IR 05000354/2025004

Integrated Inspection Report 05000354/2025004 and Independent Spent Fuel Storage Installation Inspection Report 07200048/2024001 and Exercise of Enforcement Discretion

ML26035A159
Person / Time
Site:	Hope Creek, Salem
Issue date:	02/04/2026
From:	Nicole Warnek Division of Operating Reactors
To:	Mcfeaters C Public Service Enterprise Group
References
EAF-NMSS-2025-0222 IR 2025004, IR 2024001
Download: ML26035A159 (0)

Text

February 4, 2026

SUBJECT:

HOPE CREEK GENERATING STATION - INTEGRATED INSPECTION REPORT 05000354/2025004 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200048/2024001 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Charles McFeaters:

On December 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station. On January 15, 2026, the NRC inspectors discussed the results of this inspection with Eric Larson, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

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.

The NRC identified a violation of Title 10 of the Code of Federal Regulations (10 CFR) 72.48, paragraphs (c)(1), (c)(2), and (d)(1), and provisions of 10 CFR 72.212 that resulted from a certificate of compliance (CoC) holders failure to comply with 10 CFR 72.48 for a CoC holder-generated change for the Holtec continuous basket shim multi-purpose canister variant design.

However, an Interim Enforcement Policy issued in August 2025 is applicable to this violation.

Specifically, Enforcement Policy Section 9.4, Enforcement Discretion for General Licensee Adoption of Certificate of Compliance (CoC) Holder-Generated Modifications under 10 CFR 72.48, provides enforcement discretion to not issue an enforcement action for this violation. The licensee will be expected to comply with 10 CFR 72.212 provisions after the NRC dispositions the noncompliance for a CoC holder-generated change that affects the general licensee.

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 205550001; 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 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Nicole S. Warnek, Chief Projects Branch 3 Division of Operating Reactor Safety

Docket No. 05000354 and 07200048 License No. NPF-57

Enclosure:

As stated

Inspection Report

Docket Number:

05000354 and 07200048

License Number:

NPF-57

Report Number:

05000354/2025004 and 07200048/2024001

Enterprise Identifier: I-2025-004-0037 and I-2024-001-0108

Licensee:

PSEG Nuclear, LLC

Facility:

Hope Creek Generating Station

Location:

Hancocks Bridge, NJ

Inspection Dates:

October 1, 2025 to December 31, 2025

Inspectors:

P. Finney, Senior Resident Inspector

J. Bresson, Resident Inspector

A. Christiano, Project Engineer

B. Dyke, Senior Operations Engineer

N. Floyd, Senior Reactor Inspector

A. Kostick, Health Physicist

J. Morgan, Senior Operations Engineer

R. Rolph, Senior Health Physicist

A. Turilin, Reactor Inspector

Approved By:

Nicole S. Warnek, Chief

Projects Branch 3

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Hope Creek Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Unattended High Energy Line Break (HELB) Door Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000354/2025004-01 Open/Closed

[H.9] - Training 71111.20 The inspectors identified a Green non-cited violation (NCV) of Technical Specification (TS)5.4.1, "Procedures," when PSEG did not properly implement proper barrier controls in accordance with station procedures during maintenance activities that could have affected the performance of safety-related equipment.

Additional Tracking Items

Type Issue Number Title Report Section Status EDG EAF-NMSS-2025-0222 Noncompliance Related to a General Licensees Use of Non-Qualified Spent Fuel Casks (IEP 9.4)

60855 Closed URI 05000354/2025050-03 Emergency Diesel Generator Lube Oil Heat Exchanger Maintenance Practices 71111.12 Closed URI 05000354/2025050-02 Emergency Diesel Generator Lube Oil Heat Exchanger Complex Troubleshooting 71153 Closed URI 05000354/2025001-03 Unresolved Item Regarding the NRC's Grant of a Notice of Enforcement Discretion (NOED) for an EDG under TS 3.8.1.1 71153 Closed

