IR 05000220/2019004

Integrated Inspection Report 05000220/2019004 and 05000410/2019004

ML20037B205
Person / Time
Site:	Nine Mile Point
Issue date:	02/05/2020
From:	Erin Carfang Reactor Projects Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019004
Download: ML20037B205 (24)

Text

ary 5, 2020

SUBJECT:

NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2019004 AND 05000410/2019004

Dear Mr. Hanson:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station. On January 24, 2020, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Nine Mile Point Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at Nine Mile Point Nuclear Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Nos. 05000220 and 05000410 License Nos. DPR-63 and NPF-69

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2019004 and 05000410/2019004 Enterprise Identifier: I-2019-004-0035 Licensee: Exelon Generation Company, LLC Facility: Nine Mile Point Nuclear Station Location: Oswego, NY Inspection Dates: October 01, 2019 to December 31, 2019 Inspectors: G. Stock, Senior Resident Inspector J. Dolecki, Resident Inspector B. Sienel, Resident Inspector T. Fish, Senior Operations Engineer T. Hedigan, Operations Engineer Approved By: Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

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

List of Findings and Violations Failure to Follow Procedure Resulted in Unplanned Reactor Core Isolation Cooling System Isolation and Unavailability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems NCV 05000410/2019004-01 Complacency Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified at Unit 2 when Exelon maintenance personnel failed to follow a reactor water cleanup area temperature instrument calibration procedure. Specifically, an incorrectly performed procedure step to lift a thermocouple lead, on September 24, 2019, caused a partial isolation of the reactor core isolation cooling (RCIC) system, rendering the system inoperable and unavailable.

Additional Tracking Items None.

PLANT STATUS

Unit 1 began the inspection period at 100 percent power. On October 12, 2019, operators performed a planned power reduction to approximately 70 percent to remove reactor recirculation pump 12 from service for preventive maintenance. On October 13, 2019, Unit 1 was restored to 100 percent. On October 18, 2019, operators performed a planned power reduction to approximately 85 percent to place reactor recirculation pump 12 in service. Later that day, Unit 1 was restored to 100 percent. On November 15, 2019, operators performed an emergent power reduction to approximately 50 percent to clean 11 and 12 main condenser waterboxes due to macro-fouling, to restore reactor recirculation pump 12 to service, and to remove reactor recirculation pump 11 from service for preventive maintenance. On November 17, 2019, Unit 1 was restored to 100 percent power. On November 21, 2019, operators performed a planned power reduction to approximately 85 percent to restore reactor recirculation pump 11 to service. On November 22, 2019, Unit 1 was restored to 100 percent power. Unit 1 remained at or near 100 percent power for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent power. On October 4, 2019, operators performed an emergent power reduction to approximately 82 percent to perform maintenance on the 'C' heater drain pump. On October 11, 2019, Unit 2 was restored to 100 percent power. On October 23, 2019, operators performed an emergent power reduction to approximately 40 percent to de-inert primary containment for drywell entry to identify and repair the source of elevated unidentified leakage. Following repairs to the reactor closed loop cooling piping, during power ascension on October 25, 2019, operators performed an emergent power reduction to 85 percent to repair an electro-hydraulic control system leak. On October 27, 2019, Unit 2 was restored to 100 percent power. On November 15, 2019, operators performed an emergent power reduction to approximately 65 percent to remove the 'B' feedwater pump from service due to elevated outboard seal leakage and to place the 'C' feedwater pump in service. On November 15, 2019, Unit 2 was restored to 100 percent power. On December 23, 2019, operators performed an emergent power reduction to approximately 88 percent due to a hydraulic control issue on the 'A' recirculation loop flow control valve. Unit 2 was restored to 100 percent power on December 23, 2019. Unit 2 remained at or near 100 percent 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.

