IR 05000354/2019002

Integrated Inspection Report 05000354/2019002

ML19212A245
Person / Time
Site:	Hope Creek
Issue date:	07/30/2019
From:	Brice Bickett Reactor Projects Branch 3
To:	Carr E Public Service Enterprise Group
References
IR 2019002
Download: ML19212A245 (14)

Text

uly 30, 2019

SUBJECT:

HOPE CREEK GENERATING STATION, UNIT 1 - INTEGRATED INSPECTION REPORT 05000354/2019002

Dear Mr. Carr:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Hope Creek Generating Station in Hancocks Bridge, New Jersey. On July 11, 2019, the NRC inspectors discussed the results of this inspection with Mr. Ed Casulli, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

The inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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 1; the Director, Office of Enforcement; and the NRC Resident Inspector at Hope Creek Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No. 05000354 License No. NPF-57

Enclosure:

Inspection Report 05000354/2019002

Inspection Report

Docket Number: 05000354 License Number: NPF-57 Report Number: 05000354/2019002 Enterprise Identifier: I-2019-002-0046 Licensee: PSEG Nuclear, LLC Facility: Hope Creek Generating Station Location: Hancocks Bridge, NJ 08038 Inspection Dates: April 01, 2019 to June 30, 2019 Inspectors: A. Ziedonis, Senior Resident Inspector S. Haney, Resident Inspector J. Patel, Resident Inspector D. Werkheiser, Senior Reactor Inspector L. Dumont, Reactor Inspector Approved By: Brice A. Bickett, Chief Reactor Projects Branch 3 Division of Reactor Projects

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. Licensee-identified non-cited violations are documented in report section: 71111.15.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

PLANT STATUS

The Hope Creek Generating Station (Hope Creek) began the inspection period on April 1, 2019, performing power ascension from a planned maintenance outage (P191) to perform repairs on the 'D' and H safety relief valves (SRVs). Hope Creek achieved full rated thermal power on April 7, 2019. The station performed planned power reductions to approximate power levels of 75 percent to 80 percent, for turbine valve testing and / or rod pattern adjustments, on April 23, May 15, and May 31, and returned to full power on the subsequent day following each load reduction. The station performed planned power reductions to approximately 85 percent, to remove selected portions of feedwater heating from service, on June 6, June 13, and June 20, and returned to full power on the subsequent day following each load reduction. On June 30, the station performed an additional planned power reduction to approximately 85 percent, and remained at reduced power for the remainder of the inspection period, to remove an additional feedwater heating from service.

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.

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

(1) The inspectors evaluated summer readiness of offsite and alternating current power systems on June 19, 2019.

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

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

(1) 'B' train of station service water on April 17, 2019

(2) Stator water cooling on-line leakage monitoring system during installation on June 14, 2019

(3) Feedwater heating lineup following feedwater heater string removal to verify compliance with the core operating limits report on June 14, 2019

(4) 'D' train of residual heat removal following audible indications of potential minimum flow line check valve chattering on June 28, 2019

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) The inspectors evaluated fire brigade performance on May 16, 2019.

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

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

(1) Class 1E switchgear area on April 18, 2019

(2) Core spray pump rooms on May 3, 2019

(3) Reactor building equipment airlock area and associated transient combustible free zone on June 5, 2019

(4) Reactor building elevator machine room and associated transient combustible free zone on June 17, 2019

71111.06 - Flood Protection Measures Inspection Activities - Underground Cables (IP Section 02.02c.)

The inspectors evaluated cable submergence protection in:

(1) Station service water manholes MH102, MH103, and MH105 through review of 'B' and 'C' station service water pump motor cable performance testing and dewatering system preventive maintenance and monitoring on May 23, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Training/Examinations (IP Section 03.02)

(1) The inspectors observed and evaluated a crew of licensed operators in the plant's simulator during licensed operator requalification training that involved an electrical penetration assembly alarm, loss of an electrical bus, a loss of off-site power, and a loss of coolant accident on April 15, 2019

71111.12 - Maintenance Effectiveness Quality Control (IP Section 02.02)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Review of various performance issues associated with the reactor manual control system on May 23, 2019

