IR 05000354/2024004

Integrated Inspection Report 05000354/2024004

ML25041A268
Person / Time
Site:	Hope Creek
Issue date:	02/11/2025
From:	Nicole Warnek Division of Operating Reactors
To:	Mcfeaters C Public Service Enterprise Group
References
IR 2024004
Download: ML25041A268 (1)

Text

February 11, 2025

SUBJECT:

HOPE CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000354/2024004

Dear Charles McFeaters:

On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station. On January 29, 2025, the NRC inspectors discussed the results of this inspection with Eric Larson, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. One of these findings 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.

A licensee-identified violation which was determined to be of very low safety significance 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.

If you contest the violations or the significance or severity of the violations 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 or a finding not associated with a regulatory requirement 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, Nicole S. Warnek, 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:

05000354/2024004

Licensee:

PSEG Nuclear, LLC - N09

Facility:

Hope Creek Generating Station

Location:

Hancocks Bridge, NJ

Inspection Dates:

October 01, 2024 to December 31, 2024

Inspectors:

P. Finney, Senior Resident Inspector

J. Bresson, Resident Inspector

J. Demarshall, Senior Operations Engineer

T. Fish, Senior Operations Engineer

R. Rolph, Senior Health Physicist

Approved By:

Nicole S. Warnek, 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. A licensee-identified non-cited violation is documented in report section: 71111.1

List of Findings and Violations

Failure Rate Exceeded 20 Percent During Licensed Operator Requalification Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000354/2024004-01 Open/Closed

[H.9] - Training 71111.11A A self-revealed Green finding was identified when 10 of 49 licensed operators failed at least one part of the annual operating tests or biennial requalification examinations conducted by PSEG via procedure TQ-AA-106, "Licensed Operator Requal Training Program," Revision 44.

Inadequate Procedure for Fill and Vent of 'C' Reactor Feedwater Pump (RFP)

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000354/2024004-02 Open/Closed None (NPP)71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 6.8.1, Procedures and Programs, for an inadequate feedwater procedure was identified when the C RFP was emergently removed from service due to a fire.

Additional Tracking Items

None.

PLANT STATUS

Hope Creek Unit 1 began the inspection period at rated thermal power. On November 9, 2024, the unit was reduced to 82 percent in support of emergent repairs for a #1 turbine control valve (TCV) electrohydraulic leak. The unit was returned to rated thermal power on November 11, 2024. Unit 1 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 on-site 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 10, 2024.

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)

'D' residual heat removal room cooler following maintenance, October 30, 2024

(2) Division I station service water during 'B' station service water work window, November 14, 2024

(3) Reactor protection system (RPS) instrument air, November 20, 2024

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

(1) The inspectors evaluated system configurations during a complete walkdown of the control rod drive following an emergent 'A' control rod drive pump thru-wall mechanical seal line repair on December 17, 2024.

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)

'A' and 'C' service water intake structure bay, pre-fire plan 3713, October 9, 2024

(2) Inert gases compressor room, recirculating unit area, steam vent and equipment area, pre-fire plan 3442, October 23, 2024 (3)

'D' residual heat removal room, pre-fire plan 3412, October 30, 2024 (4)

'B'/'D' service water building, pre-fire plan 3713, November 1, 2024

(5) Hydraulic control unit areas, pre-fire plan 3435, November 20, 2024

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) The inspectors reviewed and evaluated the licensed operator examination results for the requalification annual operating exams administered October to November 2024 and biennial exams administered November to December 2024.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) Biennial Requalification Written Examinations

The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered November to December 2024.

Annual Requalification Operating Tests

The inspectors evaluated the adequacy of the facility licensees annual requalification operating test administered the week of October 28, 2024.

Administration of an Annual Requalification Operating Test

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

Requalification Examination Security

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

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

Operator License Conditions

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

Control Room Simulator

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

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated crew 'B' simulator annual examination scenarios on October 2 and 3, 2024.