71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.02)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 20, 2019

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 2 Division I emergency diesel generator on October 28, 2019

(2) Unit 2 high pressure core spray system on November 20, 2019

(3) Unit 2 Division II emergency diesel generator on December 9, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) Unit 2 residual heat removal system on November 15, 2019

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

(1) The inspectors evaluated fire brigade performance during a fire drill in the Unit 2 control building east cable chase on November 19, 2019

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

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

(1) Unit 2 south electrical tunnel 214' elevation, fire area 18, on October 14, 2019

(2) Unit 2 'A' service water pump area, fire area 60, on November 12, 2019

(3) Unit 2 service water intake and discharge area, fire area 71, on November 19, 2019

(4) Unit 2 'B' service water pump area, fire area 61, on November 19, 2019

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

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 2 south electrical tunnel on October 10, 2019

(2) Unit 1 turbine building 250' elevation on October 29, 2019

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 Unit 2 licensed operator requalification examinations (operating test and written exam) was conducted by an NRC region-based inspector on December 16, 2019

(2) An in-office inspection of Pass/Fail results for Unit 1 licensed operator requalification examinations (operating test only) was conducted by an NRC region-based inspector on December 16, 2019

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 Unit 2 licensed operator biennial requalification written examinations.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the Unit 2 licensed annual requalification operating tests.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of Exelon in administering requalification operating tests required by 10 CFR 55.59(a)(2) and evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of Exelon 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 Exelon, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

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

Control Room Simulator The inspectors evaluated the adequacy of Exelon's 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 Exelon's 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) The inspectors observed and evaluated Unit 1 operations personnel performance during a planned power reduction, control rod pattern adjustment, and control rod scram time testing on October 13, 2019

(2) The inspectors observed and evaluated Unit 2 operations personnel performance during a planned downpower to 40 percent for subsequent drywell entry to correct the cause of increasing unidentified drywell leakage on October 23, 2019 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated a Unit 1 simulator evaluation which included the failure of a reactor protection system motor-generator set, a seismic event, a low power failure to scram, a failure of turbine bypass valves to open, and a failure of an automatic isolation function leading to elevated reactor building temperature on October 24, 2019

(2) The inspectors observed and evaluated a Unit 2 simulator exam which included an electrical fault on the Division III switchgear, a control rod drift, an inadvertent reactor core isolation cooling system initiation, and an unisolable coolant leak in the reactor building on November 19, 2019

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 2 stator water cooling system on October 1, 2019

(2) Unit 2 area radiation monitoring system on November 13, 2019

(3) Unit 1 main steam pressure regulation on December 17, 2019

Quality Control (IP Section 02.02) (1 Sample)

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

(1) Unit 1 commercial grade dedication of globe valves installed in the emergency diesel generator 102 cooling water system on September 25, 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) Unit 1 elevated risk during the removal of recirculation motor generator 12 from service for planned maintenance on October 12, 2019

(2) Unit 2 emergent work to identify and repair a primary component cooling leak inside the drywell on October 24, 2019

(3) Unit 2 elevated risk during an emergent downpower to 85 percent to repair an electro-hydraulic control system leak on piping to main turbine stop valve 1, 2MSS-MSV1C, on October 25, 2019

(4) Unit 1 emergent work associated with emergency condenser 12 loop following failure of the analog trip system and emergency condenser steam supply isolation valve, IV-39-08R, on October 30, 2019

(5) Unit 2 emergent work associated with a high pressure core spray master trip unit power supply failure on November 1, 2019

(6) Unit 1 emergent downpower to 75 percent due to service water fouling on November 1, 2019

(7) Unit 2 elevated risk during reactor core isolation cooling steam trap valve replacement on November 5, 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) Unit 2 service water emergency makeup to spent fuel pool isolation valve, 2SWP*MOV21B, failure to close during surveillance on September 9, 2019

(2) Unit 1 containment spray raw water pump 112 discharge check valve, CKV-93-59, failure to close on October 20, 2019

(3) Unit 1 emergency diesel generator 103 fuel oil tank with intermittent signs of water on October 22, 2019

(4) Unit 2 reactor protection system instrumentation following the identification of a missed channel functional test on October 22, 2019

(5) Unit 1 mechanical pressure regulator required set point adjustments during testing on October 28, 2019

(6) Unit 1 emergency condenser steam supply isolation valve, IV-39-08R, following failure to close on October 29, 2019

(7) Unit 2 reactor core isolation cooling room area cooler, 2HVR*UC412B, exceeded preventive maintenance replacement frequency on November 26, 2019

