IR 05000354/2025050
| ML25122A007 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/02/2025 |
| From: | Blake Welling Division of Operating Reactors |
| To: | Mcfeaters C Public Service Enterprise Group |
| References | |
| IR 2025050 | |
| Download: ML25122A007 (1) | |
Text
May 2, 2025
SUBJECT:
HOPE CREEK GENERATING STATION - SPECIAL INSPECTION REPORT 05000354/2025050
Dear Charles McFeaters:
On February 20, 2025, the U.S. Nuclear Regulatory Commission (NRC) conducted its initial assessment of water intrusion into the 'D' emergency diesel generator lubricating oil system, which occurred on February 19, 2025, at Hope Creek Generating Station. Based on this initial assessment, the NRC sent an inspection team to your site on February 25, 2025.
On March 20, 2025, the NRC completed its special inspection and 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Hope Creek Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Hope Creek Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Blake D. Welling, Director Division of Operating Reactor Safety
Docket No. 05000354 License No. NPF-57
Enclosure:
Inspection Report 05000354/2025050 w/Attachment 1: SIT Charter and Attachment 2: MD 8.3 Evaluation
Inspection Report
Docket Number:
05000354
License Number:
Report Number:
Enterprise Identifier: I-2025-050-0000
Licensee:
Facility:
Hope Creek Generating Station
Location:
Hancocks Bridge, NJ
Inspection Dates:
February 25, 2025 to March 25, 2025
Inspectors:
E. Miller, Senior Reactor Inspector
J. Kulp, Senior Reactor Inspector
C. Bickett, Senior Reactor Analyst
R. Clagg, Senior Project Engineer
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 a special inspection at Hope Creek Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Generate Notifications in Accordance with Oil Analysis Guidelines Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000354/2025050-01 Open/Closed
[P.1] -
Identification 93812 The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, when Hope Creek Generating Station (HCGS) did not generate notifications and enter them into the corrective action program to document abnormal lubricating oil analysis results as required by ER-AA-230-1001, Oil Analysis Interpretation Guideline, and ER-AA-2005, Component Health Indicator Program, between November 21, 2024, and March 4, 2025.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000354/2025050-02 Emergency Diesel Generator Lube Oil Heat Exchanger Complex Troubleshooting 93812 Open URI 05000354/2025050-03 Emergency Diesel Generator Lube Oil Heat Exchanger Maintenance Practices 93812 Open
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.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 93812 - Special Inspection In accordance with the attached updated Special Inspection Team (SIT) Charter, the inspection team conducted a detailed review of the HCGSs 'D' emergency diesel generator (EDG) failure on February 19th, 2025.
Description of Event and Reactive Inspection Basis:
Hope Creek has four EDGs. Each EDG starts automatically upon loss of offsite power or a loss of coolant accident and independently feeds one of the four Class 1E loads. EDGs are designed to start and be ready to accept load within 10 seconds after receipt of a start signal. Three out of the four EDGs provide adequate capacity to operate all the equipment necessary to prevent undue risk to public health and safety in the event of total loss of offsite power or a design basis accident.
On February 19, 2025, the D EDG was removed from service for planned maintenance.
Following completion of a maintenance run, three lube oil samples were taken and all three had visible water present. Specifically, the samples taken at the crankcase and rocker arm lube oil tank sample points were milky in appearance, indicating water in the sample. A sample taken at the lube oil heat exchanger (shell/oil side) sample point consisted of predominately water initially and then lube oil with a milky appearance. Initial analysis showed a water concentration greater than 13,000 parts per million (ppm) in the samples from the D EDG crankcase and lube oil heat exchanger, which was above the 1,000 ppm fault limit. On February 20, 2025, at 1542, HCGS declared the D EDG inoperable due to the water levels present in the lube oil. Hope Creek remained in the applicable technical specification action statement for one EDG out of service, which had been entered on February 19, 2025.
Through additional sample analysis, the licensee confirmed the source of the water was from the safety auxiliaries cooling system (SACS) via the lube oil heat exchanger, which is the only location where SACS interfaces with EDG lube oil.
A similar water intrusion event occurred previously on January 31, 2025. Specifically, an alarm was received on the D EDG for high differential pressure (D/P) across the lube oil filter, resulting in the licensee declaring the D EDG inoperable. The licensee had taken a crankcase oil sample eight days prior on January 23, 2025, and results obtained from the vendor on January 31, 2025, indicated high water content that was identified as SACS. Subsequent investigation by the licensee was unable to identify a definitive cause; however, eddy current testing on the lube oil heat exchanger identified minor indications on five tubes, which were then plugged. Follow on testing did not show further indications of leakage into the D EDG lube oil system. Following post-maintenance run and surveillance testing, the D EDG was declared operable at approximately 1700 on February 9, 2025.
The water intrusion on February 19, 2025, constituted a repetitive failure of the D EDG. The exact cause of water intrusion into the lube oil was unknown at the time; however, the degraded condition could have existed for an extended time, starting prior to the initial water sample taken on January 23, 2025, and extending through the recent discovery of water on February 19, 2025. The inspectors determined that both water intrusion events would likely have prevented the D EDG from achieving its safety-related function.
Special Inspection Team Charter Scope
1. Develop a sequence of events of the D EDG failure to include follow-up actions taken by
Public Service Enterprise Group (PSEG). The review should consider licensee-identified timelines, logs, and computer data, as applicable.
a. Inspection Scope
The inspectors conducted interviews with design engineering, procurement engineering, system engineering, corporate engineering, maintenance staff, vendor experts, operators, and outage control center (OCC) staff, and reviewed corrective action documents, surveillance run logs, OCC logs, and data focused on the troubleshooting, maintenance, and restoration of the D EDG.
b. Observations and Findings
The following timeline is an overview of the major events leading up to the failure of the D EDG on February 19, 2025, and subsequent actions taken.
- January 23:
o
'D' EDG monthly run completed. Lube oil sample taken during the monthly run (15 minutes after reaching full load) sent to Trico for analysis.
- January 26:
o 0600: 'D' EDG control room alarm received due to high rocker arm lube oil tank level. Operator in field drained 1/2 liter of water from rocker arm lube oil reservoir.
- January 27:
o 0000: A EDG declared inoperable for planned maintenance.
o 1030: Sample retaken at 'D' rocker arm lube oil. Drained 1/4 liter of water.
- January 31:
o 0705: D EDG high lube oil strainer D/P alarm received in control room.
o 0735: D EDG declared inoperable due to high lube oil strainer D/P alarm.
Entered Technical Specification Limiting Condition of Operation 3.8.1.1.e, requiring one of the two inoperable diesels to be restored within two hours. OCC staffed.
o 1230: D EDG Trico results from the 1/23 lube oil sample received by PSEG.
