IR 05000272/2019004

Integrated Inspection Report 05000272/2019004 and 05000311/2019004

ML20042D483
Person / Time
Site:	Salem
Issue date:	02/11/2020
From:	Brice Bickett NRC Region 1
To:	Carr E Public Service Enterprise Group
References
IR 2019004
Download: ML20042D483 (21)

Text

ary 11, 2020

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000272/2019004 AND 05000311/2019004

Dear Mr. Carr:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Salem Nuclear Generating Station, Units 1 and 2 and discussed the results of this inspection with David Sharbaugh, Salem Plant Manager and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Salem Nuclear Generating Station, Units 1 and 2.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Salem Nuclear Generating Station, Units 1 and 2. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket Nos. 05000272 and 05000311 License Nos. DPR-70 and DPR-75

Enclosure:

Inspection Report 05000272/2019004 and 05000311/2019004

Inspection Report

Docket Numbers: 05000272 and 05000311 License Numbers: DPR-70 and DPR-75 Report Numbers: 05000272/2019004 and 05000311/2019004 Enterprise Identifier: I-2019-004-0052 Licensee: PSEG Nuclear, LLC Facility: Salem Nuclear Generating Station, Units 1 and 2 Location: Hancocks, Bridge, NJ 08038 Inspection Dates: September 09, 2019 to December 31, 2019 Inspectors: J. Hawkins, Senior Resident Inspector M. Hardgrove, Resident Inspector E. Andrews, Health Physicist E. Burket, Senior Reactor Inspector C. Crisden, Allegations/Enforcement Specialist J. DeBoer, Reactor Inspector T. Fish, Senior Operations Engineer K. Warner, Health Physicist S. Wilson, Health Physicist Approved By: Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Salem Nuclear Generating Station, Units and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Inadequate Control of Transient Combustible Materials in accordance with the Fire Protection Program Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71111.05Q NCV 05000311,05000272/2019004-01 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of the Salem Unit 1 License Condition 2.C.(5) and Unit 2 License Condition 2.C.(10) when PSEG did not implement requirements in the Fire Protection Program (FPP) procedure. Specifically, on November 13, 2019, the inspectors identified bulk transient combustible material stored on the roof of the Auxiliary Building adjacent to (above)the critical, safety related Unit 1 and 2 Main Control Room (MCR) areas where the ceiling is not fire rated. This was contrary to Section 4.1, Transient Combustible Control General Requirements, of procedure FP-AA-011, Control of Transient Combustible Material,

Revision 6, and exceeded the transient combustible load limits established in the procedure.

Inadequate Corrective Actions for Feedwater Regulating Valve Vibrations Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.2] - 71152 FIN 05000272,05000311/2019004-02 Evaluation Open/Closed The inspectors identified a Green finding (FIN) because PSEG did not adequately implement, in part, procedure LS-AA-125, Corrective Action Program (CAP), requirements to address a condition adverse to quality (CAQ) associated with a previous equipment failure and trip of the Unit 2 reactor. Specifically, PSEG did not implement adequate corrective actions (CAs) to fix or minimize the consequence of an unacceptable condition, feedwater regulating valve (FRV)flow induced vibrations (FIVs), to acceptable levels. Consequently, PSEG experienced a repeat failure of the 23BF19 FRV due to FIV on August 11, 2019, resulting in the inability to control 23 steam generator (SG) water level and a manual trip of the Unit 2 reactor.

Additional Tracking Items Type Issue Number Title Report Section Status LER 05000311/2019-002-00 LER 2019-002-00 for Salem 71152 Closed Nuclear Generating Station,

Unit 2, Manual Reactor Trip and Auxiliary Feed Water System Actuation

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On November 30, the Salem Unit 1 reactor was downpowered from 100 percent power to 75 percent power for turbine valve testing. The unit reached rated thermal power later in the day of November 30 following completion of the turbine valve testing. There were no other operational power changes of regulatory significance for the remainder of the inspection period.