(2) The inspectors observed and evaluated licensed operator performance in the simulator during licensed operator requalification training on November 12, 2024.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 Samples)

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

(1) Work practices on safety-related equipment following unplanned maintenance on 'B' filtration recirculation ventilation system, October 24, 2024 (2)

'A' emergency diesel generator (EDG) corrective maintenance following an undemanded restart, December 2, 2024

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) Service water strainer port shoe commercial grade dedication, DP-6-1478, November 14, 2024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

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

(1) Emergent risk during temporary configuration change removal of one undervoltage trip input to the 'C' primary condensate pump, October 21, 2024

(2) Emergent risk during 'A' channel week inoperability and unavailability of the 'B' safety auxiliaries cooling system, week of November 25, 2024

71111.15 - Operability Determinations and Functionality Assessments

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

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

(1)

1. 2 TCV fast closure failed surveillance test, October 15, 2024 (2)

'B' filtration recirculation ventilation system damper linkage arm improper configuration, October 24, 2024

(3) Operability of remaining offsite power source when another offsite power source was declared inoperable for emergent maintenance, November 6, 2024 (4)

'C' EDG jacket water leakage, November 7, 2024

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) (2 Samples)

(1)

'B' filtration, recirculation, and ventilation system hydramotor replacement following an outlet damper repositioning failure during primary containment isolation system surveillance test, October 22, 2024 (2)

'C' EDG following jacket water flex hose repair, November 8, 2024

Surveillance Testing (IP Section 03.01) (2 Samples)

(1)

'B' primary containment isolation system logic system functional tests, October 17, 2024 (2)

'A' EDG operability test, October 28, 2024

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

(1) 'B' safety auxiliaries cooling system pump test, October 15, 2024

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) Godwin Dri-Prime Portable Pump HL160M (H1FLX-10-P500) functional test, October 3, 2024

71114.06 - Drill Evaluation

Additional Drill and/or Training Evolution (1 Sample)

The inspectors evaluated:

(1) Licensed operators during simulator training evolutions, with associated emergency preparedness drill and exercise performance criteria on October 2 and 3,

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, 2023 to September 30, 2024

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, 2023 to September 30, 2024

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) Manual trip of 'C' RFP, Notification (NOTF) 20966874, October 16, 2024

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.

INSPECTION RESULTS

Failure Rate Exceeded 20 Percent During Licensed Operator Requalification Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green FIN 05000354/2024004-01 Open/Closed

[H.9] - Training 71111.11A A self-revealed Green finding was identified when 10 of 49 licensed operators failed at least one part of the annual operating tests or biennial requalification examinations conducted by PSEG via procedure TQ-AA-106, "Licensed Operator Requal Training Program," Revision

44.

Description:

PSEG procedure TQ-AA-106, "Licensed Operator Requal Training Program,"

Revision 44, Step 1.1.1, states that "the purpose of the Licensed Operator Requalification Training program is to ensure the licensed individual maintains proficiency to perform the duties of a Reactor Operator (RO) or Senior Reactor Operator (SRO)." TQ-AA-106, Step 4.5.10, states that "any one of the following failures SHOULD result in the convening of a Performance Review Committee (PRC) to determine qualification status, remediation, and re-evaluation methods/actions." It continues, in part, that "the affected individual(s) SHALL be removed from the licensed duties until recommendations from the PRC have been completed if a PRC is convened. 1. A Comprehensive Written Examination failure. 2. An Annual Operating Test failure (Dynamic Simulator or JPM set)." During the facility-administered annual operating tests and biennial requalification examinations of licensed operators, the licensee training staff evaluated operator performance on operating tests, which consisted of individual and crew performance during dynamic simulator scenarios, and of individual operator performance during job performance measures, and on biennial written examinations. Facility results of those tests and examinations showed that 10 of 49 licensed operators, 20.4 percent, failed at least one portion of the tests and examinations.

Based on PSEG's successful remediation and subsequent retesting of individuals who failed a part of the annual operating tests or biennial requalification examinations prior to returning to shift, no violation of regulatory requirements occurred.

Corrective Actions: All operators who failed any portion of the tests and examinations were remediated and retested prior to performing licensed operator activities.

Corrective Action References: NOTFs 20983871, 20984031, 20981049, 20982346, 20984062, and 20979440

Performance Assessment:

Performance Deficiency: The inspectors determined that the high rate of licensed operator test and examination failures constituted a performance deficiency, because licensed operators are expected to maintain proficiency to perform the duties of a licensed operator, as demonstrated through periodic testing as required by 10 CFR 55.59(a)(2) and described in TQ-AA-106, "Licensed Operator Requal Training Program."

