IR 05000272/2024004
| ML25042A384 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/12/2025 |
| From: | Nicole Warnek Division of Operating Reactors |
| To: | Mcfeaters C Public Service Enterprise Group |
| References | |
| IR 2024004 | |
| Download: ML25042A384 (1) | |
Text
February 12, 2025
SUBJECT:
SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000272/2024004 AND 05000311/2024004
Dear Charles McFeaters:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Station, Units 1 and 2. On February 5, 2025, the NRC inspectors discussed the results of this inspection with David Sharbaugh, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Salem Nuclear Generating Station, Units 1 and 2.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Salem Nuclear Generating Station, Units 1 and 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, Nicole S. Warnek, Chief Projects Branch 3 Division of Operating Reactor Safety
Docket Nos. 05000272 and 05000311 License Nos. DPR-70 and DPR-75
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000272 and 05000311
License Numbers:
Report Numbers:
05000272/2024004 and 05000311/2024004
Enterprise Identifier: I-2024-004-0035
Licensee:
Facility:
Salem Nuclear Generating Station, Units 1 and 2
Location:
Hancocks Bridge, NJ
Inspection Dates:
October 01, 2024 to December 31, 2024
Inspectors:
J. Patel, Senior Resident Inspector
S. Quiroga, Resident Inspector
J. Bresson, Resident Inspector
N. Day, Senior Resident Inspector
M. Hardgrove, Senior Project Engineer
J. Kepley, Operations Engineer
J. Kulp, Senior Reactor Inspector
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 Salem Nuclear Generating Station, Units and 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 Hardening of Service Water (SW) and Component Cooling (CC) Water Systems During Shutdown Cooling Operation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000311/2024004-01 Open/Closed
[H.5] - Work Management 71111.20 The inspectors identified a Green finding and associated non-cited violation (NCV) of Salem Generating Station (Salem), Unit 2, Technical Specification 6.8.1, Procedures and Programs, when the licensee failed to implement written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2,
Appendix A, Section 3. Specifically, PSEG did not properly implement S2.OP-SO.SW-0003, 22 Nuclear Service Water Header Outage, Revision 33, resulting in inadequate hardening of the 21 SW header and CC system during the shutdown cooling operation while the 22 SW header was removed from service for planned maintenance.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On October 3, 2024, the unit was down powered to 89 percent for turbine valve testing. The unit was returned to rated thermal power on October 8, 2024, and remained at or near rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period at approximately 95 percent rated thermal power in coastdown in preparation for the planned refueling outage 27 (S2R27). Unit 2 shutdown and entered S2R27 on October 7, 2024. On November 25, 2024, operators commenced a reactor startup, and the unit returned to rated thermal power on December 1, 2024. Unit 2 operated 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.
REACTOR SAFETY
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 17, 2024. (Work Order (WO)
===30389610)
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
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 2, reactor containment, reactor coolant pump oil collection system, pre-fire plan FP-SA-2401, October 9, 2024
- (2) Unit 1, auxiliary feedwater pumps area, pre-fire plan FP-SA-1543, November 19, 2024
- (3) Unit 1, relay room, and 1A and 1B 125V DC safety-related battery rooms, pre-fire plan FP-SA-1551, November 20, 2024
- (4) Unit 1, 1C 125V DC safety-related battery room, pre-fire plan FP-SA-1531, November 20, 2024
- (5) Unit 1, 460V switchgear rooms and corridor, FP-SA-1541, December 26, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the on-site fire brigade training and performance during an unannounced fire drill on December 5, 2024.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2, 22 CC heat exchanger, October 25 - 31, 2024
===71111.08P - Inservice Inspection Activities (PWR)
The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities in Salem Unit 2 during refueling outage S2R27 from October 15 - 25, 2024.