PLANT STATUS

Hope Creek began the inspection period in Mode 5 during a refueling outage. PSEG commenced a reactor startup on October 31, 2025. Hope Creek reached rated thermal power on November 5, 2025. On November 6, 2025, the unit was reduced to 70 percent for a control rod pattern adjustment and returned to 100 percent power the following day. The unit was reduced to 70 percent on November 11, 2025, for another control rod pattern adjustment and returned to 100 percent power on November 13, 2025. Hope Creek remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Reactor core isolation cooling (RCIC) during high pressure coolant injection (HPCI)unavailability for steam admission valve troubleshooting, November 25, 2025 (2)

'C' service water loop post-maintenance walkdown during 'B' service water loop unavailability, December 11, 2025

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

(1) The inspectors evaluated system configurations during a complete walkdown of the 125 volts direct current '1E' system, November 25, 2025.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)

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) RCIC room, fire plan 3412, November 4, 2025

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) 'B' reactor auxiliaries cooling system heat exchanger, October 7, 2025

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01)

The following non-destructive testing was evaluated by the inspector through remote document review from November 19 - December 30, 2025:

(1)

1. Ultrasonic Examination of RPV1-W9 Lower Head to dome weld (HCGS-UT-

25-006)

2. Ultrasonic Examination of RPV1-W16-1 through -W16-8 Meridional Seam

welds (HCGS-UT-25-024, -023, -021, -020, -019, -015, -014, -012)

3. Ultrasonic Examination of RPV1-W17-1 through -W17-4 Bottom Meridional

Dollar Plate Seam welds (HCGS-UT-25-008, -009, -010, -011)

4. Liquid Penetrant Examination of Control Rod Drive Housing T-T Welds RPV1-

CRDW 339, 326, 291, 358, 248, 242, 345, 357 and 428 (HCGS-PT-25-002)

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 August 8, 2025.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during reactor startup and heatup on October 31, 2025.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (4 Samples)

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

(1)

'B2' safety auxiliary cooling system heat exchanger flange leak, October 9, 2025 (2)

'A' residual heat removal heat exchanger safety auxiliary cooling system return valve pin failures, October 17, 2025

(3) Loss of 'C' 4.16 kilovolt (kV) bus, October 18, 2025

(4) Unresolved Item (URI) (05000354/2025050-03), Emergency Diesel Generator Lube Oil Heat Exchanger Maintenance Practices, November 18, 2025

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)

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

(1) HPCI turbine wheel flaw, October 29, 2025

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary Modification - 'A' service water loop replacement of degraded spring cans with temporary dunnage supports, work order (WO) 60165383 and technical evaluation 80140023, October 30, 2025

(2) Permanent Modification - 1AD481 inverter replacement during refueling outage - Design Change Package 80132748, October 31, 2025

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated Refueling Outage 26 activities from October 1 to November 2, 2025

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) (4 Samples)

(1) Replacement of ITE-50H relay following loss of 'C' 4kV bus during the 'C' integrated diesel generator test, October 22, 2025

(2) Emergent repair of 'A' safety auxiliary cooling system to 'A' residual heat removal heat exchanger cooling outlet valve throttling capability, October 29, 2025

(3) Machining of RCIC outboard steam supply isolation valve following local leak rate testing failure, October 30, 2025

(4) HPCI following 12-year overhaul, increase in maximum revolutions, and hydraulic actuator replacement, November 5, 2025

Surveillance Testing (IP Section 03.01) (2 Samples)

(1)

'C' integrated emergency diesel generator (EDG) test, October 18, 2025 (2) 'D' main steam line flow channel calibration, November 18, 2025

Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)

(1) Feedwater seal boundary valve water leak rate test of 'A' feedwater injection header valves 1AEHV-F032A, 1BJHV-8278, and 1AEHV-F039, on October 1,

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, identifies the concentrations and quantities of radioactive materials, and 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) Workers exiting the radiologically controlled area at Hope Creek during condenser tube leak repairs

(2) Workers exiting the radiologically controlled area at Hope Creek during traversing incore probe room work.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Samples)

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

(1) Condenser tube leak repairs

(2) Traversing incore probe work (down posting area from locked high radiation area to very high radiation area)

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:

(1) Turbine condenser bay 87'

(2) Traversing incore probe detector room

(3) A reactor water cleanup (RWCU) pump 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) April 1, 2024 through September 30, 2025

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) July 1, 2024 through September 30, 2025

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) July 1, 2024 through September 30, 2025

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2024 through September 30, 2025

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, 2024 through September 30, 2025

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

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

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

(1) The inspectors evaluated URI 05000354/2025050-02, EDG Lube Oil Heat Exchanger Complex Troubleshooting, on October 1, 2025.