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human 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. Specifically, 10 of 49 licensed operators, 20.4 percent, failed to demonstrate a satisfactory understanding of the required knowledge and abilities required to safely operate the facility under normal, abnormal, and emergency conditions.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix I, Operator Requalification, Human Performance. This finding was of very low safety significance, Green, because the finding was related to the requalification exam results with a failure rate greater than 20 percent, but less than 40 percent.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, PSEG did not provide adequate operator requalification training to maintain a knowledgeable, technically competent workforce.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Licensee-Identified Non-Cited Violation 71111.12 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: TS 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities to include the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, states, in part, that "maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances."

PSEG procedure MA-AA-716-003, "Tool Pouch/Minor Maintenance," Revision 14, provides guidance for the conduct of minor maintenance. Steps 4.1.1 and 4.1.3 state, respectively, "ensure work meets definition of Tool Pouch Maintenance in this procedure," and "if activity could affect equipment operation, equipment availability, indication or alarm, then notify Operations of the intended activity."

Contrary to the above, from October 24, 2024 to October 25, 2024, a maintenance technician performed maintenance on a 'B' filtration recirculation ventilation system damper linkage that affected operability without notifying Operations in accordance with procedure MA-AA-716-003. This resulted in unplanned and unrecognized inoperability of the 'B' filtration recirculation ventilation system, and a failure to enter the appropriate TS action statement. The system was restored to operable status on October 25, 2024.

Significance/Severity: Green. The violation screened to very low safety significance (Green)in accordance with IMC 0609, Appendix A, Exhibit 3, since the finding only represented a degradation of the radiological barrier function provided for the filtration recirculation ventilation system.

Corrective Action References: NOTF 20978848

Inadequate Procedure for Fill and Vent of 'C' Reactor Feedwater Pump (RFP)

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000354/2024004-02 Open/Closed

None (NPP)71152A A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 6.8.1, Procedures and Programs, for an inadequate feedwater procedure was identified when the C RFP was emergently removed from service due to a fire.

Description:

On May 15, 2024, during power ascension following a refueling outage, the C RFP was filled and vented at 80 percent power using procedure HC.OP-SO.AE-0001, Feedwater System Operation, Revision 82, Section 4.3, "RFP Fill and Vent and Startup."

On May 20, 2024, following approximately three days of operation, operators observed abnormal C RFP vibration indications. Field operators observed and reported high inboard pump seal water flow, little outboard seal water flow, and flames emitting from the outboard seal, which was evidence of oil ignition. Main control room operators responded by reducing reactor power from 100 to 82 percent and tripping the C RFP to extinguish the fire.

PSEGs investigation revealed that during the C RFP fill and vent process in Step 4.3.2, pump damage had occurred via inadvertent rotation of 144 pump revolutions per minute for about 16 seconds coincident with a pump casing differential temperature of 131 degrees Fahrenheit (degF). PSEG attributed the pump rotation to minimum flow valve leakby, minimum flow piping voids formed during a sensing line flush to address low flow oscillation issues from previous cycles, and a higher feedwater differential pressure at 80 percent power as compared to that during PSEGs normal practice to fill and vent all RFPs at lower power.

During a subsequent Apparent Cause Evaluation (ACE) 70235573, PSEG determined that prior versions of procedure HC.OP-SO.AE-0001 included a precaution that prohibited rotating a RFP on its turning gear or by any other means with a casing differential temperature greater than 40 degF. This precaution had been added to Revision 23 in 1998. In 2001, Revision 29 relaxed the differential temperature restriction to 45 degF, and in 2004, the 40 degF restriction was restored to comply with vendor guidance and maintenance procedures. In 2005, the restriction was adjusted to be applicable only to turning gear operation, given challenges of maintaining temperature less than 40 degF without initiating the fill and vent process. The 2005 version of this precaution remained through the current Revision 82, in Step 2.1.6. There is also a note between Steps 4.3.2 and 4.3.4 that establishes and maintains pump casing differential temperature less than or equal to 40 degF. It states that the following step may be used before and after the turbine has been placed on the turning gear to maintain pump casing differential temperature less than or equal to 40 degF. There is also a caution at Step 4.3.4.1 that states, if casing delta Ts approach greater than 40 degrees and the RFP is rolling, stop the RFP from rolling by immediately securing the turning gear or closing the Min Recirc Valve. PSEG determined the Step 2.1.6 precaution, as well as the location of the note and caution around Step 4.3.4, did not provide sufficient protection during the RFP fill and vent. PSEG also determined that had the leakby, voids, and elevated differential pressure conditions existed with a casing differential temperature below the limit, pump internals would not have been damaged and, therefore, these were not contributing causes.