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic Examination
- Ultrasonic Thickness Test of Containment Liner Panel 88-037 (SW-C-UT-24-021)
- Ultrasonic Thickness Test of Containment Liner Panel 98-023 (SW-C-UT-24-023)
- Ultrasonic Thickness Test of Containment Liner Panel 98-012 (SW-C-UT-24-020)
Radiographic Examination
- Radiographic Test of 21AF23 Field Weld 3, Exam Record 41340416
Visual Examination
- General Visual Examination (VT-G) of Liner Plate 98-012 Under Insulation Panel QUAD A 98-110 (S2-C-VT-24-025)
- General Visual Examination (VT-G) of Liner Plate 98-023 Under Insulation Panel QUAD A 98-110 (S2-C-VT-24-027)
- General Visual Examination (VT-G) of Liner Plate 88-037 Under Insulation Panel QUAD A 88-98 (S2-C-VT-24-024)
- Control Rod Drive Mechanism Nozzle Thermal Sleeves (TB-07-02) (S2-I-VE-24-003)
- Bare Metal Visual (VE) Examination of Bottom Mounted Instrumentation Penetration Nozzle to Safe End DM Butt Welds (S2-I-VE-24-002)
- Bare Metal Visual (VE) Examination of Penetration Welds on Lower Reactor Pressure Vessel Head (S2-I-VE-24-001)
Welding Activities
- Replacement of 21AF23 Valve (WO 30360526)
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
(1)
- 2SJ-433 Evaluation of Boric Acid Leakage, dated 10/20/2018 (Notification (NOTF) 20978256, dated October 15, 2024)
- 2SJ-139 Evaluation of Boric Acid Leakage, dated 10/0/2021 (NOTF
===20977660, dated October 8, 2024)
PWR Inservice Inspection Activities Sample - Steam Generator Tube Inspection Activities (Section 03.04)===
The inspectors verified that the licensee is monitoring the steam generator tube integrity appropriately through a review of the following examinations:
(1)
- Eddy current examination of the 21, 22, 23 and 24 steam generator tubes o Steam Generator Tube 23-73-21 - No Relevant Indications o Steam Generator Tube 21-100-80 - Acceptable Tube Support Plate Wear o Steam Generator Tube 22-85-91 - Acceptable Tube Support Plate Wear o Steam Generator Tube 23-97-43 - Acceptable Tube Support Plate Wear o Steam Generator Tube 24-103-73-Acceptable Tube Support Plate Wear
- Secondary side cleaning and visual examination was performed on the 21, 22, 23 and 24 steam generators
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 failure rates for the requalification annual operating exam completed on September 30, 2024.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated Unit 2 licensed operator performance in the main control room during a plant shutdown for a refueling outage on October 5 - 6, 2024.
- (2) The inspectors observed Unit 2 licensed operator performance in the main control room during reactor startup activities, including mode changes and reactivity manipulations on November 24, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed a Unit 2 simulator evaluation that included reactor startup and generator synchronization on November 1, 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) Unit 1, 11 safety-related chiller tripped on low differential pressure, November 22, 2024
- (2) Unit 1, 1C emergency diesel generator (EDG) trip following relay replacement, December 12 - 13, 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) Unit 2, 2A EDG following negative-phase sequence relay failure to reset, November 19, 2024
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) Unit 1, unplanned down power in response to 12MS28 turbine stop valve failure to open following the turbine valve testing, October 3, 2024
- (2) Unit 2, elevated shutdown risk (Yellow) due to lowered inventory in reactor coolant system during scheduled reactor coolant system drain down and reactor head removal, October 8 - 9, 2024
- (3) Unit 1, elevated risk due to unavailability of credited fire safe shutdown component during 23 charging pump maintenance window, October 15, 2024
- (4) Unit 2, 21 CC train protection scheme during the 22 CC heat exchanger maintenance window, October 15, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 1, turbine stop valve closure input to reactor trip system due to failure to reopen
- 12 main turbine stop valve during turbine valve testing, October 4, 2024 (NOTF
===20976793)
- (2) Unit 2, containment electrical penetration broken stud, October 14, 2024 (NOTF 20978142)
- (3) Unit 1, crossflow system loss of communication, October 18, 2024 (NOTF 20978285)
- (4) Unit 2, debris found in 22 containment fan coil unit main cooler tubes during as-found testing, October 23, 2024 (NOTF 20977933)
- (5) Unit 2, 2A 115V AC vital instrument panel energized from non-class 1E power source during 2A vital inverter replacement, October 24, 2024 (WO 60156610)
- (6) Unit 1, 11 SW chiller condenser control valve, 11SW857, leaking by, October 24, 2024 (NOTF 20978555)
- (7) Unit 2, 21BF19 feedwater regulating valve, and 22BF40 and 24BF40 feedwater bypass valves due to stroke times, November 6, 2024 (NOTFs 20979738, 20979739, 20979740 and 20979741)
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
=
