IR 05000333/2023003
| ML23317A225 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/13/2023 |
| From: | Erin Carfang Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023003 | |
| Download: ML23317A225 (1) | |
Text
November 13, 2023
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2023003
Dear David Rhoades:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On October 26, 2023, the NRC inspectors discussed the results of this inspection with Garrick Olson, Plant Manager, 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.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as an NCV, 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-2023-003-0037
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
July 1, 2023 to September 30, 2023
Inspectors:
E. Miller, Senior Resident Inspector
B. Sienel, Resident Inspector
H. Anagnostopoulos, Senior Health Physicist
M. Hardgrove, Senior Project Engineer
J. Lilliendahl, Senior Emergency Response Coordinator
T. Winkel, Health Physicist
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. A licensee-identified NCV is documented in report section 7115
List of Findings and Violations
Failure to Adequately Scope Emergency Operating Procedure Manual Functions into the Maintenance Rule Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2023003-01 Open/Closed None (NPP)71111.12 The inspectors identified a Green finding and associated NCV of 10 CFR Part 50.65(b)(1),
Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for Constellations failure to scope safety-related structures, systems and components (SSCs)that are relied upon to remain functional during and following design basis events to ensure the capability to prevent or mitigate the consequences of an accident. Specifically, the inspectors identified a failure to adequately scope manual functions of the core spray and residual heat removal (RHR) systems used in emergency operating procedures (EOPs).
Untimely Corrective Action for Battery Sizing Calculation Errors Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2023003-02 Open/Closed
[P.3] -
Resolution 71152A The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, when Constellation did not promptly correct a condition adverse to quality. Specifically, although the low pressure coolant injection (LPCI) battery sizing calculation was found to have errors resulting in negative margin in November 2017,
Constellation did not revise the calculation or place controls on the use of the calculation prior to July 20, 2023.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000333/2023-003-00 Emergency Diesel Generator Fuel Oil Supply Procedure Error "B" Subsystem 71153 Closed
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On July 27, 2023, an unexpected increase in reactor power to 102 percent occurred due to a 'B' reactor water recirculation motor generator set malfunction. Operators took immediate action and reduced reactor power to 98 percent, isolated the malfunction and later restored power to rated thermal power the same day. The unit remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, 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
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)
'B' RHR system on August 20, 2023 (2)
'A' core spray system on September 28, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection (IP Section 03.01) (4 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) Relay room, fire area/zone VII/RR-1, on August 9, 2023
- (2) Main control room and control room heating, ventilation and air conditioning equipment rooms, elevation 300', fire area/zone VII/CR-1, on August 24, 2023
- (3) Reactor building, elevation 369', fire area/zone IX/RB-1A, on September 15, 2023
- (4) East cable tunnel, fire area/zone II/CT-2, on September 28, 2023
Fire Brigade Drill Performance (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on July 11, 2023.
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 operations personnel during a trip of the offgas recombiner system on September 1, 2023, and during reactor recirculation motor generator set maintenance on September 14, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed a simulator evaluation that included the loss of a safety-related bus, a stuck open safety relief valve and a main steam line break on September 12, 2023.
