IR 05000220/2022002
| ML22217A023 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, 07201036  |
| Issue date: | 08/08/2022 |
| From: | Erin Carfang NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022001 | |
| Download: ML22217A023 (27) | |
Text
August 8, 2022
SUBJECT:
NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2022002 AND 05000410/2022002 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07201036/2022001
Dear David Rhoades:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station. On July 21, 2022, the NRC inspectors discussed the results of this inspection with Peter Orphanos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements one was determined to be Severity Level IV. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 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 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, Digitally signed by Erin E.
Erin E. Carfang Date: 2022.08.08 Carfang 07:24:58 -04'00'
Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000220, 05000410, and 07201036 License Nos. DPR-63 and NPF-69
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000220, 05000410, and 07201036 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2022002, 05000410/2022002, and 07201036/2022001 Enterprise Identifier: I-2022-002-0036 I-2022-001-0103 Licensee: Constellation Energy Generation, LLC Facility: Nine Mile Point Nuclear Station Location: Oswego, NY Inspection Dates: April 1, 2022 to June 30, 2022 Inspectors: G. Stock, Senior Resident Inspector C. Kline, Resident Inspector B. Sienel, Resident Inspector S. Haney, Senior Project Engineer K. Mangan, Senior Reactor Inspector O. Masnyk Bailey, Health Physicist M. McLaughlin, Senior Enforcement Specialist N. Mentzer, Reactor Inspector S. Wilson, Senior Health Physicist Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety 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 Obtain Prior NRC Approval for a Change Which Increased Unit 1 Allowable Containment Bypass Leakage and the Consequences of a Loss of Coolant Accident Cornerstone Significance/Severity Cross-Cutting Report Aspect Section Barrier Integrity Green None (NPP) 71111.17T Severity Level IV NCV 05000220/2022002-01 Open/Closed The inspectors identified a Green finding and associated Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.59(c)(2)(iii), Changes,
Tests, and Experiments, when Constellation did not obtain a license amendment prior to implementing a proposed change even though the change resulted in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated). Specifically, Constellation staff changed the allowed leakage from the main steam isolation valves (MSIVs) which resulted in greater than a 10 percent increase to the calculated control room dose following a postulated accident in the Nine Mile Point Unit 1 Updated Final Safety Analysis Report (UFSAR).
Failure to Implement Adequate Procedure for Feedwater Control Valve Results in Unit 2 Scram Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.1] - 71153 NCV 05000410/2022002-02 Resources Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a was identified for Constellations failure to maintain properly sequenced steps in the stations procedure for feedwater failures. As a result, when implementing N2-SOP-06, "Feedwater Failures," the B feedwater level control valve unexpectedly closed during restoration from a maintenance activity and caused a subsequent automatic reactor scram on low water level.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On April 13, 2022, the unit was downpowered to 82 percent to remove the 15 recirculation motor generator set from service for planned maintenance and returned to rated thermal power the same day. On April 15, 2022, the unit was downpowered to 70 percent for the return of the 15 recirculation motor generator set, control rod scram time testing, turbine valve testing and a control rod pattern adjustment. The unit was returned to rated thermal power on April 16, 2022. On April 17, 2022, the unit was downpowered to 82 percent for a control rod pattern adjustment and returned to rated thermal power the same day. The unit remained at or near rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. On April 1, 2022, the unit was downpowered to 75 percent for a control rod pattern adjustment and was returned to rated thermal power on the same day. On April 5, 2022, the unit experienced an automatic reactor scram on low reactor water level while restoring from maintenance on the feedwater level control system. Startup was commenced on April 9, 2022, and rated thermal power was reached April 10, 2022. On April 10, 2022, the unit was downpowered to 80 percent for a control rod pattern adjustment and returned to rated thermal power the same day. On April 11, 2022, the unit was downpowered to 80 percent for a control rod pattern adjustment and returned to rated thermal power the same day. On May 26, 2022, the unit was downpowered to 80 percent for a control rod pattern adjustment and returned to rated thermal power the same day. The unit remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the Unit 1 instrument air 11 and 12 compressors and the Unit 2 Division I and II control building chillers.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with Constellation's design requirements and risk analysis assumptions for coping with external flooding.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2 'B' residual heat removal system on April 14, 2022
- (2) Unit 2 Division I service water system on May 2, 2022
- (3) Unit 2 Division II service water on June 27, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) Unit 1 emergency cooling system 12
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Unit 2 reactor building 261, fire areas 34 and 35, on April 13, 2022
- (2) Unit 2 reactor building 175, 'B' residual heat removal pump and heat exchanger room, fire area 3, on April 14, 2022
- (3) Unit 1 turbine building 261', diesel generator 103, fire area DG261-04, on June 13, 2022
- (4) Unit 1 turbine building 291 north, fire area TB291-01, on June 15, 2022
- (5) Unit 2 radwaste building 279', fire area 58, on June 22, 2022
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on June 7, 2022.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the:
- (1) Unit 2 reactor building 175' on June 16, 2022
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) Unit 2 'B' residual heat removal heat exchanger room unit cooler 2HVR*UC406
71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger performance on the following:
- (1) Unit 1 emergency diesel generator 102 raw water heat exchanger
- (2) Unit 1 containment spray raw water heat exchanger 111
Heat Exchanger (Closed Loop) (IP Section 03.03) (1 Sample)
The inspectors evaluated heat exchanger performance on the following:
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
The inspectors evaluated the ultimate heat sink performance on the following:
- (1) Unit 2 ultimate heat sink, Sections 03.04.c, 03.04.d, and 03.04.e
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
- (1) The inspectors observed Unit 2 operations personnel during the reactor startup from a forced maintenance outage on April 8, 2022.
