IR 05000333/2019011
| ML19241A380 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/29/2019 |
| From: | Mel Gray Engineering Region 1 Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Gray M | |
| References | |
| IR 2019011 | |
| Download: ML19241A380 (14) | |
Text
August 29, 2019
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000333/2019011
Dear Mr. Hanson:
On August 1, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Mr. Timothy Peter, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at 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/
Mel Gray, Chief Engineering Branch 1 Division of Reactor Safety
Docket No. 05000333 License No. DPR-59
Enclosure:
As stated
Inspection Report
Docket Number:
05000333
License Number:
Report Number:
Enterprise Identifier: I-2019-011-0022
Licensee:
Exelon Generation Company, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Scriba, NY
Inspection Dates:
July 14, 2019 to August 3, 2019
Inspectors:
J. Schoppy, Senior Reactor Inspector (Team Lead)
F. Arner, Senior Reactor Analyst
C. Baron, NRC Mechanical Contractor
N. Floyd, Senior Reactor Inspector
J. Kulp, Senior Reactor Inspector
H. Leake, NRC Electrical Contractor
Approved By:
Mel Gray, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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.
List of Findings and Violations
Failure to Include Appropriate Correction Factors for Lake Level in Emergency Service Water Test Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2019011-01 Open/Closed None (NPP)71111.21M The team identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control. Specifically, Exelon failed to include appropriate correction factors for lake level in procedure ST-8Q, Emergency Service Water (ESW) Comprehensive Pump Test (IST), Revision 51. This failure resulted in non-conservative acceptance criteria for ESW flowrates to safety-related components.
Additional Tracking Items
None.
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.
REACTOR SAFETY
===71111.21M - Design Bases Assurance Inspection (Teams)
The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (5 Samples)
(1)4.16KV Bus 10600 (71H06)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance effectiveness and records, and corrective action history
Control logic
Design calculations
Surveillance testing and recent test results
Environmental conditions
Contactor and fuse ratings; Component adequacy for minimum voltage
Equipment protection from fire, flood, and water intrusion or spray
The team used Appendix B guidance for Instrumentation, Circuit Breakers and Fuses, Cables, Electric Loads, and Motor Control Centers (MCCs).
- (2) B Emergency Diesel Generator (Electrical)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance effectiveness and records, and corrective action history
Control logic
Design calculations Surveillance testing and recent test results
Environmental conditions
Contactor and fuse ratings; Component adequacy for minimum voltage
Protection coordination; Load in-rush and full load current
Range, accuracy, and setpoint of installed instrumentation
Equipment protection from fire, flood, and water intrusion or spray
The team used Appendix B guidance for Instrumentation, Circuit Breakers and Fuses, Cables, Electric Loads, and As-Built System.
- (3) A Emergency Service Water Pump (46P-2A)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance effectiveness and records, and corrective action history
Equipment/environmental controls and qualification
Design calculations
Surveillance testing and recent test results
System and component level performance monitoring
Equipment protection from fire, flood, and water intrusion or spray
Heat removal cooling water and ventilation
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-Built System.
- (4) Fire Protection Piping Integrity to Preclude and/or Mitigate Internal Flooding in the Relay Room, Battery Corridor, or North Tunnel
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance effectiveness and records, and corrective action history
Operator actions
Design calculations
Surveillance testing and recent test results
Equipment protection (sealing of cable and conduits)
Equipment protection from fire, flood, and water intrusion or spray
Verify that component degradation is monitored
The team used Appendix B guidance for Valves, Instrumentation, and As-Built System.
- (5) High Pressure Coolant Injection Pump and Turbine
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance effectiveness and records, and corrective action history
Equipment/environmental controls and qualification
Design calculations
Surveillance testing and recent test results
System and component level performance monitoring
Equipment protection from fire, flood, and water intrusion or spray
Heat removal cooling water and ventilation
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-Built System.
Design Review - Large Early Release Frequency (LERF) (IP Section 02.02)===
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance effectiveness and records, and corrective action history
Equipment/environmental controls and qualification
Operator actions
Design calculations
Surveillance testing and recent test results
Equipment protection (sealing of cable and conduits)
Equipment protection from fire, flood, and water intrusion or spray
The team used Appendix B guidance for Valves, Instrumentation, Cables, Electric Loads, and As-Built System.
Modification Review - Permanent Mods (IP Section 02.03) (4 Samples)
- (1) Replacement of Valve Stem and Wedge Pin for Anchor-Darling Double Disc Gate Valves (EC 0000624991)
- (2) Evaluation of Code Reconciliation of Later Code Years for Use of Revised Allowable Stresses (EC 0000625045)
(3)10MOV-89A/B Replacement (EC 9000067365)
9000017249) Review of Operating Experience Issues (IP Section 02.06)
- (1) NRC Information Notice 2018-07: Pump/Turbine Bearing Oil Sight Glass Problems
- (2) Electroswitch Corporation 10 CFR Part 21 (EN 51915)
INSPECTION RESULTS
Failure to Include Appropriate Correction Factors for Lake Level in Emergency Service Water Test Procedures Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000333/2019011-01 Open/Closed
None (NPP)71111.21M The team identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control. Specifically, Exelon failed to include appropriate correction factors for lake level in procedure ST-8Q, Emergency Service Water (ESW) Comprehensive Pump Test (IST), Revision 51. This failure resulted in non-conservative acceptance criteria for ESW flowrates to safety-related components.