Unit 2 began the inspection period at rated thermal power. The unit remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) Unit 1, 12 residual heat removal pump following oil intrusion on October 2

(2) Unit 1, SCAF-1AF71 (88'TB)-20839405 severe corrosion on November 18

(3) Unit 2, 125 V batteries following notification 20834920 for top cover cracks on 2C 125 V batteries on October 8

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1, Relay, battery rooms and corridor on October 2

(2) Unit 2, Chillers room and inner piping penetration area on November 5

(3) Unit 1 and 2, Dunnage loading on auxiliary building 133'elevation above main control room on November 12

(4) Unit 1, Auxiliary feedwater pump area 84' elevation on December 12

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1, Mechanical penetration room with residual heat removal sump area 78' elevation on December 19

71111.07T - Heat Sink Performance Triennial Review (IP Section 02.02)

The inspectors evaluated heat exchanger/sink performance on the following:

(1) 1C Diesel Generator Lube Oil Cooler, Cooled by Service Water, Section 02.02.b

(2) 2A Diesel Generator Jacket Water Cooler, Cooled by Service Water, Section 02.02.b

(3) 21 Residual Heat Removal Heat Exchanger, Closed Loop Cooling, Section 02.02.c

(4) Unit 1 Ultimate Heat Sink, Section 02.02d, Specifically Sections 02.02.d.4, 02.02.d.6, and 02.02.d.7 were completed.

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03)

(1) An in-office inspection of Pass/Fail results for licensed operator requalification examinations (operating test and written exam) was conducted by one NRC region-based inspector on December 16, 2019. (Inspection Procedure 71111.11A).

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examinations.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the licensed operator annual requalification operating tests.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by Title 10 of the Code of Federal Regulations (10 CFR) 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

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

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

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

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

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

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) Unit 1, Downpower to 75 percent power for turbine valve testing, then back to 100 percent power on November 30 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) Volume control tank level transmitter failure, auto safety injection failure, main steamline break with multiple faulted steam generators on November 20

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1 and 2, Chiller motor contactor failures on 12 and 21 chiller on October 8

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1, 14 containment fan cooling unit declared inoperable due to flow indication failure while performing monthly surveillance test on November 6

(2) Unit 1 and 2, Dunnage loading on auxiliary building 133' elevation above main control room on November 12

(3) Unit 2, Chillers, chill water pumps, EDGs, CREACS fans and VIB INVs with chill water cross tied with unit 1 fan maintenance on December 9

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Units 1 and 2, 125 V battery calculations following ITE breaker spring charging motors not appropriately modeled and non-conservative on October 9

(2) Unit 2, 2B emergency diesel generator fuel rack booster failure on November 20

(3) Unit 2, 23 SW99, 23 chiller condenser recirculation check valve, failure during inservice testing on November 25

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Unit 1, 13 auxiliary feedwater pump relief valve replaced by blind flange October 1

(2) Units 1 and 2, Emergency diesel generator K1C relay contactors remounting for orientation change on November 26

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Unit 1, 13 charging pump 3 month prep bladders 1CVE44 & 1CVE45 checking and filling on October 29

(2) Unit 2, 21 chiller motor contactor replacement on October 8

(3) Unit 2, 'B' reactor vessel level instrumentation system on November 7

(4) Unit 2, B emergency diesel generator on November 18

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) Unit 1, 11 diesel fuel oil transfer pump surveillance test on October 28

(2) Unit 2, 2C 4 KV vital buses undervoltage surveillance test on November 13

(3) Unit 2, 22 service water pump surveillance test following high vibrations during previous surveillance test on November 25

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) Emergency preparedness training drill evaluation of simulator operators on November 21 Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

The inspectors evaluated:

(1) Loss of 5015 500 KV line, 21 CRDM vent fan damper fails closed, RCS leak inside containment, auto SI fails to actuate, large break LOCA with a loss of offsite power, auto phase A on train fails to actuate on October 8

(2) Charging master flow controller failure, 22 emergency core cooling system safety injection accumulator gas leak, phase 1 main power transformer large oil leak, main turbine fails to trip from control room requiring main steamline isolation loss of heat sink using main condensate system to restore field flow on November

RADIATION SAFETY

==71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (IP Section 02.01)

The inspectors evaluated radiological hazards assessments and controls.

Contamination and Radioactive Material Control (IP Section 02.03)==

The inspectors observed the monitoring of potentially contaminated material leaving the radiological control area and evaluated contamination and radioactive material controls.

The inspector selected several sealed sources from inventory records and assessed whether the sources were accounted for and tested for loose surface contamination.

