ML21222A140
| ML21222A140 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/11/2021 |
| From: | Brice Bickett NRC Region 1 |
| To: | Carr E Public Service Enterprise Group |
| References | |
| IR 2021002 | |
| Download: ML21222A140 (16) | |
See also: IR 05000272/2021002
Text
August 11, 2021
Mr. Eric Carr
President and Chief Nuclear Officer
PO Box 236
Hancocks Bridge, NJ 08038
SUBJECT: SALEM NUCLEAR GENERATING STATION, UNIT 1 AND 2 - INTEGRATED
INSPECTION REPORT 05000272/2021002 AND 05000311/2021002
Dear Mr. Carr:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
Salem Nuclear Generating Station, Unit 1 & 2 and discussed the results of this inspection with
you 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
Salem Nuclear Generating Station, Unit 1 & 2.
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 Brice
Brice A. A. Bickett
Date: 2021.08.11
Bickett 14:24:45 -04'00'
Brice A. Bickett, Chief
Reactor Projects Branch 3
Division of Operating Reactor Safety
Docket Nos. 05000272 and 05000311
License Nos. DPR-70 and DPR-75
Enclosure: As stated
cc w/ encl: Distribution via LISTSERV
X Non-Sensitive X Publicly Available
X SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DORS RI/DORS RI/DORS
NAME JHawkins per email BLin BBickett
DATE 8/10/21 8/10/21 8/11/21
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000272 and 05000311
License Numbers: DPR-70 and DPR-75
Report Numbers: 05000272/2021002 and 05000311/2021002
Enterprise Identifier: I-2021-002-0004
Facility: Salem Nuclear Generating Station, Unit 1 & 2
Location: Hancocks Bridge, NJ
Inspection Dates: April 01, 2021 to June 30, 2021
Inspectors: J. Hawkins, Senior Resident Inspector
M. Hardgrove, Senior Resident Inspector
K. Mangan, Senior Reactor Inspector
M. McLaughlin, Senior Enforcement Specialist
N. Mentzer, Reactor Inspector
G. Walbert, Reactor Engineer
Approved By: Brice A. Bickett, Chief
Reactor Projects Branch 3
Division of Operating Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Salem Nuclear Generating Station,
Unit 1 & 2, 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
Inadequate Preventive Maintenance for Service Water Bay Ventilation Dampers
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green None (NPP) 71111.15
Systems NCV 05000311,05000272/2021002-01
Open/Closed
A Green self-revealing finding was identified because PSEG did not properly implement the
requirements of ER-AA-210-1004, First Call Preventive Maintenance (PM) Strategy, and
ER-AA-210-1005, Predefine Change Processing to ensure proper PM was implemented for
service water ventilation (SWV) dampers. Specifically, PSEG did not consider practical
station concerns or schedule appropriate PM dates for the SWV dampers given the failure
history and the potential for age-related, degraded damper swivels observed in
2015. Consequently, on January 25, 2021, the service water (SW) pump bay ventilation
exhaust fan #23 inlet damper (2SWV9) failed to operate resulting in potential service water
ventilation inoperability.
Additional Tracking Items
None.