(8) Unit 2 reactor core isolation cooling steam discharge pressure below operator rounds guidelines on November 27, 2019

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) Temporary Modification: ECP-19-000641, Unit 1 Plugging of SOV-39-05F Due to Air Leakage

(2) Permanent Modification: N1-STI-016, Surveillance Frequency Change for 125VDC Battery Cell Surveillances

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

The inspectors evaluated the following post maintenance tests:

(1) Unit 2 main turbine stop valve, 2MSS-MSV1C, electro-hydraulic control piping leak repair on October 25, 2019

(2) Unit 1 containment spray 112 heat exchanger preventive maintenance on October 25, 2019

(3) Unit 1 emergency condenser steam supply isolation valve, IV-39-08R, repair on October 30, 2019

(4) Unit 1 emergency condenser block valve, BV-05-05, preventive maintenance on November 1, 2019

(5) Unit 2 high pressure core spray power supply replacement on November 1, 2019

(6) Unit 2 reactor core isolation cooling steam trap and valve maintenance on November 15, 2019

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

(1) N2-ESP-ENS-Q731, Quarterly Channel Functional Test of LPCS/LPCI Pumps A, B, and C (Normal and Emergency Power) Auto Start Time Delay Relays, on December 5, 2019

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) N2-CTP-GEN-W104, Miscellaneous Reactor Building Chemistry Surveillance, on October 11,

OTHER ACTIVITIES - BASELINE

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

MS08: Heat Removal Systems (IP Section 02.07) ===

(1) Unit 1 - July 1, 2018 through September 30, 2019

(2) Unit 2 - July 1, 2018 through September 30, 2019 MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 - July 1, 2018 through September 30, 2019

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

(1) Unit 1 - July 1, 2018 through September 30, 2019

(2) Unit 2 - July 1, 2018 through September 30, 2019

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

(1) The inspectors evaluated a sample of issues and events that occurred over the course of the third and fourth quarters of 2019 to determine whether issues were appropriately considered as emerging or adverse trends.

Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)

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

(1) Issue Report (IR) 04281645, Unit 2 Corrective Action Associated With Inadvertent Reactor Core Isolation Cooling Isolation Valve Closure

(2) IR 04159207, Corrective Action Associated With Extent of Condition for Inadequate Maintenance Rule Evaluation

(3) IR 04156797, Declining Trend Associated with Foreign Material Exclusion

71153 - Followup of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated Unit 1 normal service water fouling resulting in an emergent downpower to 75 percent on November 1,

INSPECTION RESULTS

Failure to Follow Procedure Resulted in Unplanned Reactor Core Isolation Cooling System Isolation and Unavailability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems NCV 05000410/2019004-01 Complacency Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified at Unit 2 when Exelon maintenance personnel failed to follow a reactor water cleanup area temperature instrument calibration procedure. Specifically, an incorrectly performed procedure step to lift a thermocouple lead, on September 24, 2019, caused a partial isolation of the reactor core isolation cooling (RCIC)system, rendering the system inoperable and unavailable.

Description:

The RCIC system operates following a reactor pressure vessel isolation concurrent with a loss of feedwater flow. It is designed to ensure that sufficient reactor water inventory is maintained to permit adequate core cooling.

On September 24, 2019, Exelon maintenance personnel lifted an incorrect lead during the performance of continuous use procedure N2-ISP-LDS-R104, Reactor Water Cleanup Equipment Area Temperature Instrument Channel Calibration. When this lead was lifted, the RCIC outboard turbine steam supply isolation valve and the turbine trip throttle valve closed, resulting in a partial isolation of the system. Operators declared the RCIC system inoperable and unavailable, thereby elevating plant risk to Yellow, and entered 14-day technical specification limiting condition for operation action statement 3.5.3.a, RCIC System.

Exelons corrective action program evaluation determined that a failure to implement basic human performance tools caused the partial RCIC system isolation. Proper verification, flagging, and procedure use and adherence practices were not performed to ensure the correct lead was lifted. A contributing cause of the event was inadequate supervisory oversight. The technicians had been on the night shift for an extended period with no supervisory oversight to ensure proper use of human performance tools.

