IR 05000333/2022003
| ML22313A124 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/10/2022 |
| From: | Erin Carfang Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2022003 | |
| Download: ML22313A124 (1) | |
Text
November 10, 2022
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2022003
Dear David Rhoades:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On November 3, 2022, the NRC inspectors discussed the results of this inspection with Timothy Peter and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, 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:
Report Number:
Enterprise Identifier: I-2022-003-0032
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
July 1, 2022 to September 30, 2022
Inspectors:
E.D. Miller, Senior Resident Inspector
J. England, Resident Inspector
J. Ambrosini, Senior Emergency Preparedness Inspector
H. Anagnostopoulos, Senior Health Physicist
S. Haney, Senior Project Engineer
M. Hardgrove, Senior Project Engineer
C. Hobbs, Reactor Inspector
C. Kline, Resident Inspector
J. Kulp, Senior Reactor Inspector
E.C. Miller, Reactor Inspector
Approved By:
Erin E. Carfang, Chief
Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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 Identify Degraded Reactor Building Water Spray Curtain Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2022003-01 Open/Closed
[H.11] -
Challenge the Unknown 71111.15 The inspectors identified a Green finding and associated non-cited violation (NCV) of License Condition 2.C(3) of the FitzPatrick Operating License because Constellation did not identify a stairwell handrail as an external interference that affected the spray pattern of a sprinkler in water spray curtain 5. Specifically, Constellation did not conduct inspections of water spray curtain 5 in accordance with FitzPatrick inspection procedure ST-76KA, Integrity Inspection of FP Water System and SGT Filter Train A FP System.
Unevaluated Scaffold in Contact with Safety-Related Equipment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2022003-02 Open/Closed
[H.1] -
Resources 71111.20 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because Constellation personnel did not adequately accomplish scaffold construction in accordance with approved scaffold control procedures. Specifically, the inspectors identified three scaffolds in direct contact with safety-related equipment without engineering and operations evaluation.
Additional Tracking Items
None.
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On July 16, 2022, FitzPatrick began end of cycle coastdown. On September 26, 2022, operators removed FitzPatrick from service to commence refueling outage 25 (J1R25). While conducting the shutdown, FitzPatrick received an unexpected scram signal. FitzPatrick remained offline for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding in the east pipe tunnel on July 12, 2022.
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'B' & 'D' emergency diesel generator (EDG) support systems during 'A' EDG monthly test on July 5, 2022
- (2) Fire protection system water piping in the reactor building, turbine building, screenwell, and major header valves during the weeks of July 4 and 11, 2022
- (3) High-pressure coolant injection system on July 27, 2022
- (4) Containment venting on August 8, 2022 (5)
'B' shutdown cooling on September 26, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection (IP Section 03.01) (8 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) Reactor building 369', 344', 326', 300', and 272', fire area/zone 1A/RB-1A, on July 1, 2022
- (2) East crescent, fire area/zone XVII/RB-1E, on July 12, 2022
- (3) East cable tunnel 258', fire area/zone II/CT-2 on July 29, 2022
- (4) West cable tunnel 258', fire area/zone 1C/CT-1 on July 29, 2022
- (5) East pipe tunnel 258', fire area/zone XIX/RW-1 on August 5, 2022
- (6) Drywell, fire area/zone XIV/PC-1 on September 26, 2022
- (7) Main steam tunnel, fire area/zone IA/MG-1, on September 26, 2022
- (8) Turbine building 252', 272', and 300', fire area/zone IE/TB-1, on September 27, 2022
Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on July 7, 2022.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) 66UC-22B, east crescent unit cooler
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed the reactor shutdown to the refueling outage on September 24 and 25, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated operator performance during a simulator evaluation which included a core spray pump failure, an inadvertent safety relief valve opening, a loss of the 10600 emergency bus, and a torus leak on August 16, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Emergency diesel generators on July 6, 2022
- (2) Primary containment atmosphere control and dilution on July 29, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Radial deep groove ball bearings associated with emergency service water pump room fan 73FN-3B on September 22, 2022
Aging Management (IP Section 03.03) (2 Samples)
The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:
- (1) East pipe tunnel, turbine building 252', on July 6, 2022
- (2) Internal drywell structure on September 29, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01) (4 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) Elevated risk due to load tap changer trouble alarm on 115KV T-2 transformer on July 7, 2022