2
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. The Unit remained at or near rated
thermal power for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. The Unit 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 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 a portion of the objectives and requirements stated in the IP could be
performed remotely. If the inspections could be performed remotely, they were conducted per
the applicable IP. In some cases, portions of an IP were completed remotely and on site. The
inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1) Unit 1 and 2, walked down circulating water bay on June 1 and evaluated readiness
for seasonal extreme weather conditions prior to the onset of summer readiness on
June 7
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Unit 1, B emergency diesel generator lube oil system following a leak from the
temperature regulating valve during the week of April 15
3
(2) Unit 1, 11 service water accumulator following an increase in the frequency of
nitrogen additions during the week of April 15
(3) Unit 2, 125V batteries following notification 20875467 for degraded batteries on the
2C train of 125V batteries on April 21
(4) Unit 2, 22 containment spray pump prior to an in-service test of the 21 containment
spray pump on June 3
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) Unit 1, Auxiliary Feedwater System on May 4
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) Unit 1, B emergency diesel generator room fire area FP-SA-1555 during the week of
April 15
(2) Unit 1, Fire in a(4) areas 1-FA-AB-84A, 1-FA-AB-84B, and 1-FA-AB-84C during
1A EDG surveillance test on June 1
(3) Unit 2, Charging pump and spray additive tank fire area FP-SA-2544 on April 20
(4) Unit 2, C emergency diesel generator room fire area FP-SA-2555 and diesel fuel oil
storage fire area FP-SA-2545 on June 16
(5) Unit 2, Auxiliary feedwater pump area 84 elevation on June 29
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
(1) Unit 2, 78 Mechanical penetration room with service water piping bays #1 and #2 on
June 15
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
(1) Unit 1, Control room observation of Turbine Valve Testing on June 4
(2) Common, Observed and evaluated licensed operator requalification training on
June 8
4
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) Unit 1, 11 reactor coolant pump loop flow channel indicator failing low due to an out-
of-calibration isolator during the week of May 2
(2) Unit 2, adverse trend in Struthers-Dunn relay failures as a result of the Unit 2
emergency bearing lube oil pump relay failure during the week of April 21
(3) Unit 2, adverse trend in service water chiller condenser recirculation pump discharge
check valves (22SW99 and 23SW99) exceeding surveillance requirements for
leak-by on April 21
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) Unit 1, elevated risk due main turbine DC lube oil pump relay failure and
troubleshooting during the week of April 9
(2) Unit 1, elevated risk due emergency diesel generator carbon dioxide system
operability testing during the week of April 9
(3) Unit 1, elevated risk due 12 residual heat removal pump room cooler scheduled
maintenance for temperature switch calibration on May 12
(4) Unit 1, review of risk associated with work planning and the control of work
associated with switchyard inspections of the 500 KV disconnects and breaker
positions during the week on June 2 and June 16
(5) Unit 2, review of risk associated with work planning and the control of work
associated with switchyard inspections of the 500 KV disconnects and breaker
positions during the week on June 2 and June 16
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) Unit 1 and 2, review of operability evaluation for emergency diesel generator control
area supply fan cooling capacity during the week of April 9
(2) Unit 2, review of operability evaluation for the chill water pump room cooler service
water control valve (2SW213) valve after it failed to open during the week of April 21
(3) Unit 2, review of operability evaluation for the 2PR1 and 2PR2 valve limit switches
exceeding qualified life during the week of May 10
5
(4) Unit 1, review of operability evaluations for main steam isolation valve closure times
due to potential bypass valve leak-by during the week of June 21
(5) Unit 2, review of operability evaluations for main steam isolation valve closure times
due to potential bypass valve leak-by during the week of June 21
71111.17T - Evaluations of Changes, Tests, and Experiments
Sample Selection (IP Section 02.01) (24 Samples)
The inspectors reviewed the following evaluations, screenings, and/or applicability
determinations for 10 CFR 50.59 from June 14 through the end of the quarter. NRC
inspection continues related to the licensee's evaluation of the Wind Port Facility.
(1) S2018-107 - TCCP 2ST18-008, EPRI Temporary RCS Online Monitoring Skid
(2) S2020-040 - Adoption of Tornado Missile Risk Evaluator (TMRE) Methodology
(3) S2018-092 - DS1.8-0104, NEXUS/ANC9 & BEACON7 Implementation
(fuel methodology)
(4) S2020-005 - Implement Tavg (EOC) at Coastdown for Salem 1 and 2
(5) S2019-029 - ARPI System Scaling Calculation (SC-RCS005-01) Tolerance Change
(6) S2015-333 - U1 Side Stream Demineralizer and a Surge Tank Recirculation Line for
Safety-Related Chillers
(7) S2016-007 - U2 Nuclear Instrumentation Upgrade
(8) S2017-203 - S1TAC-1TC59- Converter Replacement due to Obsolescence
(9) S2012-122 - Replace NAMCO Switches on Component Cooling System Valves with
Proximity Switches
(10) S2013-190 - Non-Safety-Related Auxiliary Feedwater Pump for MSPI Recovery
(11) S2014-009 - Fukushima Flood Protection Features Documentation Update
(12) S2015-489 - Unit 1 Nuclear Instrumentation Upgrade
(13) S2018-063 - Remove Automatic Rod Control
(14) S2018-099 - Revise RCS Leakage Calculation
(15) S2016-237 - SACS Trip Setpoint Time Delay Change
(16) S2020-117 - Revise Component Cooling System Thermal-Hydraulic Analysis
(17) S2021-030 - Procedures S1.OP-AB.CC-0001 and S2.OP-AB.PZR-0001
(18) S2017-191 - PORV Accumulator Capacity Analysis
(19) S2020-085 - Component Cooling Technical Specification Bases Change
(20) S2016-070 - AVR/MPT STV Relay Removal/Replacement With Sel Digital Relays
(21) S2020-050 - Salem Unit 2 Cycle 25 Core Reload Design Fuel Change Package
(22) S2021-049 - Salem Unit 1 Steam Line Break Outside Containment Analysis
(23) S017-0122 - Revise Component Cooling Technical Specification Bases
(24) S2021-003/H2021-004, Rev 0 Artificial Island Wind Port Facility - NRC inspection
continues for this sample.