Notice of Enforcement Discretion (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated URI 05000354/2025001-03, URI Regarding the NRC's Grant of a Notice of Enforcement Discretion (NOED) for an EDG under TS 3.8.1.1, and PSEG actions surrounding NOED EAF-RI-2025-0048 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML25036A046)which can be accessed at http://www.nrc.gov/reading-rm/doc-collections/enforcement/notices/noedreactor.html, on October 1,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===60855 - Operation of an Independent Spent Fuel Storage Installation

Inspections were conducted using the appropriate portions of the 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 IMC 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-than-Class C Waste at Independent Spent Fuel Storage Installations (ISFSI) and for Title 10 of the Code of Federal Regulations (10 CFR) Part 71 Transportation Packagings."

Operation of an Independent Spent Fuel Storage Installation===

(1) The inspector conducted a periodic in-office follow-up that focused on the review of the general licensees (GLs) implementation of the 10 CFR 72.48 process and associated corrective actions related to ISFSI activities. The review included:

• 10 CFR 72.48 Evaluations and Screenings: Reviewed the GLs 10 CFR 72.48 process and associated evaluation associated with the adoption of the continuous basket shim (CBS) variant.

• Corrective Action Program: Reviewed condition reports related to the design change of the CBS variant.

71003 - Post-Approval Site Inspection for License Renewal

Post-Approval Site Inspection for License Renewal (1 Partial)

(1)

(Partial)

The inspectors conducted a Phase 1 license renewal inspection at Hope Creek from November 19 to December 19, 2025. The following aging management programs (AMPs) were evaluated by the inspector remotely through document review:

1. BWR Vessel ID Attachment Welds (AMP 4) and BWR Feedwater Nozzles

(AMP 5), Commitment 4 and 5 o 24M Visual Exam/RPV Internal (WO 50250751)

2. Open-Cycle Cooling Water System (AMP 13), Commitment 13

o LR CD 36M Insp A SSW HDR 1EA026-SWI (WO 30376078)

3. ASME Section XI, Subsection IWE (AMP 28), Commitment 28

o LR - Drywell: UT Air Gap AZ 225° (WO 50239965-0090) o LR - Drywell: UT Air Gap Drains - EL 88' (WO 50239965-0100)

4. Structures Monitoring Program (AMP 32), Commitment 32

o LR Perform Reactor Cavity Seal Plate Inspection (WO 30357508)

5. Metal Enclosed Bus (AMP 38), Commitment 38

o LR-10.5Y /CRIT 10-A-109 SEC 02 INT INS (WO 30265465)

6. Small-Bore Class 1 Piping Inspection Program (AMP 45), Commitment 45 and

One-Time Inspection Program (AMP 22), Commitment 22 o LR-1"-CCA-219A-Recirc Line: Inspection (WO 60146361)o LR-1-BB-2DBA-192B-6 (WO 60161594-0050)o LR-1-BB-2DBA-192B-7 (WO 60161594-0060)o LR Small Bore 'A' Recirc Loop UT (WO 60164723)

INSPECTION RESULTS

Enforcement Discretion Enforcement Action EAF-NMSS-2025-0222: Noncompliance Related to a General Licensees Use of Non-Qualified Spent Fuel Casks (IEP 9.4)60855

Description:

Holtec International (also referred to as the CoC (certificate of compliance) holder)implemented a design change to its multi-purpose canister fuel basket, known as the CBS variant, which altered the structural configuration from welded to bolted shims. This change resulted in a departure from the method of evaluation (MOE) described in the final safety analysis report (FSAR) used to establish the design basis for tip-over events. Holtec did not fully evaluate the cumulative impact of the MOE changes or apply them consistently with the licensing basis. As a result, the NRC issued three Severity Level IV violations to Holtec for noncompliance with 10 CFR 72.48 requirements (see U.S. Nuclear Regulatory Commission Inspection Report 07201014/2022-201, Holtec International, ML23145A175, and Holtec International, Inc. - Notice of Violation; The U.S. Nuclear Regulatory Commission Inspection Report No. 07201014/2022-201, ML24016A190).