Corrective Actions: Exelon returned the RCIC steam isolation valves to their normal positions, restoring system operability and availability approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after it was rendered inoperable and unavailable. Other corrective actions included a site human performance stand-down that communicated lessons learned and reinforced the use of human performance tools, suspension of the involved technicians qualifications pending remediation, and a review of the technician observation program to ensure that periodic supervisory observations are performed.

Corrective Action References: IR 04281645

Performance Assessment:

Performance Deficiency: The failure to properly perform procedure N2-ISP-LDS-R104 Step 7.2.2 to lift field thermocouple lead 16 was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to follow procedure, N2-ISP-LDS-R104, on September 24, 2019, resulted in unplanned RCIC inoperability and unavailability.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined this finding was of very low safety significance (Green) because it did not result in a loss of safety function or RCIC inoperability for greater than its technical specification allowed outage time.

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. The technicians involved with the work did not implement appropriate error reduction tools. Specifically, verification practices were not appropriately implemented to ensure that the correct lead was lifted.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, Activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures ... Exelon established procedure N2-ISP-LDS-R104, Reactor Water Cleanup Equipment Area Temperature Instrument Channel Calibration, Revision 006T1, as the implementing procedure for performing technical specification-required surveillances on reactor water cleanup area temperature instrumentation. Procedure N2-ISP-LDS-R104, Step 7.2.2, stated, At TB-1, LIFT the following field thermocouple lead: 16, Blue (+).

Contrary to the above, on September 24, 2019, Exelon personnel failed to lift TB-1 lead 16, as instructed in Step 7.2.2, and instead lifted TB-1 lead 1. This error resulted in the unintended closure of two RCIC system isolation valves and approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of unplanned RCIC inoperability and unavailability.

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

Observation: Extent of Condition for Inadequate Maintenance Rule Evaluation 71152 The inspectors reviewed Exelons response to a July 2018 NRC question regarding the adequacy of a maintenance rule functional failure determination for the Unit 2 standby gas treatment system, as documented in IR 04159207.

Exelon reviewed the original issue and determined the failure should have been screened as a maintenance rule functional failure. The failure was then appropriately re-evaluated in accordance with the maintenance rule. Exelon performed a work group evaluation for the issue and determined that the incorrect screening occurred because the responsible engineer failed to recognize that failures for the affected, high safety significant, function should be monitored at the train level. Instead, the failure was evaluated at the system level. The clarity of the maintenance rule basis document was determined to be a contributing cause of the error.

Corrective actions included an extent of condition review of all other maintenance rule screenings performed by the involved engineer over the previous year. No other issues were identified. In addition, maintenance rule training was provided, subsequent to the original determination, which stressed the fact that high safety significant functions are monitored at the train, not system, level.

The inspectors reviewed the revised standby gas maintenance rule basis document, portions of training given to system engineers, and selected maintenance rule failure evaluations performed by the system engineer and did not identify any further issues.

The inspectors determined Exelons response to the issue was thorough, timely, and included appropriate corrective actions. The inspectors independently evaluated the deficiency noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening and Appendix E, Examples of Minor Issues. The inspectors determined this issue was of minor significance and is therefore not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Potential Trend Associated with Unit 2 Foreign Material Exclusion 71152 The inspectors reviewed Exelons evaluation and corrective actions associated with a potential adverse trend observed in foreign material exclusion (FME) prior to and through the March 2018 Unit 2 refueling outage, as documented in IR 04156797.

Exelons work group evaluation determined there was not a significant adverse trend based on the issues identified. However, Exelon concluded the most probable cause for the declining trend in FME performance was a lack of proficient and intrusive oversight of the program during the outage.

Corrective actions included completion of a focused self-assessment of the FME program by a team of industry FME experts, designation of a trained backup FME coordinator, and performance of enhanced FME-focused field observations.

The inspectors reviewed the evaluation, self-assessment, related procedures, and relevant IRs and interviewed the current and previous FME coordinators. Based on the documents reviewed and discussions with personnel, the inspectors determined Exelons evaluation of the issue was adequate and included appropriate corrective actions.