- (2) Emergent risk following south screenwell safety pump room fan 73FN-3B failure to run on July 27, 2022
- (3) Elevated risk during reactor cavity flood-up on September 27, 2022
- (4) Elevated drain down risk during control rod drive mechanism exchanges on September 29, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Functionality assessment of the water curtain between the reactor building and east crescent on July 11, 2022 (2)
'B' control room emergency ventilation air system charcoal on August 3, 2022 (3)
'B' emergency service water and 'B' and 'D' residual heat removal service water pumps following pump room fan 73FN-3B failure on July 27 and August 10, 2022
- (4) Reactor mode switch following possible failure to make full contact on transition to Mode 2 on September 26, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (2) Permanent Modification: Engineering Change 634574, Replacement of 72TIC-122B and Related Equipment
- (3) Permanent Modification: Engineering Change 634221, Decay Heat Removal System Power Supply Modification
71111.19 - Post-Maintenance Testing
Post-Maintenance Test (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Replacement of high-pressure coolant injection fire foam isolation valve solenoid 76SOV-132 on July 25, 2022
- (2) Decay heat removal system power source upgrade on September 20, 2022 (3)
'A' station battery modified performance test following breaker replacement and battery board preventive maintenance on September 29, 2022
- (4) Cable 1YL1NNC078 (345 kilovolt breaker 71PCB-10052 trip coil 1) following evaluation of chemical substance on September 30, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage (IP Section 03.01) (1 Partial)
- (1) The inspectors evaluated refueling outage J1R25 activities from September 26, 2022 through September 30, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (2) ST-21A and ST-21E Main Turbine Overspeed Tests on September 26, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) ST-39B-X7(A-D), Type C Leak Test Main Steam Line (A-D) LLRT (IST), on September 26, 2022
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated Constellation's maintenance and testing of the alert and notification system on August 8 through August 12, 2022, for the period of September 2021 through July 2022.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Constellation's emergency preparedness organization on August 8 through August 12, 2022.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
- 21-26, EP-AA-1014 Addendum 3, James A. FitzPatrick Nuclear Power Plant Emergency Action Levels, Revision 3 and EP-AA-1014 Addendum 3, Appendix 1, JAF EAL Wallboard, Revision 2
- 21-71, EP-AA-1014 Addendum 3, James A. FitzPatrick Nuclear Power Plant Emergency Action Levels, Revision 4
- 22-34, EP-AA-122-100, Drill and Exercise Planning and Scheduling, Revision 11
This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated Constellation's maintenance and testing of the emergency preparedness program on August 8 through August 12, 2022, for the period of September 2021 through July 2022.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) The inspectors evaluated the conduct of a routine FitzPatrick and Nine Mile Point emergency response drill that involved a reactor coolant leak due to a leaking safety relief valve at FitzPatrick on August 2,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Control of personnel and material entering and exiting the drywell contamination area at the drywell escape hatch control point
- (2) Egress of personnel and material at the 272' elevation administration building radiation controlled area access point
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Installation of main steam line plugs into the reactor vessel from the refueling bridge
- (2) Repairs to the 33E-4B feedwater heater in the north heater bay
- (3) Work area setup for removal of control rod drive mechanisms under-vessel
- (4) Initial surveys to support the erection of scaffolding and the removal of insulation in the main condenser bay
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Initial entry, survey and down-posting of the 252' elevation north steam tunnel
- (2) High radiation area controls for the 272' elevation reactor traversing in-core probe room
- (3) High radiation area controls for the drywell control rod drive removal access hatch
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===
- (1) July 1, 2021 through June 30, 2022
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)
- (1) July 1, 2021 through June 30, 2022
EP01: Drill/Exercise Performance (IP Section 02.12) (1 Sample)
- (1) July 1, 2021 through June 30, 2022 EP02: Emergency Response Organization Drill Participation (IP Section 02.13) (1 Sample)
- (1) July 1, 2021 through June 30, 2022
EP03: Alert and Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) July 1, 2021 through June 30, 2022
===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) Issue Report (IR) 04449171 - Failure of the Reactor Core Isolation Cooling Steam Line Break Detection Differential Pressure Transmitter (13DPT-84) to Calibrate During the Performance of ISP-251B on September 27, 2021
71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated the 'B' reactor water recirculation motor generator set lockup and the licensees performance on July 20, 2022.
