IR 05000220/2023004

Integrated Inspection Report 05000220/2023004 and 05000410/2023004

ML24032A026
Person / Time
Site:	Nine Mile Point
Issue date:	02/01/2024
From:	Erin Carfang NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023004
Download: ML24032A026 (1)

Text

February 1, 2024

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000220/2023004 AND 05000410/2023004

Dear David Rhoades:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, Units 1 and 2. On January 25, 2024, 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.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Digitally signed by Erin E.

Erin E. Carfang Date: 2024.02.01 Carfang 09:01:47 -05'00'

Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety 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: 05000220/2023004 and 05000410/2023004 Enterprise Identifier: I-2023-004-0040 Licensee: Constellation Energy Generation, LLC Facility: Nine Mile Point Nuclear Station, Units 1 and 2 Location: Oswego, NY Inspection Dates: October 1, 2023 to December 31, 2023 Inspectors: C. Swisher, Senior Resident Inspector J. England, Senior Resident Inspector E. Eve, Senior Project Engineer T. Fish, Senior Operations Engineer E. Garcia, Resident Inspector M. Hardgrove, Senior Project Engineer T. Hedigan, Operations Engineer C. Kline, Senior Resident Inspector P. Ott, Operations Engineer J. Schussler, Senior Resident Inspector B. Sienel, Resident Inspector S. Veunephachan, 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, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On October 13, 2023, the unit was downpowered to 75 percent for sequence exchange, scram time testing, and turbine valve testing. The unit was returned to rated thermal power on October 14, 2023. On October 21, 2023, the unit downpowered to 88 percent due to the trip of the 12 recirculation pump. The operators returned the unit to rated thermal power on the same day using 4 loop operation. On October 25, 2023, the unit was downpowered to 85 percent to restart the 12 recirculation pump. The unit was returned to rated thermal power the same day and 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 November 17, 2023, the unit was downpowered to 88 percent for load line adjustment. The unit returned to rated thermal power on November 18, 2023. On December 8, 2023, the unit was downpowered to 67 percent for rod pattern adjustment. The unit returned to rated thermal power on December 9, 2023, and 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the Unit 1 and Unit 2 switchyards on December 21, 2023.

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (4 Samples)

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

(1) Unit 1 emergency diesel generators 102 and 103 during planned maintenance on 11 liquid poison system on October 16, 2023

(2) Unit 2 division III diesel generator on October 30, 2023

(3) Unit 1 emergency condensers during the week of October 30, 2023

(4) Unit 2 standby liquid control system on November 17, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (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 north and south auxiliary bays 175', fire areas 1 and 2, on October 3, 2023

(2) Unit 1 reactor building northwest 198'/218', diesel generator power board rooms 102 and 103, and diesel generators 102 and 103, on October 12, 2023

(3) Unit 2 division I diesel generator room, fire area 28, on November 8, 2023

(4) Unit 2 high pressure core spray diesel generator room, fire area 30, on December 12, 2023

(5) Unit 2 division II diesel generator room, fire area 29, on December 13, 2023

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (2 Samples)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the Unit 2 requalification annual operating exams administered October through November 2023, and the Unit 2 biennial written examinations completed November 2023.

(2) The inspectors reviewed and evaluated the licensed operator examination failure rates for the Unit 1 requalification annual operating exams completed December 14, 2023.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the Unit 2 licensed operator biennial requalification written examinations administered October through November 2023.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the Unit 2 facility licensees annual requalification operating test administered the week of October 23, 2023.

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

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

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

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

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

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 1 operations personnel during reactor power and feedwater manipulations for a quarterly surveillance on October 5, 2023, and a downpower for control rod pattern adjustment on October 13, 2023.

(2) The inspectors observed Unit 2 operations personnel during a downpower for control rod pattern adjustment on October 2, 2023, and raising reactor pressure to increase plant efficiency on October 13, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed a Unit 2 simulator evaluation that included a reactor feed control valve drift, inadvertent actuation of emergency core cooling system, failure of component cooling temperature control valve, and failure of control rods on October 18, 2023.

