IR 05000333/2019010
| ML19179A067 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/28/2019 |
| From: | Anthony Dimitriadis NRC/RGN-I/DRP/PB5 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Dimitriadis A | |
| References | |
| IR 2019010 | |
| Download: ML19179A067 (16) | |
Text
une 28, 2019
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2019010
Dear Mr. Hanson:
On May 9, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 FitzPatrick.
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 05000333 License No. DPR-59
Enclosure:
As stated
Inspection Report
Docket Number: 05000333 License Number: DPR-59 Report Number: 05000333/2019010 Enterprise Identifier: I-2019-010-0007 Licensee: Exelon Generation Company, LLC Facility: James A. Fitzpatrick Nuclear Power Plant Location: Lycoming, NY Inspection Dates: March 11, 2019 to June 28, 2019 Inspectors: L. Micewski, Senior Resident Inspector M. Henrion, Emergency Response Coordinator V. Petrella, Reactor Inspector G. Stock, Resident Inspector Approved By: Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at James A. Fitzpatrick Nuclear Power Plant 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. Findings and violations being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations Finding - Failure to perform functionality determination Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152B Systems FIN 05000333/2019010-01 Complacency Open The inspectors identified a finding of very low safety significance (Green) because the licensee did not assess the effects of a degraded condition involving the reactor building closed loop cooling (RBCLC) system as required by plant procedures.
Additional Tracking Items Type Issue Number Title Report Status Section LER 05000333/2019-001- Secondary Containment 71153 Closed 00 Differential Pressure Exceeded the Technical Specification Surveillance Requirement
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
The inspectors performed a biennial assessment of the licensees problem identification and resolution in the following areas:
Corrective Action Program Effectiveness including problem identification, problem prioritization and evaluation, and corrective actions Use of Operating Experience Completed Self-Assessments and Audits Health of the Safety Conscious Work Environment
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
LER 05000333/2019-01-00, Secondary Containment Differential Pressure Exceeded the Technical Specification Surveillance Requirement (ADAMS Accession No.
ML19074A293). The circumstances surrounding this LER are documented in the Results section.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness Problem Identification: The inspectors determined that, in general, Exelon identified issues and entered them into the corrective action program at a low threshold. However, during plant walk downs, the inspectors identified several minor deficiencies not previously identified and captured in Exelon's corrective action program. Exelon promptly entered each issue into its corrective action program and took actions to evaluate and address.
The inspectors also identified that Exelon staff failed to document a condition that had the potential to cause an undesirable effect on the maintenance effectiveness program. This is documented as a minor performance violation below.
Problem Prioritization and Evaluation: Based on the samples reviewed, the inspectors determined that, in general, Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon appropriately screened issue reports (IRs) for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.
However, the inspectors identified one finding associated with the failure to perform a functionality determination for a degraded condition in the RBCLC system. The finding is documented below.
Corrective Actions: The inspectors determined that the overall corrective action program performance related to resolving problems was effective. In most cases, Exelon implemented corrective actions to resolve problems in a timely manner.
Assessment 71152B Use of Operating Experience The team determined that Exelon appropriately evaluated industry operating experience for its relevance to the facility. Exelon appropriately incorporated both internal and external operating experience into plant procedures and processes, as well as lessons learned for training and pre-job briefs.
Self-Assessments and Audits The team reviewed a sample of self-assessments and audits to assess whether the licensee was identifying and addressing performance trends. The team concluded that Exelon had an effective self-assessment and audit process.
Assessment 71152B Safety Conscious Work Environment The team interviewed a total of 47 individuals: 32 in focus groups and 15 in one-on-one interviews. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety-conscious work environment. The personnel interviewed were randomly selected by the inspectors from the Operations, Engineering, Maintenance, Security, and Chemistry work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) Coordinator to assess her perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.
All individuals interviewed indicated that they would raise safety concerns. All individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated they were adequately trained and proficient on initiating condition reports. All interviewees were aware of the licensee's ECP, stated they would use the program if necessary, and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.