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) Unit 1, Plant computer and SPDS upgrade the weeks of June 14 and June 28
6
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system
operability and functionality:
(1) Unit 1, repair of the 13 moisture separator reheater drain tank level controller
following a trip of the reheater during the week of April 27
(2) Unit 1, 13 charging recirculation pump suction stabilizer (1CVE44) bladder
replacement following flow oscillations on May 5
(3) Unit 1, planned repair of the 12 RHR pump room cooler for temperature switch
calibration during the week of May 10
(4) Unit 2, 2A1 28 VDC battery charger capacitor and circuit card replacement during the
week of April 9
(5) Unit 2, repair of the chill water pump room cooler service water control valve
(2SW213) after it failed to open during the week of April 21
(6) Unit 2, 2C 125V battery annual preventative maintenance window for battery cell
conditions on May 17
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01) (4 Samples)
(1) Unit 1, Pressurizer power operated relief valve (PORV) block valves in-service testing
on April 27
(2) Unit 1, 11 Safety Injection Pump in-service test on May 6
(3) Unit 2, quarterly pressurizer pressure operated relief valve in-service testing during
the week of April 27
(4) Unit 2, quarterly surveillance testing of 2C 125V batteries on May 7
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1
Sample)
(1) The inspectors evaluated the conduct of a routine, full participation emergency
planning drill on April 28
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
(1) The emergency planning aspects of a licensed-operator simulator evaluation was
conducted in the plant-reference simulator on May 11. This evaluation included the
initiating conditions that resulted in associated emergency classification and
notifications in accordance with PSEG's emergency plan.
7
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1) Unit 1, April 1, 2020 - March 31, 2021
(2) Unit 2, April 1, 2020 - March 31, 2021
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
(2 Samples)
(1) Unit 1, April 1, 2020 - March 31, 2021
(2) Unit 2, April 1, 2020 - March 31, 2021
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1) Unit 1, April 1, 2020 - March 31, 2021
(2) Unit 2, April 1, 2020 - March 31, 2021
71152 - Problem Identification and Resolution
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) PSEG Oil Analysis Program and Recent Equipment Challenges Associated with Unit
1 and 2 EHC Systems
INSPECTION RESULTS
Inadequate Preventive Maintenance for Service Water Bay Ventilation Dampers
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green None (NPP) 71111.15
Systems NCV 05000311,05000272/2021002-01
Open/Closed
A Green self-revealing finding was identified because PSEG did not properly implement the
requirements of ER-AA-210-1004, First Call Preventive Maintenance (PM) Strategy, and
ER-AA-210-1005, Predefine Change Processing to ensure proper PM was implemented for
service water ventilation (SWV) dampers. Specifically, PSEG did not consider practical
station concerns or schedule appropriate PM dates for the SWV dampers given the failure
history and the potential for age-related, degraded damper swivels observed in
2015. Consequently, on January 25, 2021, the service water (SW) pump bay ventilation
exhaust fan #23 inlet damper (2SWV9) failed to operate resulting in potential service water
ventilation inoperability.