Running lube oil sample: 35,980 ppm.
Wear Particles found in lube oil sample.
o 2121: A EDG declared operable.
- February 2-7:
o Performed the following maintenance activities:
Verified no plugs missing in heat exchanger.
Completed 1st round of eddy current testing with bobbin probe.
Performed pressure testing (shell side at 90 pounds per square inch (psi)).
Borescoped tube side of lube oil heat exchanger.
Plugged five tubes with minor wall loss.
Lube oil strainer was replaced.
Water/oil was cleaned out of lube oil system.
Oil in D EDG sump was run through a dehydrator.
After the tubes were plugged, a 6-hour hydrostatic test was completed with no leakage identified.
- February 8:
o 1632: D EDG post-maintenance run, shut down at T=45 minutes due to lube oil strainer D/P >15 pounds per square inch differential (psid).
- February 9:
o 0535: D EDG placed in service for monthly surveillance. Secured at T=109 minutes for lube oil strainer D/P >15.
o 0830: D EDG shutdown. Lube oil strainer replaced.
o 1303: D EDG placed in service for monthly surveillance.
o 1339: D EDG at full load, Lube oil Strainer D/P stayed constant at 3 psid.
o 1516: D EDG shutdown at conclusion of surveillance test.
o 1700: D EDG declared operable. OCC disbanded.
- February 19:
o 0200: D EDG declared inoperable for planned maintenance.
o 1900: Water identified in oil during D EDG post-maintenance run.
o 1900: OCC staffed.
o 1200: D EDG oil sample results acquired by PSEG. Lube oil heat exchanger drain and crankcase >13,000 ppm.
- February 20:
o 1900: D EDG tagged out for maintenance.
- February 20-26:
o Performed the following maintenance activities:
Verified no plugs missing in heat exchanger.
Performed Helium pressure testing (shell side at 83 psi).
Lube oil strainer was replaced.
Water/oil was cleaned out of lube oil system.
Completed 2nd round of eddy current testing with an array probe.
Lube oil in D EDG was run through a dehydrator.
- February 26:
o Lantern ring and associated packing was removed from the system.
o New lantern ring was installed and system restoration commenced.
- February 27:
o Hydro testing completed satisfactorily.
- February 28 - March 2:
o Restoration of D EDG.
- March 3:
o 0844: D EDG maintenance run commences. Completed satisfactorily.
o 2356: D EDG surveillance run commences.
- March 4:
o 0425: D EDG declared operable. OCC disbanded.
- March 6:
o Sample results from surveillance run obtained:
Rocker arm lube oil sample: 1,071 ppm
Running lube oil sample: 448 ppm
2. Evaluate the adequacy of operator response to the D EDG failure. This should include a
review of procedure adherence and technical specification compliance.
a. Inspection Scope
The inspectors conducted interviews with system engineering, operations, and OCC staff, and reviewed corrective action documents, control room logs, adverse condition monitoring plans, and procedural guidance associated with alarm response, technical specifications, and surveillance runs for the D EDG.
b. Observations and Findings
The inspectors determined that the immediate actions taken by the licensee in response to the water intrusion event were appropriate and per procedural guidance. Hope Creek appropriately complied with technical specifications when declaring the D EDG inoperable on February 19, 2025.
3. Evaluate PSEGs identification of the failure mode and the troubleshooting approach and
activities that supports the stations understanding and confidence in their determination of the direct cause.
a. Inspection Scope
The inspectors conducted interviews with design engineering, system engineering, maintenance staff, vendor experts, operators, and OCC staff, and reviewed corrective action documents and data focused on the troubleshooting, maintenance, and restoration of the D EDG as part of the inspection activity.
b. Observations and Findings
The inspection team determined that PSEG's identification of the degraded lantern ring and associated packing as the cause of the water intrusion event was reasonable. However, the team noted that PSEGs complex troubleshooting activities between January 31, 2025, and March 4, 2025, may not have been adequately completed. The licensee planned to evaluate their troubleshooting efforts as part of a root cause evaluation. As such, the NRC opened an unresolved item (URI) associated with Charter Item 3 in the Results section of this report to determine whether performance deficiencies exist regarding the complex troubleshooting activities associated with the restoration of the D EDG.
4. Evaluate whether PSEG appropriately considered past operating experience, including
internal operating experience as well as generic communications, in determining the direct cause.
a. Inspection Scope
The inspectors reviewed historical corrective action documents, including those captured and identified by the licensee in the complex troubleshooting plan; interviewed maintenance and operations staff regarding past activities associated with abnormal and degraded conditions of the D EDG; and reviewed industry operating experience that was associated with EDG lube oil systems.
b. Observations and Findings
The inspection team determined that PSEG's past operating experience may not have been fully evaluated, and there appeared to be a lack of maintenance activities associated with the lube oil heat exchanger lantern ring and associated packing, based on requirements set forth by Regulatory Guide 1.33. Since NRC's review of PSEG's root cause evaluation will not be complete prior to issuing this report, a URI was opened associated with Charter Item 4 in the Results section of this report to determine if performance deficiencies exist regarding complex troubleshooting activities associated with the restoration of the D EDG.
5. Evaluate PSEGs prompt corrective actions to address the failure, including the adequacy of
repair and testing activities to restore D EDG operability.
a. Inspection Scope
The inspectors conducted interviews with design engineering, procurement engineering, system engineering, corporate engineering, maintenance staff, vendor experts, operators, and OCC staff, and reviewed corrective action documents, procurement documentation, complex troubleshooting plans, and data focused on maintenance activities, work control, and restoration of the D EDG.
b. Observations and Findings
The prompt corrective actions performed by PSEG between February 19, 2025, and March 4, 2025, included the replacement of the D EDG lube oil heat exchanger lantern ring and associated packing. These components were procured as non-safety parts. The inspectors questioned the acceptability of installing non-safety parts into the safety-related system. This issue was dispositioned via the Very Low Safety Significance Issue Resolution (VLSSIR)process and is documented in the Results section of this report titled PC4, Non-Safety Parts Installed in the D EDG Lube Oil Heat Exchanger.
6. Review the circumstances associated with the D EDG failure to identify potential common
failure modes and generic safety concerns.
a. Inspection Scope
The inspectors conducted interviews with design engineering, system engineering, maintenance staff, vendor experts, operators, and OCC staff; reviewed corrective action documents, system drawings, and work controls; and performed multiple system walkdowns of all four EDGs.
b. Observations and Findings
The inspectors determined that the reviews and evaluations performed by the licensee to potentially identify common failure modes associated with the D EDG failure were appropriate.