(2) 'D' emergency diesel generator planned maintenance on June 21, 2019

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) Emergent work in response to reactor manual control system problems on April 14, 2019

(2) Emergent troubleshooting in response to 'C' reactor feed pump not adequately controlling reactor water level while in automatic level control on April 24, 2019

(3) Reactivity risk assessment in support of control rod friction testing on May 1, 2019

(4) Emergent work in response to reactor core isolation cooling containment isolation valve failure alarm on June 10, 2019

(5) Emergent work in response to high pressure coolant injection system barometric condenser pump failure on June 12, 2019

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) Reactor protection system operability in the oscillation power range monitor region on April 29, 2019

(2) 'D' emergency diesel generator operability following logic card failure on May 14, 2019

(3) Impacts on remaining cycle 22 operation and cycle 23 reload design due to prior cycle operation with a feedwater 'A' flow miss-calibration on May 16, 2019

(4) Safety relief valve operability following tailpipe temperature step charges on May 17, 2019

(5) Residual heat removal system internal leakage with respect to alternate source term limits on May 20, 2019

(6) 125 volt direct current distribution panel BD417 feeder breaker operability with trip setting non-conformance on May 31, 2019

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

The inspectors evaluated the following permanent modification:

(1) 'A' station service water traveling water screen structural support and spray wash piping on June 4, 2019

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

The inspectors evaluated the following post maintenance tests:

(1) 'D' emergency diesel generator loss of offsite power logic card replacement on May 17, 2019

(2) High pressure coolant injection steam outboard isolation valve following packing leak repairs on May 30, 2019

(3) 'A' safety and turbine auxiliaries system heat exchanger A2 outlet valve planned maintenance on June 7, 2019

(4) 'D' station service water screen planned maintenance on June 18, 2019

(5) 'A' primary containment instrument gas compressor following troubleshooting and repair on June 21, 2019

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

(1) HC.OP.IS.BC-0001, 'A' residual heat removal pump inservice and two-year comprehensive pump testing on April 5, 2019

(2) HC.OP.IS.BJ-0001, high pressure coolant injection main and booster pump inservice test on June 5, 2019

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) HC.IC-TR.AB-0003, channel A2 main steam isolation valve closure trip response time on May 10, 2019

71114.06 - Drill Evaluation Drill/Training Evolution Observation (IP Section 03.02)

The inspectors evaluated:

(1) A simulator training evolution for licensed operators that involved an electrical penetration assembly alarm, loss of an electrical bus, a loss of off-site power, and a loss of coolant accident on May 23,

OTHER ACTIVITIES - BASELINE

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

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) ===

(1) April 1, 2018 - March 31, 2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) April 1, 2018 - March 31, 2019 IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)

(1) April 1, 2018 - March 31, 2019 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

(1 Sample)

(1) April 1, 2018 - March 31, 2019 IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) April 1, 2018 - March 31, 2019 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) April 1, 2018 - March 31, 2019

71152 - Problem Identification and Resolution Annual Follow-Up of Selected Issues (IP Section 02.03)

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

(1) Molded-case circuit breaker replacement project progress, ground fault relay functionality, and breaker quality issues as documented in LTAM H-13-0084 and notifications 20704923, 20770877, and 20771839 during the week of June 10, 2019

Semiannual Trend Review (IP Section 02.02) (1 Sample)

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

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Condition 2.C(1) of the Hope Creek Operating License authorized PSEG to operate the facility at reactor core power levels not in excess of the maximum power level in accordance with Facility Operating License NPF-57.

Contrary to the above, PSEG identified that reactor core power exceeded the authorized maximum power level from July 30, 2001, to April 12, 2018. Specifically PSEG identified, during a maintenance and refueling outage in the spring of 2018, that ultrasonic feedwater flow detectors were not properly calibrated following installation in 2001 during a measurement uncertainty recapture power uprate. PSEG removed the ultrasonic flow detectors during the refueling and maintenance outage in the spring of 2018, and installed new leading edge flowmeter instrumentation.

Significance: Green. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, and Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined that the finding was of very low safety significance (Green).