- (2) The inspectors observed Unit 1 operations personnel during the planned downpower to approximately 82 percent to remove recirculation motor generator set 15 from service for planned maintenance on April 13, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
- (1) The inspectors observed a Unit 1 simulator evaluation that included a seismic event with electronic pressure regulator oscillations, a loss of a non-vital powerboard, a loss of coolant accident inside containment, and a failure to scram on June 7, 2022.
- (2) The inspectors observed a Unit 2 simulator evaluation that included a loss of a reactor protection system bus, an inadvertent high pressure core spray initiation, a loss of extraction steam leading to a loss of feedwater heating, and a small break loss of coolant accident requiring reactor pressure vessel blowdown on June 14, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Unit 2 control room ventilation
- (2) Unit 1 reactor building structural monitoring
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2 elevated risk during planned 'A' residual heat removal heat exchanger service water valve maintenance on April 19, 2022
- (2) Unit 2 elevated risk during a planned Line 5 alignment to the alternate supply on May 16, 2022
- (3) Unit 2 elevated risk during planned restoration of Line 5 normal supply on May 24, 2022
- (4) Unit 1 elevated risk during emergent work on 103 diesel motor-driven fuel oil pump on June 15, 2022
- (5) Unit 1 elevated risk during planned 10-year preventive maintenance on battery charger SBC-161B on June 28, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 2 reactor protection system instrumentation following failed main steam isolation valve relay testing on April 6, 2022
- (2) Unit 2 service water pump 2SWP*P1F breaker unexpectedly opened during surveillance testing on April 18, 2022
- (3) Unit 1 service water pump 11 following identification of water in oil reservoir on May 11, 2022
- (4) Unit 2 diesel fire pump following identification of increased fuel dilution on May 19, 2022
- (5) Unit 1 emergency diesel generator 103 following ground identified on 12 station battery on June 13, 2022
- (6) Unit 2 Division III diesel generator following minor jacket water leak on June 29, 2022
71111.17T - Evaluations of 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 from May 16 through 20, 2022.
- (1) Evaluation 2020-01, Reactor Recirculation Cavitation Protection Interlock Design Function, Revision 0
- (2) Evaluation 2020-02, PCTCC- Bypass Unit 2 SFC Pump Trips, Revision 0
- (3) Evaluation 2022-01, DEHC Low Pass Filter Modification, Revision 0
- (4) Evaluation 2019-02, NMP2 Feedwater Digital Controls Upgrade, Revision 0
- (5) Evaluation 2021-01, NMP2 Increased Core Average Exposure (CAVEX), Revision 0
- (6) Evaluation 2019-03, NMP2 MSIV Internals Upgrade, Revision 0
- (8) Evaluation 2021-03, Data Validation and Reconciliation to Increase Core Thermal Power Accuracy at NMP1, Revision 0
- (9) 5059-2019-125, Install Breakers in Alternate Feed Cubicles for Switchgears 2ENS*SWG101, 2ENS*SWG102 and 2ENS*SWG103, Revision 0
- (10) 5059-2020-033, Elimination of NMP2 Fuse Holder Inspection Program, Revision 0
- (11) 5059-2020-073, Replace 2RCS*MOV10BActuator 2RCS-MOV10B-ACT Motor, Revision 0
- (12) 5059-2020-136, Unit 1 Shutdown Cooling Steam Leak Detection Isolation and High Inlet Temperature Trip Bypass Switch Installation, Revision 0
- (13) 5059-2021-076, ERVR Nitrogen Supply Inboard Solenoid Operated Valve Replacement With Check Valve, Revision 0
- (14) 5059-2021-0147, Freeze Seal Evaluation at 2-SWP-003-135-3 for Valve Maintenance on 2SWP*MOV21B, Revision 0
- (15) 5059-2021-155, Remove NMP2 Service Water Pump 18-second Lockout, Revision 0
- (16) 5059-2019-137, Unit 1 EDG 102/103 Fuel Oil Storage Level Indicating System and Oil Spill Prevention System Upgrade, Revision 0
- (17) 5059-2019-151, Replace Ultrasonic Level Switch 2CSH-LS143, Revision 0
- (18) 5059-2019-171, Unit 2 Tornado Generated Missile Protection Design Basis, Revision 0
- (19) 5059-2020-141, Remove Positioner on FCV-29-23 & FCV-29-24, Revision 0
- (20) 5059-2020-164, Configuration Change to Address Slow Stroke of SCRAM Discharge Volume Drain Valve 2RDS-AOV130, Revision 0
- (21) 5059-2021-122, Unit 2 RHR Isolation and Pump Trip Bypass Switch Installation, Revision 0
- (22) 5059-2021-129, New Computer Points for Vessel Level Indication During Shutdown, Revision 0