PSEG has written notifications to create work orders for the replacement of the lantern rings and associated packing on the lube oil heat exchangers for the other three EDGs.
7. Evaluate and provide a recommendation to the Regional Administrator as to whether the
special inspection should be continued or be upgraded to an augmented inspection after the first three days of on-site information gathering and inspection.
a. Inspection Scope
The inspectors conducted interviews with design engineering, procurement engineering, system engineering, corporate engineering, maintenance staff, vendor experts, operators, and OCC staff, and reviewed corrective action documents, surveillance run logs, OCC logs, and data focused on the troubleshooting, maintenance, and restoration of the D EDG as part of the inspection activity.
b. Observations and Findings
After the first three days of on-site information gathering, the team concluded that an upgrade to an augmented inspection was not necessary and recommended to the Regional Administrator that the special inspection should be continued.
INSPECTION RESULTS
Failure to Generate Notifications in Accordance with Oil Analysis Guidelines Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000354/2025050-01 Open/Closed
[P.1] -
Identification 93812 The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, when HCGS did not generate notifications and enter them into the corrective action program to document abnormal lubricating oil analysis results as required by ER-AA-230-1001, Oil Analysis Interpretation Guideline, and ER-AA-2005, Component Health Indicator Program, between November 21, 2024, and March 4, 2025.
Description:
The Component Health Indicator Program (CHIP) (ER-AA-2500) is the methodology used by HCGS to determine the overall health of important plant components. CHIP gathers and integrates information gathered from the Predictive Maintenance Program, Online Monitoring and Analysis Program, Wireless Program, and other condition monitoring activities. The Oil Analysis Program (ER-AA-230-1001) is one of the condition monitoring activities that inputs data into CHIP and establishes owner defined action levels (normal, watch/trend, alert, fault, emergency use only) to evaluate physical parameters, wear metals, additives, and contaminant levels, and provides guidance on actions to be taken in the event that the action levels are exceeded. ER-AA-230-1001, 7, Diesel Engines (Mobil Del Vac 1240), delineates the licensees preset limits applicable to the EDGs at HCGS. Both programs direct the use of the corrective action program when abnormal results are received, or preset limits are exceeded.
Step 4.1.2 of ER-AA-2500 requires that the data collector or an analyst generate a corrective action program notification to document abnormal conditioning monitoring data results. On multiple occasions between November 21, 2024, and March 4, 2025, abnormal oil results exceeding the licensees preset limits were returned from vendor and corporate oil analysis laboratories, but no notifications were generated. Examples include:
On November 21, 2024, the D EDG running crankcase lube oil sample identified the presence of 5 ppm of silver, which is in the alert range.
On January 23, 2025, the 'D' crankcase lube oil sample identified numerous parameters in the alert range, including anti-wear, total wear, and boron.
On March 3, 2025, the D EDG rocker arm lube oil sample identified a viscosity value at 183.56 centistokes (cSt), which is in the fault range.
On March 4, 2025, oil samples from the D EDG (e.g., running crankcase lube oil and rocker arm lube oil) identified a viscosity value of 177.42 cSt, which is in the alert range.
Corrective Actions: HCGS updated the CHIP and wrote a notification to capture the issue.
Corrective Action References: HCGS entered this issue into the corrective action program as Notification 20989532.
Performance Assessment:
Performance Deficiency: HCGS did not enter abnormal conditions indicated by lube oil analysis results into the corrective action program for resolution as directed by ER-AA-2005, Component Health Indicator Program, ER-AA-230-1001, Oil Analysis Interpretation Guideline, and LS-AA-120, Issue Identification and Screening Process.
Screening: The inspectors determined the performance deficiency was more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, absent NRC intervention, HCGS could continue to miss opportunities to capture, track, and analyze abnormal oil analysis results, which could have an adverse impact on equipment function, and could have caused HCGS to miss actions that the CHIP procedure would have required, such as oil changes or other maintenance activities.
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 determined this finding to be of very low safety significance (Green), because, when screened utilizing Exhibit 2 Mitigating Systems Screening Questions, Question 1, it was determined that this finding did not directly result in the loss of the diesel generators operability or probabilistic risk assessment functionality.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. (PI.1).
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. ER-AA-230-1001, Oil Analysis interpretation Guide, provides parameters for the diesel generators and directs the use of the corrective action program when abnormal results are received or preset limits are exceeded.
Contrary to the above, between November 21, 2024, and March 4, 2025, HCGS did not generate notifications and enter them into their corrective action program to document abnormal lubricating oil analysis results as directed by ER-AA-230-1001, Oil Analysis Interpretation Guideline, and ER-AA-2005, Component Health Indicator Program.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item (Open)
Emergency Diesel Generator Lube Oil Heat Exchanger Complex Troubleshooting URI 05000354/2025050-02 93812
Description:
The inspectors identified a URI for a potential performance deficiency related to complex troubleshooting associated with the 'D' EDG that occurred between January 31, 2025, and March 4, 2025.
Following the initial water intrusion event discovered on January 31, 2025, HCGS developed complex troubleshooting plans to diagnose the cause of water intrusion in the lube oil system for the 'D' EDG. This degraded condition is considered to be the reason that, on January 31, 2025, the 'D' EDG lube oil strainer D/P exceeded 20 psid, which resulted in operations declaring the diesel inoperable.
HCGS exited the complex troubleshooting effort on February 9, 2025, without refuting all the potential faults identified in failure Mode 3, lube oil heat exchanger leak, of their complex troubleshooting. PSEG entered complex troubleshooting a second time on February 19, 2025, following the second water intrusion event, and failure Mode 3 was confirmed. Due to the confirmation of failure Mode 3, inspectors questioned if HCGS had exited their initial troubleshooting preemptively. Additionally, the inspectors questioned the completeness of HCGS's refutation of other failure modes. As a result, the NRC opened a URI to evaluate if a performance deficiency exists related to the implementation of complex troubleshooting for the D EDG lube oil system.
Planned Closure Actions: In order to determine if a performance deficiency exists, the inspectors will review the results of HCGS's root cause evaluation which will be completed at a later date.
Licensee Actions: HCGS is evaluating the completion of their complex troubleshooting plan through a formal root cause evaluation. Additionally, HCGS has developed an adverse conditioning monitoring plan for the 'D' EDG lube oil system to monitor for additional water intrusion, including daily oil samples at several locations performing and increased monitoring on the 'D' EDG strainer and filter D/P gauges.
