IR 05000333/2021013
| ML21217A068 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/11/2021 |
| From: | Erin Carfang NRC/RGN-I/DORS |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2021013 | |
| Download: ML21217A068 (15) | |
Text
August 11, 2021
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2021013
Dear Mr. Rhoades:
On July 1, 2021, 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. Tim Peter, 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant.
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 James A. FitzPatrick Nuclear Power Plant.
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: 2021.08.11 Carfang 12:29:28 -04'00'
Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000333 License No. DPR-59
Enclosure:
As stated
Inspection Report
Docket Number: 05000333 License Number: DPR-59 Report Number: 05000333/2021013 Enterprise Identifier: I-2021-013-0016 Licensee: Exelon Nuclear Facility: James A. FitzPatrick Nuclear Power Plant Location: Oswego, NY Inspection Dates: June 14, 2021 to July 01, 2021 Inspectors: G. Stock, Senior Resident Inspector J. DeBoer, Senior Project Engineer J. England, Resident Inspector C. Khan, Senior Project Engineer 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 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.
List of Findings and Violations
Failure to Correct a Condition Adverse to Quality for Fuel Failures Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.12] - Avoid 71152B NCV 05000333/2021013-01 Complacency Open/Closed The inspectors identified a self-revealed, Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,
Criterion XVI, Corrective Action, when Exelon did not correct a condition adverse to quality.
Specifically, Exelon did not plan or complete required maintenance on the condensate booster pump check valves whose failure had previously resulted in fuel failures.
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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) 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
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness -
The inspectors determined that Exelons problem identification and resolution program adequately supported nuclear safety and security.
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 the review of issue reports (IRs) generated during the inspection period, the inspectors noted an appreciable reduction in the quantity of IRs generated during the COVID-19 public health emergency. The inspectors did not identify additional safety significant issues that had not been captured in the corrective action program.
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 IRs for operability and reportability, categorized IRs by significance, and assigned actions to the appropriate department for evaluation and resolution.
Corrective Actions: The inspectors determined that, in general, 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.
However, the inspectors identified one Green NCV and two minor performance deficiencies associated with IRs 4369128, 4290066, and 4351989 respectively. These performance deficiencies pertain to resolving issues identified and evaluated in the corrective action program and are documented below.
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. In general, the team concluded that Exelon had an effective self-assessment and audit process.
However, the inspectors noted that previously identified NRC finding 05000333/2020001-02 had not been thoroughly reviewed for adequacy of evaluation and completion of corrective actions during Exelon's self-assessments. This issue is being documented as a Green NCV in the results section below.
Assessment 71152B Safety Conscious Work Environment -
The team interviewed site personnel across different functional areas to determine the adequacy of the safety conscious work environment. 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, Chemistry, Radiation Protection, and Emergency Preparedness work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) Coordinator to assess their 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. In general, 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.
Failure to Correct a Condition Adverse to Quality for Fuel Failures Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.12] - Avoid 71152B NCV 05000333/2021013-01 Complacency Open/Closed The inspectors identified a self-revealed, Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, when Exelon did not correct a condition adverse to quality. Specifically, Exelon did not plan or complete required maintenance on the condensate booster pump check valves whose failure had previously resulted in fuel failures.
Description:
FitzPatrick has a series of pumps to transfer reactor water from the condenser to the reactor vessel for core cooling and steam production. There are three condensate pumps which supply water to three condensate booster pumps (CBPs) which supply water to two feedwater pumps. Each set of pumps has a discharge check valve to ensure pumps do not receive reverse flow when a pump is secured. On June 24, 2016, the C CBP catastrophically failed due to reverse flow when the C CBP discharge check valve failed. This catastrophic failure introduced foreign material into the reactor coolant system which led to five fuel failures during the following fuel cycle that ended September 10, 2018.
The inspectors previously reviewed IR 4097375 which was initiated to perform a root cause evaluation of the fuel failures. Exelon determined that the maintenance procedure had inadequate detail for securing the CBP discharge pump check valve stem nut to the stem disc. The corrective actions included an update to the maintenance procedure to provide additional clarity, a repair of the C check valve, and scheduling of the repairs of A and B check valves. This review resulted in a self-revealed, Green finding and associated NCV of Technical Specification 5.4.1, Procedures, when Exelon did not maintain adequate guidance for securing the stem nut to the stem disc of condensate check valves, which resulted in a check valve failure, CBP failure, and subsequent fuel failures. Exelon generated IR 4341410 as a result of the NCV. See NRC inspection report 05000333/2020001, dated April 28, 2020 (ML20119A050), for additional details.
Among other assignments, IR 4341410 included an action to determine if corrective actions were completed or in place to address all aspects of the violation to prevent re-occurrence.
