IR 05000272/2021013
| ML22069A078 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 03/10/2022 |
| From: | Mel Gray NRC/RGN-I/DORS |
| To: | Carr E Public Service Enterprise Group |
| Gray M | |
| References | |
| IR 2021001, IR 2021013 | |
| Download: ML22069A078 (13) | |
Text
March 10, 2022 Mr. Eric Carr President and Chief Nuclear Officer PSEG Nuclear, LLC - N09 P. O. Box 236 Handcocks Bridge, NJ 08038 SUBJECT: HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 - EVALUATION OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000354/2021013, 05000272/2021013 AND 05000311/2021013 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200048/2021001 RELATED TO PSEG EVALUATIONS OF THEIR GENERATING STATIONS AND THE PLANNED WIND PORT MANUAFACTURING FACILITY
Dear Mr. Carr:
On February 3, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station and Salem Nuclear Generating Station, Units 1 and 2. These inspections reviewed evaluations completed by your staff regarding your Salem and Hope Creek Generating Stations and the potential impacts of a Wind Port Manufacturing Facility. On February 15, 2022, the NRC inspectors discussed the results of this inspection with Mr. Charles Mcfeaters, Senior Vice President of Nuclear Operations and other members of your staff. The results of this inspection are documented in the enclosed report.
A Severity Level IV violation without an associated more than minor finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
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 and 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, Digitally signed by Melvin K.
Gray Melvin K. Gray Date: 2022.03.10 09:37:37-05'00'
Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000354, 05000272, 05000311 and 07200048 License Nos. NPF-57, DPR-70 and DPR-75
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000354, 05000272, 05000311 and 07200048 License Numbers: NPF-57, DPR-70 and DPR-75 Report Numbers: 05000354/2021013, 05000272/2021013, 05000311/2021013 and 07200048/2021001 Enterprise Identifier: I-2021-013-0019 I-2021-013-0020 Licensee: PSEG Nuclear, LLC Facility: Hope Creek Generating Station and Salem Nuclear Generating Station, Units 1 and 2 Location: Hancocks Bridge, NJ Inspection Dates: June 21, 2021 to February 15, 2022 Inspectors: K. Mangan, Senior Reactor Inspector J. Nicholson, Senior Health Physicist P. Koch, Structural Engineer Approved By: Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting inspections to review evaluations completed by the licensee regarding the Salem and Hope Creek Generating Stations and potential safety hazards resulting from a Wind Port Manufacturing Facility to be located adjacent to the Salem-Hope Creek nuclear site. This report documents an Evaluation of Changes, Tests, and Experiments inspection and Operation of an Independent Spent Fuel Storage Installation inspection at Hope Creek Generating Station and Salem Nuclear Generating Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The NRC also performed onsite inspections of Salem-Hope Creek Emergency Preparedness and Security Plan change documents completed by the licensee considering the current status of the adjacent Wind Port Manufacturing Facility. These inspections are documented in NRC inspection reports dated November 30, 2021 (ADAMS Accession No. ML21334A105) and November 19, 2021 (ADAMS Accession No. ML21323A104), respectively. 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
Incorrect Safety Conclusion Related to Hope Creek (HC), Salem Unit 1, and Salem Unit 2 Technical Specification Definitions and Planned Industrial Facility Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71111.17T NCV 05000354/2021013-01, 05000272/2021013-01, 05000311/2021013-01 Open/Closed The inspectors identified a violation of 10 CFR 50.59C(1)(i) which states a licensee may make changes in the facility as described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if a change to the technical specifications incorporated in the license is not required. PSEG staff concluded that a portion of the Wind Port Manufacturing Facility (WPMF), an industrial purposed facility, could occupy the restricted area shown in HC Technical Specification (TS) Figure 5.1.1-1 and Salem Unit 1 and 2 TS Figures 5.1-3 without a change to the TS. The inspectors determined this was contrary to the TS definition of Unrestricted Area which states that the area where industrial activity occurs within the site boundary is an Unrestricted Area. As a result, the inspectors found PSEG staffs conclusion in the safety evaluation that a license amendment was not required was incorrect because a change to applicable HC and Salem TS definition was needed which required prior NRC review and approval.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000354/2021013-02, URI - Evaluations associated 71111.17T Open 05000272/2021013-02, with the impact on the intake 05000311/2021013-02 structure of new hazards associated with barge traffic, ship traffic, and fuel oil spills
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.