Unresolved Item (Open)
Emergency Diesel Generator Lube Oil Heat Exchanger Maintenance Practices URI 05000354/2025050-03 93812
Description:
The inspectors identified a URI for a potential performance deficiency related to the implementation of the maintenance plan for the 'D' EDG lubrication system. The inspectors noted that the as-found degraded condition of the D EDG lube oil heat exchanger lantern seal and packing assembly was identified by HCGS to be the likely cause of the D EDG being declared inoperable. These components were not included in a formal maintenance plan, and inspectors questioned if these components should have been monitored and maintained in accordance with a preventive maintenance program, based on requirements set forth by Regulatory Guide 1.33. As a result, the NRC opened a URI to evaluate if a performance deficiency exists related to the implementation of the maintenance plan for the 'D' EDG lube oil system.
Planned Closure Actions: In order to determine if a performance deficiency exists, the inspectors will review the results of HCGS's root cause evaluation which will be completed at a later date.
Licensee Actions: HCGS replaced the lantern ring and packing assembly on the D EDG. HCGS is developing maintenance activities to replace the packing and lantern rings on the lube oil heat exchangers associated with the other three EDGs.
Very Low Safety Significance Issue Resolution Process: PC4, Non-Safety Parts Installed in the 'D' Emergency Diesel Generator Lube Oil Heat Exchanger 93812 This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.
Description:
On February 19, 2025, the D EDG was removed from service due to a water leak into the EDG lube oil system requiring the replacement of the lantern ring and associated packing on the floating end of the lube oil heat exchanger. The replacement and testing were completed on March 4, 2025, and the D EDG was restored to operable. The inspectors identified that, during the replacement of the lantern ring and associated packing, the components procured and installed into the lube oil heat exchanger were PC4 (non-safety)components.
Licensing Basis: The HCGS updated final safety analysis report (UFSAR), section 9.5.7, states that the EDG lubrication system is a safety-related system. The UFSAR provides additional context in table 3.2-1, where it identifies the lube oil heat exchanger as a quality assurance component for which 10 CFR Part 50, Appendix B applies. To ensure quality of safety-related systems, any materials, parts, and components must be controlled and procured through a process to ensure quality. This led the inspectors to believe that the lantern ring and packing assembly installed in the lube oil heat exchanger should have been PC1 (safety-related components) or PC2 (commercial grade dedicated components).
However, in accordance with HCGS UFSAR, table 3.2-1, the lube oil heat exchanger is a safety Class 3 component. UFSAR, table 3.2-1, also identifies that the principal construction codes and standards for the lube oil heat exchanger is American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BP&V) code, section III, class 3. This states, in part, that certain replacement parts that do not have a pressure retaining function, such as shafts, stems, trim, spray nozzles, bearings, bushings, springs, wear plates, seals, packing, gaskets, valve seats, and ceramic insulating material and special alloys used as seal material in electrical penetration assemblies are excluded from the ASME standards.
Without further substantial research, the inspectors were unable to determine if the licensees installation of PC4, non-safety packing and a PC4, non-safety lantern ring were acceptable components to be installed in the lube oil heat exchanger. 10 CFR Part 50, Appendix B guidance would suggest that all aspects of a safety-related system should be procured in a way that ensures quality; however, ASME BP&V code suggests that there are certain items and components that are exempt from the ASME code which could affect the way 10 CFR Part 50, Appendix B is applied.
Significance: For the purpose of the VLSSIR process, the inspectors screened the issue of concern through IMC 0612, Issue Screening, and determined the issue of concern would likely be greater than minor. The issue was also screened through IMC 0609, Appendix A, The Significance Determination Process for Findings At-power, and determined that the issue of concern would screen as very low safety significance (Green).
Technical Assistance Request: No technical assistance request was processed in support of this issue.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 20, 2025, the inspectors presented the special inspection results to Eric Larson, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
93812
Corrective Action
Documents
20982231
20987274
20987554
20987553
20989521
20989532
20986136
20986210
20986309
20986551
20986746
20986761
20986795
20986796
20986920
20987065
20987066
20987078
20987182
Corrective Action
Documents
Resulting from
Inspection
20987274
20988124
20988125
20988126
20988127
20989521
20989532
20990826
20990718
20988678
20989723
20988231
20988015
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Evaluations
80138542-0020
High Water Content 'C' EDG Oil Sample
Revision 0
Miscellaneous
TRICO Condition Report 'D' EDG Rocker Arm Lube Oil Tank
(LAH-7563D) Sample Date: 03/04/2025
03/07/2025
TRICO Condition Report 'D' EDG Crankcase H1KJ-1D-G-
400 (V715) Sample Date: 03/04/2025
03/10/2025
TRICO Condition Report 'D' EDG Rocker Arm Lube Oil Tank
(LAH-7563D) Sample Date: 01/23/2025
01/31/2025
ACM HC 25-001
Adverse Condition Monitoring Plan: D EDG Lube Oil Water
Intrusion
Revision 1
OTDM 25-001:
20986169
Operational and Technical Decision Maker: 'D' Emergency
Diesel Generator
2/07/2025
PO 4501308979
2/05/2025
Procedures
Component Health Indicator Program
Revision 2
Oil Analysis Interpretation Guideline
Revision 2
HC.OP-ST.KJ-
0004
EDG 1DG400 Operability Test
Revision 82
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD, STE 102
KING OF PRUSSIA, PA 19406-1415
February 25, 2025
MEMORANDUM TO:
Eric
Engineering Branch 2
Division of Operating Reactor Safety
THRU:
Nicole
- S. Warnek, Branch Chief, Team Manager
Projects Branch 3
Division of Operating Reactor Safety
FROM:
Andrea L. Kock
Regional Administrator
SUBJECT:
SPECIAL INSPECTION TEAM CHARTER - HOPE CREEK
GENERATING STATION EMERGENCY DIESEL GENERATOR
FAILURE
This memorandum designates you as the special inspection team leader. Your duties will
be as described in Inspection Procedure 93812, "Special Inspection," dated June 7, 2022.
The team composition has been discussed with you directly. During performance of special
inspection activities, designated team members are separated from their normal duties and
report directly to you. The team is to emphasize fact finding in its review of the
circumstances surrounding the event, and it is not the responsibility of the team to examine
the regulatory process. Safety concerns identified that are not directly related to the event
should be reported to the Region I office for appropriate action.
The team should begin inspection activities on or before February 25, 2025, based on the
licensees schedule of activities. You should notify the licensee and conduct an entrance
meeting at an appropriate time at the site, if desired by the licensee. A report documenting
the results of the inspection, including findings and conclusions, should be issued within 45
days of the exit meeting conducted at the completion of the inspection. While the team is
active, you will provide periodic status briefings to Region I management.
The enclosed Charter may be modified should the team develop significant new information
that warrants review. Should you have any questions concerning this Charter, contact Nikki
Warnek, Team Manager, Division of Operating Reactor Safety, at (610) 337-6954.