(1) The inspectors verified the following sealed sources are accounted for and are intact:

• S-4

• S-5

• S-1179

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Use of Respiratory Protection Devices (IP Section 02.02)

The inspectors evaluated the licensees use of respiratory protection devices by:

(1) Observing in-field applications; verifying the licensee validated the level of protection provided by the devices; inspecting the material condition of devices, reviewing records and certification of devices issued for use; reviewing the qualifications of workers that use the devices; and observing workers donning, doffing and testing devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)

The inspectors evaluated self-contained breathing apparatus program implementation.

(1) The inspectors reviewed the following:

• Status and surveillance records for five SCBA units

• Maintenance records for five SCBA units

• SCBA fit for two on-shift operators

71124.05 - Radiation Monitoring Instrumentation Walk Downs and Observations (IP Section 02.01)

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) Portable Survey Instruments

• Eberline RO-2

• Ludlum 9-4

• MGP Telepole

• MGP AMP 100

• Ludlum 30-7 Source Check Demonstration

• Ludlum 30-7

• Ludlum 9-4

• Ludlum 2360

• MGP Telepole Area Radiation Monitors and Continuous Air Monitors

• S1 FHB 130' General Area AMS-4

• S2 FHB 130' General Area AMS-4

• S1 Chemistry Lab Count Room ARM 1R20B

• S2 FHB Area ARM 2R5

• S1 FHB Area ARM 1R9 Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

• ARGOS-5 100' Main Control Point

• CRONOS4 100' Main Control Point

• GEM-5 100' Main Control Point

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

• Whole Body Counter - Fastscan

• Ludlum 30-7 Failure to Meet Calibration or Source Check Acceptance Criteria

• None were available during this inspection.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the following areas:

• Liquid radwaste processing area

• Solid radwaste and reusable materials processing area

• RAM storage areas within the main RCA and sea-land storage locations The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:

• Approximately 15 steel drums of contaminated equipment stored in the auxiliary building

• Approximately 30 Sea-Land containers stored outside of the buildings Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems [and processes] during plant walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems

• Liquid radwaste processing system

• Solid radwaste and reusable materials processing area. Most of this material is shipped offsite to a vendor for processing, decontamination, and disposal as necessary.

Radioactive Waste Resin and/or Sludge Discharges Processes

• Liquid radwaste processing for batch releases. Batch tank circulation and sampling.

• Waste resins and activated charcoal are shipped for further processing to an offsite vendor then disposed at a licensed facility.

• Solid radwaste and resins are loaded into High Integrity Containers (HIC's)and stored in the Low-level Radioactive Waste building where they are protected from the elements and shielded to protect workers.

Waste Characterization and Classification (IP Section 02.03) (1 Sample)

The inspectors evaluated the radioactive waste characterization and classification for the dry active waste stream and solid waste.

Shipment Preparation (IP Section 02.04) (1 Sample)

The inspectors evaluated the following radioactive material shipment preparation processes:

(1) No active shipments were available for observation by the inspectors. Instead, the inspectors observed PSEG certified shippers demostrate how they prepare a radioactive material shipment in accordance with procedures.

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

(1)

• Low-level radioactive bead resin shipment number 19-107

• Low-level dry radioactive waste shipment number 19-066

• Low-level dry radioactive waste shipment number 19-127, package number

===300001750

• Radioactive material shipment (baffle bolts) number 19-127, package number

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) ===

(1) Unit 1, October 1, 2018 - September 30, 2019

(2) Unit 2, October 1, 2018 - September 30, 2019 MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1, October 1, 2018 - September 30, 2019

(2) Unit 2, October 1, 2018 - September 30, 2019 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2018 - September 30, 2019 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, 2018 - September 30, 2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) Review of root cause evaluation for corrective actions and extent of cause for feedwater regulating valves position feedback linkage; root cause evaluation for reactor coolant system drain down event, and root cause evaluation for knuckle plate issue on November 14 Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Review of repetitive issues 21SW122 on November 20

(2) Review of repetitive issues with the BF19 feedwater regulating valves on November

INSPECTION RESULTS

Inadequate Control of Transient Combustible Materials in accordance with the Fire Protection Program Procedure Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.12] - Avoid 71111.05Q NCV 05000311,05000272/2019004-01 Complacency Open/Closed The inspectors identified a finding of very low safety significance (Green) and associated non-cited violation (NCV) of the Salem Unit 1 License Condition 2.C.(5) and Unit 2 License Condition 2.C.(10) when PSEG did not implement requirements in the Fire Protection Program (FPP) procedure. Specifically, on November 13, 2019, the inspectors identified bulk transient combustible material stored on the roof of the Auxiliary Building adjacent to (above)the critical, safety related Unit 1 and 2 Main Control Room (MCR) areas where the ceiling is not fire rated. This was contrary to Section 4.1, Transient Combustible Control General Requirements, of procedure FP-AA-011, Control of Transient Combustible Material, Revision 6, and exceeded the transient combustible load limits established in the procedure.