- (23) 5059-2021-175, Update NMP2 Fire Loading Calculations, Revision 0
- (24) 5059-2019-118, Unit 2 PM Frequency Change to Performance-Based for Multiple Systems, Revision 0
- (25) 5059-2021-027, Change Torus Corrosion Monitoring Program Inspection Frequency, Revision 0
- (26) 5059-2021-152, Data Validation and Reconciliation to Increase Core Thermal Power Accuracy at NMP2, Revision 0
- (27) 5059-2021-178, Permanently Gag Relief Valves 2CCP-RV35A, B and C, Revision 0
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (12 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Unit 2 recirculation pump following breaker replacement on April 4, 2022
- (2) Unit 2 main steam following outboard MSIV 2MSS*AOV7B air pack replacement on April 4, 2022
- (3) Unit 2 reactor core isolation cooling following flow controller replacement on April 19, 2022
- (4) Unit 2 reactor pressure vessel and ASME Class I system leakage test on May 3, 2022
- (5) Unit 2 'B' residual heat removal pump room unit cooler, 2HVR*UC401C, following chemical cleaning on May 4, 2022
- (6) Unit 2 reactor core isolation cooling following valve maintenance and testing on May 12, 2022
- (7) Unit 2 digital electro-hydraulic control following low pass filter installation on May 16, 2022
- (8) Unit 2 service water following Division II diesel generator service water outlet valve internals replacement on May 18, 2022
- (9) Automatic depressurization system (ADS) following replacement of the 'B' ADS header low flow pressure control valve, 2IAS*SOVY186, on May 20, 2022
- (10) Unit 1 emergency service water 12 pump following breaker maintenance on June 7, 2022
- (11) Unit 1 emergency diesel generator 103 following fuel pump replacement on June 17, 2022
- (12) Unit 2 standby liquid control pump mechanical preventive maintenance and relay replacement on June 21, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Unit 2 forced outage activities from April 5 through 9, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) N2-OSP-RHS-Q@005, RHR System Loop 'B' Pump and Valve Operability Test, System Integrity Test and ASME XI Pressure Test, on April 14, 2022
- (2) N1-ST-Q20, Reactor Building Heating, Cooling, and Ventilation Test, on May 3, 2022
- (3) N2-OSP-EGS-R004, Operating Cycle Diesel Generators Simulated Loss of Offsite Power With and Without ECCS Division 1/2, on June 7, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) N1-ST-Q1D, Core Spray 122 Pump and Valve Operability Test, on June 27, 2022
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
- (1) The inspectors evaluated the conduct of a routine Constellation emergency preparedness drill on June 21, 2022.
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
- (1) A Unit 1 simulator evaluation which included a loss of coolant accident, a failure to scram, and the declaration of a Notice of Unusual Event and an Alert on June 7, 2022
- (2) A Unit 2 simulator evaluation which included a loss of coolant accident requiring a reactor pressure vessel blowdown, and the declaration of an Alert on June 14,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Sampling and Analysis (IP Section 03.02) (2 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
- (1) Unit 2 main stack wide range gaseous effluent monitoring system compensatory samples during maintenance periods in September 2020
- (2) Unit 2 main stack wide range gaseous effluent monitoring system sample representativeness and integrity of the sample system
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the Constellations radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated Constellations implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
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) Unit 1 (April 1, 2021 through March 31, 2022)
- (2) Unit 2 (April 1, 2021 through March 31, 2022)
BI02: RCS Leak Rate Sample (IP Section 02.11) (2 Samples)
- (1) Unit 1 (April 1, 2021 through March 31, 2022)
- (2) Unit 2 (April 1, 2021 through March 31, 2022)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed Constellations implementation of its corrective action program related to the following issues:
- (1) The inspectors reviewed a corrective action program evaluation and corrective actions for a trend in drill and exercise performance failures (Issue Report 04451339).
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed Constellation's corrective action program for potential adverse trends that might be indicative of a more significant safety issue.