The inspectors evaluated the following temporary or permanent modifications:
(1)2A bus overload relay wiring configuration, Design Change Package 80137886
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated the Unit 2 refueling outage, 2R27, from October 6 to November 26, 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) (8 Samples)
- (1) Unit 2, 2B EDG following the SW cooling valve, 22SW39, replacement, October 2, 2024 (WO 60161040)
- (2) Unit 1, 12 main turbine stop valve following troubleshooting and repair activities, October 3 - 8, 2024 (WO 60138379)
- (3) Unit 2, 2A EDG following the exciter replacement, October 14, 2024 (WO 60158973)
- (4) Unit 2, 2C vital inverter bus following circuit card replacement, October 20, 2024 (WO
===60158125)
- (5) Unit 2, 2CV69, charging header safety injection motor-operated valve following indication of anomaly during diagnostic testing, November 4, 2024 (WO 60162049)
- (6) Unit 2, 21 residual heat removal pump following motor replacement, November 22, 2024 (WO 60155444)
- (7) Unit 2, 21MS29 governor valve following linkage adjustment, November 22, 2024 (WO 60162560)
- (8) Unit 2, 23 safety injection accumulator following check valve replacement, November 25, 2024 (WO 60161093)
Surveillance Testing (IP Section 03.01)===
- (1) Unit 2, S2.MD-ST.SEC-0002, "2B Safeguards Equipment Control (SEC) 18 Month Time Response Surveillance Test," November 4 - 5, 2024 (WO 50243775)
- (2) Unit 2, S2.OP-ST.SSP-0003, "SEC Mode Ops Testing 2B Vital Bus,"
November 16, 2024 (WO 50219794)
- (3) Unit 2, S2.OP-ST.DG-0003, "2C Diesel Generator Surveillance Test,"
December 9, 2024 (WO 50254812)
- (4) Unit 2, S2.OP-ST.AF-0007, "Inservice Testing Auxiliary Feedwater Valves Modes 1 - 3," December 10, 2024 (WO 50243050)
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Unit 2, S2.OP-ST.RHR-0005, "Inservice Testing Residual Heat Removal Valves and Orifices," October 8, 2024 (WO 50243161)
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) Unit 2, S2.OP-LR.CC-0004, "Type 'C' Leak Rate Test 2CC136, 2CC186, and 2CC187," October 8, 2024 (WO 50243078)
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) SH.OP-PT.FLX-0005, "Testing Godwin Dri-Prime Portable Pump HL160M," October 9, 2024 (WO 30361341)
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (2 Samples)
The inspectors evaluated:
- (1) The conduct of a routine drill involving a simulated fire in the auxiliary building resulting in an unusual event declaration on December 5, 2024
- (2) A simulator scenario and the associated emergency classification on December 9,
RADIATION SAFETY
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) Surveys of potentially contaminated material leaving the Unit 2 containment
- (2) Surveys of potentially contaminated material leaving the radiologically controlled area at the Units 1 and 2 access control point during the during a refueling outage
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) Unit 2, move the core barrel from the reactor vessel to the deep end of the canal
- (2) Unit 2, baffle bolt repairs
- (3) Unit 2, clevis bolt replacements
- (4) Unit 2, thimble tube replacements 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 and very high radiation areas:
- (1) Unit 2, seal table room
- (2) Unit 2, access to area under the reactor vessel/reactor sump 78'
- (3) Unit 2, regenerative heat exchanger room
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.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05)===
- (1) Unit 1, October 1, 2023 through September 30, 2024
- (2) Unit 2, October 1, 2023 through September 30, 2024
MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)
- (1) Unit 1, October 1, 2023 through September 30, 2024
- (2) Unit 2, October 1, 2023 through September 30, 2024
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) October 1, 2023 through 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 through September 30, 2024
71152S - Semi-Annual Trend Problem Identification and Resolution Semi-Annual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensee's corrective action program for potential adverse trends that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Inadequate Hardening of Service Water (SW) and Component Cooling (CC) Water Systems During Shutdown Cooling Operation Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000311/2024004-01 Open/Closed
[H.5] - Work Management 71111.20 The inspectors identified a Green finding and associated non-cited violation (NCV) of Salem Generating Station (Salem), Unit 2, Technical Specification 6.8.1, Procedures and Programs, when the licensee failed to implement written procedures as required by Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A, Section 3. Specifically, PSEG did not properly implement S2.OP-SO.SW-0003, 22 Nuclear Service Water Header Outage, Revision 33, resulting in inadequate hardening of the 21 SW header and CC system during the shutdown cooling operation while the 22 SW header was removed from service for planned maintenance.