Description:

On November 13, 2019, during a walkdown of the Salem Auxiliary Building roof, directly above the Unit 1 and 2 MCR areas, the inspectors identified approximately 3500 cubic feet (cu-ft) of wood railroad ties (dunnage) staged for the movement and use of a crane (WO 30218780; 11MS167-HO actuator). PSEG had designated the dunnage with a transient combustible permit (TCP) staged in the proximity of the work, TCP-SC-2019-028, on October 29, 2019. The inspectors found that this TCP was approved for work on the turbine deck, a non-safety related building per FP-AA-011 with a floor that is not fire rated, and not the Auxiliary building roof which is part of a safety related building. The inspectors further noted that the dunnage was staged directly above the Unit 1 and 2 MCR areas, a critical area with a ceiling that is not fire rated per Salem Pre-Fire Plans FP-SA-1561 and -2561. The inspectors estimated that the fire loading for the 3500 cu-ft of dunnage was approximately 1.45 billion BTUs (3500 cu-ft x 414,000 BTUs/cu-ft) of transient combustible material.

On November 14, 2019, PSEG documented this issue in NOTF 20839175. PSEGs evaluation noted that Salem is committed to Appendix A to BTP APCSB 9.5-1, BTP B.2 which states that Effective administrative measures should be implemented to prohibit bulk storage of combustible materials inside or adjacent to safety related buildings or systems during operation or maintenance periods. PSEGs procedure FP-AA-011, Section 4.1.5, goes on to state that Bulk transient combustibles should not be stored adjacent to critical structures. Some exterior boundaries of safety related structures are not designated as fire barriers. PSEG determined that [the dunnage that] currently exists on the Auxiliary building, service building, and turbine building roofs should be considered bulk [transient combustibles]

and removed ASAP. The inspectors also noted Section 4.2.7.7 which states that when a risk determination cannot be made due to an overall fire load without engineering support, compensatory actions are to be put in place OR the material causing the concern is to be removed. The Salem transient combustible load limit in all areas excluding the battery and diesel generator control rooms is 5 million BTUs, and this limit may be exceeded with prior Engineering approval. In this case, Engineering had not reviewed and approved the storage of these bulk combustible materials (290 times the fire loading limit) on the roof of the Auxiliary Building above the MCR areas.

Corrective Actions: Immediately following identification by the NRC of the combustible materials being stored not in accordance with procedure FP-AA-011, PSEG performed extent of condition walk downs of other similar areas, promptly removed the dunnage from the Auxiliary building roof, and entered the issue in corrective action program. PSEG also added the auxiliary building roof to the daily transient combustible inspection list contained in SC.FP-SV.ZZ-0058 and revised the pre-fire plan applicable areas.

Corrective Action References: 20839175 and 70210377

Performance Assessment:

Performance Deficiency: The inspectors determined that the PSEG not controlling transient combustible materials on the roof of the Auxiliary building, just above the Unit 1 and 2 main control room areas, in accordance with procedure FP-AA-011 was a performance deficiency that was reasonably within the licensees ability to foresee and should have been prevented. Specifically, on November 13, 2019, the inspectors identified bulk transient combustible materials stored adjacent to (above) the critical, safety related Unit 1 and 2 main control room areas where the ceiling is not fire rated.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding is also similar to example described in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, Section 4k. Specifically, PSEG did not account for the amount of transient combustibles present in the area and the amount of combustible loading exceeded the maximum load limit allowed by the FPP procedure.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using Appendix F, Attachment 1, Fire Protection SDP Phase 1 Worksheet, the inspectors assigned the category to fire prevention and administrative controls. The inspectors determined that the safety significance of the finding was very low because based on the SDP qualitative screening question (step 1.4.1) related to fire prevention and administrative controls, the finding does not increase the likelihood of a fire, delay detection of a fire, or result in a more significant fire than previously analyzed such that the credited safe shutdown strategy was adversely impacted.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, individuals involved with staging equipment associated with outage work activities did not consider undesired consequences of their actions with staging bulk transient combustibles adjacent to the MCR areas. These individuals were not aware of the requirements in FP-AA-011.