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)
- (1) The inspectors evaluated a Unit 2 reactor scram and Constellation's response on April 5,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60854 - Preoperational Testing of an ISFSI
- (1) The inspectors evaluated Constellations preoperational dry run activities involving dry cask movement from the reactor bay into the spent fuel pool on May 3, 2022, that were performed to fulfill requirements in Certificate of Compliance No. 1032, Amendment 3. Specifically, the inspectors observed the following activities:
- Pre-job briefings to assess the licensees ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors
- Simulated radiological field surveys and radiation protection coverage of transportation activities
- Movement of the multi-purpose canister and the HI-TRAC transfer cask into the spent fuel pool
- Multi-purpose canister lid installation
INSPECTION RESULTS
Failure to Obtain Prior NRC Approval for a Change Which Increased Unit 1 Allowable Containment Bypass Leakage and the Consequences of a Loss of Coolant Accident Cornerstone Significance/Severity Cross-Cutting Report Aspect Section Barrier Green None (NPP) 71111.17T Integrity Severity Level IV NCV 05000220/2022002-01 Open/Closed The inspectors identified a Green finding and associated Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.59(c)(2)(iii), Changes, Tests, and Experiments, when Constellation did not obtain a license amendment prior to implementing a proposed change even though the change resulted in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated). Specifically, Constellation staff changed the allowed leakage from the main steam isolation valves (MSIVs) which resulted in greater than a 10 percent increase to the calculated control room dose following a postulated accident in the Nine Mile Point Unit 1 Updated Final Safety Analysis Report (UFSAR).
Description:
The inspectors reviewed 50.59 safety evaluation (SE) 2020-03, NMP1 MSIV Leakage Optimization. The SE evaluated a revision to the allowable containment bypass leakage limits to provide greater operational flexibility with respect to bypass leakage. The inspectors requested the historical analyses of record which calculate the loss of coolant accident (LOCA) dose consequences associated with assumed containment bypass leakage limits to determine whether the change resulted in more than a minimal increase in the consequences of an accident.
The inspectors reviewed calculation H21C092, Unit 1 LOCA w/ LOOP, AST Methodology.
The inspectors found that the calculation was completed on December 14, 2006, to support License Amendment 194 (ML073230597). The inspectors noted that a few weeks after the approved License Amendment 194, Constellation staff identified a conservative input error to the calculation (IR 02036454) and calculated lower dose consequences with the corrected input values in H21C092, Revision 1, dated April 8, 2008. However, the inspectors noted Constellation staff did not incorporate the change into their design basis for the plant to reflect the change in the UFSAR at that time. Subsequently, Constellation staff implemented an engineering change (EC20090056-000, Revise Bypass Leakage Design Basis and LOCA Dose Consequences to Support RFO20) on March 19, 2009, which combined the corrected input values, increased the containment bypass leakage limits, and incorporated the results into the Unit 1 design basis. The inspectors noted that the corrected input valves added margin while the increased containment bypass leakage reduced margin to the dose consequence of a LOCA. However, the Constellation staff 10 CFR 50.59 review evaluated the combined impact to dose of the two changes and screened this change as an equivalent change because the new calculated dose to the control room was the same as the dose from the original calculation.
The inspectors determined that H21C092, Revision 1, was the analysis of record at the time the change was implemented to increase the allowable containment bypass leakage limits (EC20090056). As a result, the calculated dose to the control room from Revision 1 (4.37 rem) should have been used to evaluate the resulting calculated dose (4.81 rem) due to the increased allowed leakage. The inspectors determined this change resulted in more than a 10 percent increase in the consequences of an accident previously analyzed in the UFSAR.
As a result, the inspectors found Constellation staff did not obtain a license amendment prior to implementing a change that resulted in more than a minimal increase in the consequences of an accident discussed in 10 CFR 50.59(c)(2)(iii).
In addition, the inspectors noted Constellation staff did not update the UFSAR with the design basis dose values, specifically table XV-32 Loss of Coolant Accident Doses, following H21C092, Revision 1, and change EC20090056-000. As a result, Constellation staff referenced the UFSAR values rather than the analyses of record when completing their 50.59 SE 2020-03.
Corrective Actions: Constellation staff entered the issues into their corrective action program, reviewed the most recent containment bypass leakage test results and calculation assumptions, and determined the MSIVs remained operable. Constellation staff is currently evaluating and correcting the changes related to containment bypass leakage. The inspectors found, based on the most recent leak test results, dose consequences would not exceed regulatory limits following postulated accidents.
Corrective Action References: IR 04500884, IR 04500886, IR 04501018
Performance Assessment:
Performance Deficiency: Constellation staff did not obtain a license amendment prior to implementing a change to the facility in accordance with 10 CFR 50.59(c)(2)(iii), for a change that resulted in more than a minimal increase in consequences of a LOCA. Specifically, Constellation staff incorrectly determined the change made in EC20090056-000 was an equivalent change when the change actually resulted in more than a minimal increase in dose consequences to control room staff as a result of a postulated accident.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the revised containment bypass leakage resulted in more than a minimal increase to the consequences of a LOCA.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically using Exhibit 3 Barrier Integrity Screening Questions, Section 3, Reactor Containment, the finding screened as having very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment and did not involve the function of the hydrogen igniters. Constellation staff provided the most recent containment bypass leak test results. Although leakage from one MSIV was greater than the previous allowable leakage of 50 scfh per MSIV, it is not considered to represent an actual open pathway in containment because Constellation staff confirmed the combined total MSIV leakage for both main steam lines remained less than the previous total allowable leakage of 100 scfh.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
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: Since the violation resulted in a condition that was determined to have very low safety significance (Green in the significance determination process), the traditional enforcement violation was determined to be a Severity Level IV violation, consistent with the example in paragraph 6.1.d.2 of the NRC Enforcement Policy.