This assignment was marked as complete on June 13, 2020. On September 13, 2020, during the shutdown to enter the R24 refueling outage, the B CBP discharge check valve failed, resulting in reverse flow through the B CBP. Issue Report 4369128 was initiated to perform a corrective action program evaluation (CAPE) to evaluate this issue. The CAPE found that the actions from IR 4097375 from the 2016 C CBP check valve failure had not been completed or planned. Therefore, the actions from IR 4341410, which was generated in response to an NRC-issued NCV to verify these actions were completed or planned, was incorrectly marked as complete and no actions remained to ensure the required corrective actions to prevent future fuel failures would be completed.
Corrective Actions: Following the failure of the 'B' CBP discharge check valve in September 2020, Exelon secured the stem nut to the stem disc using the updated procedure during the R24 refueling outage.
Corrective Action References: 4097375, 4341410, 4369128
Performance Assessment:
Performance Deficiency: Exelon did not correct a condition adverse to quality as required by 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and was determined to be a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Cladding 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.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined the significance to be Green because this finding did not involve control manipulations that unintentionally added positive reactivity, did not result in a mismanagement of reactivity by operators that challenged fuel cladding integrity, and did not result in the mismanagement of foreign material exclusion or reactor coolant chemistry control program that challenged fuel cladding integrity.
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. Specifically, the closure of IR 4341410 provided Exelon the opportunity to recognize the failure to complete or plan the corrective actions associated with IR 4097375. Exelon did not recognize this mistake, which resulted in the failure of the 'B' CBP discharge check valve in the same manner that in 2016 resulted in fuel failures.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, states, in part, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to this requirement, prior to September 2020, Exelon did not adequately establish measures to assure that conditions adverse to quality were identified and corrected, in that maintenance on the CBP check valves that could affect the performance of safety-related equipment such as the reactor fuel cladding, was not preplanned. Specifically, IRs 4341410 and 4369128 were closed without corrective maintenance being scheduled or performed. The corrective maintenance was determined to be required to prevent a catastrophic failure of CBP and the introduction of foreign material from the pump and discharge check valve into the safety related reactor coolant system.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71152B Minor Violation: The inspectors determined that Exelon did not prescribe documented instructions of a type appropriate to the circumstances for an activity affecting quality associated with their maintenance procedure for 4.16 kV Magna-Blast breakers. Contrary to 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, Exelon's maintenance procedure, MP-054.01, 4.16 kV Magna-Blast Breakers, did not have sufficient detail. Specifically, step 8.32.1, states, check latching pawl spring retainer plate bolts are tight, which would not ensure the retaining bolts would remain tight and secured under all operating conditions until the next performance of the maintenance procedure as demonstrated on the 4.16 kV 'D' residual heat removal (RHR) breaker in October 2019.
Screening: The inspectors determined the performance deficiency was minor. The failure to adequately specify instructions to ensure the pawl latch bolts are tight and remain secure in the procedure is minor, because it did not adversely affect any cornerstones objectives, did not lead to a more significant safety concern, and was not a precursor to a more significant event. Specifically, a loose pawl latch support bolt was found inside a breaker cabinet in October 2019 and did not impact the operability of the 4.16 kV 'D' RHR breaker from performing its safety function.
Enforcement:
This failure to comply with 10 CFR Part 50, Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Minor Violation 71152B Minor Violation: The inspectors determined that Exelons failure to revise procedure MA-AA-716-237, CDA Work Activity Process, is contrary to 10 CFR 73.55(b)(10), General Requirements, that was reasonably within Exelons ability to foresee and correct and was a performance deficiency. Specifically, IR 4351989, Assignment 4 included actions to revise MA-AA-716-237 to include guidance on the requirement to perform a baseline audit of critical digital assets onsite. The assignment was closed without a revision being completed, which could lead to the failure to include guidance for the requirement for a baseline audit in a future revision to the procedure.
Screening: The inspectors determined the performance deficiency was minor. The failure to adequately revise procedure MA-AA-716-237 is minor, because it did not adversely affect any cornerstone objectives, did not lead to a more significant safety concern, and was not a precursor to a more significant event. Specifically, a failure to include the guidance for a baseline audit of critical digital assets onsite does not constitute an adverse impact to the cyber security program.