REACTOR SAFETY
===71111.17T - Evaluations of Changes, Tests, and Experiments The inspectors reviewed PSEGs safety evaluation (SE) and supporting hazards analyses (HAs)to determine whether the change (construction and operation of the WPMF) to the Salem and Hope Creek Nuclear Power Plants (NPPs) as described in their respective Updated Final Safety Analysis Reports (UFSARs) was completed in accordance with NRC regulatory requirements in 10 CFR 50.59. In addition, the inspectors evaluated whether PSEG was required to obtain a license amendment prior to implementing the change.
The inspectors reviewed PSEGs SE/HA for each of the hazards previously described in their UFSAR and determined whether new hazards would result from WPMF construction and operation. The inspectors reviewed PSEGs evaluation of the potential for chemical releases, fires, explosions, and missile generation (port related debris) initiating from WPMF activity to impact the Salem and HC plants, particularly the control room air intakes and safety-related structures, systems, and components (SSCs).
The inspectors also reviewed the potential for waterborne hazards (safety-related service water intake blockage/collision/fire from barge or ship) associated with WPMF related traffic near the HC and Salem intake structures (HC intake is closer and limiting in this regard). The inspectors reviewed the Salem and HC current licensing basis with particular attention to waterborne HAs submitted to the NRC in September 1974 and March 1983. The inspectors reviewed these documents to determine the assumptions, evaluations, and conclusions made by PSEG related to external river borne hazards that had been previously reviewed and found acceptable by the NRC. The inspectors evaluated whether hazards associated with the WPMF were bounded by these previous evaluations. These reviews were completed by the inspectors on a sampling basis to independently assess the adequacy of PSEGs 2021 HA used to support their SE conclusions.
The inspectors interviewed PSEG staff and their contractors, and reviewed supporting information including calculations, analyses, the UFSAR, and plant drawings to assess the adequacy of the SE and supporting HA. Additionally, the inspectors walked down the land where the WPMF is being located, the HC intake structure, and the potentially impacted HC SSCs. The inspectors independently reviewed, on a sampling basis, calculational methodologies and technical inputs to assess whether the methodologies and inputs used by PSEG staff were technically supported. In reviewing methodologies, the inspectors considered whether methods and inputs were consistent with NRC regulatory guidance related to external hazards.
The inspectors noted and reviewed statements in the SE related to the planned sale of land within the site boundary from PSEG Nuclear to NDEV LCC, a wholly owned subsidiary of PSEG Power. The inspectors considered if the transfer of the land constituted a partial release of land for unrestricted use as described in 10 CFR 50.83; required a change to Salem and HC license condition 2.a related to ownership; meets the requirements for an exclusion area as defined in 10 CFR Part 100; or if a change to the TSs was required as a result of the planned sale. During the inspection, PSEG staff informed the inspectors of a change in PSEG plans that had been completed whereby PSEG Nuclear maintains ownership of the land and leases it directly to the State of New Jersey for the construction and operation of the WPMF. The inspectors noted this change in their review.
Additionally, the inspectors reviewed the requirements for control of the exclusion area as described in 10 CFR Part 100. PSEG stated in their SE that the WPMF workforce would be considered Members of the Public. The inspectors determined the exclusion area is defined as the boundary where members of the public would not receive a dose in excess of 10 CFR 50.67 requirements. The inspectors noted PSEG conclusions in their SE that they would maintain authority to remove personnel and property in-order-to continue to consider the leased land within the exclusion area under their control. PSEG actions to provide for this control of WPMF personnel to date, were reviewed by regional inspectors with specialties in emergency preparedness and security and documented in NRC inspections reports dated November 30, 2021 (ADAMS Accession No. ML21334A105) and November 19, 2021 (ADAMS Accession No. ML21323A104), respectively.
Finally, the inspectors evaluated if the operation of an industrial facility within a restricted area (Exclusion Area) would be allowed without a change to the TS.
To determine the adequacy of the SE, the inspectors compared the SE to the regulatory requirements in 10 CFR 50.59, and considered the guidance and methods described in PSEG procedures and, to the extent implemented by PSEG procedures, Nuclear Energy Institute (NEI)96-07, Guidelines for 10 CFR 50.59 Evaluations, as endorsed by NRC Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments.
