP-ST.BB-0001, "Recirculation Jet Pump Operability," October 25, 2023

(3) HC.OP-IS.BD-0001, "Reactor Core Isolation Cooling Pump Inservice Test,"

November 21, 2023

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) HC.OP-IS.BH-0004, "Standby Liquid Control Pump," December 26, 2023

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated a simulator training evolution for licensed operators, with associated emergency preparedness drill and exercise performance criteria on October 4, 2023.

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors observed:

(1) The inspectors evaluated the conduct of a licensed operator simulator training scenario involving an operating basis earthquake, fuel damage, loss of two emergency diesel generators and standby liquid control, and a failure of the high-pressure coolant injection steam line outside primary containment resulting in a General Emergency declaration on December 20,

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, 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 how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) The inspectors observed workers exiting the radiologically controlled area during a maintenance shutdown to work on power operated relief valves.

(2) The inspector observed the controls established at the drywell personnel access for the maintenance shutdown.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) The inspectors observed controls during repair of the moisturizer manway leak.

(2) The inspectors observed the controls in place on the refuel floor during normal operation.

(3) The inspectors observed the controls in place for the shipment of irradiated hardware from the spent fuel pool.

(4) The inspectors observed the controls in place at the drywell personnel access area.

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 (HRAs) and very high radiation areas (VHRAs):

(1) Transient Incore Detector room (VHRA)

(2) Reactor water cleanup pump room, locked high radiation area

(3) Radwaste Drumming room, locked high radiation area

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.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1) North end of Hope Creek storage area, waste and laundry

(2) Low Level Radioactive Waste Storage Building, high integrity containers, storage drums of scaffold

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) Walked down the accessible portions of the Hope Creek phase separator tank and transfer to a liner for shipment; Hope Creek does not process waste onsite

(2) Walked the accessible area of the drain collection system

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) Shipment #22-006 - Dry activated waste, Class AS

(2) Shipment #23-015 - Condensate pre-filters, No waste class

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed the preparation of radioactive shipment #23-095 of irradiated hardware on December 13, 2023.

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Shipment #22-022 - Irradiated hardware packaged in a Type B Cask, Type C Classification

(2) Shipment #22-015 - Irradiated hardware packaged in a Type B Cask, Type C Classification

(3) Shipment #22-020 - Irradiated hardware packaged in a Type B Cask, Type C Classification

(4) Shipment #23-095 - Irradiated hardware packaged in a Type B Cask, Type C Classification

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

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

(1) October 1, 2022 through September 30, 2023

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) October 1, 2022 through September 30, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) Root Cause Evaluation 70229351 and corrective actions associated with the unexpected core response during the startup following a maintenance outage resulting from an unexpected reduction in control blade rod worth (2)

'A' emergency diesel generator speed switch failure

(3) Filtration recirculation and ventilation system, north plant vent, south plant vent, and hardened torus vent radiation monitors sensor calibration using decayed check source

71152S - Semi-annual Trend Problem Identification and Resolution Semi-annual Trend Review (Section 03.02)

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

71153 - Follow-Up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated Hope Creek unit automatic shutdown due to #4 turbine control valve fast closure and licensees response on December 14, 2023.

(2) The inspectors evaluated the unexpected slow closure of #4 turbine control valve and the licensee's response from December 21, 2023 to December 27, 2023.

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000354/2023-002-00, "Shutdown Margin Less than Expected Resulting in a Condition Prohibited by Technical Specifications" (ML23293A002). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

INSPECTION RESULTS

Observation: Review of PSEGs Equipment Reliability Evaluation Related to the A Emergency Diesel Generator Speed Switch Failure 71152A The inspectors evaluated PSEGs corrective actions associated with the speed switch failure on the A emergency diesel generator. The issue and corrective actions completed were documented in PSEGs corrective action program as Notifications (NOTFs) 20941525, 20942676, 20943329, and 20952991. PSEG completed an Equipment Reliability Evaluation 70230823 to review the cause of the failure and develop corrective actions to address it. The equipment reliability evaluation determined the cause of the failure was irrecoverable damage to the speed switch circuit board. PSEG performed a failure analysis of the failed switch and discovered that the circuit board had an open trace on the input signal, and the circuit board showed signs of arcing, indicating that it was likely damaged by a high energy event, such as electrical overstress. The failure analysis revealed that the circuit board exhibited poor workmanship, which may have contributed to the failure. Based on these findings, PSEG initiated an action to perform an evaluation to determine if the failure constituted a defect or noncompliance, and therefore, should be reported under the 10 CFR 21, Reporting of Defects and Noncompliance.

The inspector reviewed PSEG's evaluations, work order documents, and planned and completed corrective actions, as applicable, and did not identify any performance deficiency of more than minor significance.