(2) The inspectors observed a Unit 1 simulator evaluation that included a fuel failure and an unisolable reactor water cleanup leak on November 7, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:

(1) Unit 1 diesel-driven fire pump

(2) Unit 1 instrument air system

(3) Unit 1 emergency service water system

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (2 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 scheduled maintenance on the division I residual heat removal system on October 17, 2023

(2) Unit 2 elevated risk during scheduled maintenance on the reactor core isolation cooling system during the week of November 6, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2 automatic depressurization system due to degraded solenoid valve 2IAS*SOVY186 on October 11, 2023

(2) Unit 2 division II emergency diesel generator jacket water heater failure to shut off on October 17, 2023

(3) Unit 1 primary containment due to IV-68-08 failed stroke time operability test on October 24, 2023

(4) Unit 1 turbine anticipatory and generator load rejection and bypass reactor scram due to a missed surveillance test on October 25, 2023

(5) Unit 1 'B' emergency service water train following identification of a through wall leak on the 12 emergency service water pump discharge test line on October 30, 2023

(6) Unit 1 102 emergency diesel generator overvoltage due to rheostat installation error on November 20, 2023

(7) Unit 2 'D' service water pump due to rising inboard bearing temperature on December 14, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality: Post-Maintenance Testing (IP Section 03.01)

(1) N1-ST-Q6A, Containment Spray System Loop 111 Quarterly Operability Test, following planned maintenance, on September 28, 2023

(2) N2-FSP-FPW-R002, Deluge Sprinkler System Piping Inspection/Flow Test Reserve Station Transformers, following sprinkler head replacement and line cleaning, on October 5, 2023

(3) N2-S-EPM-GEN-063, Motor Operated Valve (MOV) Diagnostic Testing for 2RHS*MOV12A, outlet valve for 'A' residual heat system heat exchanger, on October 9, 2023

(4) N1-ST-Q8A, Liquid Poison Pump 11 and Check Valve Operability Test, on October 17, 2023

(5) N2-EPM-GEN-550, GE 4.16KV Magne-Blast Breaker Preventive Maintenance (PM),for 2RHS*P1A, on October 18, 2023

(6) N1-ST-M4A, Emergency Diesel Generator 102 and Power Board (PB) 102 Operability Test, following planned maintenance, on October 27, 2023

(7) N1-PM-C3, Electric and Diesel Fire Pump Performance Tests, following diesel fire pump replacement, on November 7,

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Unit 2 control room envelope ventilation system

Temporary Ventilation Systems (IP Section 03.02) (1 Sample)

The inspectors evaluated the configuration of the following temporary ventilation systems:

(1) Unit 2 refuel floor temporary ventilation

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Whole body count assessment related to Issue Report (IR) 04484571

(2) Whole body count assessment related to IR 04564858

Special Dosimetric Situations (IP Section 03.04) (2 Samples)

The inspectors evaluated the following special dosimetric situations:

(1) Declared pregnant worker program

(2) Neutron dosimetry program

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 for the period of October 1, 2022 through September 30, 2023

(2) Unit 2 for the period of October 1, 2022 through September 30, 2023

MS09: Residual Heat Removal Systems (IP Section 02.08) (2 Samples)

(1) Unit 1 for the period of October 1, 2022 through September 30, 2023

(2) Unit 2 for the period of October 1, 2022 through September 30, 2023

MS10: Cooling Water Support Systems (IP Section 02.09) (2 Samples)

(1) Unit 1 for the period of October 1, 2022 through September 30, 2023

(2) Unit 2 for the period of October 1, 2022 through September 30, 2023

OR01: Occupational Exposure Control Effectiveness (IP Section 02.15) (1 Sample)

(1) Units 1 and 2 for the period of October 1, 2022 through September 30, 2023 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)

(1) Units 1 and 2 for the period of October 1, 2022 through September 30, 2023

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

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

(1) IR 04688411 - Part 21 for Voltage Regulators on Emergency Diesel Generators

(2) IR 04547699 - Review of Corrective Actions Following Unit 1 Failed Fuel Assembly