Finding - Failure to perform functionality determination Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152B Systems FIN 05000333/2019010-01 Complacency Open The inspectors identified a finding of very low safety significance (Green) because the licensee did not assess the effects of a degraded condition involving the reactor building closed loop cooling (RBCLC) system as required by plant procedures.
Description:
On April 23, 2019, NRC inspectors identified a potentially degraded seismic support (the spring can was bottomed out) on a section of the RBCLC system in the reactor water recirculation motor generator set room. This condition potentially affected the systems ability to comply with its design basis and, therefore, could have adversely affected the systems ability to perform its safety-related functions. Exelon initiated IR 4242812 to document the issue.
The RBCLC system is a closed-loop system that provides piping that supplies cooling water to several safety-related loads including the residual heat removal pumps, control rod drive pumps, and the post-accident sample cooler. If a piping seismic support is degraded, it could result in a loss of pipe integrity during a design basis accident, which could prevent the system from supplying adequate cooling to safety-related loads. Exelon did not assess the impact of the identified issue on the systems functionality until NRC inspectors raised the concern that Exelon procedure, OP-AA-108-115, Operability Determinations, required that the licensee perform an assessment. Both the site ownership committee and management review committee reviewed the IR but did not recognize a functionality assessment was required. The licensee believed that a functionality assessment was not required because RBCLC is not a safety-related system. However, the inspectors noted that this is a recurring issue, and the licensee was previously made aware that the failure to complete functionality assessments for degradations in the RBCLC is a performance deficiency, as documented in Integrated Inspection Report 05000333/2018002. At the time, the licensee acknowledged the issue and initiated IR 4153271 to attempt to address the deficiency.
Corrective Actions: For the potentially degraded RBCLC seismic support, the licensee performed a functionality assessment and determined that the seismic support and the system remained functional. No additional corrective actions were required to address the condition of the seismic support. For the missed functionality assessment, the licensee performed a discretionary crew clock reset for all operations crews, and performed an extent of condition looking at RBCLC and more broadly at systems and organizations that may require a functionality assessment and did not receive the required evaluation.
Corrective Action Reference: IR 4245107
Performance Assessment:
Performance Deficiency: Exelon procedure, OP-AA-108-115, Operability Determinations, requires that functionality should be assessed immediately upon the discovery that a structure, system, or component, not subject to technical specifications, is in a degraded or nonconforming condition. The inspectors determined that the licensee did not immediately evaluate the functionality of the RBCLC system, a non-technical specification structure, system, or component, after NRC inspectors identified a potentially degraded seismic support for a section of the systems piping on April 22, 2019.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The failure to perform timely functionality assessments could result in the failure to identify the loss of the capability of a structure, system, or component to perform a safety-related or design basis function so that timely corrective action to restore functionality can be completed. This issue is also similar to the more than minor example 4a in Inspection Manual Chapter 0612, Appendix E, which states that a procedural error (not performing required evaluations) is not minor if the licensee routinely failed to perform evaluations on similar issues.
Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The inspectors determined the significance to be Green because this finding does not represent a loss of system and/or function, does not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems out-of-service for greater than its technical specification allowed outage time, and does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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. On multiple occasions, personnel automatically defaulted to the assumption that an evaluation is never required for a system such as RBCLC because it is not a technical specification system, even though it has some safety-related and design basis functions.
Enforcement:
The inspectors did not identify a violation of regulatory requirements associated with this finding.
Minor Violation 71152B The inspectors reviewed a violation of 10 CFR 50.65(a)(3) that occurred when the most recent periodic maintenance evaluation exceeded the required interval of at least every refueling cycle. The periodic assessment required under 10 CFR 50.65(a)(3) evaluates the effectiveness of maintenance by considering industry operating experience and the need to balance equipment availability and reliability. The most recent assessment was due in January 2018, but because of challenges associated with transitioning the FitzPatrick Maintenance Rule process to the Exelon database, Engineering management made the decision to postpone the assessment. The licensee completed the assessment twelve months late and did not identify any necessary adjustments for the maintenance program.