Corrective Actions: PSEG replaced the C RFP breakdown bushings, shaft sleeve, sleeve nut, seal cover, upper and lower bearing inserts, and oil seal rings. PSEG also reassembled the outboard journal and thrust bearings.

Corrective Action References: NOTFs 20966622 and 20966874

Performance Assessment:

Performance Deficiency: The inspectors determined that PSEG's failure to provide an adequate procedure for filling, venting, and startup of the RFP, as required by TS 6.8.1, was a performance deficiency. Specifically, PSEG procedure HC.OP-SE.AE-0001 did not provide adequate guidance to ensure RFP casing differential pressure was maintained within allowable limits, which resulted in damage to the pump and subsequent pump failure.

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. Specifically, the condition required an unplanned power reduction of 18 percent and an emergent trip and unplanned unavailability of the C RFP.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Appendix A, Exhibit 2, and determined the finding to be of very low safety significance, Green, because the degraded condition was not a design or qualification deficiency, a TS system, or a loss of a probabilistic risk analysis system or function for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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. Specifically, the current procedure revision reflected the same casing temperature guidance since 2005.

Enforcement:

Violation: TS 6.8.1 states, in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A, Section 4, for boiling water reactors includes procedures for filling, venting, and startup systems; and Section 4.o is the feedwater system (feedwater pumps to reactor vessel). Contrary to this, from February 3, 2005 to May 20, 2024, PSEGs procedure HC.OP-SO.AE-0001 for fill, vent, and startup of a RFP did not ensure the pump would not rotate with a casing temperature in excess of 40 degF which resulted in an unplanned downpower of 18 percent and an emergent trip and unplanned unavailability of the 'C' RFP.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Manual Trip of 'C' Reactor Feedwater Pump (RFP)71152A Inspectors reviewed ACE 70235573, for an emergent trip of the 'C' RFP on May 20, 2024, and shared several observations regarding the ACE's quality with PSEG. Inspectors subsequently learned the Management Review Committee (MRC), that reviews, approves, and grades corrective action program evaluations, had approved this ACE "with comments" on August 14, 2024. This grading score criterion includes that there are "changes required to clarify." PSEG's procedure LS-AA-125, "Corrective Action Program," Revision 29, allows the MRC to approve an evaluation but also provide comments to the evaluator/presenter.

However, these comments are not required to be documented, and it is left to the evaluator and their manager to ensure that all comments have been incorporated into the final product and properly addressed. The inspectors reviewed the ACE of record in mid-October 2024, but that version had not yet been updated with MRC comments from August 2024. The comments and changes that needed to be incorporated either rendered the NRC inspectors observations irrelevant or addressed them. For instance, MRC directed that a section on coping with risk be eliminated, a change that removed one of two preliminary causes.

Inspectors concluded there is no method to ensure that all MRC-provided comments are captured accurately and thoroughly. Further, there is no procedure or process timeline for when those comments and corrections are to be incorporated into the final ACE. PSEG captured the inspector's ACE observations in NOTF 20980077. A self-revealing Green NCV associated with the 'C' RFP trip is documented separately in this inspection report. The NRC inspectors did not identify any further findings or violations 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.

Procedure Use and Adherence

A potential adverse trend continued in the area of the procedure use and adherence. During the second quarter of 2024, inspectors documented a procedure use and adherence trend (Inspection Report 05000354/2024-002, ADAMS Accession No. ML24211A161). During three observed pump inservice tests in the second half of 2024, inspectors also identified procedure use and adherence issues (NOTFs 20978321, 20974023, and 20974569).

Additionally, inspectors identified that PSEG did not adhere to an abnormal procedure appendix establishing temporary heating of a battery room (NOTF 20974727). In response to this apparent trend, a Hope Creek Operations Management Review Meeting subsequently documented a gap in Operations' focus on procedure use and adherence (NOTF 20981337),and the PSEG Operations Corporate Functional Assessment Manager documented an area of concern (NOTF 20978798). In the area of maintenance, a self-revealing Green NCV was documented for improperly implementing a surveillance test procedure in July 2024 (05000354/2024003-02, ADAMS Accession No. ML24297A057). In late November 2024, the

'B' safety auxiliary cooling system pump rotated backward during restoration from maintenance (NOTF 20982886) which was attributed, in part, to inadequate motor lead identification in accordance with procedure MA-AA-716-100, "Maintenance Alteration Process."