8
Description: Each of the SW pump bays is equipped with its own once-through ventilation
system. The system is designed to start automatically and limit the maximum room
temperature when the SW pumps are operating and is designed to limit the room temperature
to 110F when ambient conditions are 95F with all equipment operating. The small exhaust
fan (12000 CFM capacity) auto starts when SW pump bay temperature reaches 70F and
increasing. The large exhaust fan (32000 CFM capacity) will auto start when the SW Pump
Bay temperature reaches 80F and increasing. When each fan starts its associated inlet
damper will open. The control room will alarm if temperature in a pump room or control area
reaches 110F. The components in the SW bays, including the dampers, are exposed to
harsh conditions (temperature swings and humidity from brackish water).
During a 6 year inspection of the 2SWV9 (30276511) on January 25, 2021, operators found
the damper failed in the closed position with a broken main bracket, several bent linkages,
and all of the linkage pivot pins or swivels seized or corroded. PSEG documented this
condition in their corrective action program (CAP) under NOTF 20868781. PSEG designated
this NOTF as a condition adverse to regulatory compliance (CARC), repaired the damper
(60148696), and documented a technical evaluation (TE 70216465) on March 4, 2021, for a
past operability and reportability review which determined that there were no past operability
or reportability concerns associated with the failure of this damper.
The inspectors reviewed PSEGs NOTF, repair activities, PM procedures, and evaluation,
and questioned whether a potential adverse trend existed due to recent dampers
failures. The inspectors also questioned PSEG about previous actions taken to address
repetitive failures (70172691 and 70173741) of these dampers due to age-related cyclic
fatigue of the damper swivels in 2015. Specifically, the inspectors noted two missed
opportunities for PSEG to have corrected the damper PMs to adequately address the swivel
failure mechanism:
SWV damper PMs and WOs to include replacement of the damper swivels.
- On July 9, 2015, SWV maintenance rule (a)(1) action plan (70173741) did not create earlier
initial corrective maintenance work orders for each of the SWV dampers that still required
swivel replacement.
The inspectors noted that PSEGs procedure for First Call PM Strategy, ER-AA-210-1004,
prescribes the strategy for scheduling new or revised PM strategies, directing that the PM be
performed at the scheduling limit of the PM. However, Section 4.3 states that components
with degraded material condition and a failure history receive earlier (appropriate) initial
schedule dates.
In addition to this, PSEGs procedure for revising PM strategies, ER-AA-210-1005,
Attachment 3, Section 8, directs the consideration of practical station concerns when revising
PM activities, which include the need to prevent the failure mechanism that the PM aims to
manage. The procedure also allows practical station concerns to override equipment
reliability issues provided the basis for that decision is documented.
Contrary to the requirements of these procedures, PSEG did not schedule appropriate initial
dates for the revised PM activities intended to manage the age-related failures, and PSEG
did not document why practical station concerns overrode equipment reliability demands.
9
In addition, when revising the existing PM activities to include swivel replacement, PSEG did
not update all of the maintenance plans for SWV dampers.
Corrective Action References: 20868781, 20872467, 70216465 and 70217403
Performance Assessment:
Performance Deficiency: The inspectors determined that PSEG not properly implementing
the requirements of their PM procedures. Specifically, PSEG did not schedule appropriate
initial dates for the revised PM activities intended to manage the age-related failures of the
SWV dampers and did not adequately update the necessary SWV damper maintenance
plans. The inspectors determined this was a performance deficiency within their ability to
foresee and correct and which should have been prevented additional failures.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance 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. The inspectors determined the performance deficiency was
more than minor because it was associated with the Equipment Performance attribute of the
Mitigating Systems cornerstone and adversely affected its objective to ensure the availability
and reliability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage). Specifically, PSEG not establishing and performing
appropriate PM on the SWV dampers lead to in-service component deterioration and failures
of the 2SWV9 resulting in potential SWV inoperability and a maintenance rule conditioning
monitoring event.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed
the significance of the finding using Exhibit 2, Mitigating Systems Screening Questions, of
IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power,
dated December 20, 2019, and determined this finding was of very low safety significance
(Green) because Yes was not answered to any of the screening questions.
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance. Not Present Performance. No cross-cutting aspect was assigned to this
finding because the inspectors determined the finding did not reflect present license
performance.