Corrective Action References: 70201260, 70201814, 70203091, 70200694, 20797558, 20802467, 20802468, 20802469, 20804995, and 20804885 Observation: Molded-Case Circuit Breaker Replacement Project, Ground Fault 71152 Relay Functionality, and Breaker Quality Issues A review of the molded-case circuit breaker (MCCB) replacements indicates that PSEG has segmented the project into three phases and has prioritized MCCBs that are Class 1E and in a harsh environment (EQ-rated) to be replaced first. The project has been on-going since 2011 with steady progress, contingent on system and electrical bus work windows and resources (engineering and materials). The majority of the first phase is planned to complete by 2021. The inspectors noted material and engineering delays due to PSEG staff appropriately identifying issues with the new breakers received by the vendor. This necessitated PSEG to reconcile or correct material deficiencies in the new breakers before installing into the unit. The inspectors noted notifications were being generated when appropriate, a comprehensive repair plan by PSEG, and engineering engagement with the vendor to address quality issues. The inspector observed that there was no adverse trend notification in the corrective action program. The inspectors determined that there was no performance deficiency associated with the lack of an adverse trend notification for this issue.

A notification was created (NOTF 20828128) to address this.

The inspectors also reviewed a separate issue that was identified by PSEG regarding two failures of ground fault relays (GFRs) in 2015 (NOTF 20699440) and 2017 (NOTF 20779798), respectively. These failures occurred in motor control center (MCC) breaker cubicles that are related to Phase 2 MCCB replacements, which have not yet been replaced (the GFRs are replaced along with the MCCBs). PSEG determined the failure to be likely due to age or wear. The GFRs are visually inspected on a 6-year frequency during MCC preventive maintenance. PSEG determined that 66 GFRs in the Phase 2 MCCB project population were vulnerable. The inspectors reviewed PSEGs CAP, work orders, and plans to address the affected GFRs and determined there was inconsistent documentation regarding a bridging strategy to expedient replacement or ensure the functionality of these affected GFRs until their replacement during the MCCB project. Further discussions with engineering staff revealed that after the second GFR failure, a work group evaluation (WGE 20779798), and subsequent oversite committee review, the licensee conducted a one-time replacement of the most consequential GFRs (i.e., emergency diesel generator jacket water heater breakers) in the affected population. The inspectors determined this early replacement action to be appropriate. The inspectors reviewed the list of remaining affected GFRs and noted all to be in low or mild environments and classified as non-critical. This would support PSEG's assessment of a lower probability of failure until a planned schedule replacement, prioritizing these remaining GFRs, was implemented. PSEG created a notification to review their documented GFR functionality and bridging strategy and to re-evaluate for any proposed changes (NOTF 2082819).

Observation: Semiannual Trend Observations 71152 The inspectors evaluated a sample of condition reports generated over the course of the past two quarters, and determined that, in general, PSEG was appropriately identifying and resolving trends. Most notably, PSEG identified a negative trend associated with multiple control rod performance problems during a controlled shutdown evolution for a planned maintenance outage on March 28, 2019. The inspectors noted all the rods inserted during the reactor scram. PSEG entered the control rod problems into CAP, and performed testing of the control rods in accordance with the channel distortion testing program. As a result of the testing, three controls rods were identified with evidence of elevated friction, and were fully inserted in the reactor core, to perform thermal soaking, following startup from the maintenance outage on March 31, 2019. The control rods remained fully inserted at the end of the inspection period, except for brief periods of additional friction testing and trending. PSEG performed corrective action program evaluation 70206790 to further evaluate the control rods with evidence of elevated friction, and assign additional future corrective actions. No performance deficiencies were identified as a result of this trend review.