When the GL chooses to adopt a change the CoC holder made pursuant to a CoC holder's change authority under 10 CFR 72.48 (referred to herein as a CoC holder-generated change), the GL must perform a separate review using the requirements of 10 CFR 72.48(c).

Accordingly, when the GL chooses to adopt a CoC holder-generated change, and that change results in a non-conforming cask, there is a violation of 10 CFR 72.48 and certain provisions of 10 CFR 72.212 by the GL, in addition to a CoC holder violation of 10 CFR 72.48. As it relates to the adoption of the CBS variant casks, the GL failed to recognize the noncompliance with 10 CFR 72.48 requirements made by the CoC holders design change and subsequently loaded the CBS variant casks.

Corrective Actions: The GL entered this into its corrective action program with actions to restore compliance with the 10 CFR 72.212 provisions that require each cask to conform to the terms, conditions, and specifications of a CoC or an amended CoC listed in 10 CFR 72.214.

Corrective Action References: Long Term Corrective Action 70233688-0010, 72.212 Report 14A, ECO-5014-320 Rev. 2

Enforcement:

Significance/Severity: This violation was dispositioned in accordance with Section 9.4, Enforcement Discretion for General Licensee Adoption of CoC Holder-Generated Changes Under 10 CFR 72.48, of the NRCs Enforcement Policy.

Specifically, as stated in the Policy, the NRC will exercise enforcement discretion and not issue an enforcement action to a GL, for a noncompliance with the requirements of paragraphs (c)(1) and

(2) and (d)(1) of 10 CFR 72.48 and with provisions of 10 CFR 72.212 that require GLs to ensure use of casks that conform to the terms, conditions, and specifications of a CoC listed in 10 CFR 72.214, when the noncompliance results from a CoC holders failure to comply with 10 CFR 72.48 for a CoC holder-generated change.

Violation: 10 CFR 72.48 (c)(1) requires, in part, that a GL or certificate holder may make changes in the facility or spent fuel storage cask design as described in the FSAR (as updated), without obtaining:

(ii) CoC amendment submitted by the certificate holder pursuant to § 72.244 if:

(c) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section.

10 CFR 72.48(c)(2) requires, in part, that a GL shall request that the certificate holder obtain a CoC amendment, prior to implementing a proposed change, if the change would: (viii) Result in a departure from an MOE described in the FSAR used in establishing the design bases or in the safety analyses.

10 CFR 72.48(d)(1) requires, in part, that the licensee shall have a written evaluation which provides the bases for the determination that the change does not require a CoC amendment pursuant to 10 CFR 72.48(c)(2).

10 CFR 72.212(b)(3) requires, in part, a GL must ensure that each cask used by the GL conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 10 CFR 72.214.

Contrary to the above, in May 2023, the GL loaded the first CBS design variant and failed to maintain records of changes in the spent fuel storage cask design made pursuant to 10 CFR 72.48(c) that include a written evaluation which provided the bases for the determination that the change did not require a CoC amendment. The GL failed to request that the certificate holder obtain a CoC amendment, prior to implementing a proposed change, if the change would: (viii) result in a departure from an MOE described in the FSAR used in establishing the design bases or in the safety analyses. Further, the GL failed to ensure each cask conformed to the terms, conditions, and specifications of a CoC or amended CoC listed in 10 CFR 72.214.

Basis for Discretion: When a GL chooses to adopt a CoC holder-generated change, and that change results in a non-conforming cask, there is a violation of 10 CFR 72.48 and certain provisions of 10 CFR 72.212 by the GL, in addition to a CoC holder violation of 10 CFR 72.48.

And, when a GL chooses to adopt a CoC holder-generated change without performing a separate 10 CFR 72.48 analysis, the GL is in violation of 10 CFR 72.48. These requirements could lead to enforcement actions being issued against both the GL's 10 CFR 72.48 program (as well as certain 10 CFR 72.212 violations) and the CoC holder's 10 CFR 72.48 program for changes that originated with the CoC holder. The NRC has concluded that this enforcement approach would be inconsistent with efficiency, which is one of the NRC's Principles of Good Regulation, and NRC's mission of efficient and reliable oversight.