71111.12 - Maintenance Effectiveness
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) Commercial grade dedication associated with capacitors on A071 board for 'A' LPCI independent power supply inverter on July 26, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01) (3 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 during planned turbine trip solenoid surveillance and troubleshooting on August 4, 2023
- (2) Elevated risk during planned 'B' emergency service water piping replacement on September 19, 2023
- (3) Elevated risk during planned 'A' core spray maintenance on September 26, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)
'B' RHR pump low differential pressure on July 15, 2023 (2)71INV-3A, 'A' LPCI motor operated valve independent power supply inverter due to low main voltage on July 24, 2023 (3)
'L' safety relief valve after unidentified leakage reached the adverse condition monitoring plan setpoint for evaluation on August 14, 2023
- (4) RHR valve 10MOV-149B to RHR service water valve 10MOV-148B leakby through 10SOV-150B on August 15, 2023
- (5) Reactor core isolation cooling inboard steam supply isolation valve, 13MOV-15, electrically backseated on August 18, 2023 (6)115-kilovolt offsite power alternating power distribution due to identification of 4-amp phase imbalance on September 11, 2023 (7)
'D' RHR service water pump due to inservice test in alert range on September 12, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (IP Section 03.01) (5 Samples)
(1)71BAT-3B, 'B' LPCI battery cells 50, 92, and 96 following individual cell charge, on July 20, 2023 (2)70TCV-120A, relay room air handling unit AHU-12A chilled water outlet temperature control valve following actuator replacement, on August 2, 2023 (3)71-10640, 4160V supply breaker (serial number 0224A8987-005) for 10P-3D, RHR pump 'D' motor following extent of condition evaluation of the closing coil, on September 12, 2023 (4)02-184-1B(ACT), 'B' reactor water recirculation motor generator set actuator potentiometer, on September 14, 2023 (5)
'A' core spray system following planned maintenance, on September 27, 2023
Surveillance Testing (IP Section 03.01) (3 Samples)
- (1) ST-18BB, control room emergency ventilation system (CREVAS) B Operability Test, on August 23, 2023
- (2) ST-4N, High Pressure Coolant Injection (HPCI) Quick Start, Inservice, and Transient Monitoring Test (IST), on September 13, 2023
- (3) ST-3JA, Core Spray Initiation Logic System 'A' Functional Test, on September 27, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) ST-24J, Reactor Core Isolation Cooling (RCIC) Flow Rate and IST, on September 7, 2023
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a simulator scenario that included the declaration of an unusual event and site area emergency due to a reactor fuel failure and main steam line break on September 12,
RADIATION SAFETY
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Internal dose assessment for employee ID number 991314
- (2) Internal dose assessment for employee ID number 990179
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Declared pregnant worker documented on June 30, 2023
- (2) Declared pregnant worker documented on June 30,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (IP Section 02.04)===
- (1) For the period October 1, 2022 through June 30, 2023
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) For the period October 1, 2022 through June 30, 2023
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) For the period October 1, 2022 through June 30, 2023
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) For the period October 1, 2022 through June 30, 2023
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) For the period October 1, 2022 through June 30, 2023
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) For the period October 1, 2022 through June 30, 2023
===71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03)===
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) IR 04691648 - Untimely Corrective Actions for Battery Sizing Calculation Errors
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000333/2023-003-00, "Procedure Error in Emergency Diesel Generator Fuel Oil Supply 'B' Subsystem" (ADAMS Accession No. ML23174A067). The inspection conclusions associated with this LER are documented in this report under Inspection Results. This LER is Closed.
Personnel Performance (IP Section 03.03) (2 Samples)
- (1) The inspectors evaluated 'B' reactor water recirculation pump speed increase and the licensee's performance on July 27, 2023.
- (2) The inspectors evaluated 'B' reactor feedwater pump elevated pump bearing vibration and the licensee's performance on September 26, 2023.
Reporting (IP Section 03.05) (2 Samples)
- (1) On-shift control room staffing of the shift technical advisor on August 17, 2023
- (2) Emergency diesel generator fuel injector failure during pre-installation testing on August 31,
INSPECTION RESULTS
Failure to Adequately Scope Emergency Operating Procedure Manual Functions into the Maintenance Rule Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000333/2023003-01 Open/Closed
None (NPP)71111.12 The inspectors identified a Green finding and associated NCV of 10 CFR Part 50.65(b)(1),
Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for Constellations failure to scope SSCs that are relied upon to remain functional during and following design basis events to ensure the capability to prevent or mitigate the consequences of an accident. Specifically, the inspectors identified a failure to adequately scope manual functions of the core spray and RHR systems used in EOPs.
Description:
The emergency core cooling system (ECCS) at FitzPatrick includes four RHR pumps and two core spray pumps, which provide low head safety injection. Each of the RHR and core spray pumps receive signals to automatically start during a loss of coolant accident due to high drywell (containment) pressure or low reactor water level. The pumps can also be manually started and stopped by operators using safety-related switches in the main control room during implementation of EOPs.
FitzPatrick experienced three main control room ECCS switch failures between November 2021 and December 9, 2022. Specifically, the C RHR pump switch failed on November 30, 2021, the A core spray pump switch failed on March 1, 2022, and the B core spray pump switch failed on December 9, 2022. These failures were entered into the corrective action program as IRs 04463794, 04481502, and 04541686, respectively.