- (2) The inspectors evaluated the 'A' 125-volt direct current station battery ground and the licensees performance on August 20, 2022.
- (3) The inspectors evaluated operator performance following a reactor scram on Group 1 isolation on September 26,
INSPECTION RESULTS
Failure to Identify Degraded Reactor Building Water Spray Curtain Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000333/2022003-01 Open/Closed
[H.11] -
Challenge the Unknown 71111.15 The inspectors identified a Green finding and associated non-cited violation (NCV) of License Condition 2.C(3) of the FitzPatrick Operating License because Constellation did not identify a stairwell handrail as an external interference that affected the spray pattern of a sprinkler in water spray curtain 5. Specifically, Constellation did not conduct inspections of water spray curtain 5 in accordance with FitzPatrick inspection procedure ST-76KA, Integrity Inspection of FP Water System and SGT Filter Train A FP System.
Description:
The water spray curtain systems at FitzPatrick are designed as an automatically actuated water spray curtain for the purpose of providing boundary separation between adjacent fire zones in the reactor building where no fire rated physical barriers exist, to prevent a fire from progressing from one fire zone to another fire zone. The water spray curtain systems are an integral part of the FitzPatrick fire protection system and provide justification for several exemptions to Appendix R of 10 CFR Part 50.
Water spray curtain 5 includes two heat sensing fire detectors and four open sprinklers located around the southeast stairwell positioned at the floor opening of the reactor building 272' elevation floor, and provides boundary separation where an open stairwell connects two different fire zones, fire zone RB-1E and fire zone RB-1A. Fire zone RB-1E contains safety significant equipment such as the high-pressure coolant injection pump and turbine, the B and D residual heat removal pumps, and the B core spray pump. Fire zone RB-1A contains safety significant equipment such as the B residual heat removal heat exchanger and valves for the high-pressure coolant injection and residual heat removal systems.
Procedure ST-76K, Integrity Inspection of FP Water System and SGT Filter Train A FP System, Revision 0, Section 8.1.5 states verify there is no external interference around spray nozzles which may affect spray pattern. Contrary to this, on July 1, 2022, during a walkdown of the reactor building 1A fire zone, the inspectors identified a sprinkler head for water spray curtain 5 was obstructed by a stairwell handrail. External interferences could affect the water spray pattern from a sprinkler head and adversely affect the water spray curtains function to provide boundary separation.
To address the adverse condition, Constellation staff developed a technical evaluation to determine if there was any remaining overlap from adjacent sprinkler heads. Although detailed information was not able to be provided on adequacy of the spray pattern (i.e.
bounding heat input from a postulated fire, spray water droplet size and heat capture) to prevent combustible gas transfer between fire zones RB-1E and RB-1A, there was adequate overlap from the adjacent sprinkler heads. The inspectors determined the evaluation along with additional fire detection, suppression, and fire brigade response provided reasonable assurance that the spread of a fire between fire zone RB-1E and RB-1A could be mitigated.
To ensure full restoration of the spray curtain, on September 14, 2022, Constellation removed the handrail.
Corrective Actions: Constellation removed the section of stairwell handrail that obstructed the water spray curtain 5 sprinkler, eliminating the external interference.
Corrective Action References: IR 04510360
Performance Assessment:
Performance Deficiency: Constellation did not identify a stairwell handrail as an external interference that affected the spray pattern of a sprinkler in water spray curtain 5. Specifically, Constellation did not conduct inspections of water spray curtain 5 in accordance with FitzPatrick inspection procedure ST-76KA, Integrity Inspection of FP Water System and SGT Filter Train A FP System. The inspectors reviewed the most recently completed performance of this surveillance in September 2021. The inspectors noted that the tests inspections were recorded as completed satisfactorily, and no issues were noted.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, Constellation did not identify a stairwell handrail as an external interference that affected the spray pattern of a sprinkler in water spray curtain 5.