Sample Selection (IP Section 02.01) ===
The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59.
- (1) Artificial Island Wind Port Facility
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60855 - Operation of an Independent Spent Fuel Storage Installation (ISFSI) The State of New Jersey plans to build and operate an offshore wind port located in Salem County north of the PSEGs Hope Creek Nuclear Generating Station. As part of the project, an area of land will be developed north of the HC Independent Spent Fuel Storage Installation (ISFSI) pad. The inspectors, along with technical staff from the Office of Nuclear Material Safety and Safeguards (NMSS), Division of Fuel Management (DFM), reviewed PSEGs geotechnical analysis to determine if the surcharging of the area associated with the construction will adversely affect the HC ISFSI pad and the stored Holtec HI-STORM 100 storage systems.
The surcharge area is located approximately 400 feet north of the HC ISFSI pad. The NRC staff reviewed PSEGs geotechnical analyses to determine if the assumptions, evaluations, and conclusions made by PSEG were appropriate. The staff noted that PSEG concluded that stress increases have a negligible effect on structures at distances greater than 100 feet from the surcharge area. The DFM staff independently confirmed that the stress increases caused by the surcharge load are small and can be considered to have a negligible effect on the ISFSI pad. The DFM staff verified that the overall methodologies used in the geotechnical analyses are consistent with accepted industry practices and are technically adequate.
Operation of an Independent Spent Fuel Storage Installation (ISFSI) ===
- (1) The inspectors reviewed PSEG's evaluations of the construction phase of the wind port project on the ISFSI pad.
INSPECTION RESULTS
Incorrect Safety Conclusion Related to Hope Creek (HC), Salem Unit 1, and Salem Unit 2 Technical Specification Definitions and Planned Industrial Facility Cornerstone Severity Cross-Cutting Report Aspect Section Not Severity Level IV Not 71111.17T Applicable NCV 05000354/2021013-01, Applicable 05000272/2021013-01, 05000311/2021013-Open/Closed The inspectors identified a violation of 10 CFR 50.59C(1)(i) which states a licensee may make changes in the facility as described in the final safety analysis report (as updated)without obtaining a license amendment pursuant to Sec. 50.90 only if a change to the technical specifications incorporated in the license is not required. PSEG staff concluded that a portion of the Wind Port Manufacturing Facility (WPMF), an industrial purposed facility, could occupy the restricted area shown in HC Technical Specification (TS) Figure 5.1.1-1 and Salem Unit 1 and 2 TS Figures 5.1-3 without a change to the TS. The inspectors determined this was contrary to the TS definition of Unrestricted Area which states that the area where industrial activity occurs within the site boundary is an Unrestricted Area. As a result, the inspectors found PSEG staffs conclusion in the SE that a license amendment was not required was incorrect because a change to applicable HC and Salem TS definition was needed which required prior NRC review and approval.
Description:
The inspectors reviewed SE H2021-004/S2021-003, Revision 0 to determine PSEG staffs basis for concluding that a license amendment was not required for changes to the Salem and HC facilities due to the construction and operation of the WPMF. The inspectors found that PSEG staff had concluded that this change would not affect the HC TSs.
The inspectors reviewed HC TS Figure 5.1.1-1 which identified the restricted and Unrestricted Areas, the Site Boundary, and the exclusion area boundary for the facility. The inspectors noted the WPMF would be located north of the HC Protected Area fence and that portions of the facility would be located within the site area boundary, restricted area, and the HC exclusion area as shown in the TS figure. The inspectors asked if TS Figure 5.1.1-1 needed to be changed as a result of planned changes to the site boundary, exclusion area, or Unrestricted Area. PSEG informed the inspectors that this figure did not need to be revised to address changes associated with the construction and operation of the WPMF. The inspectors noted the Salem TS Figures 5.1-3 showed similar information.