Since this violation meets the conditions of the NRC's Enforcement Policy, Section 9.4, "Enforcement Discretion for General Licensee Adoption of Certificate of Compliance Holder-Generated Changes under 10 CFR 72.48" (ML25224A097), and the GL has entered the noncompliance into the corrective action program, the NRC is exercising enforcement discretion by not issuing an enforcement action for this violation.

Unresolved Item (Closed)

Emergency Diesel Generator Lube Oil Heat Exchanger Maintenance Practices URI 05000354/2025050-03 71111.12

Description:

The inspectors identified an unresolved item (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 PSEG 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 be monitored and maintained in accordance with a preventative maintenance program as required by TSs.

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. Inspectors follow-up actions included reviewing PSEG's root cause evaluation and WOs, and interviewing PSEG staff.

This URI is closed to the White finding and associated violation in Inspection Report 05000354/2025091 (ML25237A290).

Corrective Action References: Root Cause Evaluation 70239337; WO 70239337-0410, -0417,

-0419, -0420, -0430, and -0440; WOs 60163187-0190, 60163188-0200, 60163189-0190, and 60163110-0130.

Unattended High Energy Line Break (HELB) Door Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000354/2025004-01 Open/Closed

[H.9] - Training 71111.20 The inspectors identified a Green NCV of TS 5.4.1, "Procedures," when PSEG did not properly implement proper barrier controls in accordance with station procedures during maintenance activities that could have affected the performance of safety-related equipment.

Description:

Hope Creek Updated Final Safety Analysis Report, section 3.6.1.2.1.7 describes the RCIC steam supply line that transits the RCIC pipe chase. Protection against over pressurization of the RCIC pipe chase as a result of a steam supply line break is provided by steam venting paths to the suppression chamber compartment and then to a steam vent containing blow out panels leading to the outside atmosphere. For a RCIC steam supply line break outside the drywell, the steam supply line containment isolation valves are closed automatically on high steam flow, or high steam temperature of the RCIC piping outside the drywell, terminating reactor vessel blowdown.

During refueling outage preparations on September 18, 2025, NRC inspectors observed the RCIC pipe chase door 4319 fully open and unattended. PSEG procedure OP-HC-103-103, High Energy and Internal Flooding Barrier Control Program, Rev. 1 and evaluation H-1-ZZ-FEE-1803, Separation Barrier Control Aid for Hope Creek, Rev. 0 identify door 4319 as a water-tight/pressure-tight door as well as a fire Class I, high energy line break (HELB), and internal flood door. Inspectors contacted the control room and requested an equipment operator come and secure the door. PSEG subsequently determined that a scaffold crew had left the door open for at least two hours unattended.

CC-AA-201, Plant Barrier Control, Rev. 8, implements compensatory measures when HELB barriers are impaired. Step 4.1.1 states that, Doors should always be placed in their required position and secured properly after use in order to be considered capable of performing credited barrier functions. Step 4.1.2.4.a states that, "A plant barrier impairment is required when the barrier is credited as a HELB barrier since a HELB is a rapidly occurring event and creates an adverse environment that is difficult to justify an attendant will be able to restore before the barrier is challenged.

FP-AA-002, Fire Protection Impairment Program, Rev. 6, step 4.1.1 states that work activities affecting fire doors shall be controlled through the fire protection impairment program that ensures appropriate compensatory measures are implemented. FP-HC-004, Actions for Non-Functional Fire Protection - Hope Creek Station, Rev. 9, Att. 7, Table 6 requires an hourly fire watch when door 4319 is impaired.

The inspectors determined that PSEG was not properly implementing their procedures for an impaired HELB, internal flood and fire barrier, in accordance with their Barrier Control and Fire Protection programs. Additionally, Hope Creek Limiting Condition for Operation (LCO) 3.0.9, Unavailable Barrier, establishes conditions under which systems described in TSs are considered to remain operable when required barriers are not capable of providing their related support function. The improper implementation of the barrier impairment process also precluded Hope Creek Operations review of this 30-day LCO.

Corrective Actions: A PSEG operator secured the door and checked the status of remaining HELB doors in the reactor building. PSEG also stood down all scaffold crews.