Description:
On October 10, 2024, with Salem Unit 2 in Mode 6 (Refueling), PSEG implemented procedure S2.OP-SO.SW-0003 to prepare for the removal of the 22 SW header for maintenance. This procedure provides instructions for aligning the required safety-related systems to facilitate the removal of the 22 SW header from service and provides guidance on the support systems for residual heat removal in Modes 5 and 6. The procedure ensures system redundancy is maintained during the removal of the 22 SW header by hardening systems or components supplied by the 21 SW header. Specifically, Step 2.1.9 of the procedure identifies components, including the 21 CC heat exchanger and CC essential header loads, required to support residual heat removal loop operability during the 22 SW header outage.
Additionally, Salem Unit 2, Technical Specification Bases 3/4.9.8, "Residual Heat Removal and Coolant Circulation," states, for support systems SW and CC, component redundancy is necessary to ensure no single active component failure will cause the loss of decay heat removal (DHR). The support systems needed before entering into the desired configuration (e.g., one SW loop (header) out for maintenance in Modes 5 or 6) are controlled by procedures, and includes the following:
- A requirement that the two residual heat removal, two CC, and two SW pumps, powered from two different vital buses be kept operable
- A listing of the active (air/motor-operated) valves in the affected flow path to be locked open or disabled.
These requirements are incorporated into procedure S2.OP-SO.SW-0003. Section 2.2, "Limitation," emphasizes that system redundancy for SW and CC must be preserved to prevent any single active component failure from causing loss of DHR. Specifically, Step 4.1.16 directs performing Attachment 1, which specifies actions to eliminate single-point failures on specific valves, such as removing their power to prevent a loss of DHR.
On October 11, 2024, the inspectors performed a walkdown of the 21 SW header hardening, which included verification of components in accordance with Attachment 1, Disabled/Locked Valve Lineup, of the procedure. During this walkdown, the inspectors identified that two valves listed in Attachment 1 were not properly hardened. Specifically, the inspectors found that the breakers for CC header 21 and 22 crossover valve, 21CC3, and CC header 22 to 23 crossover valve, 22CC3, were energized, contrary to the hardening requirements. These breakers should have been de-energized and tagged with white caution tags as specified in the procedure.
The inspectors determined that failure to de-energize these valves introduced a vulnerability to single-point failures that could result in the loss of DHR. For the plant configuration at the time, the 21 CC pump was secured, while the 22 and 23 CC pumps were in service. A single failure on these valves could have caused a loss of CC flow to the 21 CC heat exchanger, which was in service to provide cooling to the residual heat removal heat exchanger for shutdown cooling. This condition represented a potential risk to the operability of shutdown cooling support systems.
Additionally, the inspectors reviewed the plant's Shutdown Safety Plan, which analyzed the plant condition for unavailability of 22 SW header and determined the shutdown safety risk to be YELLOW for the key safety functions of shutdown cooling and SW. Defense-in-depth credit to maintain risk at an acceptable level was attributed to the hardening of the 21 SW header. The failure to adequately harden the 21 SW header, as identified during the walkdown, deteriorated this risk mitigation strategy.
Corrective Actions: PSEGs immediate corrective action was to de-energize the 21CC3 and 22CC3 motor-operated valves. PSEG documented the issue in their corrective action program as NOTF 20977520. Furthermore, PSEG conducted a work group evaluation to address the cause of the issue and implement corrective actions. PSEG plans to revise the procedure to provide clearer guidance and to add a requirement for independent verification of Attachment 1 components.