In addition, the inspectors identified an apparent equipment trend associated with the high pressure coolant injection (HPCI) barometric condenser pump performance. Specifically, between late December 2018 and June 2019, there were four examples where the pump failed to start on high condensate level (20828072, 20826171, 20823217, and 20816651). PSEG determined that none of the barometric condenser pump failures to start affected the HPCI system safety function, and the inspectors did not identify any deficiencies in this determination. In each example, PSEG wrote a notification, prioritized pump motor brush replacements, and performed manual actions, when needed, to manually drain the barometric condenser. However, the inspectors noted that the station did not identify an adverse trend associated with the repetitive equipment problem. The inspectors questioned PSEG as to whether there was any assigned work order to replace the pump and/or motor, or perform some other long-term action to address the repetitive failures of the pump to start on high level demand. In response, PSEG provided the inspectors with an existing work order (60130438), originally created in 2016, that incurred a scope revision in March 2019 to include a barometric condenser pump and motor replacement. At the time of inspection, the inspectors noted the work order was scheduled in the next refueling and maintenance outage. Additionally, PSEG ensured sufficient spare brushes were available in the interim, and placed the barometric condenser pump issue on the priority work list to evaluate for additional interim repair actions. The inspectors determined these action were reasonable to the circumstances. No performance deficiencies were identified as a result of this trend review.

EXIT MEETINGS AND DEBRIEFS

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

• On July 11, 2019, the inspectors presented the integrated inspection results to Mr. Ed Casulli, Site Vice President, and other members of the licensee staff.

• On June 13, 2019, the inspectors presented the Molded-Case Circuit Breaker Problem Identification and Resolution Annual Focused Sample to Mr. M. Richers, Hope Creek Engineering Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152 Corrective Action 20698578 'C' EDG Failure (N1) 08/04/2015

Documents 20699440 'C' EDG Failure (N2) 08/04/2015

20699521 'C' EDG Jacket Water Heater Breaker GFR Relay (N1) 08/11/2015

20699989 'C' EDG Jacket Water Heater Breaker GFR Relay (N2) 08/11/2015

20704923 Replace 1E MCC Cubicle With GFR Relays 10/06/2015

20730156 INPO Observation Gap - Ground Fault Strategy 05/19/2016

20779798 'D' EDG Jacket Water Keep-Warm Temperature Low 10/24/2017

Corrective Action 20828128* No Notification on Adverse Trend in MCC Quality 06/13/2019

Documents 20828129* NRC PI&R Inspection Observation of MCCBs 06/13/2019

Resulting from

Inspection

Miscellaneous DCP Bucket Repair Plan 06/11/2019

IEEE 242-1986 IEEE Recommended Practices for Protection and

Coordination of Industry and Commercial Power Systems

LTAM H-13-0084 Hope Creek MCC Remaining Bucket Replacement 08/08/2016

NEMA AB-4 Guidelines for Inspection and Preventive Maintenance of 2009

Molded Case Circuit Breakers Used in Commercial and

Industrial Applications

NRC Information Periodic Testing and Preventive Maintenance of Molded 08/12/1993

Notice 93-64 Case Circuit Breakers

PCR 80116806- MCC Breaker PM Program Change 04/28/2016

Westinghouse Replacement Solutions for Obsolete Molded Case Circuit 06/28/2004

Technical Bulletin Breakers, UL Testing Issues, Breaker Design Life, and Trip

TB-04-13 Band Adjustment

Westinghouse Aging Issues and Subsequent Operating Issues for Molded 05/13/2014

Technical Bulletin Case Circuit Breakers That Have Reached 20-Year

TB-14-2 Design/Qualified Lives; UL Certification/Testing Issues

Update

71152 Procedures HC.MD-CM.PH- 480 Volt MCC Starter Maintenance Revision 10

0001(Q)

HC.MD-PM.PH- 480 Volt MCC Starter Preventive Maintenance Revision 30

0001(Q)

LS-AA-120 Issue Identification and Screening Process Revision 18

LS-AA-125 Corrective Action Program Revision 25

LS-AA-125-1001 Cause Analysis Revision 17

MA-AA-716-210- PM Program for Motor Control Center Breakers Revision 7

1005

SM-AA-4003- Guidance for PSEG Nuclear Parts Quality Program Revision 3

1000

Work Orders 60137312 10YY-52-411021-GFR1: Replace GFR A-JWKW 02/03/2019

60137313 Replace 10YY-52-421021-GFR1: B-JWKW 02/15/2019

70179133 'C' EDG Failure 06/14/2017

70179342 'C' EDG Jacket Water Heater Breaker GFP Relay 02/16/2016

70180724 Replace 1E MCC Cubicles with GFR Relays 10/13/2017

70186969 INPO Observation Gap - Ground Fault Strategy 06/19/2018

11