Observation: Unexpected Core Response During the Startup Following a Maintenance Outage Resulting from an Unexpected Reduction in Control Blade Rod Worth 71152A On May 4, 2023, during reactor startup following a maintenance outage, operators observed nuclear instrumentation indicating that criticality conditions existed in the core earlier than predicted in the reactivity management plan. As a result, the startup was halted and the reactivity management plan was re-examined. Following the subsequent startup, evaluation of local power range monitor responses and traversing incore probe data later determined that a loss of control blade worth existed in CRBs 10-19 and 34-19.

PSEG performed a root cause evaluation to examine why the loss of control blade worth was not detected by the station before it became a self-revealing issue during startup.

The inspectors reviewed the Root Cause Evaluation 70229351, associated procedures, corrective action program documentation, and proposed and/or completed corrective actions implemented by PSEG due to the event. The inspectors noted that the licensee performed a thorough evaluation of the event, extent of condition, and relevant operating experience.

Some examples of the corrective actions taken or planned included the development of a new procedure for monitoring for potential control blade worth reduction, establishment of a more conservative replacement threshold for CRBs, planned replacement of the affected blades, and examination and adjustment of the reactivity plan for the remaining operating cycle to ensure an adequate SDM is maintained at all times. The inspectors noted that the approach used to monitor the health of and determine when to replace CRBs prior to the event was in alignment with vendor recommended practices. This event revealed that the vendor recommendations regarding CRB end-of-life may not have been conservative. The inspectors noted that the more conservative monitoring and replacement threshold implemented as corrective actions seemed reasonable, and that these corrective actions should ensure that any potential future control blade loss of worth issues would be more readily identified.

The inspectors did not identify any performance deficiencies of more than minor significance as a result of this inspection.

Observation: Review of Inability to Calibrate Hardened Torus Vent Radiation Monitor Due to Low Activity of Check Source 71152A The inspectors evaluated PSEGs corrective actions associated with the inability to calibrate the hardened torus vent radiation monitor due to the low activity of the check source. The issue and corrective actions completed were documented in PSEGs corrective action program as NOTFs 20947695 and 20948728. The original notification documented that the as found reading for the Cd-109 source was out of specification low and that this had been a consistent trend over the last five performances of the calibration procedure. This was due to the Cd-109 check source decaying to a low activity and was previously identified in NOTFs 20673520, 20658539, and 20448820. PSEG initiated corrective actions to ensure that the check source is replaced before it decays below the necessary activity and to revise the applicable procedures to verify that the check source is within the required activity range before performance of the calibration.

The inspector reviewed PSEG's evaluations, work order documents, and planned and completed corrective actions, as applicable, and did not identify any performance deficiency of more than minor significance.

Observation: Semi-annual Trend Observations 71152S 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 database, trend reports, major equipment problem lists, system health reports, and maintenance or corrective action program backlog. The inspectors determined that, in general, PSEG appropriately identified, evaluated, and resolved issues and potential trends. The inspectors noted an emerging trend in the area of transient combustible controls and performance of fire watches related to the implementation of PSEGs fire protection program. Specifically, PSEG identified multiple examples of missed fire watches, transient combustible stored in risk areas without an approved transient combustible permit, and also instances of expired transient combustible permits. Examples are documented in the following NOTFs: 20942429, 20946030, 20945480, 20945506, 20945785, 20946630, 20954234, 20945479, and 20945593.

PSEG evaluated each of these examples individually and entered the appropriate corrective action processes to address each. PSEG documented this trend and entered it in their corrective action program (NOTFs 20946853, 20944957, 20953526, 20953542, 20945572).

The inspectors did not identify any findings or violations of more than minor significance during this semi-annual trend review.

Shutdown Margin Not Within Limits Required by Technical Specification Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000354/2023004-01 Open/Closed

Not Applicable 71153 A self-revealing Severity Level IV non-cited violation (NCV) of Technical Specification (TS)3.1.1 was identified when PSEG determined the shutdown margin (SDM) was less than required by the TS. Specifically, due to the reduced reactivity worth of the two control rod blades (CRBs), the calculated SDM for the current fuel cycle (Cycle 25) was lower than expected, and less than required by TS during the early part of the fuel cycle, about 24 days into the fuel cycle that began on October 25, 2022.

Description:

Hope Creek TS 3.1.1, Shutdown Margin, requires the SDM be equal to or greater than 0.38% delta k/k with the highest worth rod analytically determined. With the SDM less than specified, reestablish the required SDM within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

On May 4, 2023, during reactor startup following a maintenance outage, operators in the main control room observed that the nuclear instrumentation readings were rapidly rising during continuous withdrawal of a CRB 10-23 from position 00 to 48. The operators inserted CRB 10-23 to position 00, and followed with inserting control rods to the pre-defined subcritical hold point. The operators subsequently performed a reactor shutdown by fully inserting all control rods. PSEG documented this event in NOTF 20935488 and completed a prompt investigation that determined the CRB 10-23 exhibited a worth higher than predicted during the approach to criticality on May 4, 2023. PSEGs initial investigation did not reveal any errors in sequence development, estimated critical positions, or rod worth calculations, and was independently verified by the fuel vendor. However, PSEG modified the startup sequence that left CRB 10-23 inserted. A second startup with this revised sequence was succeeded, with criticality occurring close to the estimated critical position.