Corrective Action References: Notification 21001283

Performance Assessment:

Performance Deficiency: The inspectors determined that PSEGs improper implementation of barrier controls during maintenance activities in accordance with station procedures CC-AA-201, "Plant Barrier Control," and FP-AA-002, "Fire Protection Impairment Program," was within PSEGs ability to foresee, correct, should have been prevented, and was, therefore, 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 Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, plant design documents and procedures assume HELB barriers will only be open during normal ingress and egress. Leaving the door open challenged assumptions within the plant's design basis regarding the impacts of a RCIC steam line break.

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 the finding to be of very low safety significance (i.e., Green) by answering 'No' to all of the questions in Exhibit 2, "Mitigating Systems Screening Questions."

Specifically, systems, structures, and components potentially affected by the deficiency maintained their operability and functionality.

Cross-Cutting Aspect: H.9 - Training: The organization provides training and ensures knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, PSEGs investigation revealed many of those in the work crew were new to nuclear plants or had been away for several years resulting in proficiency challenges.

Enforcement:

Violation: TS 5.4.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance, states that, Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

CC-AA-201, Plant Barrier Control, Rev. 8, implements compensatory measures when HELB barriers are impaired. Step 4.1.1 states that, Doors should always be placed in their required position and secured properly after use in order to be considered capable of performing credited barrier functions. Step 4.1.2.4.a states that, A plant barrier impairment is required when the barrier is credited as a HELB barrier since a HELB is a rapidly occurring event and creates an adverse environment that is difficult to justify an attendant will be able to restore before the barrier is challenged.

FP-AA-002, Fire Protection Impairment Program, Rev. 6 step 4.1.1 states that work activities affecting fire doors shall be controlled through the fire protection impairment program that ensures appropriate compensatory measures are implemented. FP-HC-004, Actions for Non-Functional Fire Protection - Hope Creek Station, Rev. 9, Att. 7, Table 6 requires an hourly fire watch when door 4319 is impaired.

Contrary to the above, on September 18, 2025, PSEG performed maintenance activities that impaired a credited barrier but did not ensure appropriate barrier controls were implemented as required by station procedures CC-AA-201 and FP-AA-002.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Semi-Annual Trend 71152S Foreign material (FM). During the R26 refueling outage, PSEG identified an adverse trend in FM that stemmed from a series of reactor cavity intrusions as well as FM discovered in the A reactor recirculation pump mechanical seal area and main turbine lube oil reservoir (Notification (NOTF) 21004660). While PSEG completed a common cause evaluation of these events, inspectors noted additional FM events during this period outside of the evaluation's scope:

2. Shavings were discovered in the B RWCU purge flow y-strainer (NOTF 21005335).

FM was generated as a result of the A control rod drive (CRD) pump inboard seal leak and failure (NOTFs 21004782, 21005935). Subsequently, debris and metal shavings were found in the A CRD downstream filter (NOTF 21005086). PSEG experienced challenges restoring CRD backfill stations to reactor vessel instruments which cited the A CRD filter and B RWCU strainer NOTFs (NOTFs 210055562, 21005946(7,8)).

3. In the turbine building, an air sampling monitor was bumped through an FM barrier into

the condenser (NOTF 21004769). Sand blast media was discovered on main condenser tubesheets and in some tubes from a circulating water waterbox project (NOTF 21004762). During subsequent closeout inspection of the waterboxes, PSEG discovered plastic debris-cleaning devices for that blast media in the outlet (NOTF 21005053).

Bus losses. On August 12, 2025, the B reactor protection system bus tripped (NOTF 20999460). During the R26 refueling outage, Hope Creek experienced two bus losses. On October 18, 2025, during performance of the integrated C EDG test with the C EDG paralleled with offsite power, the safety-related C 4kV bus tripped (NOTF 21004799). At the time, the C 4kV bus was not credited in applicable TSs. On October 27, 2025, while restoring the A primary condensate pump to service, the pump and its non-safety-related 7kV bus 10A110 tripped (NOTF 21005183). PSEG determined in these latter two events that the cause was age-related due to stuck contactors on ITE-50H relays that had not been replaced in the life of the plant. PSEG generated NOTFs 21008085 through 210008106 to replace the ITE-50H relays on all 4kV safety-related bus offsite power source breakers as well as other non-safety-related busses. The NRC issued Information Notice 84-20 regarding the service life of Unresolved Item (Closed)

Emergency Diesel Generator Lube Oil Heat Exchanger Complex Troubleshooting URI 05000354/2025050-02 71153

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 and March 4, 2025. Following an initial water intrusion event discovered on January 31, 2025, PSEG developed complex troubleshooting plans to diagnose the cause of water intrusion in the lube oil system for the 'D' EDG. PSEG 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 PSEG had exited their initial troubleshooting preemptively. Additionally, the inspectors questioned the completeness of PSEG'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. Inspector follow-up actions included review of PSEG's root cause evaluation.