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the Nine Mile Point corrective action program for potential adverse trends that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Observation: Part 21 for Voltage Regulators on Emergency Diesel Generators 71152A The inspectors performed an in-depth review of Constellations evaluation and corrective actions associated with a Part 21 received related to the voltage regulators for the emergency diesel generators at Units 1 and 2. On July 3, 2023, Constellation received a Part 21 notification from Engine Systems, Inc., stating that some of the voltage regulators shipped to the site were not properly assembled. In the notification, Engine Systems, Inc. explained that the copper conductors on the voltage regulators were not properly positioned, causing current to pass through the stainless steel fasteners, potentially resulting in an overheating condition that could prevent the emergency diesel generator from performing its safety-related function.

Constellation entered this notification into their corrective action program as IR 04688411.

Constellation verified that none of the defective voltage regulators are currently installed in any of the emergency diesel generators by performing a visual inspection of the serial numbers. The inspectors noted that while the defective voltage regulators are in the Constellation supply system at Nine Mile Point and were to be installed during future refueling outages, those will now be repaired prior to installation. Specifically, Constellation has a planned corrective action to return the voltage regulators to Engine Systems, Inc. for proper assembly.

The inspectors reviewed the corrective action program products and did not identify any violations or performance deficiencies.

Observation: Review of Corrective Actions Following Unit 1 Failed Fuel Assembly 71152A The inspectors reviewed Constellations corrective action program evaluation and corrective actions regarding a failed fuel assembly for Unit 1 during full-power operations on January 9, 2023.

During the end-of-cycle planning, Constellation reactor engineering planned and scheduled load drops every three to four weeks to adjust control rod patterns in order to sustain rated power until the N1R27 refueling outage in March 2023. The proposed rod pattern for two control rods was chosen as it adequately managed thermal limits while allowing for an easy load line adjustment and eventual withdrawal of the rods. The two controls rods for withdrawal were adjacent to specific nuclear fuel. The control rods are cruciform in design; thus, they insert between four fuel assemblies, making up a cell. These two controls rods were installed in Unit 1 on December 21, 2022, to control thermal limits and fuel conditioning.

On January 7, 2023, reactor power was lowered to approximately 88 percent in order to perform a load line adjustment, during which, the two control rods were withdrawn. On January 9, 2023, Unit 1 offgas radiation monitors indicated significantly elevated activity. Chemistry analysis from offgas radiological samples confirmed that one or more fuel failures had occurred in accordance with criteria in NF-AA-430, "Failed Fuel Action Plan."

Constellation entered the issue into the corrective action program as IR 04547699 and completed a root cause evaluation. Constellation determined that the probable cause of the failed fuel assembly was related to pellet clad interaction. Procedure JNF-AB-720-F-7, Control Rod Sequence Preparation and Review Checklist, was revised to include a recommendation to avoid notching control rods at certain locations. This notching could create power peaking consistent with industry events resulting in fuel failures. Other additions were to minimize the use of control rods in cells that contain or are adjacent to cells containing this specific nuclear fuel. Industry guidance states that control rods adjacent to this specific nuclear fuel should either be in an all-in or all-out position. However, if this specific fuel needs to be controlled, the rod needs to be eventually withdrawn. Constellation followed the fuel conditioning rules during the control rod movement on January 7, 2023, load line adjustment.

The inspectors reviewed the root cause evaluation, corrective actions, and other documentation. The inspectors reviewed the fuel conditioning rules and procedures for the January 7, 2023, load line adjustment. The inspectors noted Constellations evaluation and corrective actions were in accordance with site procedures.

Observation: Semiannual Trend 71152S The inspectors evaluated a sample of issues and events that occurred from July 2023 through December 2023 to determine whether issues were appropriately considered as emerging or adverse trends. As part of this review, the inspectors included repetitive or closely related issues documented by the licensee in the corrective action program database, trend reports, site performance indicators, system health reports, and maintenance backlogs.

The inspectors verified issues were appropriately evaluated by Constellation staff for potential trends and addressed within the scope of the corrective action program or through department review.