Violation: The inspectors identified a violation of 10 CFR 50.59(c)(2)(iii), Changes, Tests, and Experiments, which states, in part, that a licensee shall obtain a license amendment prior to implementing a proposed change that would result in more than a minimal increase in the consequences of an accident previously evaluated in the UFSAR. Contrary to the above, on March 19, 2009, Constellation staff did not obtain a license amendment prior to implementing a change to revise allowable containment bypass leakage that resulted in more than a minimal increase in calculated dose consequences of a LOCA.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Performance Deficiency 71152A Minor Performance Deficiency: The inspectors reviewed the corrective action program (CAP)evaluation and corrective actions completed in response to a trend in drill and exercise performance (DEP) failures as documented in issue report (IR) 04451339. The inspectors identified one minor performance deficiency related to the classification of DEP failures as conditions adverse to quality in the problem identification and resolution program.
The Constellation CAP uses the issue identification and screening process to determine the significance of issues and assign appropriate investigation class. Any issues that are not required to be included in CAP are captured in the non-corrective action program (NCAP). Step 4.6.6.3 of PI-AA-120, Issue Identification and Screening Process, directs the Station Ownership Committee to determine the significance of CAP issues in accordance with 2, CAP Issue Report Level and Class Criteria, which provides a list of condition adverse to quality examples that Constellation has determined require specific management screening to ensure the issues are addressed. In the Significance Level 3 Guidance of 2, "Operational Execution - Emergency Preparedness," example LL lists Overall objective or DEP opportunity failure. Classification of an issue as a condition adverse to quality in the CAP requires corrective action to restore the condition adverse to quality to an acceptable condition or capability.
Contrary to that PI-AA-120 guidance, the inspectors identified three IRs documenting DEP failures that were not categorized appropriately. Issue Report 04379903 for a DEP failure in October 2020 was classified as Significance Level 4, and IRs 04443766 and 04439898, which captured DEP failures in August 2021, were classified as NCAP.
Screening: The inspectors determined the performance deficiency was minor. Specifically, although those IRs were classified as Significance Level 4 or NCAP, the existing actions that were taken to address those issues would have been acceptable corrective actions to address the conditions adverse to quality. This minor performance deficiency is captured in IR 04508486.
Observation: Semi-Annual Trend Review 71152S The inspectors evaluated a sample of issues and events that occurred from January 2022 through June 2022 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified issues were appropriately evaluated by Constellation staff for potential trends and addressed within the scope of the CAP or through department review.
The inspectors did not identify any new trends that could indicate a more significant safety issue. Constellation identified a trend in failures associated with the potentiometers on the Unit 2 feedwater level control valves and documented the issue in IR 04494878. Each of these failures resulted in operator challenges in ensuring reactor water level remained stable.
Also, the restoration from a maintenance activity due to one of these failures is what led to the April 5, 2022 automatic scram on low reactor water level. The subject potentiometers have since been replaced with a different style potentiometer. The inspectors also noted other minor potential adverse trends identified by Constellation staff in the areas of signal noise in the Unit 1 recirculation system master controller, Unit 2 main steam isolation valve closure times, work orders not meeting post-maintenance testing requirements, and Unit 1 emergency diesel generator circulating oil pump failures.
Failure to Implement Adequate Procedure for Feedwater Control Valve Results in Unit 2 Scram Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.1] - 71153 NCV 05000410/2022002-02 Resources Open/Closed A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specification (TS) 5.4.1.a was identified for Constellations failure to maintain properly sequenced steps in the stations procedure for feedwater failures. As a result, when implementing N2-SOP-06, "Feedwater Failures," the B feedwater level control valve unexpectedly closed during restoration from a maintenance activity and caused a subsequent automatic reactor scram on low water level.
Description:
On April 5, 2022, Unit 2 was operating at 100 percent power with feedwater level control in automatic. The Unit 2 feedwater system has three pumps - 'A', 'B', and 'C' - with a level control valve for each pump. Each level control valve has both a primary and backup valve position feedback potentiometer for redundancy. The 'A' and 'B' feedwater pumps were in service. Level control valve 'A' (2FWS-LV10A) was controlling in automatic on the backup potentiometer (primary potentiometer was non-functional) and level control valve 'B' (2FWS-LV10B) was in manual with both primary and backup position feedback potentiometers non-functional. While in manual, the level control valve will not change position without operator input.