Corrective Action References: NOTFs 20977520, 20978124, 20978335, 70237713
Performance Assessment:
Performance Deficiency: The inspectors determined that PSEGs failure to ensure adequate hardening of the SW and CC systems as required by procedure S2.OP-SO.SW-0003, to eliminate a single active component failure vulnerability, was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to de-energize motor-operated valves 21CC3 and 22CC3 as required introduced a vulnerability to single-point failures. This condition could have resulted in the loss of DHR, thereby challenging the key safety functions of shutdown cooling during shutdown operations. As a result, PSEG was required to take immediate corrective actions, including opening the breakers for these valves and applying white caution tags to comply with the procedural requirements.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process. Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings. The inspectors used Exhibit 2, Initiating Events Screening Questions, and determined the finding to be of very low safety significance, Green, because it did not result in the loss of shutdown cooling or increase the likelihood of a shutdown initiating event. Specifically, PSEG maintained the availability of the 21 CC pump, which could have been placed into service if needed to restore CC flow through the 21 CC heat exchanger to support DHR function. Additionally, the unit was in Mode 6 (Refueling) with the cavity flooded, and time to boil was calculated to be 300 minutes. This provided sufficient time for operators to respond to any loss of CC flow affecting the DHR function.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the CC pumps lineup was not reviewed in the work package, which impacted the tagging for 21CC3 and 22CC3 during SW hardening.
Enforcement:
Violation: Salem Unit 2, Technical Specification 6.8.1, Procedures and Programs, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 3, states, in part, that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the CC water system and SW system.
Contrary to these requirements, from October 10 to 11, 2024, PSEG failed to adequately implement procedure S2.OP-SO.SW-0003, which required hardening the SW and CC systems to prepare for the removal of a SW header for maintenance. As a result, a vulnerability was introduced such that a single-point failure could have resulted in the loss of DHR, thereby challenging the key safety functions of shutdown cooling during shutdown operations.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Semi-Annual Trend Review 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 list, system health reports, and maintenance or corrective action program backlog. The inspectors review was conducted to assess PSEGs ability to appropriately identify, evaluate, and resolve issues and potential trends. Some trends reviewed by the inspectors and identified by PSEG included:
1. NOTF 20971436, adverse trend in human error prevention. Gaps have been identified
in the areas of verification practices, situational awareness, and use of work instructions (Check-in Self-Assessment 70236445).
2. NOTF 20974647, trend in work instruction quality and adherence.
3. NOTF 20978623, adverse trend in operators adherence to proper procedure use and
adherence standards (place keeping and use of available procedures). Observed gap resulted in entry into a one hour shutdown limiting condition for operation, operations of steam generator feed pump cooler without procedure in hand, and a level 3 status control event (SW hardening, which was NRC identified Green NCV documented in Section 71111.20 of this inspection report).
4. NOTF 20974316, Station Ownership Committee documented trend in new solenoid
valves failures. Four failures noted between June 1, 2024 and September 1, 2024.
Based on the overall results of the semi-annual trend review, the inspectors determined that issues were appropriately evaluated by PSEG for potential trends and resolved within the scope of the corrective action program. The inspectors determined that PSEG's actions in response to the human performance issues were appropriate to the circumstances.
The 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 February 5, 2025, the inspectors presented the integrated inspection results to David Sharbaugh, Site Vice President, and other members of the licensee staff.
- On October 29, 2024, the inspectors presented the radiation protection 71124.01 inspection results to Rick Desanctis, Plant General Manager, and other members of the licensee staff.
- On November 14, 2024, the inspectors presented the inservice inspection results to Tammy Morin, Manager, Station Compliance, 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
Procedures
SC.OP-PT.ZZ-
0002
Station Preparation for Seasonal Conditions
Miscellaneous
NOTF 20977520
71111.07A Miscellaneous
20975096,
20978782,
20980151
Work Orders
30330364,
30364781
Corrective Action
Documents
20978182
2A EDG Negative-Phase Sequence Relay Failed Testing
20982348
Miscellaneous
Technical
Evaluation
30345691-0020-
0001
GE INC77B3A Negative-Phase Sequence Cannot Reset
Miscellaneous
NOTF 20978258
NOTF 20978358
NOTF 20978461
Miscellaneous
NOTF 20976793
Miscellaneous
NOTF 20939233
NOTF 20942123
NOTF 20964349
NOTF 20977858
NOTF 20978738
NOTF 20979943
Procedures
Diagnostic Testing and Inspection of Motor-Operated Valves
Work Orders
290445
60161093
71151
Corrective Action
Documents
20980156