Enforcement:

Violation: The Salem Unit 1 License Condition 2.C.(5) and Unit 2 License Condition 2.C.(10),in part, require PSEG to implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR. Implementing procedure FP-AA-011, Control of Transient Combustible Material, requires that Bulk transient combustibles should not be stored adjacent to critical structures. Some exterior boundaries of safety related structures are not designated as fire barriers. Attachment 4 of procedure FP-AA-011 establishes combustible load limits of 5 million BTU per room in any area of the plant and allows to exceed this limit with prior Engineering approval.

Contrary to the above, on November 13, 2019, PSEG did not implement FPP requirements as stated in the procedure FP-AA-011. Specifically, PSEG stored bulk transient combustible materials adjacent to (above) the critical, safety related Unit 1 and 2 main control room areas where the ceiling is not fire rated. In this case, Engineering had not reviewed and approved the storage of these bulk combustible materials.

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

Inadequate Corrective Actions for Feedwater Regulating Valve Vibrations Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [P.2] - 71152 FIN 05000272,05000311/2019004-02 Evaluation Open/Closed The inspectors identified a Green finding (FIN) because PSEG did not adequately implement, in part, procedure LS-AA-125, Corrective Action Program (CAP), requirements to address a condition adverse to quality (CAQ) associated with a previous equipment failure and trip of the Unit 2 reactor. Specifically, PSEG did not implement adequate corrective actions (CAs)to fix or minimize the consequence of an unacceptable condition, feedwater regulating valve (FRV) flow induced vibrations (FIVs), to acceptable levels. Consequently, PSEG experienced a repeat failure of the 23BF19 FRV due to FIV on August 11, 2019, resulting in the inability to control 23 steam generator (SG) water level and a manual trip of the Unit 2 reactor.

Description:

The FRVs are required to throttle flow into the secondary sides of the SGs in response to SG water level and feed water flow signals. These valves are designed to take this input and throttle open or closed depending on demand. Position feedback is accomplished through linkage from the actuator stem rod to a lever attached to the shaft assembly with a magnet that provides input to the positioner.

On August 11, 2019, during a planned load reduction to 55 percent reactor power for maintenance, the 23BF19 started cycling full open and closed while in automatic at 83 percent reactor power. Operators attempted to take manual control of the valve but could not adequately control 23 SG water level and manually tripped the Unit 2 reactor (EN 54211 and LER 05000311/2019-02-00). PSEGs investigation revealed that the main screw holding the 23BF19 external positioner linkage arm unscrewed and disengaged due to vibrations not allowing for the positioner to control the valves position. PSEGs extent of condition inspections found two other Unit 2 FRVs with loose main screws, the 22BF19 and 24BF19.

PSEG completed a root cause evaluation (RCE 70208741) which determined that the screw loosening was due to general system vibration, not the acute, high magnitude vibration seen during the previous vibration-induced failure of the 23BF19 on September 14, 2018 (RCE 70202713 and NRC FIN 05000311/2019001-01). PSEG determined that their review of the 2018 event had not adequately evaluated all the potential vibration induced failure modes for the BF19s and that the BF19s were susceptible to FIV that could damage the valves. PSEGs CAs included establishing real-time BF19 vibration monitoring and operational limits until more long term system design CAs could be completed.

The inspectors reviewed PSEGs RCEs, previous events involving the BF19s, and conducted interviews with engineering and operations personnel. While the inspectors agreed that PSEGs review of the 2018 event had not adequately evaluated all the potential vibration induced failure modes for the BF19s, the inspectors noted that the 2019 RCE did not discuss the adequacy of PSEGs 2018 RCE CAs as implemented through PSEGs Adverse Condition Monitoring Plan (ACMP) and their operating procedure for controlling FRV vibration.

PSEGs ACMP 18-010, 21-24BF19 Elevated Vibrations, was implemented following the September 14, 2018, 23BF19 failure and monitored for: 1. BF19 vibration velocity (Limits:

warning >2 inches per second (ips) in any direction; danger >10 ips vertical or axial / >5 ips lateral); 2. Ambient noise level changes; and, 3. match-mark positions. If the warning limits were reached, the ACMP directs implementation of S2.OP-IO.ZZ-0004, Attachment 7, Controlling FRV Vibration procedure .

The inspectors noted the following:

1. Condition Report CA (CRCA) 70202713-0310 implemented continuous tri-axial

vibration monitoring at the BF19s until long term changes were completed to the FRV design.