The inspectors reviewed the HC and Salem TS definition of Unrestricted Area which states:
UNRESTRICTED AREA: An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY access to which is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the SITE BOUNDARY used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes. (emphasis added)
Following review of the TS, the inspectors questioned if the area where the WPMF was to be located was going to be considered a restricted or Unrestricted Area by PSEG. The inspectors found that, if the area would be used for industrial purposes and was within the Site Boundary, it would need to be considered an Unrestricted Area in order to comply with the TS definition of Unrestricted Area. However, the TS figures identify the area, where portions of the WFMF will be located, is as a restricted area. PSEG staff informed the inspectors the area was to be maintained such that PSEG would control all activities including exclusion or removal of personnel and property and remain a restricted area. The inspectors concluded PSEG could not locate portions of the WPMF (an industrial facility) in a restricted area because the TS definition for Unrestricted Area precluded this approach. As a result, a license amendment to change the TS definition or figure was required and 10 CFR 50.59(c)(1)(i) was not met.
During the inspection PSEG informed the inspectors that they were preparing a license amendment to address the TS conflict. The license amendment request was subsequently submitted for the HC and Salem Unit 1 and 2 TSs on September 29, 2021 (ADAMS Accession No. ML21272A184).
Corrective Actions: PSEG submitted a license amendment request (ADAMS Accession No.
ML21272A184) on September 29, 2021. The license amendments (Nos. 230, 342, and 323) were approved by the NRC on February 14, 2022 (ADAMS Accession No.
Corrective Action References: Notification 20893857
Performance Assessment:
The inspectors determined this violation was associated with a minor performance deficiency. The performance deficiency for the failure to make a change to the facility that affected technical specifications without a license amendment was considered a minor performance deficiency for the Reactor Oversight Process (ROP)because industrial activity had not occurred in the restricted area when the issue was identified by the inspectors.
Enforcement:
The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: In accordance with NRC Enforcement Manual, Section 2.1.3, Enforcement of 10 CFR 50.59 and Related FSAR Violations, Section D.5.a, the inspectors determined this violation is categorized as Severity Level IV because the change required prior Commission review and approval, and the licensee failed to obtain Commission approval. In reaching this conclusion, the inspectors determined that the violation is more than minor because it was similar to NRC Enforcement Manual, Appendix E, Examples of Minor Violations - Minor Changes to Requirements because the change required prior NRC review and approval. The violation is categorized at Severity Level IV because the safety significance of the change would not be assessed as greater than Green under the ROP.
Violation: 10 CFR 50.59C(1)(i) states in part, a licensee may make changes in the facility as described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if a change to the technical specifications incorporated in the license is not required. Contrary to the above, on April 12, 2021, the licensee approved a change to the facility as described in the updated final safety analysis report without obtaining a license amendment pursuant to Section 50.90. Specifically, PSEG staff concluded that a license amendment was not required to address the TS limitations prior to building and operating the WPMF. PSEG concluded the WPMF, an industrial purposed facility, could occupy the HC restricted area shown in TS Figure 5.1.1-1, contrary to the TS definition of Unrestricted Area, which states that the area where industrial activity occurs within the site boundary is an Unrestricted Area.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Unresolved Item URI - Evaluations associated with the impact on the intake 71111.17T (Open) structure of WPMF hazards associated with barge traffic, ship traffic, and fuel oil spills URI 05000354/2021013-02, 05000272/2021013-02, 05000311/2021013-02
Description:
PSEG staff prepared SE H2021-004/S2021-003, Revision 0, to document their conclusions regarding the potential impacts to their Salem and HC NPPs as a result of the construction and operation of a WPMF. The SE addressed NRC regulatory requirements in 10 CFR 50.59 to determine whether a license amendment is required for the changes to the facility, which, in this instance involved the construction and operation of the WPMF located within the site and exclusion boundaries north of the HC protected area. To support their conclusions documented in the SE, PSEG staff developed a HA to evaluate the impact of postulated hazards associated with the WPMF on the NPPs. The HA evaluated the effects of external hazards on safety-related and important-to-safety SSCs.
PSEG staff described in their SE their plans to sell land where a portion of the WPMF was to be located to a wholly owned subsidiary of PSEG Power who would then lease the land to the State of New Jersey with the intent to develop the WPMF. This land straddles the Site Boundary (defined in TSs) and the co-located HC exclusion area boundary. PSEG staff asserted that activities on this land within the Site Boundary would remain in PSEGs control. Finally, PSEG Nuclear staff concluded that, although portions of the leased land were within the sites exclusion boundary, this would not adversely affect doses to members of the public because WPMF employees, considered members of the public, would be required, and directed to evacuate the WPMF in the event of an Alert declaration related to the Salem or HC NPPs.