On May 9, 2023, PSEG initiated a review of local power range monitor responses during the withdrawal of CRBs in the vicinity of CRB 10-23 during the power ascension. The local power range monitor traces indicated a potential loss of rod worth in CRBs 10-19 and 34-19. To support further investigation, PSEG performed traversing incore probe runs and gathered additional data. PSEG evaluated the local power range monitor and traversing incore probe data and determined that two CRBs, 10-19 and 34-19, experienced unexpected loss of rod worth due to likely depletion of boron. On May 28, 2023, PSEG completed an Operability Evaluation, "Operable with Engineering Justification (OEJ)," to assess the operability with respect to the SDM requirements for the remainder of the Cycle 25. PSEG determined the SDM can be satisfied for the remainder of the cycle.

Additionally, PSEG engaged their fuel vendor, Global Nuclear Fuels, to perform a SDM analysis of the Cycle 25 reactor core. The analysis confirmed that the minimum SDM at the beginning of the Cycle 25 was below the TS limit of 0.38% delta k/k. Cycle 25 began on October 25, 2022, with reactor startup from the refueling outage. This condition existed until core average exposure reached approximately 500 MWd/ST on November 21, 2022. At that point, the SDM was determined to have been greater than 0.38% delta k/k, and therefore compliance with TS was restored.

As a result, PSEG submitted LER 05000354/2023-002-00, Shutdown Margin Less than Expected Resulting in a Condition Prohibited by Technical Specifications, (ML23293A002).

In the LER, PSEG concluded the safety significance was very low, as the SDM was calculated to be positive (greater than zero) during the noncompliance period. PSEG conducted a technical evaluation with input from the Global Nuclear Fuels SDM analysis, which supported a positive value for SDM, and indicated that the reactor would have been able to shut down under all operating conditions, including transients and postulated accidents between October 25, 2022 and November 21, 2022. The inspectors reviewed this and determined it supported PSEGs conclusion. The inspector did not identify any performance deficiencies during this review.

Corrective Actions: PSEGs corrective action was to ensure compliance with SDM requirements by inserting CRBs 10-15 and 10-23 to position 00, and establishing administrative control to ensure that those CRBs remain inserted in all conditions for the remainder of the Cycle 25. In addition, PSEG planned corrective actions to replace affected CRBs during the next refueling outage in April 2024, and revised Nuclear Fuel Procedure, NF-AB-135-1410, with appropriate end-of-life criteria based on internal and external operating experience for CRBs currently installed in the core, with new limits that would remove CRBs susceptible to cracking.

Corrective Action References: 20935616, 20935827, 20937849, 20939189, 20939633, 20943470, 20943472, 70229227, 70229351

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.

Enforcement:

The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance.

Severity: This issue is assigned a Severity Level IV violation based on its similarity to example 6.1.d.1 in the Enforcement Policy. The inspectors reviewed the NRC Enforcement Policy, Section 2.2.1, Factors Affecting Assessment of Violations, which states, in part, that in determining the appropriate enforcement response to a violation, the NRC considers, whenever possible, risk information in assessing the safety or security significance of violations and assigning severity levels. The inspectors determined the issue to be of very low safety significance because the SDM was positive, and therefore, the safety function was not compromised. As a result, the inspectors determined that the violation is characterized at Severity Level IV.

Violation: TS 3.1.1 requires that the SDM shall be equal to or greater than 0.38% delta k/k with the highest worth rod analytically determined, or 0.28% delta k/k with the highest worth rod determined by test. With the SDM less than specified, reestablish the required SDM within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or be in at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Contrary to this requirement, from October 25, 2022 to November 21, 2022, PSEGs calculated SDM for the current fuel cycle was less than required by TS for greater than TS allowed outage time.

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 January 17, 2024, the inspectors presented the integrated inspection results to Robert DeNight, Site Vice President, and other members of the licensee staff.

• On October 25, 2023, the inspectors presented the radiological hazard and exposure control effectiveness inspection results to Robert DeNight, Site Vice President, and other members of the licensee staff.

• On December 14, 2023, the inspectors presented the radioactive solid waste processing and radioactive material handling, storage, and transportation inspection results to Mo Davis, Radiation Safety Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Drawings

2731AG0004

Safety Injections and Containment Spray Systems

2731SH0001

Safety Injection and Containment Spray Systems

Procedures

OI-3A

Safety Injection and Containment Spray

3900