Enclosure:
As stated
NICOLE
WARNEK
Digitally signed by
Date: 2025.02.25
07:55:12 -05'00'
ANDREA
KOCK
Digitally signed by
Date: 2025.02.25
23:12:53 -05'00'
HOPE CREEEK GENERATING STATION - SPECIAL INSPECTION CHARTER
This special inspection team is chartered to assess the circumstances surrounding the D
emergency diesel generator (EDG) failure that occurred at Hope Creek Generating Station
(Hope Creek) on February 19, 2025. The special inspection will be conducted in accordance
with Inspection Procedure 93812, Special Inspection. The inspection team will conduct an exit
meeting upon completion of the inspection and document the inspection findings and
conclusions in a Special Inspection Team final report within 45 days of inspection completion.
A. Basis
Hope Creek has four EDGs. Each EDG starts automatically upon loss of offsite power or a
loss of coolant accident and independently feeds one of the four Class 1E loads. EDGs are
designed to start and be ready to accept load within 10 seconds after receipt of a start
signal. Three out of the four EDGs provide adequate capacity to operate all the equipment
necessary to prevent undue risk to public health and safety in the event of total loss of
offsite power or a design basis accident.
On February 19, 2025, the D EDG was removed from service for planned maintenance.
Following completion of a maintenance run, three lube oil samples were taken and all three
had visible water present. Specifically, the samples taken at the crankcase and rocker arm
lube oil tank sample points were milky in appearance, indicating water in the sample. A
sample taken at the lube oil heat exchanger (shell/oil side) sample point consisted of
predominately water initially and then lube oil with a milky appearance. Initial analysis
showed a water concentration greater than 13,000 parts per million (ppm) in the samples
from the D EDG crankcase and lube oil heat exchanger, which was above the 1000 ppm
fault limit. At 1542 on February 20, 2025, Hope Creek declared the D EDG inoperable
due to the water levels present in the lube oil. Hope Creek remained in the applicable
technical specification action statement for one EDG out of service, which had been entered
on February 19, 2025.
Through additional sample analysis, the licensee confirmed the source of the water was
from the safety auxiliaries cooling system (SACS) via the lube oil heat exchanger, which is
the only location where SACS interfaces with EDG lube oil.
A similar water intrusion event occurred previously, on January 31, 2025. Specifically, an
alarm was received on the D EDG for high differential pressure across the lube oil and
filter, resulting the in licensee declaring the D EDG inoperable. The licensee had taken a
crankcase oil sample eight days prior, on January 23, 2025. Results obtained from the
vendor on January 31, 2025, indicated high water content that was identified as SAC
- S.
Subsequent investigation by the licensee was unable to identify a definitive cause; howeverProperty "Contact" (as page type) with input value "S.</br></br>Subsequent investigation by the licensee was unable to identify a definitive cause; however" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
eddy current testing on the lube oil heat exchanger identified minor indications on 5 tubes,
which were then plugged. Follow on testing did not show further indications of leakage into
the D EDG lube oil system. Following a post-maintenance run and surveillance testing, the
D EDG was declared operable at approximately 1700 on February 9, 2025.
The February 19, 2025, water intrusion constitutes a repetitive failure of the D EDG. The
exact cause of water intrusion into the lube oil is unknown; however, the degraded condition
may have existed for an extended time, starting prior to the initial water sample taken on
January 23, 2025, and extending through the recent discovery of water on February 19,
25. Both failures would likely have prevented the D EDG from achieving its safety-related
function in an event.
B. Scope
The team is expected to perform information gathering and fact-finding to address the
following areas:
1.
Develop a sequence of events of the D EDG failure to include follow-up actions taken
by Public Service Enterprise Group (PSEG). The review should consider licensee-
identified timelines, logs, and computer data, as applicable.
2.
Evaluate the adequacy of operator response to the D EDG failure. This should
include a review of procedure adherence and technical specification compliance.
3.
Evaluate PSEGs identification of the failure mode and the troubleshooting approach
and activities that supports the stations understanding and confidence in their
determination of the direct cause.
4.
Evaluate whether PSEG appropriately considered past operating experience,
including internal operating experience as well as generic communications, in
determining the direct cause.
5.
Evaluate PSEGs prompt corrective actions to address the failure, including the
adequacy of repair and testing activities to restore D EDG operability.
6.
Review the circumstances associated with the D EDG failure to identify potential
common failure modes and generic safety concerns.
7.
Evaluate and provide a recommendation to the Regional Administrator as to
whether the special inspection should be continued or be upgraded to an
augmented inspection after the first three days of on-site information gathering and
inspection.
C. Team Members
-
Eric Miller, Team Leader
-
Jeff Kulp, Team Member
Issue Date: 12/14/23
E1-1
0309
Decision Documentation for Reactive Inspection
(Deterministic and Risk Criteria Analyzed)
PLANT: Hope Creek
EVENT DATE:
February 19, 2025
EVALUATION DATE:
February 20, 2025
Brief Description of the Significant Operational Event or Degraded Condition:
On February 19, 2025, during a D Emergency Diesel Generator (EDG) preventative
maintenance outage, following completion of a maintenance run, lube oil samples were taken
with visible water present. Specifically, samples taken at the crankcase and rocker arm lube
oil tank sample points were milky in appearance, indicating water in the sample. A sample
taken at the lube oil heat exchanger (shell/oil side) sample point showed predominately water
initially and then lube oil with a milky appearance, indicating water in the sample.
The licensee sent oil samples to an offsite vendor and is awaiting results to determine the
amount of water intrusion and validate the water source. However, initial sample results
analyzed at the site on February 20 showed > 13,000 ppm water in the samples from the D
EDG crankcase and lube oil heat exchanger, which is above the 1000 ppm limit fault limit for
the lube oil. Additionally, initial visual indication, specifically a lack of pink color of the water in
the samples, indicated that it was from the Safety Auxiliaries Cooling System (SACS) vice the
D EDG jacket water system, which has a corrosion inhibitor added that produces a pinkish
hue to the water.
At 1542 on February 20, 2025, Hope Creek declared the D EDG inoperable due to the water
levels present in the lube oil. (Note: the EDG was already inoperable for the maintenance
window, which began on February 19, 2025.) The licensees troubleshooting is focused on
the EDG lube oil heat exchanger, which is the only SACS / lube oil interface. Subsequent
testing results by the licensee confirmed SACS as the source of the water in the lube oil
system.