The inspectors determined Exelons response to the issue was thorough, timely, and included appropriate corrective actions. The inspectors independently evaluated the issue noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening and Appendix E, Examples of Minor Issues. The inspectors determined this issue was of minor significance and is therefore not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Semi-Annual Trend Review 71152 The inspectors evaluated a sample of issues and events that occurred from July to December 2019 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified that these issues were appropriately evaluated by Exelon staff for potential trends and addressed within the scope of the corrective actions program and through department review.

During the trend review, inspectors identified 13 IRs associated with issues requiring immediate operability determinations or functionality assessments where the evaluations were not completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of IR initiation as required by Exelon procedure, OP-AA-108-115, Operability Determinations. The failure to complete required operability determinations in the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> established in OP-AA-108-115 is a performance deficiency. However, in the IRs identified during the review, the late evaluations did not delay the timely declaration of inoperability of the applicable technical specification systems or components. Exelon acknowledged the issue and entered it into the corrective action program as IR 04305465, and reviewed the relevant IRs. Corrective actions include adding an item to senior reactor operator cycle training to reinforce the requirements of OP-AA-108-115 and management's expectations for the timeliness of evaluations.

Exelon documented a number of trends over the inspection time frame. Exelon documented a rising trend in the number of corrective action products being returned from the management review committee (MRC) in IR 04274444. The MRC is the final approval step for evaluations in Exelon's corrective action process. With an increasing number of corrective action products being returned following MRC review, the likelihood of inadequate evaluations being approved rises. Exelon has taken a number of actions to resolve the issue and implemented appropriate corrective actions to improve corrective action program product quality. The inspectors noted these corrective actions were adequate and commensurate with the safety significance of the issue. In the IRs reviewed, the inspectors did not identify any approved corrective action products that should have been returned.

The inspectors independently evaluated these deficiencies for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that these conditions were deficiencies of minor significance and, therefore, are not subject to enforcement action in accordance with the NRC's Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

• On January 24, 2020, the inspectors presented the integrated inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 04287025

Documents 04304681

Work Orders C93124993

C93669076

C93669077

C93717057

71111.04Q Corrective Action 04284375

Documents 04291960

Drawings PID 033-A Piping and Instrumentation Diagram High Pressure Core 19

Spray System

PID 033-B Piping and Instrumentation Diagram High Pressure Core 15

Spray System

PID 104E Piping and Instrumentation Diagram Lube Oil Standby Diesel 8

Generator System

PID-104A Piping and Instrumentation Diagram Standby Diesel 31

Generator System

PID-104C Piping and Instrumentation Diagram Standby Diesel 9

Generator System

PID-104D Piping and Instrumentation Diagram Jacket Water Standby 7

Diesel Generator System

PID-104F Piping and Instrumentation Diagram Fuel Oil Standby Diesel 5

Generator System

Procedures N2-OP-100A Standby Diesel Generators 02800

N2-OP-33 High Pressure Core Spray System 01700

N2-OP-33- High Pressure Core Spray System - LINEUPS 00100

LINEUPS

Work Orders C93724712

71111.04S Corrective Action 04299507

Documents

Resulting from

Inspection

Drawings PID-31A Piping and Instrumentation Diagram Residual Heat Removal 26

Inspection Type Designation Description or Title Revision or

Procedure Date

System

PID-31B Piping and Instrumentation Diagram Residual Heat Removal 23

System

PID-31C Piping and Instrumentation Diagram Residual Heat Removal 16

System

PID-31D Piping and Instrumentation Diagram Residual Heat Removal 21

System

PID-31E Piping and Instrumentation Diagram Residual Heat Removal 21

System

PID-31F Piping and Instrumentation Diagram Residual Heat Removal 16

System

PID-31G Piping and Instrumentation Diagram Residual Heat Removal 15

System

Procedures N2-ISP-RHS- Quarterly Functional Test of the RHS Pump Discharge Flow 00900

Q022 Instrument Channels

N2-OP-31 Residual Heat Removal System 03600

Work Orders C93681775

C93682516

71111.05A Miscellaneous Nine Mile Point Fire Drill Scenario in Unit 2 Control Building November

288' East Cable Chase 19, 2019

Procedures OP-AA-201-003 Fire Drill Performance 17

71111.05Q Corrective Action 04289692

Documents

Resulting from

Inspection

Drawings EB-022A Fire Protection Arrangement Unit 2 Station Buildings Plan El. 15