The NRC requires each holder of an operating license for a nuclear power plant under 10 CFR 50.65 to monitor the performance or condition of SSCs against licensee-established goals, in a manner sufficient to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. As such, Constellation scoped the RHR and core spray systems into the maintenance rule program as required by 10 CFR 50.65 (b)(1) and (b)(2).
Constellation also established performance criteria for each systems functions. Constellation reviewed each of the switch failures against the functions that they established for RHR and core spray and determined there was no failure to meet any of the functions described.
The inspectors reviewed each switch failure against the system functions. The inspectors determined the scoped functions for RHR LPCI and core spray injection failed to adequately include manual actions used in EOPs. Either manual or automatic operation of the system was credited to accomplish the functions. However, in specific sections of the EOPs, manual operation alone may be required.
Constellation procedure ER-AA-320-1001, Maintenance Rule 18-10 - Scoping, Revision 0, Section 4.1.2.3 states, in part:
Include the non-safety functions of safety-related and non-safety-related SSCs:
-that are used in plant Emergency Operating Procedures... Used in plant EOPs means the functions of SSCs that are explicitly used in the plant EOPs are included in the scope of the rule.
The inspectors reviewed Nuclear Management and Resources Council (NUMARC) 93-01, Nuclear Energy Institute Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4A, Nuclear Energy Institute (NEI) Technical Report 18-10, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 0 and Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4. Of note, NUMARC 93-01, Section 8.2.1.3, Non safety-related SSCs that are used in Emergency Operating Procedures, requires scope into the maintenance rule by paragraph 10 CFR 50.65(b)(2)(i) if explicitly used in the EOP to provide a mitigating function.
Although not directly applicable because the RHR LPCI and core spray systems are safety-related and therefore are being addressed under 10 CFR 50.65(b)(1), it is important to note the definition of explicitly used, which is consistent in both NUMARC 93-01 and NEI 18-10.
The definition states those SSCs specifically called out in the EOP by tag identification or noun name that provide a mitigating function and includes those SSCs required to support the explicitly used SSCs even though they are not called out in the EOP.
The inspectors reviewed the maintenance rule basis document (MRBD) for each system. The RHR MRBD states the following for Function 1, Provide manual or automatic low pressure core cooling (LPCI mode) following a design basis accident that results in low reactor vessel level or high drywell pressure. Function 1 also provides a reference to EOP-2, -3, and -7.
The core spray MRBD states, for Function 1, Manually or automatically initiate removal of decay heat by spraying water over the fuel assemblies initiated by low reactor vessel level or high drywell pressure. The inspectors found that other manual functions for RHR, such as placing shutdown cooling in service and containment spray, are included with reference to their applicable EOPs. It is important to note that the concern is only with RHR LPCI injection and core spray injection scope for when they are explicitly used in EOPs.
The inspectors reviewed the EOPs to determine when RHR LPCI and core spray manual functions will be explicitly used. Following operators entering EOP-RC, "Hot RPV Control,"
operators will control reactor pressure vessel (RPV) water level under section RPV/L. Section RPV/L-3 states, Restore and maintain RPV water levelusing one or more Group 1 Water Level Control Systems (Table L-1). Table L-1 provides various systems used for RPV injection and specifically includes RHR LPCI when RPV pressure is below 250 psig and core spray when RPV pressure is below 320 psig.
The James A. FitzPatrick "EOP Bases Document Volume II: EOPs for Hot Conditions,"
Revision 2, provides the following:
The optimal combination of injection systems is event specific and determined by such factors as pump capacities, water quality, power availability, suction location, RPV pressure, and system operating characteristics.
Since most of the listed systems start or operate automatically, verifying system lineups may be the only action required in this step. For example:
- If RPV water level is low due to shrink following a turbine trip, the feedwater system is capable of restoring water level automatically.
- If a break occurs with the RPV at high pressure, the high pressure ECCS are designed to automatically inject.
As a transient progresses, the most effective modes of system operation may change. For example, all ECCS pumps may inject following a large pipe break, but a single pump may be sufficient to maintain RPV water level once it is restored within the specified range. Continued adjustments to system lineups and injection flows may thus be required to effectively control RPV water level within the preferred band."