Enforcement:
Violation: The inspectors did not identify a violation of regulatory requirements associated
with this inspection finding.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend 71152
Due to recent equipment failures, the inspectors reviewed several issues associated with
PSEGs preventive maintenance change and optimization process governed by
ER-AA-210-1005. The inspectors determined, that in most cases, issues and potential
10
adverse trends were appropriately identified, evaluated, and resolved by PSEG. However,
the inspectors did note the following examples of equipment issues that occurred due to less
than adequate adherence to the PM change process.
- Salem initiated NOTF 20871682 with actions to review the failure trend of the chiller service
water condenser recirculation pump discharge check valves and review the associated PM
frequencies. The inspectors noted that the PM on these valves was previously extended in
2018 from every year to every 2 years (70191216-0370), and then again, prior to performing
the PM, it was extended to every 4 years in 2019 (80124896-0350). Since this most recent
extension of the PM, four of these valves have failed to meet their surveillance requirements,
and as of April 7, 2021, a PM change request (PCR 80111049) was completed to change the
PM frequency back to every 2 years. The inspectors noted that the PCR completed in 2019,
was done as part of the Salem PM optimization program, when PM frequencies were being
extended. The inspectors also noted that PSEGs evaluation products (70217042 and
70216919), which identified this gap, did not address the gap with corrective actions or
potential extent of condition concerns to other safety-related PMs that may have been
inappropriately extended.
- Salem initiated NOTF 20874578 with actions to review the PM frequency on SW223 service
water valves which was changed in 2019 from every 4 years to every 6 years and
experienced multiple valve failures since the PM extension. While PSEGs review
determined that no PM change was required and that these valves will be replaced in 2022
(70217185), the inspectors noted that this PM change did not meet the justification
requirements per ER-AA-210-1005, which requires use of previous IST data and equipment
history.
- Salem initiated NOTF 20868000 and 70217581 for a review of the 13 moisture separator
reheater trip that occurred on April 26, 2021, due to a failed level controller from age-related
degradation. The main steam coil drain tank level controller PMs were changed in 2007 from
every 36 months to every 54 months (70067605-0010) without adequate justification.
- Salem initiated NOTF 20849512 and PCR 70212644 for service water component cooling
heat exchanger outlet air-operated valves (SW127s). The inspectors noted that the vendor
had previously recommended the valve actuator PM be performed every 2 years and not
every 6 years as PSEG had been performing it, and that this vendor recommendation had not
been evaluated or dispositioned.
- Salem initiated NOTF 20875704 and PCR 70216965 for service water intake structure
damper inspections from every 6 years to every 4.5 years and ensuring the replacement of
the damper swivels due to multiple recent damper failures. (See FIN 2021002-01)
The inspectors evaluated these issues IAW IMC 0612, Appendix B, Issue Screening, and
Appendix E, Examples of Minor Issues, and determined the issues did not constitute
performance deficiencies or were of minor significance. Consequently, these issues were not
subject to enforcement action in accordance with the NRCs enforcement policy.
Observation: Annual Sample: Review of PSEG Oil Analysis Program and 71152
Recent Equipment Issues Associated with Unit 1 and 2 EHC Systems
The inspectors reviewed PSEGs causal evaluations, procedures, and the Unit 1 and 2 EHC
fluid sample analysis results from January 2017 to February 2021. The inspectors confirmed
that historically, EHC fluid quality, wear particulate count (WPC), has been out of specification
11
on both Units. More specifically, Unit 1 EHC fluid quality since 2017 routinely exceeded the
industry ISO code limits of */12/8 (averaging in 2017 and 2018 */15/11; 2019 */12/8;
2020 */17/11). Based on PSEGs procedure ER-AA-230-1001, Oil Analysis Interpretation,
which provides guidance for the common equipment types and common lubricating oil and
EHC fluid used at PSEG, Section 4.2.4 Particle Count Analysis Guidelines for EHC and
Attachment 12 for the EHC Reservoir, a EHC fluid particulate fault limit of */14/12 required the
generation of a NOTF to condition the oil to less than the trend limit, and an emergency limit
of greater than four times the baseline value requiring fluid replacement. The inspectors
confirmed that these limits were routinely exceeded during this timeframe and although
NOTFs were documented for the condition, actions to condition or replace the fluid were
ineffective or were not timely and resulted in numerous equipment challenges during the last
two operating cycles of both Units.