A similar water intrusion event occurred previously, on January 31, 2025. Specifically, at
0735 on January 31, an alarm was received on the D EDG for high lube oil filter differential
pressure (dP), resulting in the licensee declaring the EDG inoperable. The licensee had
taken a crankcase oil sample 8 days prior, on January 23. Results obtained from the vendor
on January 31 indicated high water content that was identified as SACS. Subsequent
investigation by the licensee was unable to identify a definitive cause; however, eddy current
testing on the lube oil heat exchanger identified minor indications on 5 tubes, which were
then plugged. Follow on testing did not show further indications of leakage into the D EDG
lube oil system. Following restoration activities, a post-maintenance run, and surveillance
testing, the D EDG was declared operable at approximately 1700 on February 9, 2025.
The February 19, 2025, water intrusion into the D EDG lube oil constitutes a repetitive
failure of the D EDG. The exact cause of water intrusion into the lube oil is unknown;
however, the degraded condition may have existed for an extended period of time, starting
prior to the initial water sample taken on January 23, 2025, and extending through the recent
discovery of water on February 19, 2025.
Issue Date: 12/14/23
E1-2
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Y/N
DETERMINISTIC CRITERIA
N
a. Involved operations that exceeded, or were not included in, the design bases of
the facility
Remarks: No design bases were exceeded during these events.
N
b. Involved a major deficiency in design, construction, or operation having potential
generic safety implications
Remarks: There was no identified design, construction or operation having potential
generic safety implications.
N
c. Led to a significant loss of integrity of the fuel, primary coolant pressure boundary,
or primary containment boundary of a nuclear reactor
Remarks: There was no impact or challenge on the integrity of the fuel or primary
containment boundary.
N
d. Led to the loss of a safety function or multiple failures in systems used to mitigate
an actual event
Remarks: These events did not lead to loss of a safety function or cause failures in
multiple systems used to mitigate an actual event.
N
e. Involved possible adverse generic implications
Remarks: There are no adverse generic implications.
N
f. Involved significant unexpected system interactions
Remarks: There were no significant unexpected system interactions.
Y
g. Involved repetitive failures or events involving safety-related equipment or
deficiencies in operations
Remarks: The safety-related D EDG experienced repetitive failures due to
water intrusion into the lube oil system within a one-month period. On
January 31, 2025, the D EDG was declared inoperable due to high lube oil
differential pressure caused by a SACS leak into the lube oil system. Following
repair and restoration to operable status on February 9, 2025, the D EDG was
again declared inoperable on February 20, 2025, due to a water leak into the
lube oil, also from SAC
failures would likely have prevented the D EDG from achieving its safety-
related function during an event.
N
h. Involved questions or concerns pertaining to licensee operational performance
Remarks: There are no questions or concerns pertaining to licensee operational
performance.
Issue Date: 12/14/23
E1-3
0309
CONDITIONAL RISK ASSESSMENT
RISK ANALYSIS BY: C. Bickett/F. Arner
DATE: 02/20/2025
The SRAs used the Hope Creek SPAR model (Version 8.81) and SAPHIRE (Version 8.2.12)
to assess this condition, with the following assumptions and adjustments:
Assumptions
x
Given current information, the SRAs assumed the accumulation of water in the lube oil
only occurred while the EDG was running. Therefore, the SRAs modeled failure of the D
EDG as a failure to run.
x
More inspection is required to determine the exposure time of the degraded condition for
the D ED
- G. Because of this uncertainty, for this analysis, the SRAs assumed the
exposure time started on 01/23/2025, which was the date of the original D EDG
crankcase oil sample that was out of specification due to high water content. The
exposure time(s) associated with any potential performance deficiencies evaluated as
part of the significance determination process could be longer.
x
The SRAs considered that the D EDG was inoperable for the entire duration of the A
EDG maintenance window (i.e., 01/27/2025 00:00 - 01/31/2025 20:21)
x
The SRAs considered the 10K107 air compressor unavailable (out of service due to high
vibration since 12/24/2024).
x
The SRAs assumed an end date of 02/20/2025, but risk continues to accrue as PSEG
troubleshoots and repairs this condition at power.
SPAR Model Adjustments
x
Set the D EDG fail-to-run basic event to TRUE to model the degraded condition
x
For the period where the A EDG was out of service for a maintenance window, set the
A EDG test and maintenance basic event to TRUE.
x
Set the 10K107 air compressor test and maintenance basic event to TRUE.
x
Added modeling for the AOT diesel generator and removed the gas turbine generator
from the model
x
Added credit for operator action to crosstie of instrument air to the primary containment
instrument gas system
x
Added credit for operator action to crosstie of the safety auxiliaries cooling system
x
Updated loss of offsite power initiating event frequencies to 2021 data (INL/RPT-22-
68809)
x
Adjusted common cause failure to account for the D EDG failure to run with the A EDG
in a test and maintenance condition
Risk Assessment
The SRAs did not have an estimate for fire risk with only the D EDG out of service.
However, during the Notice of Enforcement Discretion call on January 31, 2025, PSEG
stated that for 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, with both the A and D EDGs out of service, fire risk would be 2.8E-
7/yr. Assuming the D EDG was inoperable for the entire duration of the A EDG
maintenance window, the SRAs estimated the fire risk for this condition to be approximately
~9.2E-7/yr.
Using the fire information above, and the Hope Creek SPAR model to quantify internal event
risk, the SRAs determined that the total estimated incremental conditional core damage
Issue Date: 12/14/23
E1-4
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SUREDELOLW\\ ,&&'3RU&'3 ZDVDWOHDVWa(-6. There is uncertainty in this result, as it
does not include fire risk for periods when just the D EDG was out of service, and overall
risk could be higher depending on the cause of the degraded condition and how long the
condition existed. Additionally, the SRAs assumed an end date of 02/20/2025, but risk
continues to accrue as PSEG troubleshoots and repairs this condition at power. Therefore,
based on the assumptions described above, the SRAs concluded that this event falls at least
within the no additional inspection/special inspection overlap region (1E-6 to 5E-6).
RESPONSE DECISION
USING THE ABOVE INFORMATION AND OTHER KEY ELEMENTS OF CONSIDERATION
AS APPROPRIATE, DOCUMENT THE RESPONSE DECISION TO THE EVENT OR
CONDITION, AND THE BASIS FOR THAT DECISION
DECISION AND DETAILS OF THE BASIS FOR THE DECISION:
The Division of Operating Reactor Safety (DORS), Projects Branch 3, and the regional SRAs,
recommend performing a Special Inspection at Hope Creek.
Based on the repetitive failures involving safety-related equipment, specifically the D EDG
failures on January 31 and February 20, 2025, one of the IMC 0309 Deterministic Screening
Criteria for Risk Assessment are met. Conditional Risk Assessment has been completed
VKRZLQJDQHVWLPDWHGLQFUHPHQWDOFRQGLWLRQDOFRUHGDPDJHSUREDELOLW\\ ,&&'3RU&'3 of
at least ~ 3E-6 which falls at least within the no additional inspection/special inspection
overlap region (1E-6 to 5E-6).