External interferences could affect the water spray pattern from a sprinkler head and adversely affect the water spray curtains function to provide boundary separation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors assigned this issue a finding category of fire confinement as it is related to water curtains. The inspectors determined this issue to have a high degradation rating assignment in accordance with IMC 0609 Appendix F, Attachment 2, Degradation Rating Guidance, because greater than 10 percent of heads were obstructed. The inspectors screened this issue as Green in Step 1.4.4 by answering Yes to Question 1.4.4-A. Specifically, Constellation subsequently determined that overlap from adjacent sprinkler heads installed in the system provided adequate water coverage for the stairwell, and therefore water spray curtain 5 remained functional.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, Constellation staff failed to maintain a questioning attitude during ST-76KA, a technical human performance behavior that could have aided in identifying the external interference or questioning if the external interference met the procedure criteria for failure of the acceptance criteria. As a result, the handrail in front of the sprinkler head in water spray curtain 5 was not identified.
Enforcement:
Violation: FitzPatrick Operating License Condition 2.C(3) requires, in part, that Constellation shall implement and maintain in effect provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility. FitzPatrick Final Safety Analysis Report Section 9.8.5, Fire Protection Program, states, in part, that the Technical Requirements Manual (TRM) will be used to implement the FitzPatrick Fire Protection Program. Technical Requirement Surveillance (TRS) 3.7.I.8 of FitzPatrick TRM 3.7.I, Water Spray and Sprinkler System, requires that a visual inspection of each spray nozzle of the Boundary 5 water spray curtain be performed every 24 months.
FitzPatrick Procedure ST-76KA, Integrity Inspection of FP Water System and SGT Filter Train A FP System, implements TRS 3.7.I.8 requirements. ST-76KA directs that, "Applicable Steps 8.1.1 through 8.1.6 are performed for each area to be inspected on Table 1. Table 1 of ST-76KA directs that Step 8.1.5 be performed for Stairwell Water Spray Curtain Boundary Number 5. Step 8.1.5 states, Verify there is no external interference around spray nozzles which may affect spray pattern.
Contrary to this, until July 1, 2022 Constellation did not identify a stairwell handrail as an external interference that affected the spray pattern of a sprinkler in water spray curtain 5.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Unevaluated Scaffold in Contact with Safety-Related Equipment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2022003-02
[H.1] -
Resources 71111.20 Open/Closed
The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because Constellation personnel did not adequately accomplish scaffold construction in accordance with approved scaffold control procedures. Specifically, the inspectors identified three scaffolds in direct contact with safety-related equipment without engineering and operations evaluation.
Description:
During pre-outage plant barrier impairment walkdowns the week of August 29, 2022, the inspectors identified multiple scaffolds associated with work orders (WO) 5282988, WO 5088137, and WO 5127325, appeared to be in direct contact with a safety-related cable tray 1TC215B, safety-related structural support for south safety pump room fan 73FN-3B, and safety-related structural support for crescent unit cooler 66UC-22A.
Constellation staff performed a walkdown of the scaffolds and confirmed that each scaffold was attached to or in direct contact with safety-related equipment.
Procedure MA-AA-716-025, Scaffold Installation, Modification, and Removal Request Process, Revision 19, requires that checklist MA-AA-716-025-F-1, "Non-Permanent Scaffold Request Form," be completed for non-permanent scaffolds. Step 4.1.3.5 requires completion of Section B, Pre-Erection Review, obtaining Engineering involvement, as necessary.
Section B.1 asks 1. Can scaffold be erected per Station Seismic Scaffold and Safety Related spacing criteria? However, there was no station seismic procedure in place to establish spacing criteria. Following additional inspector followup, it was determined that the station had not implemented site specific scaffold criteria following license transfer from Entergy to Exelon, (now Constellation) in 2017. FitzPatrick procedure MA-JF-796-024-1001, Seismic Criteria for FitzPatrick Nuclear Power Plant," Revision 0, was not in an active status, which prevented the ability to determine the need for additional Engineering review. As a result, engineering staff have not been involved in walkdowns of scaffold erections. Constellation supplemental workforce were also not being provided adequate training to identify safety-related equipment.