175'-0", 196'-0" and 198'-0"

EB-022AB Fire Protection Arrangement Unit 2 Station Buildings Plan El. 3

214'-0" and 215'-0"

Fire Plans N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans 05

71111.06 Corrective Action 04087085

Documents CR-2011-003454

Drawings C-18496-C Reactor Building Floor Drainage Piping Plan at Elev. 340'-0" 7

C-18510-C Turbine Building Auxiliary Equipment Area Floor & 17

Inspection Type Designation Description or Title Revision or

Procedure Date

Equipment Drain Piping Plan at Elev. 243'-0" and 250'-0"

C-26650-C Turbine Building Common Mode Failure Barrier Walls 0

EB-406B Air & Water Tightness Design Requirements Plan El 214'-0" 5

& 215'-0"

EE-37AJ Plans, Sections and Details Electrical Sleeves Reactor 9

Building and Auxiliary Bays

Procedures N2-FSP-FPP- Fire Rated Assemblies and Watertight Penetration Visual 00500

R001 Inspection

Work Orders C93469624

C93650682

71111.11Q Procedures N1-OP-43B Normal Power Operations 02500

N1-ST-R1 Control Rod Scram Insertion Time Test 02600

Work Orders C93675993

71111.12 Corrective Action 04218955

Documents 04225619

232520

233592

234833

244521

254658

281527

293628

293890

295264

295996

297932

Drawings C-18026-C, Emergency Diesel Generator #102 Starting Air, Cooling 28

Sheet 1 Water, Lube Oil & Fuel

Miscellaneous Procurement Test & Inspection Report 02-0122

Purchase Order 02-38357

Procurement Requirements Evaluation Form 2204

NMP-2-2019- Operational Decision Making - Stator Water Follow 0

257 Degrading Flow

Inspection Type Designation Description or Title Revision or

Procedure Date

SDBD-804 Emergency Diesel Generator System Design Basis 11

Document

Procedures ER-AA-320 Maintenance Rule Implementation per NEI 18-10 00

MA-AA-716-008 Foreign Material Exclusion Program 14

N1-IPM-302-001 Electronic Pressure Regulator (EPR) 02000

N1-PM-Q7 Quarterly Main Turbine Testing and Generator Core Monitor 00500

Testing

N2-OP-26 Generator Stator and Exciter Rectifier Cooling System 01300

Work Orders C93654284

C93703755

C93704042

C93723903

71111.13 Corrective Action 04247964

Documents 04290993

291138

292465

292467

293482

293643

293916

293934

293947

294223

Drawings PID-23B Piping and Instrumentation Diagram Turbine Hydraulic Oil 10

System

PID-35C Piping and Instrumentation Diagram Reactor Core Isolation 29

Cooling

Procedures N1-OP-1 Nuclear Steam Supply System (NSSS) 075T1

N1-OP-64 Meteorological Monitoring 01900

N1-SOP-1.1 Emergency Power Reduction 00600

N1-SOP-18.1 Service Water Failure/Low Intake Level 00600

N2-OP-23A Hydraulic Isolation and Restoration of Turbine Stop or 00000

Turbine Control or Combined Intercept Valves or Bypass

Inspection Type Designation Description or Title Revision or

Procedure Date

Valves

N2-OP-33 High Pressure Core Spray System 01700

N2-OP-35 Reactor Core Isolation Cooling 01500

Work Orders C93635522

C93667389

C93708670

C93727149

71111.15 Corrective Action 02535772

Documents 03993689

276238

277608

285351

289904

290602

292465

292868

298756

298811

04301820

Corrective Action 04298898

Documents

Resulting from

Inspection

Engineering ECP-19-000628 RCIC Room Area Cooler Replacement Delayed Due to 0000

Changes Scheduling Error

Miscellaneous PCR-19-04859

Procedures N1-OP-45 Emergency Diesel Generators 04900

N1-PM-Q7 Quarterly Main Turbine Testing and Generator Core Monitor 00500

Testing

N1-SOP-31.2 Pressure Regulator Malfunction 00600