PSEGs corrective actions included replacing the 12MS29 valve, flushing the EHC system
orifices, replacing system filters, performing an extent of condition for all Unit 1 and 2
governor, stop, reheat intercept and reheat stop valves, and implementing an equipment
reliability strategy (S-20-0118) for Salem Unit 1 and 2 EHC Fluid Quality and Filters. PSEG
also drained the EHC reservoir, cleaned the reservoir, and enhanced the work instructions for
flushing the system. Work instructions for managing EHC Fluid quality have also been
revised to include guidance regarding filter operation, and feed and bleed fluid replacement
[70215972 and 70216103]. The inspectors determined that the untimely CAP actions
discussed above were evaluated to be minor violations in accordance with IMC 0612,
Appendix B and Appendix E. Consequently, these issues were not subject to enforcement
action in accordance with the NRCs enforcement policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 21, 2021, the inspectors presented the 10 CFR 50.59 Team inspection results
to David Sharbaugh, Vice President, Salem and other members of the licensee staff.
- On June 30, 2021, the inspectors presented the integrated inspection results to Eric Carr
and other members of the licensee staff.
12
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.17T Corrective Action 20878651
Documents 20879053
Resulting from 20879108
Inspection 20880503
Engineering 80106921 Replace NAMCO Switches on Component Cooling System Rev. 0
Changes Valves with Proximity Switches
80109704 S1TAC-1TC59- Converter Replacement due to Obsolescence Rev. 0
80109909 Fukushima Flood Protection Features Documentation Update Rev. 0
80109929 Non-Safety-Related Auxiliary Feedwater Pump for MSPI Rev. 1
Recovery
80111452 U2 Nuclear Instrumentation Upgrade Rev. 0
80112300 Unit 1 Nuclear Instrumentation Upgrade 9/25/2020
80114075 U1 Side Stream Demineralizer and a Surge Tank Recirculation Rev. 2
Line for Safety-Related Chillers
80116848 AVR/MPT STV Relay Removal/Replacement With Sel Digital Rev. 0
Relays
80118531 SACS Trip Setpoint Time Delay Change Rev. 0
80119978 Adoption of TMRE Methodology 3/19/2020
80120385 Revise Component Cooling Technical Specification Bases Rev. 1
80120919 PORV Accumulator Capacity Analysis Rev. 0
80122162 Remove Automatic Rod Control Rev. 0
80122489 Revise RCS Leakage Calculation Rev. 0
80122525 TCCP 2ST18-008, EPRI Temporary RCS Online Monitoring 6/07/2018
80123789 Salem Unit 2 Cycle 25 Core Reload Design Fuel Change Rev. 0
Package
80124401 ARPI System Scaling Calculation (SC-RCS005-01) Tolerance Rev. 0
Change
80125006 Salem Unit 1 Cycle 27 Cycle Management Fuel Change Rev. 0
Package (Revised Beacon Model)
80125095 Implement Tavg (EOC) at Coastdown for Salem 1 and 2 3/02/2020
13
Inspection Type Designation Description or Title Revision or
Procedure Date
80127450 Component Cooling Technical Specification Bases Change 07/27/2020
80127556 Revise Component Cooling System Thermal-Hydraulic 05/05/2021
Analysis
80128807 SALEM Unit 1 Steam Line Break Outside Containment Rev. 0
Analysis
DS1.8-0104 NEXUS/ANC9 & BEACON7 Implementation 6/21/2018
S2021-030 Procedures S1.OP-AB.CC-0001 and S2.OP-AB.PZR-0001 03/16/2021
Engineering TE 70191327 Salem Generating Station Component Cooling Water Pump 06/07/2017
Evaluations Operability
TE 80127354- CC System Crosstie MOV Technical Specification Rev. 0
0030 Requirement
Miscellaneous LR-N19-0045 Report of Changes, Tests, and Experiments 04/03/19
Procedures 1-EOP-APPX-1 Component Cooling Water Restoration Rev. 26
2-EOP-APPX-1 Component Cooling Water Restoration Rev. 27
S1.OP-SO.CC- 11 & 12 Component Cooling Heat Exchanger Operation Rev. 33
0002(Q)
S1.OP-SO.CC- 21 & 22 Component Cooling Heat Exchanger Operation Rev. 28
0002(Q),
14