Step 4.1.4 requires completion of Section C, Pre-Erection Operations Review. Operations did not require a post-erection inspection even though the scaffolds were in close proximity to safety-related equipment. This allowed the scaffold builders to erect scaffolding using the structural steel of safety-related components for bracing without additional Operations or Engineering review. The inspectors concluded that if a post-erection inspection had been required and performed, procedure MA-AA-716-025-F-6, Operations Post Installation Walkdown Checklist," would have also driven Engineering review, approval and documentation of the scaffold contact with safety-related equipment.
Constellation took immediate corrective action and removed or adjusted these scaffolds. A seismic event would have resulted in increased failure probability of 73FN-3B. The systems it supports, B emergency service water pump, B and D residual heat removal service water pumps, had the potential to fail due to elevated temperatures without 73FN-3B between August 19, 2022 and August 31, 2022. This had the potential to affect B and D emergency diesel generator operation. In addition, Operations staff would have been reliant on conducting compensatory monitoring of temperatures to ensure reliability of the pumps.
Constellation staff entered each of the issues into the corrective action program. Each issue was then assigned to have a past operability evaluation to assess for the potential impact due to seismic criteria.
Corrective Actions: Constellation removed or modified the scaffolds to ensure no direct contact with plant equipment. Constellation personnel performed extent-of-condition walkdowns of accessible scaffolding. Constellation also conducted a human performance review board and briefings of the requirements for scaffold construction and provided staff with lanyard cards stating seismic and clearance requirements for all scaffold builds.
Constellation also implemented MA-JF-796-024-1001, Seismic Criteria for FitzPatrick Nuclear Power Plant," Revision 0, after identifying the station failed to adopt site-specific scaffold requirements. Constellation also assigned Engineering staff to perform pre-and post-scaffold build evaluations.
Corrective Action References: IRs 4519993, 4519987, 4520169
Performance Assessment:
Performance Deficiency: Scaffolding was built and approved contrary to the scaffold control procedure guidance. Specifically, on August 31, 2022 the inspectors identified three scaffolds in direct contact with safety-related equipment without engineering and operations evaluation.
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. The inspectors also noted that the performance deficiency was similar to Example 4.a of Inspection Manual Chapter (IMC) 0612, Appendix E. Specifically, each issue did not have engineering or operations evaluation to assess seismic impact of the scaffolds in contact with safety-related equipment. The attachment of the scaffold to the safety-related support of fan 73FN-3B rendered it subject to seismic induced loads that had not been considered in the original analysis and increased the probability of fan failure during accident mitigation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined this finding to be of very low safety significance (Green) in accordance with Exhibit 2, because it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g.,
seismic snubbers, flooding barriers, tornado doors) for greater than 14 days.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, a procedure containing site specific seismic scaffold criteria and safety-related spacing criteria was not available to support successful scaffold erection.
Enforcement:
Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Constellation procedure MA-AA-716-025, Scaffold Installation, Modification, and Removal Request Process, Revision 19, contains the requirements for non-permanent scaffolds, and requires that checklist MA-AA-716-025-F-1, "Non-Permanent Scaffold Request Form," be completed for non-permanent scaffolds. Step 4.1.3.5 requires completion of Section B, Pre-Erection Review, obtaining Engineering involvement, as necessary. Section B.1 asks 1. Can scaffold be erected per Station Seismic Scaffold and Safety Related spacing criteria? Step 4.1.4 requires completion of Section C, Pre-Erection Operations Review, which asks, Post Erection Inspection required (e.g. close proximity to safety-related equipment)?