Uncertainty currently exists with respect to the duration of the degraded condition. A special
inspection will allow for an independent and timely assessment of the most recent D EDG
failure, including an in-depth understanding of licensees troubleshooting efforts and other
performance aspects associated with this event. It will also allow the region to ascertain
whether Hope Creek implemented adequate troubleshooting efforts and corrective actions
associated with the previous failure of the D EDG.
BRANCH CHIEF REVIEW:
DIVISION DIRECTOR REVIEW:
ADAMS ACCESSION NUMBER: ML25052A166
EVENT NOTIFICATION REPORT NUMBER (as applicable): N/A
E-mail to NRR_Reactive_Inspection@nrc.gov
NICOLE
WARNEK
Digitally signed by NICOLE WARNEK
Date: 2025.02.21 14:10:07 -05'00'
BLAKE
WELLING
Digitally signed by BLAKE
WELLING
Date: 2025.02.21
14:15:47 -05'00'
Issue Date: 12/14/23
E2-1
0309
Decision Documentation for Reactive Inspection
(Deterministic-only Criteria Analyzed)
PLANT: Hope Creek
EVENT DATE:
February 19, 2025
EVALUATION DATE:
February 20, 2025
Brief Description of the Significant Operational Event or Degraded Condition:
Refer to Enclosure 1.
REACTOR SAFETY
Y/N
IIT Deterministic Criteria
N
Led to a Site Area Emergency
Remarks: The event did not lead to a site area emergency.
N
Exceeded a safety limit of the licensee's technical specifications
Remarks: No Technical Specification safety limits were exceeded.
N
Involved circumstances sufficiently complex, unique, or not well enough
understood, or involved safeguards concerns, or involved characteristics the
investigation of which would best serve the needs and interests of the Commission
Remarks: The event did not involve circumstances sufficiently complex, unique, or
not well enough understood, or involved safeguards concerns, or involved
characteristics the investigation of which would best serve the needs and interests
of the Commission.
Y/N
SI Deterministic Criteria
N
Significant failure to implement the emergency preparedness program during an
actual event, including the failure to classify, notify, or augment onsite personnel
Remarks: There was no declared event.
N
Involved significant deficiencies in operational performance which resulted in
degrading, challenging, or disabling a safety function or resulted in placing the plant
in an unanalyzed condition for which available risk assessment methods do not
provide an adequate or reasonable estimate of risk.
Remarks: The events did not involve an unanalyzed condition or disabling of a
safety system function.
Issue Date: 12/14/23
E2-2
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RADIATION SAFETY
Y/N
IIT Deterministic Criteria
N
Led to a significant radiological release (levels of radiation or concentrations of
radioactive material in excess of 10 times any applicable limit in the license or 10
times the concentrations specified in 10 CFR Part 20, Appendix B, Table 2, when
averaged over a year) of byproduct, source, or special nuclear material to
unrestricted areas
Remarks: This event did not involve a radiological release
N
Led to a significant occupational exposure or significant exposure to a member of
the public. In both cases, significant is defined as five times the applicable
regulatory limit (except for shallow-dose equivalent to the skin or extremities from
discrete radioactive particles)
Remarks: This event did not involve an occupational exposure or exposure to a
member of the public.
N
Involved the deliberate misuse of byproduct, source, or special nuclear material
from its intended or authorized use, which resulted in the exposure of a significant
number of individuals
Remarks: This event did not involve the misuse of byproduct, source, or SNM.
N
Involved byproduct, source, or special nuclear material, which may have resulted in
a fatality
Remarks: This event did not involve the misuse of byproduct, source, or SNM.
N
Involved circumstances sufficiently complex, unique, or not well enough
understood, or involved safeguards concerns, or involved characteristics the
investigation of which would best serve the needs and interests of the Commission
Remarks: This event did not involve circumstances sufficiently complex, unique, or
not well enough understood, or involved safeguards concerns, or involve
characteristics the investigation of which would best serve the needs and interests
of the Commission.
Y/N
AIT Deterministic Criteria
N
Led to a radiological release of byproduct, source, or special nuclear material to
unrestricted areas that resulted in occupational exposure or exposure to a member
of the public in excess of the applicable regulatory limit (except for shallow-dose
equivalent to the skin or extremities from discrete radioactive particles)
Remarks: This event did not involve a radiological release.
N
Involved the deliberate misuse of byproduct, source, or special nuclear material
from its intended or authorized use and had the potential to cause an exposure of
greater than 5 rem to an individual or 500 mrem to an embryo or fetus
Issue Date: 12/14/23
E2-3
0309
Remarks: This event did not involve the misuse of byproduct, source, or SNM.
N
Involved the failure of radioactive material packaging that resulted in external
radiation levels exceeding 10 rads/hr or contamination of the packaging exceeding
1000 times the applicable limits specified in 10 CFR 71.87
Remarks: This event did not involve the failure or RAM packaging.
N
Involved the failure of the dam for mill tailings with substantial release of tailings
material and solution off site
Remarks: This event did not involve the failure of the dam for mill tailings.
Y/N
SI Deterministic Criteria
N
May have led to an exposure in excess of the applicable regulatory limits, other
than via the radiological release of byproduct, source, or special nuclear material to
the unrestricted area; specifically:
x
occupational exposure in excess of the regulatory limits in 10 CFR 20.1201
x
exposure to an embryo/fetus in excess of the regulatory limits in
CFR 20.1208
x
exposure to a member of the public in excess of the regulatory limits in
CFR 20.1301
Remarks: This event would not have led to an exposure in excess of regulatory
limits.
N
May have led to an unplanned occupational exposure in excess of 40 percent of the
applicable regulatory limit (excluding shallow-dose equivalent to the skin or
extremities from discrete radioactive particles)
Remarks: This event would not have led to an unplanned occupational exposure.
N
Led to unplanned changes in restricted area dose rates in excess of 20 rem per
hour in an area where personnel were present or which is accessible to personnel
Remarks: This event did not involve unplanned changes in dose rates.
N
Led to unplanned changes in restricted area airborne radioactivity levels in excess
of 500 DAC in an area where personnel were present or which is accessible to
personnel and where the airborne radioactivity level was not promptly recognized
and/or appropriate actions were not taken in a timely manner
Remarks: This event did not involve unplanned changes in restricted area airborne
radioactivity levels.