Maintenance personnel replaced the primary positioner for 2FWS-LV10B to restore functionality to the automatic control of valve position. The procedure to complete the position feedback potentiometer replacement could not be completed as written since positioner readings taken before and after the positioner was replaced required the valve to be in Automatic control. Maintenance personnel notified operations personnel and the issue was resolved by using steps from N2-SOP-06, "Feedwater Failures," Attachment 1. After replacing the primary potentiometer, 2FWS-LV10B was taken to automatic control on the primary position feedback potentiometer to record in-service position feedback on the maintenance laptop computer. At this point, the valve control system was receiving an actual valve position from the secondary (non-selected) potentiometer of 43.8 percent open and an indicated position from the primary potentiometer (selected) of 80 percent open in accordance with the circuit design. The signal mismatch caused 2FWS-LV10B to close to 10 percent open. Automatic operation of 2FWS-LV10A was insufficient to counter the level transient and at 0222 reactor vessel water level reached 159.3 inches, initiating a Level 3 signal and automatic reactor trip. Water level reached Level 2 (108.8 inches) and reactor core isolation cooling (RCIC) and high pressure core spray (HPCS) initiated, restoring reactor water level. Level rose to the high reactor water level setpoint, Level 8 (202.3 inches), tripping both feed pumps and securing flow from HPCS and RCIC. The operators responded to the reactor scram and stabilized the plant in Mode 3.
The inspectors reviewed the work order, applicable operating procedures, operator logs, the automated plant parameter data recording system (R-time), human performance review board report, and root cause evaluation and determined that the cause of the low level condition was incorrect procedure guidance for nulling the demand and position signal in N2-SOP-06, "Feedwater Failures," Attachment 1. The sequence of steps in N2-SOP-06 combined with the work order sequence allowed for restoring normal control on the primary positioner with a significant mismatch between actual and indicated valve position. The existing valve position-to-position sensor mismatch resulted in a close signal being sent to the positioner and the reduction in feedwater flow to the reactor.
Corrective Actions: Constellations corrective actions included revising N2-SOP-06 to correct the latent error and providing clear guidance for nulling the demand and position signals based on how the primary and backup potentiometers are wired into the level control valve control system. Also, procedure OP-AA-107-F01, "Risk Screening/Mitigation Plan," was revised to adjust the order of the table to ensure high risk is screened first to improve human factoring and promote a conservative risk selection. Additional corrective actions include developing an operations standing order requiring station duty manager concurrence to resume work following a work stoppage; performing additional training for operations, maintenance and selected engineering personnel on digital feedwater flow system and signal paths; updating the applicable simulator to model operation of the potentiometer and mode control switches; and conducting an extent-of-cause review on similar digital modifications.
Corrective Action References: IR 04490223
Performance Assessment:
Performance Deficiency: Constellations failure to maintain properly sequenced steps in the stations procedure for feedwater failures was a performance deficiency within Constellations ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to maintain properly sequenced procedure steps in the stations procedure for feedwater failures resulted in an automatic reactor trip when restoring 2FWS-LV10B to service.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that although this finding caused a reactor scram, it did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable condition. Therefore, the inspectors determined the finding to be of very low safety significance (Green).
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The inspectors determined that both the operations procedure and maintenance work instructions required to complete the maintenance provided inadequate guidance to personnel, resulting in a plant transient and automatic protective action. The maintenance work instructions were inadequate, requiring unexpected additional steps to be taken by operations personnel. The operations procedure included steps that were not appropriately sequenced, ultimately resulting in a reactor trip.
Enforcement:
Violation: Technical Specification 5.4.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 6.j, requires procedures for loss of feedwater or feedwater system failures.
Contrary to the above, on April 5, 2022, Constellation failed to maintain a procedure to address the requirements of Regulatory Guide 1.33, Appendix A, Section 6. Specifically, Constellation procedure N2-SOP-06, Feedwater Failures, Revision 2, Attachment 1 provides guidance for restoration of 2FWS-LV10 control. This procedure was used by maintenance and operations personnel when attempting to restore 2FWS-LV10B following primary potentiometer replacement. The improperly sequenced steps in N2-SOP-06, 1, Steps 1.2.4 and 1.2.5 resulted in restoring the potentiometer before its indicated position was aligned with actual valve position, resulting in the control system shutting 2FWS-LV10B and causing a low reactor water level trip.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 20, 2022, the inspectors presented the evaluations of changes, tests, and experiments triennial team inspection results to Peter Orphanos, Site Vice President, and other members of the licensee staff.
- On June 16, 2022, the inspectors presented the triennial heat sink inspection results to Peter Orphanos, Site Vice President, and other members of the licensee staff.
- On June 30, 2022, the inspectors presented the radiation environmental monitoring program inspection results to Nicholas Tryt, Director of Engineering, and other members of the licensee staff.