Contrary to the above, from August 19, 2022 to August 31, 2022, Constellation staff constructed scaffolds with direct contact between the scaffold and safety-related equipment without Engineering or Operations inspection or evaluation.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Failure of the RCIC Steam Line Break Detection Differential Pressure Transmitter (13DPT-84) to Calibrate During the Performance of ISP-251B on September 27, 2021 71152A The inspectors reviewed Constellations corrective actions regarding the failure of the reactor core isolation cooling steam line break detection differential pressure transmitter (13DPT-84)to calibrate during the performance of ISP-251B on September 27, 2021. Constellation declared the transmitter inoperable, placed the affected channel in trip per Technical Specification 3.3.6.1 Condition A, replaced the 13DPT-84 and restored the system to operable. On February 24, 2022, Constellations failure analysis (Exelon PowerLabs, JAF-46923) determined that the failure mode was unable to be duplicated and that the transmitter did not exhibit any degraded performance. Constellations issue report (IR 04449171) documented that the likely cause of the 13DPT-84 failure was possible foreign material or an obstruction of the transmitter low side vent valve/piping.
The inspectors reviewed Constellations issue report, transmitter calibration procedure, work orders, preventive maintenance history, and applicable engineering and corrective action program procedures to assess Constellations conclusions and corrective actions. The inspectors did not identify and findings or violations of more than minor significance associated with the reactor core isolation cooling steam line break detection differential pressure transmitter corrective actions implementation.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 12, 2022, the inspectors presented the emergency preparedness program inspection results to Timothy Peter, Site Vice President, and other members of the licensee staff.
- On September 15, 2022, the inspectors presented the radiological environmental monitoring program baseline inspection results to Timothy Peter, Site Vice President, and other members of the licensee staff.
- On October 3, 2022, the inspectors presented the radiological hazards assessment and exposure controls inspection results to Timothy Peter, Site Vice President, and other members of the licensee staff.
- On November 3, 2022, the inspectors presented the integrated inspection results to Timothy Peter, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
2966-PE(N)-
019-0
High Energy Line Break Analysis in the Turbine Building for
Class 1E Electrical Equipment Qualification in Response to
IEB 79-01B
Calculations
JAF-RPT-15-
00004
James A. FitzPatrick Flooding Hazard Re-Evaluation Report
Fire Plans
East Pipe Tunnel, Elevation 258', Fire Area/Zone XIX/RW-1
Procedures
Hazard Barrier Controls
Procedures
Plant Barrier Control Program
Corrective Action
Documents
Resulting from
Inspection
04510088
Drawings
Flow Diagram Residual Heat Removal, System 10
Procedures
Stack Rad Monitor HI
Procedures
Stack Rad Monitor HI-HI
Procedures
Stack Hi Range Effluent Monitor B HI-HI
Procedures
CY-JF-170-301
Offsite Dose Calculation Manual
Procedures
Procedures
Hot Primary Containment Control
Procedures
Post Accident Containment Venting and Gas Control
Procedures
Addendum 3, Appendix 1, JAF EAL Wallboard
Procedures
Flow Diagram High-Pressure Coolant Injection System 23
Procedures
Procedures
High-Pressure Coolant Injection
Procedures
Diesel Generator Emergency Power
Procedures
Fire Protection
Corrective Action
Documents
Resulting from
Inspection
04509380
Corrective Action
Documents
04509604
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Corrective Action
Documents
Resulting from
Inspection
04510360
Corrective Action
Documents
Resulting from
Inspection