The inspectors reviewed the SE/HA evaluation and conclusions related to the impact on SSCs required to safely shutdown Salem Units 1 and 2 and HC. The inspectors questioned the evaluations associated with the impact on the intake structure of WPMF related hazards associated with barge traffic, ship traffic, and fuel oil spills.
Specifically:
- The inspectors were not able to conclude that the potential hazards (waterborne missile hazard) to the HC safety-related intake structure associated with WPMF barge traffic was not increased. Additional information is needed to determine if the hazard is bounded by the HC current licensing basis analysis or that there is not a more than minimal increase in the frequency of this hazard. The information needed is related to WPMF associated barge size and shape to assess intake structure hazard.
- The inspectors were not able to conclude that the potential hazards (ship ramming)associated with windmill component delivery shipping and completed windmill transportation shipping associated with the operation of the WPMF was not increased.
Additional information is needed to determine if the hazard is bounded by the HC current licensing basis analysis or that there is not a more than minimal increase in the frequency of this hazard. The information needed is related to the size and draft of WPMF associated ships.
- The inspectors were not able to determine if the potential hazard (fuel oil pool fire)associated with a failure of fuel tanks from the shipping associated with the WPMF on the intake structure was properly evaluated. Additional information is needed to determine if the hazard is bounded by the HC current licensing basis analysis or that there is not a more than minimal increase in the frequency of this hazard. The information is related to the size of the WPMF associated ship postulated fuel spill, time for a fire to consume all the fuel oil, and the location of the fire in relation to the HC intake structure.
During the inspection, PSEG informed the inspectors that they planned to perform an engineering evaluation and revise their SE to both address inspector questions and to reflect their decision to lease land directly to the State of New Jersey instead of a land sale. This URI also tracks the inspectors review of PSEGs planned revision(s) to their 10 CFR 50.59 SE related to the TS compliance and the lease features which would provide for PSEG control of leased land to ensure that there is not a more than minimal increase in the consequence (dose) of postulated accidents to a member of the public.
Planned Closure Actions: The inspectors plan to review the revised PSEG 10 CFR 50.59 safety evaluation and associated revised hazards analyses to determine if the criteria described in 10 CFR 50.59 have been met.
Licensee Actions: During the inspection, PSEG informed the inspectors that they would be creating an engineering package to develop the activities credited in their SE and to address inspector questions. Additionally, during the inspection PSEG Nuclear signed a lease with the State of New Jersey for the use of the land and informed the inspectors they would not be selling the property to NDEV LLC.
Corrective Action References: EC
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 15, 2022, the inspectors presented the Evaluation of Changes, Tests, and Experiments inspection results to Mr. Charles Mcfeaters, Senior Vice President of Nuclear Operations and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
60855 Calculations VTD 433590 Geotechnical Calculations for Surcharge Impacts - Parcel A
Engineering 50.59 Screening Artificial Island Windport Facility Revision 0
Evaluations No. H2021-
004/S2021-003
Miscellaneous NFS21-018 Wind Port Construction Phase 1 Considerations for ISFSI
Operations and 10 CFR 72.48
71111.17T Corrective Action Notification
Documents 000020893857
Resulting from
Inspection
Engineering An Update on the Analysis of Waterborne Traffic on the March 1983
Evaluations Safety of the Control Room and Water Intakes at Hope
Creek Generating Station
Analysis of Waterborne Traffic on the Safety of the Control September
Room and Water Intakes at Hope Creek Generating Station 1974
433600 Impact of Siting the Proposed Offshore Windport Facility Rev. 0
Northwest of the HCGS ISFSI Pad on the PSEG Nuclear
Island Hazards Analyses
H2021- Artificial Island Wind Port Facility Rev. 0
004/S2021-003
Miscellaneous LTR from PSEG to Director of NRR - SER Outstanding Issue 10/1/1985
"Riverborne Missiles" Hope Creek Generating Station
LTR from PSEG to Director of NRR - SER Outstanding Issue 09/16/1985
"Riverborne Missiles" Hope Creek Generating Station
NUREG-1048 Supplement 4 December
Safety Evaluation Report related to the operation of Hope 1985
Creek Generating Station
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