2. BF19 vibration limits were established by a 2018 RCE corrective action (CRCA 70202713-0330) and based on a vendor calculation, 0108-0497-MEMO-005. Section 2.2.5 of this calculation states that if peak vibrations are above 1.6 ips then take action to reduce vibrations.

3. S2.OP-IO.ZZ-0004, Att. 7, revised due to 2018 RCE CRCA 70202713-0360, limitation 2.2.15, states to Implement [Att. 7] when peak vibration levels on any BF19 FRV exceeds 2 ips in any direction to prevent exceeding the positioner feedback arm design limits. This procedure provides specific strategies for reducing FRV vibration by taking manual control of the BF40 bypass valves and documenting this action in a NOTF.

After reviewing the vibration data for the 2019 event, the inspectors found that the ACMP limits had been exceeded nine minutes before operators noted the erratic operation of 23BF19 and fourteen minutes before operators manually tripped the reactor. The inspectors found that operators did not attempt to open the BF40s to reduce vibrations on the BF19s per Att. 7 even though an operator was stationed at the valves continuously monitoring vibration levels. As a result, the inspectors questioned PSEG about the ACMP limits and the inability for operators to determine whether the limits had been exceeded. PSEG documented NOTF 20832019* stating that operators monitoring the 23BF19 vibrations during the 2019 event did not see vibration levels greater than 0.7 ips, but that the field data showed vibration levels had exceeded 10 ips. PSEGs ACMP procedure, OP-AA-108-111, Steps 4.4.4.5 and 6 states, in part, that Parameters are readily available to Data Collectors, and Threshold values are established with consideration of known operational limits, and timely and consistent responses by all personnel. ACMP instructions also state that, This data must be readily accessible by the Data Collector, without reliance on contacting support personnel.

Because of this, the inspectors reviewed specific Unit 2 BF19 vibration data accrued since the 2018 event and found:

1. Multiple instances where the Unit 2 BF19s experienced sustained vibration levels above the ACMP limits.

2. PSEG was not consistently documenting NOTFs as required by Att. 7 when the BF40s are manipulated to reduce vibrations on the BF19s.

3. PSEGs 2019 RCE cause of the loosening screw being due to general system vibration and not the high magnitude vibration seen during the 2018 event was not supported by the recorded vibration data. The inspectors found that the 23BF19 experienced higher vibrations for longer periods of time than the other Unit 2 FRVs resulting in its screw becoming loose before any of the other valves screws.

PSEGs CAP procedure, LS-AA-125, Section 2.7 states that a CRCA is an action to restore or address the cause of a CAQ. Section 1.1.1.2 states that CAs fix or minimize the consequence of the unacceptable condition to acceptable levels. Based on this, the inspectors determined that PSEG did not implement adequate CAs to fix or minimize the consequence of an unacceptable condition, FRV FIVs, to acceptable levels. Consequently, PSEG experienced a repeat failure of the 23BF19 FRV due to system vibration on August 11, 2019.

Corrective Actions: PSEGs CAs included replacing the 23BF19 positioner assembly, installing the screws with thread locker, performing extent of condition inspections on all Unit 1 and 2 BF19 and BF40 valve positioners and linkages. PSEG also took actions to replace all the actuator air supply flexible hoses, install bracket bolting for the valve positioners and limit switches, and revised their vibration monitoring system and ACMP.

Corrective Action References: 20831038, 20831103*, 20831322*, 20832019*, 20832034, 20832141, 20832376, 20832449, 20836535*, 20836550*, 20836718*, 70202713, 70208436, and 70208741.

Performance Assessment:

Performance Deficiency: The inspectors determined that PSEG not implementing adequate CAs to fix or minimize the consequence of an unacceptable condition, FRV FIVs, to acceptable levels was a performance deficiency within their ability to foresee and correct and which should have been prevented.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, PSEG not adequately implementing their procedures resulted in the repeat failure of the 23BF19 and a manual trip of the Unit 2 reactor.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The finding screened to Green, very low safety significance, using IMC 0609, Appendix A, since the finding did not cause both a reactor trip and a loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. Specifically, the auxiliary feedwater system remained operable and available.