04525004
Corrective Action
Documents
Resulting from
Inspection
04525096
Fire Plans
East Cable Tunnel/Elevation 258' Fire Area/Fire Zone II/CT-
Fire Plans
West Cable Tunnel, Elevation 258' Fire Area/Fire Zone
1C/CT-1
Fire Plans
Crescent Area-East/Elev. 227' 242' Fire Area/Zone XVII/RB-
1E
Fire Plans
Drywell Elev. 256' Fire Area/Zone XIV/PC-1
Fire Plans
Drywell Elev. 2292' Fire Area/Zone XIV/PC-1
Fire Plans
Drywell Elev. 268' Fire Area/Zone XIV/PC-1
Fire Plans
Reactor Building/Elev. 272' Fire Area/Zone IX/RB-1A
Fire Plans
Motor Generator Set Room Elevation 300', Fire Area 1A/Fire
Zone MG-1
Fire Plans
Reactor Building/Elev. 300' Fire Area/Zone IX/RB-1A
Fire Plans
Reactor Building/Elev. 326' Fire Area/Zone IX/RB-1A
Fire Plans
Reactor Building/Elev. 344' Fire Area/Zone IX/RB-1A
Fire Plans
Reactor Building/Elev. 369' Fire Area/Zone IX/RB-1A
Fire Plans
East Pipe Tunnel, Elevation 258', Fire Area/Fire Zone
XIX/RW-1
Fire Plans
Condenser Pit /Elev. 244' Fire Area/Zone IE/TB-1
Fire Plans
Turbine Building - North /Elev. 252' Fire Area/Zone IE/TB-1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Fire Plans
Turbine Building - South /Elev. 252' Fire Area/Zone IE/TB-1
Fire Plans
Turbine Building - North /Elev. 272' Fire Area/Zone IE/TB-1
Fire Plans
Turbine Building - South /Elev. 272' Fire Area/Zone IE/TB-1
Miscellaneous
Drill Scenario 22-14
Procedures
Fire Drill Performance
Corrective Action
Documents
Resulting from
Inspection
04509912
Drawings
West Crescent Cooler(s) 66UC-22A, C, E, G & J Tube
Plugging Map(s)
Drawings
East Crescent Cooler(s) 66UC-22B, D, F, H & K Tube
Plugging Map(s)
Work Orders
244701-01
71111.11Q Drawings
FM-20A, Sheet 1
Flow Diagram Residual Heat Removal System 10
71111.11Q Procedures
EOP Bases Document, Volume I: Introduction and
References
71111.11Q Procedures
EOP Bases Document, Volume II: EOPs for Hot Conditions
71111.11Q Procedures
Emergency Depressurization
71111.11Q Procedures
Hot Primary Containment Control
71111.11Q Procedures
Hot Secondary Containment Control-Radioactivity Release
Control
71111.11Q Procedures
Addendum 3, James A. FitzPatrick Nuclear Power Plant
71111.11Q Procedures
Addendum 3, Appendix 1, JAF EAL Wallboard
71111.11Q Procedures
4160 V and 600 V Normal AC Power Distribution
71111.11Q Procedures
Shutdown Operation
Corrective Action
Documents
Resulting from
Inspection
04509377
Corrective Action
Documents
Resulting from
Inspection
04509378
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
04520942
Engineering
Changes
0449325
Need Design Engineering Assistant to Determine if 12 Pole
Relay Can Be Used for 8 Pole Applications EIDS: 93-74C-
1EDGB13 & 93-74C-1EDGA13 for CATID 32098340
09/09/2021
Engineering
Changes
9000032513
Engineering Standard for CR2810 and CR 2811 Relay
Replacements - Replace with Equivalent Square D Relays
2/09/2012
Miscellaneous
27: Primary Containment Atmosphere Control and Dilution
Maintenance Rule Basis Document
Miscellaneous
Catalogue ID
26547
Miscellaneous
Catalogue ID
1578495
Miscellaneous
JAF-RPT-07-
00006
Maintenance Rule Structural Monitoring Report
and 6
Miscellaneous
Procurement
Requirement
Evaluation Form
05409
Rolling Element Shielded and Sealed Bearings
Procedures
MA-AA-716-230-
1002
Vibration Analysis/Acceptance Guideline
Procedures
EDG System Mechanical PM*
Procedures
Primary Containment Atmosphere Dilution System
Procedures
Warehouse Operations
Procedures
Suppression Chamber and Drywell Deterioration Inspection
Work Orders
04978270
Work Orders
05145851
Corrective Action
Documents
04510493
Corrective Action
Documents
04510528
Corrective Action
Documents
04525376
Corrective Action
04525708
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Drawings
4160V One Line Diagram Sheet 3 Bus 10400
Procedures
Refueling Water Level Control
Corrective Action
Documents
205802
Corrective Action
Documents
04498893
Corrective Action
Documents
04513174
Corrective Action
Documents
04513331