N
Led to an uncontrolled, unplanned, or abnormal release of radioactive material to
the unrestricted area:
x
for which the extent of the offsite contamination is unknown; or,
x
that may have resulted in a dose to a member of the public from loss of
radioactive material control in excess of 25 mrem (10 CFR 20.1301(e)); or,
Issue Date: 12/14/23
E2-4
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x
that may have resulted in an exposure to a member of the public from
effluents in excess of the ALARA guidelines contained in Appendix I to
CFR Part 50
Remarks: This event did not involve a release of RAM.
N
Led to a large (typically greater than 100,000 gallons), unplanned release of
radioactive liquid inside the restricted area that has the potential for ground-water,
or offsite, contamination
Remarks: This event did not involve a release of radioactive liquid.
N
Involved the failure of radioactive material packaging that resulted in external
radiation levels exceeding 5 times the accessible area dose rate limits specified in
CFR Part 71, or 50 times the contamination limits specified in 49 CFR Part 173
Remarks: This event did not involve the failure of RAM packaging.
N
Involved an emergency or non-emergency event or situation, related to the health
and safety of the public or on-site personnel or protection of the environment, for
which a 10 CFR 50.72 report has been submitted that is expected to cause
significant, heightened public or government concern
Remarks: This event did not involve an emergency or non-emergency event or
situation, related to the health and safety of the public or on-site personnel or
protection of the environment, for which a 10 CFR 50.72 report has been submitted
that is expected to cause significant, heightened public or government concern.
SAFEGUARDS/SECURITY
Y/N
IIT Deterministic Criteria
N
Involved circumstances sufficiently complex, unique, or not well enough
understood, or involved safeguards concerns, or involved characteristics the
investigation of which would best serve the needs and interests of the Commission
Remarks: This event did not involve circumstances sufficiently complex, unique, or
not well enough understood, or involved safeguards concerns, or involved
characteristics the investigation of which would best serve the needs and interests
of the Commission
N
Failure of licensee significant safety equipment or adverse impact on licensee
operations as a result of a safeguards initiated event (e.g., tampering).
Remarks: This event did not involve a failure of licensee significant safety
equipment or adverse impact on licensee operations as a result of a safeguards
initiated event.
N
Actual intrusion into the protected area.
Remarks: This event did not involve actual intrusion into the PA.
Y/N
AIT Deterministic Criteria
Involved a significant infraction or repeated instances of safeguards infractions that
Issue Date: 12/14/23
E2-5
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N
demonstrate the ineffectiveness of facility security provisions
Remarks: This event did not involve a significant infraction or repeated instances of
safeguards infractions that demonstrate the ineffectiveness of facility security
N
Involved repeated instances of inadequate nuclear material control and accounting
provisions to protect against theft or diversions of nuclear material
Remarks: This event did not involve repeated instances of inadequate nuclear
material control and accounting provisions to protect against theft or diversions of
nuclear material
N
Confirmed tampering event involving significant safety or security equipment
Remarks: This event did not involve confirmed tampering involving significant safety
or security equipment
N
Substantial failure in the licensees intrusion detection or package/personnel search
procedures which results in a significant vulnerability or compromise of plant safety
or security
Remarks: This event did not involve substantial failure in the licensees intrusion
detection or package/personnel search procedures which results in a significant
vulnerability or compromise of plant safety or security
Y/N
SI Deterministic Criteria
N
Involved inadequate nuclear material control and accounting provisions to protect
against theft or diversion, as evidenced by inability to locate an item containing
special nuclear material (such as an irradiated rod, rod piece, pellet, or instrument)
Remarks: This event did not involve inadequate nuclear material control and
accounting provisions to protect against theft or diversion, as evidenced by inability
to locate an item containing special nuclear material (such as an irradiated rod, rod
piece, pellet, or instrument
N
Involved a significant safeguards infraction that demonstrates the ineffectiveness of
facility security provisions
Remarks: This event did not involve a significant safeguards infraction that
demonstrates the ineffectiveness of facility security provisions
N
Confirmation of lost or stolen weapon
Remarks: This event did not involve a lost or stolen weapon
N
Unauthorized, actual non-accidental discharge of a weapon within the protected
area
Remarks: This event did not involve an unauthorized, actual non-accidental
discharge of a weapon within the protected area
N
Substantial failure of the intrusion detection system (not weather related)
Remarks: This event did not involve a failure of the intrusion detection system
Issue Date: 12/14/23
E2-6
0309
N
Failure to the licensees package/personnel search procedures which results in
contraband or an unauthorized individual being introduced into the protected area
Remarks: This event did not involve the licensees package/personnel search
procedures resulting in contraband or an unauthorized individual being introduced
into the protected area
N
Potential tampering or vandalism event involving significant safety or security
equipment where questions remain regarding licensee performance/response or a
need exists to independently assess the licensees conclusion that tampering or
vandalism was not a factor in the condition(s) identified
Remarks: This event did not involve potential tampering or vandalism
Issue Date: 12/14/23
E2-7
0309
RESPONSE DECISION
USING THE ABOVE INFORMATION AND OTHER KEY ELEMENTS OF CONSIDERATION
AS APPROPRIATE, DOCUMENT THE RESPONSE DECISION TO THE EVENT OR
CONDITION, AND THE BASIS FOR THAT DECISION
DECISION AND DETAILS OF THE BASIS FOR THE DECISION:
None of the deterministic criteria were met for Enclosure 2.
A special inspection is recommended in accordance with the results documented in
1. Specifically, one deterministic criterion was met (g. Involved repetitive failures or
events involving safety-related equipment or deficiencies in operations), and the total
HVWLPDWHGLQFUHPHQWDOFRQGLWLRQDOFRUHGDPDJHSUREDELOLW\\ ,&&'3RU&'3 for the event
falls within the no additional inspection/special inspection overlap region (1E-6 to 5E-6).
Uncertainty currently exists with respect to the duration of the degraded condition. A special
inspection will allow for an independent and timely assessment of the most recent D EDG
failure, including an in-depth understanding of licensees troubleshooting efforts and other
performance aspects associated with this event. It will also allow the region to ascertain
whether Hope Creek implemented adequate troubleshooting efforts and corrective actions
associated with the previous failure of the D EDG.
BRANCH CHIEF REVIEW:
DIVISION DIRECTOR REVIEW:
ADAMS ACCESSION NUMBER: ML25052A166
EVENT NOTIFICATION REPORT NUMBER (as applicable): N/A
E-mail to NRR_Reactive_Inspection@nrc.gov
NICOLE
WARNEK
Digitally signed by NICOLE WARNEK
Date: 2025.02.21 14:10:41 -05'00'
BLAKE
WELLING
Digitally signed by BLAKE
WELLING
Date: 2025.02.21
14:16:24 -05'00'