Enforcement:
This failure to comply with 10 CFR 73.55(b)(10) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 1, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Tim Peter, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or Date
Procedure
71152B Corrective Action 4088255, 4172631,
Documents 4172786, 4181419,
203649, 4209610,
214072, 4214685,
217452, 4217456,
217461, 4217469,
235204, 4242588,
242812, 4242967,
243175, 4243309,
243467, 4245107,
248381, 4249285,
252619, 4252625,
254542, 4255339,
259118, 4259960,
261157, 4263641,
264673, 4266594,
266619, 4268075,
272535, 4272607,
275996, 4277359,
278000, 4280784,
283131, 4284016,
286038, 4286782,
287157, 4288680,
290066, 4290155,
295495, 4298887,
4301960, 4303018,
4303614, 4310346,
4314313, 4333464,
4334577, 4335845,
4340861, 4342700,
4347674, 4347868,
4351640, 4351989,
Inspection Type Designation Description or Title Revision or Date
Procedure
4351992, 4352172,
4352692, 4356688,
4362198, 4368023,
4369253, 4370217,
4371328, 4377749,
4384096, 4387104,
4391081, 4391085,
4391086, 4391691,
4399580, 4403261,
4403310, 4403583,
4403584, 4406839,
4406877, 4408097,
4416039, 4416224,
4416476, 4416743,
21382
Corrective Action 4429725, 4429750,
Documents Resulting 4429931, 4429938,
from Inspection 4429973, 4431571,
4432229, 4432231,
4432253, 4432254,
4432404, 4432510,
4432529, 4432708,
4433131
Miscellaneous 4155642-52 Perform a Level 3 OPEX Review L3- 04/26/2019
19-3 Unplanned Dose Rate
4383175, 4369885 NRC IN 2020-03 Recall of Edwards 12/09/2020
135 Degree Heat Detectors
4406799, 4336123 Part 21 - SF-1154 Degraded Snubber 04/04/2021
Hydraulic Fluid
4155642-53 Surry Control Room Chiller Service 04/19/2019
Water Pump Outlet Valve Identified
Closed versus Open
256218 NRC IN 2019-02: EDG Excitation 06/12/2019
System Diode Failures
Inspection Type Designation Description or Title Revision or Date
Procedure
291213-02 10CFR21 Reporting of Defects and 10/24/2019
Non-Compliance for EMD Fuel
Injector - seized plunger and bushing
4307626-03 Reportable Occurrence under 12/23/2019
10CFR21: Reported Failure in
Analog High Range Radiation
Monitor (RP-2)
4359360-02 IER L2-20-05, Ineffective Use of 10/06/2020
Operating Experience Challenges
FLEX Mitigation Strategies
4369686-02 NRC Information Notice 2020-02, 10/06/2020
FLEX Diesel Generator Operational
Challenges
4391803-03 NRC Information Notice 2020-04 12/23/2020
Operating Experience Related to
Failure of Buried Fire Protection Main
Yard Piping
4407914 Part 21 - Failure of Main Steam 03/10/2021
Isolation Valve Air Packs
Procedures MP-054.01 4.16 KV MAGNE-BLAST BREAKER 34
MP-054.03 4.16 KV MAGNE-BLAST BREAKER 9
OVERHAUL
OU-AA-101-1002 High Impact (HIT) Teams 8
PI-AA-115 Operating Experience Program 5
PI-AA-120 Issue Identification and Screening 11
Process
PI-AA-125 Corrective Action Program (CAP) 7
Procedure
PI-AA-125-1001 Root Cause Analysis Manual 6
PI-AA-125-1003 Corrective Action Program Evaluation 6
Manual
PI-AA-125-1006 Investigation Techniques Manual 5
Self-Assessments 4231579 10 CFR 50.65 (a)(3) Periodic 04/26/2019
Assessment (Maintenance Rule),
Inspection Type Designation Description or Title Revision or Date
Procedure
November 15 to March 2019
4315062 Chemistry Self Assessment for 06/05/2020
Program Oversight
4371929 JAF 2020 In Storage Maintenance 12/30/2020
Assessment
4088157 IST/APP J Self Assessment 12/29/2017
4088171 Maintenance Rule Self Assessment 10/31/2020
216474 Raw Water Piping Integrity 09/17/2019
Management Program
217856 Clearance and Tagging Self 06/11/2019
Assessment
246072 Maintenance Rule A3 Assessment 05/07/2021
4310717 Maintenance Rule (a)(3) Periodic 04/23/2021
Maintenance Effectiveness
Assessment (4/1/19 - 3/31/21)
4312967 Conduct of Maintenance
NOSA-JAF-19-05 J. A. FITZPATRICK ENGINEERING 08/21/2019
DESIGN CONTROL AUDIT
REPORT, PLAN AND TECHNICAL
SPECIALIST ORIENTATION GUIDE
NOSA-JAF-20-03 Emergency Preparedness Audit 04/22/2020
Report
NOSA-JAF-20-05 J. A. FITZPATRICK ENGINEERING 06/10/2020
PROGRAMS AUDIT REPORT, PLAN
AND TECHNICAL SPECIALIST
2