Technical Specification (TS) Application

A potential adverse trend exists in PSEG's application of TSs. Section 3 of the TS is titled "Applicability," and these TSs establish the general requirements applicable to all Specifications and apply at all times unless otherwise stated. Inspectors documented a Green finding for an inappropriate application of TSs as an equivalent of standard TS 3.0.6 on August 9, 2024 (05000354/2024003-01, ADAMS Accession No. ML24297A057).

Subsequently, inspectors identified a minor violation of TS 3.05 when PSEG improperly invoked that TS on September 18, 2024. Specifically, PSEG removed a half scram on the RPS B1 channel and raised power over seven hours from 83 to 92 percent prior to testing an operable TCV fast closure following emergent maintenance. TS 3.0.5. states, in part, that "equipment removed from service or declared inoperable to comply with ACTIONS, may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY." Inspectors determined that raising power over the course of seven hours with the half scram removed was not an allowed use of TS 3.0.5. This issue was determined to be minor based on PSEG's subsequent evaluation that the associated RPS instrumentation had not been inoperable. PSEG entered this into their corrective action program as NOTFs 20966622 and 20966874.

Emergency Diesel Generators (EDGs)

A potential adverse trend exists in the EDG system. On September 14, 2023, the 'B' EDG was unable to achieve 110 percent loading during a 24-hour operability run and hot restart surveillance test (NOTF 20945127). On November 7, 2024, the 'C' EDG was secured during a 24-hour operability run and hot restart surveillance test for an intercooler jacket water leak that developed on a flex hose (NOTF 20980081). A similar leak occurred on January 11, 2023, during a previous 'C' EDG during the same procedure (NOTF 20924911).

While attempting to perform the same test on the 'A' EDG on August 29, 2024, the generator field did not flash during the hot restart (NOTF 20974245). Inspectors reviewed EDG performance further and observed that, of the last three 24-hr operability run and hot restart surveillance tests on each EDG, four of them had equipment challenges that resulted in the surveillance test(s) being stopped to address them. On November 29, 2024, the 'A' EDG had an undemanded restart following a shutdown from a monthly surveillance test (20982896). PSEG captured this potential trend as NOTF 20982833. Subsequently, an engineering Corporate Functional Assessment Manager documented an area of concern (NOTF 20984050) for recurring, long term EDG challenges. At the end of November 2024, PSEG assessed the EDGs as Maintenance Rule (a)(1) status (Evaluation 70237403).

Turbine Control Valves (TCVs)

A potential adverse trend exists in the EHC system. In December 2023, the #4 TCV experienced an EHC leak (NOTF 20953800). Following restoration from a weld repair and further troubleshooting, an automatic reactor scram occurred, (ADAMS Accession ML24211A161). In September 2024, the #2 TCV failed a surveillance test (NOTF 20975065)that required a power reduction to troubleshoot and repair. In November 2024, the #1 TCV experienced an EHC leak (NOTF 20980091) that also required a power reduction to troubleshoot and repair. PSEG wrote NOTFs 20979800 and 20980119 regarding EHC weld leaks and EHC fitting failures on TCV actuators causing unplanned downpowers. PSEG also captured this as a trend in NOTF 20982832.

The NRC inspectors did not identify any findings or violations of more than minor significance.

EXIT MEETINGS AND DEBRIEFS

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

• On January 29, 2025, the inspectors presented the integrated inspection results to Eric Larson, Site Vice President, and other members of the licensee staff.

THIRD PARTY REVIEWS

Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Corrective Action

Documents

Resulting from

Inspection

20983990

71111.04

Corrective Action

Documents

Resulting from

Inspection

20981633

20981786

20916985

20983885

20981556

20984045

20984046

20984043

20984357

20984863

20984226

71111.05

Corrective Action

Documents

Resulting from

Inspection

20977758

20978599

20978799

20980185

71111.11Q Corrective Action

Documents

Resulting from

Inspection

20977688

20981115

71111.13

Corrective Action

Documents

Resulting from

Inspection

20983531

71111.15

Corrective Action

Documents

Resulting from

Inspection

20980073

20979762

20981819

71111.24

Corrective Action

20978064

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

Resulting from

Inspection

20977818

20978669

20978601

20979147