N2-ISP-NMS- LPRM/APRM Channel 1 Calibration 022T1

R001

Inspection Type Designation Description or Title Revision or

Procedure Date

N2-ISP-NMS- LPRM/APRM Channel 2 Calibration 021T1

R002

N2-ISP-NMS- LPRM/APRM Channel 3 Calibration 022T2

R003

N2-ISP-NMS- LPRM/APRM Channel 4 Calibration 024T2

R004

N2-ISP-NMS- 2-out-of-4 Logic Module Channel Functional Test 00600

SA002

N2-STI-018 Risk Evaluation of Surveillance Interval Extension for 0

LPRM/APRM Logic Module Channel Functional Test

N2-SURV-004 Missed Surveillance Risk Assessment for N2-ISP-NMS- 0

SA002

S-EPM-GEN-067 Limitorque MOV Actuator P.M. 00900

Work Orders C91449250

C93149512

C93616240

C93617215

C93656433

C93705843

C93722343

71111.18 Engineering ECP-19-000641 Air is Porting From SOV-39-05F and Requires SOV Plugging 0000

Changes With Unit On-Line

Miscellaneous N1-STI-016 Surveillance Test Interval Evaluation Form for 125VDC 00

Battery Cell Surveillances

N1-STI-031 Risk Evaluation of Surveillance Interval Extension for the 0

25 VDC Battery Test

Procedures ER-AA-425 Implementation of the Technical Specification Surveillance 2

Frequency Control Program

ER-AA-425-1001 Surveillance Test Interval Evaluation Form 1

71111.19 Corrective Action 04292467

Documents

Miscellaneous PCR-19-03669

Procedures ER-AA-340-1002 HX Inspection Report 8

GAP-HSC-02 System Aging Inspection and Cleaning Controls 02000

Inspection Type Designation Description or Title Revision or

Procedure Date

N1-MPM-080-410 Containment Spray Heat Exchangers PM (HTX-80-13, HTX- 01200

80-14, HTX-80-33, HTX-80-34)

N1-ST-Q4 Reactor Coolant System Isolation Valves Operability Test 02700

N2-OP-23A Hydraulic Isolation and Restoration of Turbine Stop or 00000

Turbine Control or Combined Intercept Valves or Bypass

Valves

N2-OSP-ICS- RCIC Gas Accumulation Monitoring and Valve Lineup 01200

M001 Verification

N2-OSP-ICS- RCIC Pump and Valve Operability Test and System Integrity 01500

Q@002 Test and ASME XI Functional Test

and Analysis

S-EPM-GEN-067 Limitorque MOV Actuator P.M. 00800

Work Orders C93656433

C93667389

C93703618

C93727149

C93727983

71111.22 Procedures ER-AB-331-1006 BWR Reactor Coolant System Leakage Monitoring and 2

Action Plan

N2-CSP-CMS- Primary Containment Sampling 00201

@344

N2-CTP-GEN- Miscellaneous Reactor Building Chemistry Surveillance 00401

W104

N2-ESP-ENS- Quarterly Channel Functional Test of LPCS/LPCI Pumps A, 00800

Q731 B, and C (Normal and Emergency Power) Auto Start Time

Delay Relays

71151 Corrective Action 04281645

Documents

Miscellaneous NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

Procedures LS-AA-2200 Mitigating System Performance Index Data Acquisition and 6

Reporting

N1-MSPI-001 Nine Mile Point Unit 1 MSPI Basis Document 11

N1-OP-13 Emergency Cooling System 04300

N2-MSPI-001 Nine Mile Point Unit 2 MSPI Basis Document 15

Inspection Type Designation Description or Title Revision or

Procedure Date

71152 Corrective Action 04061195

Documents 04133018

04133018

04156797

04159207

04162477

265913

266278

280067

285351

290736

291216

291360

292027

292465

292467

293524

295757

297146

297736

04303785

272272

281645

Corrective Action 04305465

Documents

Resulting from

Inspection

Procedures MA-AA-716-008- Definitions and Measurements of FME Events 6

1000

N2-ISP-LDS- Reactor Water Cleanup Equipment Area Temperature 006T1

R104 Instrument Channel Calibration

21