- On July 21, 2022, the inspectors presented the integrated inspection results to Peter Orphanos, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Corrective Action 04495995
Documents
Procedures N1-OP-64 Meteorological Monitoring 02100
N2-MPM-GEN- Probably Maximum Precipitation (PMP) Flood Berm and 00400
A016 10,000 Year Culvert Inspection
N2-OP-102 Meteorological Monitoring 02800
Work Orders C93745032
C93785079
C93789418
71111.04 Corrective Action 04485362
Documents 04501040
Drawings 12177-PID-11-1 Piping and Instrumentation Diagram, Service Water
Fundamental
C-18017-C Emergency Cooling System P&I Diagram 58.00
PID-11A Piping and Instrumentation Diagram Service Water System 18
PID-11B Piping and Instrumentation Diagram Service Water System 20
PID-11L Piping and Instrumentation Diagram Service Water System 25
Procedures N1-OP-13 Emergency Cooling System 04300
N2-OP-11 Service Water System 015
N2-OP-31 Residual Heat Removal System - LINEUPS
N2-OSP-RHS- RHR System Loop B Pump and Valve Operability Test, 16
Q@005 System Integrity Test and ASME XI Pressure Test
71111.05 Fire Plans N1-PFP-0101 Unit 1 Pre-Fire Plans 7
N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans 07
Procedures OP-AA-201-003 Fire Drill Performance 20
71111.06 Drawings PID-63 A-E Reactor Building Equipment and Floor Drains
Procedures N2-OP-63 Reactor Building Drains Rev 4, CH 2
71111.07A Corrective Action 04470142
Documents 04475865
Procedures N2-PM-HVR-406 Performance Evaluation Test for Unit Cooler 2HVR*UC406 00000
71111.07T Calculations S14-93HX07 Determine Allowable Fouling Factor Based on K-Value Used 00
Inspection Type Designation Description or Title Revision or
Procedure Date
in Torus Heatup Analysis with 84F Service Water Temperature
S15-79-HTX04 Thermal Performance Evaluation for Unit 1 Emergency Diesel 00.00
Generator (EDG) Jacket Water Coolers
Corrective Action 04504741
Documents
Work Orders C93654286 Diesel Engine - Emergency Diesel Generator Unit102 09/24/2021
C93751836 111 Containment Spray Heat Exchanger 03/28/2022
C93769066 Unit 2 Service Water Forebay Cleaning 09/27/2021
71111.11Q Corrective Action 04492884
Documents
Resulting from
Inspection
Procedures N1-OP-1 Nuclear Steam Supply System (NSSS) 07700
N2-OP-101A Plant Start-up 05400
NM1C25-05 Reactivity Maneuver Plan 0
NM2C19-SU Reactivity Maneuver Plan 0
71111.12 Corrective Action 04357136
Documents 04425429
04461978
04462597
04473366
04480577
04484546
Procedures ER-AA-330-005 Visual Examination of Section XI Class CC Concrete 16
Containment Structures
ER-AA-450 Structures Monitoring 10
N2-OP-53A Control Building Ventilation System 02000
S-MRM-REL- Structural Monitoring Program 01000
0102
Work Orders C93770053
C93812875
71111.13 Corrective Action 04508066
Documents
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedure OP-AA-108-117 Protected Equipment Program 007
WC-AA-101 On-Line Work Control Process 32
WC-AA-101-1004 On-Line Maintenance for Limiting Condition for Operation of 9
Systems or Components
71111.15 Corrective Action 04474566
Documents 04485867
04488015
04496729
04502995
04505189
04508229
Miscellaneous Nine Mile Point Final Updated Safety Analysis Report 26
NEI 06-09-A Risk-Informed Technical Specifications Initiative 4b: Risk- 0
Managed Technical Specifications (RMTS) Guidelines
RICT Record For March 28, 2022 Failed MSIV 7D RPS Testing 04/06/2022
Procedures MA-AA-716-230- Oil Analysis Interpretation Guideline 20
1001
N1-ARP-A3 Control Room Panel A3 16
N1-OP-45 Emergency Diesel Generators 51
N1-OP-47A 125VDC Power Systems 32
N2-OSP-SWP- Service Water Actuation Test and Valve Operability Test 02100
R001
OP-AA-108-118 Risk Informed Completion Time 2
71111.17T Calculations EC-032 Diesel Generator Loading 13
H21C-103 U2 CRDA, AST Methodology 1
Corrective Action 04049527
Documents 04104838
243234
243411
243421
04309064
04385110
04435291
Inspection Type Designation Description or Title Revision or
Procedure Date
04500267
Corrective Action 04498221
Documents 04500166
Resulting from 04500632
Inspection 04500733
04500884
04500886
04501018
04501028
Engineering ECP-19-000301- Design Report Approval Certification, NMP2 Main Steam 1
Changes CN-010 Isolation Valve, MSIV, Stress Analysis Report