This URI is closed to the White finding and associated violation in Inspection Report 05000354/2025091 (ML25237A290).

Corrective Action Reference: Root Cause Evaluation 70239337

Unresolved Item (Closed)

Unresolved Item Regarding the NRC's Grant of a Notice of Enforcement Discretion (NOED) for an EDG under TS 3.8.1.1 URI 05000354/2025001-03 71153

Description:

By letter (ML25034A230) dated February 3, 2025, PSEG requested that the NRC exercise discretion to not enforce compliance with the actions required by Hope Creek TS LCO 3.8.1.1.e for two inoperable EDGs and extend the expiration of the completion time by 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> to February 2, 2025, at 1:35 a.m., to allow Hope Creek additional time to return the A EDG to operable status. As communicated verbally to Hope Creek at approximately 9:15 p.m.,

on January 31, 2025, the NRC exercised discretion to not enforce compliance with TS LCO 3.8.1.1.e for the 28-hour period from January 31, 2025, at 9:35 p.m., until February 2, 2025, at 01:35 a.m. Hope Creek returned the A EDG to operable status on January 31, 2025, at 9:21 p.m., and the approved NOED was not utilized. The NRC issued a letter to PSEG documenting the grant of this NOED on February 5, 2025 (ML25036A046). In accordance with IMC 0611, 06.05.o, when a NOED is granted, a URI shall be opened in accordance with the NRC Enforcement Manual, Appendix F, Notices of Enforcement Discretion. Inspector follow-up actions included review of PSEG's root cause evaluation and additional corrective action program documents, and interviewed PSEG staff.

This URI is closed to the White finding and associated violation in Inspection Report 05000354/2025091 (ML25237A290).

relays in safety-related systems stating, in part, "preventative maintenance programs should recognize the service life of relays supplied by other manufacturers."

The NRC inspectors did not identify any findings or violations of more than minor significance Corrective Action References: NOTF 20986945 and Root Cause Evaluation

EXIT MEETINGS AND DEBRIEFS

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

• On January 15, 2026, the inspectors presented the integrated inspection results to Eric Larson, Site Vice President, and other members of the licensee staff.

• On December 11, 2025, the inspectors presented the 71151 RP PI Verification inspection results to Robert McLaughlin, Hope Creek Plant Manager, and other members of the licensee staff.

• On December 11, 2025, the inspectors presented the 71124.01 Inspection Debrief inspection results to Robert McLaughlin, Hope Creek Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Corrective Action

Documents

Resulting from

Inspection

21010436

21010886

71111.04

Drawings

M-10-1(Q)

71111.04

Procedures

HC.MD-ST.PK-

0001(Q)

71111.05

Fire Plans

FP-HC-3412

71111.08G Corrective Action

Documents

21003268

71111.12

Corrective Action

Documents

21004799

71111.12

Engineering

Evaluations

80139869-0209

71111.15

Corrective Action

Documents

21003713

71111.20

Corrective Action

Documents

Resulting from

Inspection

21004382

21004391

21004744

21004777

21004778

21004823

21004824

21004825

21004826

21004827

21004197

21005537

21005567

21005503

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

21009042

21009040

21010456

71111.24

Corrective Action

Documents

21004031

71111.24

Corrective Action

Documents

Resulting from

Inspection

21006465

71111.24

Work Orders

60165347

60165191

250156

240503

60165341

30341218

80138538

60151065

71152A

Corrective Action

Documents

Resulting from

Inspection

21007428

21007430

21009075

21007977

21009071

21009745

21005320

71152S

Corrective Action

Documents

Resulting from

Inspection

21007670

21007668

71153

Corrective Action

Documents

Resulting from

Inspection

21006024

19