The inspectors determined that Procedure PI-AA-120, Issue Identification and Screening Process, Revision 8 requires that conditions that have or could have an undesirable effect on performance of equipment, programs, or organizations or that are potential regulatory issues are properly documented and assigned to the corrective action program. Contrary to the guidance, the licensee did not document the decision to postpone the required periodic maintenance evaluation past the required due date in the corrective action program.
Screening: The inspectors evaluated this issue using IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues, and determined it was of minor significance because the answers to all screening questions were negative. The failure to perform the periodic evaluation by the required interval did not adversely affect the effectiveness of the maintenance program or the balance between the availability and reliability of equipment. Once it was completed, no adjustments to the maintenance program were required.
Enforcement:
This failure to comply with 10 CFR 50.65(a)(3) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Minor Performance Deficiency 71153 The inspectors identified a minor performance deficiency associated with Exelon procedure ER-AA-2003, System Performance Monitoring and Analysis, Revision 15 for the failure to properly monitor and communicate system conditions prior to the isolation of the normal reactor building ventilation system. This resulted in a reportable condition in accordance with 10 CFR 50.72 for reactor building differential pressure being greater than the Technical Specification 3.6.4.1 limit.
The licensee promptly documented the issue in the corrective action program as IR 4211279. Corrective actions include revisions to procedure OP-51A, Reactor Building Ventilation and Cooling System, Revision 52, to include steps for declaring secondary containment inoperable when manually isolating the reactor building ventilation system and increasing the normal differential pressure in secondary containment. The licensee documented the inspectors concerns in IR 4254148 to address the communications issues between Engineering and Operations that could have prevented the event.
Screening: The inspectors evaluated this issue using IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues, and determined it was of minor significance because they answered no to all screening questions. The condition existed for approximately 10 seconds and returned to within limits when the isolation sequence was completed. The differential pressure did not exceed 0, so there was no unmonitored exfiltration and no actual radiological release.
The disposition of this performance deficiency closes LER 05000333/2019-001-00.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 9, 2019, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action CAPE 4084456 Visual Weld Inspection Certification Expired 10/07/2017 January 29,
Documents 2018
71152B Corrective Action CAPE 4120968 Radiation Protection Human Performance Errors May 2, 2018
Documents
71152B Corrective Action CAPE 4124138 Safeguards material found outside approved storage May 4, 2018
Documents location
71152B Corrective Action CAPE 4130392 Level 3 Tagging Error during work on 71T-3 Load Tap May 23,
Documents Changer relay 62-TD 2018
71152B Corrective Action CAPE 4137227 Alpha Reactor Recirculation Generator Failure May 13,
Documents 2018
71152B Corrective Action CAPE 4162425 Maintenance & Technical Training Programs INPO Team August 24,
Documents Identified Finding 2018
71152B Corrective Action CAPE 4164618 13LS-76B found OOT and Unable to Reset October 7,
Documents 2018
71152B Corrective Action CAPE 4181884 B RWR MG Set Tripped During Tuning October 9,
Documents 2018
71152B Corrective Action CAPE 4200410 Failure of Running Air Compressor April 1, 2019
Documents
71152B Corrective Action 4242812 Spring Can Bottomed Out April 23,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4242824 NRC Identified - Cover for Disconnect Switch is Hanging April 22,
Documents Open 2019
Resulting from
Inspection
71152B Corrective Action 4242826 PRM 17-04-8B Cabinet Has Broken Doors April 23,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4242832 Evidence of Boron in Packing for 11SLC-752A April 23,
Documents 2019
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