Description:
The team reviewed test procedure ST-8Q, Emergency Service Water (ESW)
Comprehensive Pump Test (IST), Revision 51. In addition to evaluating the test results for in-service test acceptance criteria, Exelon staff used the test procedure to evaluate if flow was adequate to supplied ESW components. The team noted that ST-8Q, Attachment 4 included correction factors to account for the differences between test conditions and ESW system design conditions. These correction factors were applied to the design flows for each component to establish target flows to be used as acceptance criteria for the ESW system comprehensive test. The team noted that the correction factor for lake level for the emergency diesel generator jacket water heat exchangers was listed as 0 and questioned this factor as, based on the system design and engineering principles, the ESW flow through the emergency diesel generator jacket water heat exchangers should vary directly with lake level (the ESW pump suction source). Subsequently, upon further review, engineering determined that the correction factor was incorrect. The incorrect coefficient was the result of an error in calculation 01-107, Emergency Service Water Flow Response to Variations in Lake Level, Strainer Differential Pressure and Pump Speed, Revision A. The results of this calculation were used in calculation JAF-CALC-SWS-00621, Flow Equations for ST-8Q Acceptance Criteria, Revision 3, to develop correction factors for the subject test procedure.
The incorrect factors were also included in Attachment 3 of test procedures ST-8QA, Testing of ESW Loop A (IST), Revision 4, and ST-8QB, Testing of ESW Loop B (IST), Revision
4. On July 30, 2019, Exelon staff initiated a corrective action issue report (AR 04268131) to
address this issue.
During the inspection, Exelon engineering personnel reviewed recent comprehensive ESW test results and determined that in several cases ESW flows to some safety-related components would have had negative margin if appropriate correction factors for lake level had been applied. In accordance with test procedure ST-8Q, failure to meet target component flows would have required additional engineering evaluation or testing to verify operability. Exelon engineering personnel reviewed lake level data from August 2014 through July 2019 and determined that the minimum lake level was approximately 243 feet, similar to the actual lake level during the most recent ESW system comprehensive test. Engineering staff determined that based on this historical data that there was no loss of operability or functionality due to this finding during this time period. The team found these conclusions to be reasonable. The team noted that the licensee accepted vendor calculation 01-107 on January 21, 2002, and did not identify the calculation errors that led to non-conservative correction factors at that time.
Corrective Actions: Exelon personnel entered the issue into their corrective action program and performed an evaluation to determine the impact of these errors. Exelons evaluation provided reasonable assurance that the ESW system was operable.
Corrective Action Reference: Action Request 04268131
Performance Assessment:
Performance Deficiency: The team determined that the failure to include appropriate correction factors for lake level in ESW test procedures was a performance deficiency that was reasonably within the licensees ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to include appropriate correction factors for lake level in ESW test procedures resulted in in non-conservative acceptance criteria for ESW flowrates to safety-related components. Additionally, the performance deficiency was similar to IMC 0612, Appendix E, Example of Minor Issues, Question 3.J in that there was reasonable doubt of operability of the ESW system because non-conservative acceptance criteria could have resulted in inadequate ESW flow to safety-related equipment under design basis lake level conditions.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was evaluated using the significance determination process in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings. Because the finding impacted the Mitigating Systems cornerstone, the team screened the finding through IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, using Exhibit 2, Mitigating Systems Screening Questions. The finding was determined to be of very low safety significance because it was a design deficiency confirmed not to result in a loss of operability.
Cross-Cutting Aspect: Not Present Performance. No cross cutting aspect was assigned to this finding because the inspectors determined the finding involved a historical design issue not indicative of current performance. Specifically, the associated ESW hydraulic model (including calculation 01-107) was not changed within the last three years and there was no recent operating experience that was directly applicable to the performance deficiency.
Enforcement:
Violation: The team identified a violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Contrary to the above, between January 21, 2002, and July 30, 2019, Exelon did not establish measures to assure that regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, Exelon failed to include appropriate correction factors for lake level in procedure ST-8Q Emergency Service Water (ESW) Comprehensive Pump Test (IST), Revision 51.
Enforcement Action: This violation is being treated as a non-cited violation, 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 August 1, 2019, the inspectors presented the design basis assurance inspection (teams) results to Mr. Timothy Peter, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Assessment of the Emergency Service Water System to
Provide Minimum Required Safety Related Flows with the
Valves 15MOV-102 and 15MOV-103 Open
A
JAF-CALC-09-
00016
JAF Auxiliary Power System Analysis
JAF-CALC-11-
00002
James A. Fitzpatrick Fast Bus Transfer Analysis
JAF-CALC-EDG-
03358
JAF Single Emergency Diesel Generator Loading
Corrective Action
Documents
AR 04073961
AR 04156632
AR 04160340
AR 04224342
AR 04252625
AR 04263528
AR 04264855
AR 04266746
CR-JAF-2010-
03689
CR-JAF-2016-
244
Corrective Action
261707
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
264295
264535
264577
264651
264656
264855
264864
264891
264926
264929
265097
265126
265259
265514
267249
267262
267278
267291
268131
268271
268900
Drawings
Service Water Piping - Screen Well & Tunnels
Engineering
Changes
2093
EC for Replacement of EQ Electroswitch Branded Isolation
Switches Currently Installed in Reliance Electric Safe
Shutdown Panels
67365
R22: 10MOV-89A/B Replacement
Engineering
Evaluations
JAF-RPT-12-
00001
JAF 115 kV Bus Voltage Evaluation with Replacement
115/4.16kV Transformers (71T-2 and 71T-1)
Internal Flood Evaluation Summary Notebook
Miscellaneous
PES-S-006
Procedures
MOV Post Maintenance Test Matrix
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Constant Level Oiler and Sight Glass Maintenance
High Pressure Coolant Injection
HPCI Quick-Start, Inservice, and Transient Monitor Test (IST)
1/21/14 and
7/24/19
Testing of the Emergency Service Water System (IST)
performed
4/13/19