The inspectors determined that operators may take manual actions depending on the event and may need to adjust system lineup, including starting and stopping ECCS pumps (i.e.,
RHR LPCI injection and core spray).
The inspectors also reviewed additional actions in EOP-RC; EOP-ED, Emergency Depressurization; and EOP-FLOOD, RPV Flooding. The inspectors identified the following regarding use of RHR LPCI and core spray system in these EOPs:
- Procedure EOP-RC contains actions under Section RC/L-8 to conduct an emergency depressurization if RPV water level cannot be restored before reaching top of active fuel.
- The next action under Section RC/L-9 states, Lineup for injection, start pumps, and inject into the RPV using one or more Group 1 Water Level Control Systems (Table L-1).
- In addition, an if/then statement is provided: If adequate core cooling cannot be restored and maintained, then maximize injection into the RPV using available Group 1 Water Level Control Systems (Table L-1), Group 3 Water Level Control Subsystems (Table L-3), and Group 2 Water Level Control Systems (Table L-2).
Further, Adequate Core Cooling is defined as either of the following:
- RPV water level can be restored and maintained above -19 inches
- Core spray subsystem flow can be restored and maintained at least 4725 gallons per minute AND
- RPV water level can be restored and maintained at or above - 44.5 inches
Group 3 Water Level Control Systems (Table L-3) include LPCI 'A' and 'B', and core spray 'A' and 'B'. In addition, the core spray subsystem flow is a value determined analytically to ensure the minimum steam cooling water level.
Procedure EOP-FLOOD, Section RF-6 states, Flood the RPV to the elevation of the main steam lines using one or more Group 1 and Group 2 Water Level Control Systems (Tables L-1 and L-2), defeating high RPV water level isolations and interlocks if necessary. Procedure EOP-FLOOD also includes actions for "Anticipated Transient without Scram." Section AF-1 includes actions to terminate injection to the RPV, should primary containment water level and pressure not be maintained below the primary containment pressure limit and RPV flooding conditions can be maintained. The actions to terminate and prevent may include manually stopping and starting Group 1 Water Level Control Systems that include RHR LPCI and core spray to maintain RPV water level.
The inspectors determined the low pressure injection systems with high volume such as RHR LPCI and core spray are explicitly used based on being called out by noun name to mitigate the consequences of an accident. As discussed in the EOP basis document, continued manual adjustments to system lineups and injection flows may thus be required to effectively control RPV water level within the preferred band. They may be used individually or in some combination due to the RPV being depressurized. In addition, RHR shutdown cooling will be placed in service, requiring additional RHR pumps to be used for RPV injection.
Based on the information above, the inspectors concluded that Constellation failed to ensure manual functions were adequately scoped into the maintenance rule. Specifically, the RHR LPCI and core spray maintenance rule functions for injection allow manual or automatic operation for success. However, certain sections of the EOPs may require manual action to use these systems for injection. As a result, the current function for RHR LPCI and core spray injection prevented the ability to screen manual actions alone as a functional failure because the automatic functions remained operable.
Corrective Actions: Constellation entered this issue into the corrective action program to consider potential enhancements to the maintenance rule basis documents.
Corrective Action References: IRs 04680630 and 04683486
Performance Assessment:
Performance Deficiency: Constellation failed to ensure manual functions were adequately scoped into the maintenance rule.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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, the scoped functions for RHR LPCI and core spray injection failed to require the ability to take manual actions necessary in EOPs. As a result, the manual functions were not able to be properly screened for potential maintenance rule functional failures.
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
- (1) it did not involve a deficiency affecting the design or qualification of a mitigating SSC that affected its operability or probabilistic risk assessment (PRA)functionality;
- (2) it was not a degraded condition that represented a loss of the PRA function of a single train technical specification (TS) system for greater than its TS allowed outage time;
- (3) it did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time;
- (4) it did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;
- (5) it did not represent a loss of a PRA system and/or function as defined in the Plant Risk Information Book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and
- (6) it did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk significant in accordance with Constellation's maintenance rule program for greater than 3 days.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR 50.65 (b)(1) requires the scope of the of the monitoring program specified in paragraph (a)(1) shall include safety-related structures, systems, and components. Safety-related structures, systems or components include those that are relied upon to remain functional during and following design basis events to ensure, in part, the capability to prevent or mitigate the consequences of accidents.