The inspection did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that Constellation personnel were identifying trend issues at a low threshold and entering them into the corrective action program for resolution. The inspectors noted a low-level trend regarding equipment reliability. There were several equipment issues between July 2023 and December 2023, specifically regarding the Unit 1 reactor building closed loop cooling pump, the Unit 1 diesel driven fire pump, the Unit 1 recirculation pump 12 motor generator, the Unit 2 automatic depressurization system header pressure fluctuations, and the Unit 2 D service water pump. The inspectors continue to monitor these equipment reliability issues through routine inspection activities.

EXIT MEETINGS AND DEBRIEFS

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

• On January 25, 2024, 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 Procedures WC-AA-107 Seasonal Readiness 28

71111.04 Corrective Action 02574691

Documents 02574692

04068988

04449971

04557550

04672264

04694596

Corrective Action 04710060

Documents 04714094

Resulting from

Inspection

Drawings Drawing C-18017- Piping and Instrumentation Diagram, Emergency Cooling 58

C, Sheet 1 System

Drawing C-18026- Emergency Diesel Generator #102 Starting Air, Cooling 29

C, Sheet 1 Water

Drawing C-18026- Emergency Diesel Generator #102 Starting Air, Cooling 33

C, Sheet 2 Water

PID-36A Piping & Instrumentation Diagram, Standby Liquid Control 26

Procedures N2-OP-100B HPCS Diesel Generator - Lineups 00200

71111.05 Fire Plans N1-PFP-0101 Unit 1 Pre-Fire Plans 00700

N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans 07

Procedures N1-FPM-FPE- Fire Protection Equipment Monthly Inspection 00900

M0005

N2-FPM-FPE- Maintenance and Inspection - Portable Fire Extinguishers 01500

A001

71111.11Q Procedures N1-ST-Q3 High Pressure Coolant Injection Pump and Check Valve 02100

Operability Test

71111.12 Corrective Action 02738398

Documents 04264097

04353146

04461267

04464430

Inspection Type Designation Description or Title Revision or

Procedure Date

04464683

04479190

04520644

04531301

04544502

04547812

04549997

04550513

04554348

04559467

04695042

04706242

Procedures MA-AA-716-011 Work Execution and Closeout 28

N1-MPM-100-851 Diesel Fire Pump Engine Preventive Maintenance 800

Work Orders C93851427

C93896486

71111.15 Calculations ES-002 KSV-16-T Diesel Generators 0

A

Corrective Action 04486693

Documents 04543409

04683194

04683647

04685349

04701455

04710753

04713705

04718736

04723637

Drawings 0001040209034 Piping & Instrumentation Diagram, Jacket Water Schematic 01

2EGS*EG1/EG3

PID-019D Piping & Instrumentation Diagram, Instrument and Service 24

Air

Engineering ENGDOC-23- 4-inch Pipe Upstream of BV-72-77, 12 Emergency Service 11/01/23

Evaluations 000008 Water Pump Test Blocking Valve

NDE Reports NMP1-UT-23-178 Emergency Service Water Pump 12 10/30/23

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures N1-ISP-002-013 Turbine Stop Valve Closure and Generator Load Rejection - 00600

Bypass Reactor Scram Instrument Channel Test/Calibration

OP-AA-108-115 Operability Determinations (CM-1) 26

Work Orders C93785657

C93815323

C93911150

C93911165

71111.24 Corrective Action 04707396

Documents

Procedures N1-PM-C3 Electric and Diesel Fire Pump Performance Tests 01800

N1-ST-M4A Emergency Diesel Generator 102 and PB 102 Operability 032

Test

N1-ST-Q6A Containment Spray System Loop 111 Quarterly Operability 022

Test

N2-FSP-FPW- Deluge Sprinkler System Piping Inspection/Flow Test 0100

R002 Reserve Station Transformers

Work Orders C93668201

C93790802

C93805436

C93878689

C93881534

C93946369

C93959393

71151 Miscellaneous N1-MSPI-001 Nine Mile Point 1 MSPI Basis Document 12

N2-MSPI-001 Nine Mile Point 2 MSPI Basis Document 16

NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

71152S Corrective Action 04677833

Documents 04701455

04710571

04711520

04722226

04723637

13