Cross-Cutting Aspect: P.2 - Evaluation: The organization thoroughly evaluates issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. This finding, in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014, has a cross-cutting aspect in the Problem Identification and Resolution area associated with Evaluation, in that PSEG did not thoroughly evaluate the FIV issue to ensure that the resolutions addressed the causes and extent of conditions commensurate with their safety significance. Specifically, PSEG did not ensure that the ACMP was implementable using the installed BF19 vibration monitoring equipment. (P.2)

Enforcement:

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

Observation: Semi-Annual Trend Review 71152 The inspectors evaluated a number of issues and associated notifications (NOTFs) generated over the course of the past two quarters by departments that provide input to the quarterly trend reports. The inspectors determined that, in most cases, issues and potential trends were appropriately identified, evaluated and resolved by PSEG.

However, the inspectors did note a few instances where PSEG was not timely or did not recognize, until prompted by the inspectors, that issues and adverse trends were not appropriately identified, evaluated and resolved. Examples of these are documented below:

- The inspectors reviewed the repeated failures of the 21 component cooling water heat exchanger service water inlet valve (21SW122) to fully open that occurred on June 21, 2018 (ERE 70201302), September 5 and 10, 2019 (ERE 70209093). The inspectors noted that PSEG performed no failure analysis or confirmation of the assumed failure mechanism. PSEGs causal evaluation found that they were willing to accept the condition without fully understanding the problem and poor troubleshooting. The inspectors also noted that the failure analyses are still open (FAs 70209100 and 70209578).

- On November 18, 2019, NOTF 20839565 documented an NRC-identified issue involving fire protection header piping in the Unit 1 turbine building severely corroded at a 2 inch drain valve (1FP900). PSEG took immediate action to clean the affected piping and perform ultra-sonic testing measurements of the pipes thickness which determined that the piping thickness was just above the nominal required thickness for operability. PSEG performed extent of condition walk downs of other fire protection piping and plans to recoat this section of pipe during scheduled maintenance.

- On November 26, 2019, NOTF 20840275 documented an NRC-identified issue involving water and oil collecting in the 22 AFW pump bearing cavity. PSEG has created corrective actions to clean out the pump cavity during the next maintenance period.

- On November 26, 2019, NOTF 20840824 documented an NRC-identified issue involving the 13 AFW pump enclosure floor drain being obstructed with debris. PSEG also documented additional concerns related to the floor drain cover in NOTF 20840300. PSEG took immediate actions to clear out the drain and created actions to evaluate the condition under 70209479 and

EXIT MEETINGS AND DEBRIEFS

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

• On November 1, 2019, the inspectors presented the RP Inspection Results and Observations inspection results to Chaz McFeaters, Salem Vice President and Rick DeSanctis, Salem Acting Plant Manager / Senior Director of Operations and other members of the licensee staff.

• On November 21, 2019, the inspectors presented the Triennial Heat Sink Performance inspection inspection results to Mr. Rick DeSanctis, Salem Operations Director and other members of the licensee staff.

• On January 16, 2020, the inspectors presented the integrated inspection results to Robert DeNight, Senior Salem Engineering Director and other members of the licensee staff

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.07T Corrective Action 20840231

Documents

Corrective Action 20840234

Documents

Resulting from

Inspection

Procedures ER-AA-340-1001 GL 89-13 Program Implementation Instructional Guide Revision 9

71124.01 Procedures RP-AA-15 Radioactive Contamination Control Program Description Revision 3

71124.03 Procedures RP-AA-301 Radiological Air Sampling Program Revision 8

RP-AA-440 Respiratory Protection Program Revision 10

71124.05 Miscellaneous Salem Unit 2 System Health Report (Q2-2019) Radiation

Monitoring System

Procedures RP-AA-501 Control of Radiation Protection Instruments Revision 3

RP-AA-504 Routine Operation of the Radiation Protection Gross Revision 5

Counting Facility

RP-AA-517 Fixed Monitor Routine Surveillance Checks Revision 0

71124.08 Corrective Action 20832409 Self-Identified Improvement to RP-AA-460 September

Documents 11, 2019

Corrective Action 20837002 HPN inspection observation October 31,

Documents 2019

Resulting from 20837002 HPN inspection observation October 31,

Inspection 2019

Procedures NRP9902RMATC- Radiation Protection Technician Training - Radioactive January 31,

Materials Shipping 2017

RP-AA-602 Packaging of Radioactive Material Shipments Revision 16

71151 Procedures LS-AA-2001 Collecting and Reporting of NRC Performance Indicator Revision 1

Data

18