GEH OOSN4274 LaSalle, Clinton, NMP2 Jet Pump Cavitation Evaluation 0
Engineering NER-2E-031 Identification of NMP2 Fuse Holders in the Scope of the 2
Evaluations License Renewal Aging Management Program for Fuse
Holders
TODI 00597084- Structural Screen of Penetrations 05/31/2017
00086-1
TODl-16-000016 Low Pass Filter Modification Information 0
Procedures N2-MPM-Gen- Reactor Vessel Disassembly 01900
903
N2-OSP-RDS- SCRAM Discharge Volume Vent and Drain Valve Operability 00400
Q001 Test
N2-PM-082 RPV Flood Up/Draindown 02000
71111.19 Corrective Action 04208724
Documents 04484572
04484854
04487343
04490103
04498919
Corrective Action 04492744
Documents
Resulting from
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
Procedures N1-EMP-GEN- Maintenance of 600V Breakers Type AK-2-15 and Type AK-2- 00800
145 25
N1-OP-45 Emergency Diesel Generators 45
N1-RCPM-GEN- Load Testing of AK and ITE Breaker Trip Devices 00500
155
N1-ST-M4B Emergency Diesel Generator 103 and PB 103 Operability Test 26
N2-EMP-GEN- Target Rock SOV Maintenance 01500
513
N2-ESP-EPS- 60 Month 13.8KV Breaker Inspection and Preventive 01200
5Y565 Maintenance
N2-IPM-ICS-R010 Reactor Core Isolation Cooling (RCIC) Tuneup 00500
N2-ISP-RPS- Operating Cycle Calibration of Reactor Scram on MSIV 01200
R107 Closure Instrument Channels, MSIV Position Indication, and
MSIV Slow Closure Stroke Time
N2-MFT-324C DEHC [digital electro-hydraulic control] Low Pass Filter 00000
Modification
N2-MMP-GEN- Maintenance of Target Rock Solenoid Operated Valves 01100
236
N2-OSP-IAS- Instrument Air System Valve Position Indication Operability 00900
R001 Test
N2-OSP-ICS- RCIC Pump and Valve Operability Test and System Integrity 01600
Q@002 Test and ASME XI Functional Test and Analysis
N2-OSP-ICS- RCIC System Flow Test 00500
R002
N2-OSP-MSS- Main Steam Isolation Valve Operability Test 01100
CS001
N2-OSP-RPV- Reactor Pressure Vessel and All Class I System Leakage Test 01400
@003 with the RPV Solid
N2-OSP-SLS- Standby Liquid Control Pump, Check Valve, Relief Valve 23
Q001 Operability test and ASME XI Pressure Test
N2-PM-HVR-401 Performance Evaluation Test for Unit Cooler 2HVR*UC401A, 00100
B, C, D, E, and F
S-EPM-GEN-063 MOV Diagnostic Testing 01300
Work Orders C93331000
Inspection Type Designation Description or Title Revision or
Procedure Date
C93654825
C93693714
C93731154
C93735279
C93757171
C93809087
C93812720
71111.20 Procedures LS-AA-119 Fatigue Management and Work Hour Limits 15
N2-OP-101A Plant Start-up 05400
N2-OP-38 Spent Fuel Cooling and Cleanup System 02700
OP-AA-109-101 Personnel and Equipment Tagout Process 16
OP-AA-300 Reactivity Management 14
OU-NM-103-101 Shutdown Safety Management Program 00700
71111.22 Procedures N1-ST-Q1D CS 122 Pump and Valve Operability Test 23
N1-ST-Q20 Reactor Building Heating, Cooling, and Ventilation Test 01600
N2-OSP-EGS- Operating Cycle Diesel Generators Simulated Loss of Offsite 01900
R004 Power With and Without ECCS Division 1/2
N2-OSP-RHS- RHR System Loop B Pump and Valve Operability Test, 16
Q@005 System Integrity Test and ASME XI Pressure Test
Work Orders C93738265
71114.06 Procedures EP-AA-1013 Addendum 4, Appendix 1, NMP Unit 2 EAL Wallboard 2
EP-AA-112-200 TSC Activation and Operation 14
EP-AA-122-300 Drill and Exercise Evaluation 3
71151 Miscellaneous NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7
71152A Corrective Action 04158484
Documents 04273651
04317315
04379903
04439898
04443766
04451339
Corrective Action 04508486
Documents 04509312
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
Miscellaneous Nine Mile Point 2021 Graded Exercise Evaluation Report 11/02/2021
Procedures EP-AA-122-300- Drill & Exercise Evaluation Criteria L
F-01
EP-AA-125-1002 ERO Performance - Performance Indicators Guidance 14
PI-AA-120 Issue Identification and Screening Process 1
PI-AA-120-1003 Corrective Action Program Evaluation Manual 6
PI-AA-125 Corrective Action Program (CAP) Procedure 8
TQ-AA-155 Conduct of Simulator Training and Evaluation 12
TQ-AA-225 Training - Evaluation Phase 9
TQ-AA-225-F020 Training Effectiveness Evaluation Worksheet 3
71152S Corrective Action 04479394
Documents 04483399
04494878
04504730
04508572
71153 Corrective Action 04490223
Documents
Procedures N2-SOP-06 Feedwater Failures 12
24