71152B Corrective Action 4242834 Evidence of Boron in Packing for 11SLC-752B April 23,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4242967 D EDG Thermocouple April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4242970 B EDG Annunciator Window Damaged April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4242972 B EDG Annunciator Window Damaged April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4242981 B EDG Run Indicator Window Damaged April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243019 Fluid on Instrument Battery Cells April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243048 Walkdown Housekeeping Items - RCIC Room April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243120 Ladder in TB 252 NE Not Secured April 24,
Documents 2019
Resulting from
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 4243123 Small Cracks on Charger Pedestal April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243161 Small Gap Between Two Cells and Side Rail April 24,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243387 Red Duct Tape Around LHRA Door Seal April 25,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243390 Housekeeping Issues in RCIC Room April 25,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243467 EDG A Flywheel has Approx. 6 Chipped Teeth April 25,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4243666 Loose Door Knob on the W Water Box Door April 26,
Documents 2019
Resulting from
Inspection
71152B Corrective Action 4245107 Functionality Review Not Performed May 1, 2019
Documents
Resulting from
Inspection
71152B Corrective Action 4247092 NRC Identified CA From CR-JAF-2016-1766 Not Still in May 7, 2019
Documents Place
Resulting from
Inspection
71152B Miscellaneous NCV Control Room Emergency Ventilation Air Supply (CREVAS) August 7,
05000333/2017002- System 2017
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Miscellaneous NCV Inadequate Design Control for Battery Sizing Calculation February 14,
05000333/2017004- 2018
71152B Miscellaneous NCV Human Error Resulting in Unplanned HPCI Isolation February 14,
05000333/2017004- 2018
71152B Miscellaneous NCV Employee not in the FFD Follow-up Program April 30,
05000333/2018411- 2018
71152B Miscellaneous NCV Failure to Report a Programmatic Failure in the FFD April 30,
05000333/2018411- Program 2018
71152B Miscellaneous NCV Failure to Control Safeguards Information October 10,
05000333/2018412- 2018
71152B Procedures EN-LI-102 Corrective Action Program Revision 26
71152B Procedures EN-OP-104 Operability Determination Process Revision 7
71152B Procedures OP-51A Reactor Building Ventilation and Cooling System Revision 52
71152B Procedures OP-AA-1 Conduct of Operations Revision 1
71152B Procedures OP-AA-101-111- Operations Standards and Expectations Revision 22
1001
71152B Procedures OP-AA-108-111 Adverse Condition Monitoring and Contingency Plan Revision 13
71152B Procedures OP-AA-108-115 Operability Determinations Revision 21
71152B Procedures PI-AA-120 Issue Identification and Screening Process Revision 8
71152B Procedures PI-AA-125 Corrective Action Program (CAP) Procedure Revision 6
71152B Procedures PI-AA-125-1001 Root Cause Analysis Manual Revision 3
71152B Procedures PI-AA-125-1003 Corrective Action Program Evaluation Manual Revision 4
71152B Procedures PI-AA-125-1004 Effectiveness Review Manual Revision 2
71152B Self-Assessments NOSA-JAF-18-01 Maintenance Functional Area Audit Report March 26,
2018
71152B Self-Assessments NOSA-JAF-18-03 Emergency Preparedness Audit Report April 25,
2018
71152B Self-Assessments NOSA-JAF-18-04 Chemistry, Radwaste, Effluent and Environmental August 1,
Inspection Type Designation Description or Title Revision or
Procedure Date
Monitoring Audit Report 2018
71152B Self-Assessments NOSA-JAF-18-05 Engineering Programs and Station Blackout Audit Report May 9, 2018
71152B Self-Assessments QA-12-18-2017-
JAF-1 Audit 2017
71152B Self-Assessments QA-14-2017-JAF-1 Radiation Protection July 27,
2017
71152B Self-Assessments QA-16-2016-JAF-1
- J.A. Fitzpatrick Security, Information Technology and December 6,
Regulatory Assurance Audit Report 2016
71152B Self-Assessments QA-19-2017-JAF-1
2017
71152B Self-Assessments QA-2-6-15-2017- Chemistry, Effluents, Environmental Monitoring and Rad September
JAF-1 Waste 12, 2017
71152B Self-Assessments QA-4-2017-JAF-1 Engineering Design Control Quality Assurance Audit August 16,
Report 2017
71152B Self-Assessments QA-7-2017-JAF-1 Emergency Preparedness Quality Assurance Audit Report April 17,
2017
71152B Self-Assessments QA-8-2017-JAF-1 Engineering Programs Quality Assurance Audit Report February 22,
2017
71152B Self-Assessments QA-9-2017-JAF-1
2017
13