Corrective Action
Documents
04515852
Corrective Action
Documents
04524574
Corrective Action
Documents
Resulting from
Inspection
04510360
Drawings
Elem Diag Reactor Protection System
Procedures
F1-83-036
Reactor Building Sprinkler per Appendix R
Procedures
F1-92-180
Modification to Water Curtains to Eliminate Obstructions
Procedures
MA-JF-731-001
Work Orders
04811112
Work Orders
04874576
Calculations
JAF-CALC-ADC-
00676
Battery Room Temperature (72TIC-122A&B) Setpoint and
Channel Uncertainty Calculation
Calculations
JAF-CALC-ADC-
00676
Battery Room Temperature Setpoint and Channel
Uncertainty Calculation
2A
Corrective Action
Documents
04476356
Corrective Action
04507463
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Drawings
Flow Diagram Feedwater System 34
Engineering
Changes
634221
Decay Heat Removal System Power Supply Modification
09/22/2022
Engineering
Changes
634574
Replacement of 72TIC-122B and Related Equipment
Miscellaneous
Design Basis Document for the Administration Building
HVAC Systems
Miscellaneous
Tagout 34-0013-
Feedwater System Pressure Switch PS-124A Root Valve
08/22/2022
Procedures
Exelon 50.59 Resource Manual
Work Orders
05088137
Work Orders
271841
Corrective Action
Documents
04497226
Corrective Action
Documents
04497328
Corrective Action
Documents
04497663
Procedures
Station Battery A Modified Performance Test
Procedures
HPCI Foam System Sample and Test
Procedures
Decay Heat Removal System
Work Orders
05088137-097
Work Orders
05088137-037
Work Orders
05127664
Corrective Action
Documents
Resulting from
Inspection
04519987
Corrective Action
Documents
Resulting from
Inspection
04519993
Corrective Action
04524705
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Corrective Action
Documents
Resulting from
Inspection
04525028
Corrective Action
Documents
Resulting from
Inspection
04525511
Procedures
Refueling Water Level Control
Procedures
4160 V and 600 V Normal AC Power Distribution
Procedures
Startup and Shutdown Procedure
135
Procedures
Startup and Shutdown Procedure
136
Procedures
Shutdown Operation
Procedures
Shutdown Safety Management Program
Work Orders
05116084-08
Corrective Action
Documents
04369253
Corrective Action
Documents
04524581
Corrective Action
Documents
04524739
Drawings
Flow Diagram Reactor Core Isolation Cooling System 13
Procedures
SEP-IST-007
Inservice Testing (IST) Program Plan
Procedures
Procedures
Main Turbine Overspeed Test (Actual Overspeed Trip Test -
Valves Remain Open)
Procedures
Main Turbine Overspeed Backup Trip System Test (Actual
Procedures
RCIC Flow Rate and Inservice Test (IST)
Procedures
Type B and C LLRT of Containment Penetrations (IST)
Procedures
Type C Leak Test Main Steam Line A MSIVs (IST)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Type C Leak Test Main Steam Line B MSIVs (IST)
Procedures
Type C Leak Test Main Steam Line C MSIVs (IST)
Procedures
Type C Leak Test Main Steam Line D MSIVs (IST)
Work Orders
05079038
Work Orders
05079392
Work Orders
05079393
Work Orders
05079394
Work Orders
05079395
Work Orders
05185565-01
Miscellaneous
Nine Mile Point Nuclear Generating Station and James A.
FitzPatrick Nuclear Power Plant Public Alert and Notification
System Design Report
Miscellaneous
Exelon Nuclear Standardized Radiological Emergency Plan
Miscellaneous
Exelon Nuclear Radiological Emergency Plan Annex for
James A. Fitzpatrick Station
Procedures
Addendum 3, Appendix 1, JAF EAL Wallboard
Procedures
Emergency Classification and Protective Action
Recommendations
Corrective Action
Documents
04524574
Corrective Action
Documents
04524581
Elementary Diagram Reactor Protection System
Miscellaneous
Reactor Protection System Design Basis Document
Procedures
Reactor Scram
Procedures
Isolation Verification and Recovery
Procedures
Procedures
MSIV Closure Trip in Bypass
Procedures
Recirculation System
Procedures
Startup and Shutdown Procedure
136
Procedures
Post Transient Review
15