Contrary to the above, prior to October 26, 2023, Constellation did not adequately scope RHR LPCI and core spray injection manual actions used in EOPs in the monitoring program specified in 10 CFR 50.65(a)(1). As a result, the manual functions were not able to be properly screened for potential maintenance rule functional failures.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Untimely Corrective Action for Battery Sizing Calculation Errors Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000333/2023003-02 Open/Closed
[P.3] -
Resolution 71152A The inspectors identified a Green finding and NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when Constellation did not promptly correct a condition adverse to quality. Specifically, although the LPCI battery sizing calculation was found to have errors resulting in negative margin in November 2017, Constellation did not revise the calculation or place controls on the use of the calculation prior to July 20, 2023.
Description:
FitzPatrick has two trains of LPCI. Each train consists of two pumps, piping, motor operated valves, and valve power supplies. The valves are powered by a 600 volts alternating current (VAC) power supply system which is composed of two separate and independent power supplies that includes a 419 volts direct current (VDC) battery, 600 VAC emergency bus power supply, an inverter, a rectifier/charger, a transformer, and associated circuit breakers. The normal valve power supply is the 419 VDC LPCI battery.
The inspectors reviewed corrective actions associated with NRC identified NCV 05000333/2017004-01, Inadequate Design Control for Battery Sizing Calculation, from December 31, 2017, for errors in calculation JAF-CALC-ELEC-01857. Constellation staff provided the inspectors with JAF-CALC-ELEC-01857, 419V DC LPCI Power Supply System 3A and 3B Sizing Calculation, as a basis for the adequacy of the LPCI battery capacity. The inspectors noted that the calculation provided was the original calculation from 2017.
As a result of the NCV in 2017, IR 04077089 was written and closed to action request (AR)4112191, which was then closed on April 15, 2019, to engineering change (EC) 627934. EC 627934 is an engineering change to revise the battery sizing calculation but has not yet been completed. The Constellation document control system does reflect the open engineering change for JAF-CALC-ELEC-01857. At the time of the inspection there was no approved design calculation demonstrating adequate capacity for the LPCI batteries and no controls in place to prevent the existing calculation from being referenced.
Corrective Actions: Constellation performed an operability evaluation that shows the batteries will remain operable with the current calculation above 60 degrees Fahrenheit (the design value is 50 degrees Fahrenheit). In addition, recent battery performance surveillances have measured battery capacity to be above 100 percent. Constellation has prioritized the completion of the revised calculation.
Corrective Action References: IR 04691648
Performance Assessment:
Performance Deficiency: Constellation failed to promptly correct a condition adverse to quality. Specifically, although the LPCI battery sizing calculation was found to have errors in November 2017 which invalidated its results, Constellation had not issued a corrected calculation by July 2023.
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. This issue is also similar to Inspection Manual Chapter 0612, Appendix E, Example 2.a because the original approach resulted in unfavorable margin.
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 involved a deficiency affecting the design of the mitigating SSC and the SSC maintained its operability.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part that measures are taken to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, from November 21, 2017, until July 20, 2023, Constellation failed to assure that the LPCI battery sizing calculation was corrected. Specifically, although the LPCI battery sizing calculation was found to have errors in November 2017, which invalidated its results, Constellation had not issued a corrected calculation by July 2023.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Performance Deficiency 71152A Minor Performance Deficiency: The inspectors reviewed Constellation IRs 04497226 and 04497328 from May 2022, which documented NRC identified failures to adequately implement safety-related battery discharge testing.
The inspectors reviewed the subsequent modified performance discharge test for station battery A, MST-071.26, performed on September 27, 2022, as documented in work order 5007719, to assess the effectiveness of corrective actions. Step 9.4.2 of this procedure determines the average battery cell temperature which is used to determine the battery discharge rate. The battery discharge rate directly impacts the measured capacity of the battery which is a TS required parameter to ensure operability of the battery. Due to the significance of this step, it requires independent verification. The recorded average temperature in the work order was 78.1 degrees Fahrenheit. The inspectors independently calculated the average temperature and determined the correct value was 78.4 degrees Fahrenheit. This error was not identified by the independent verification. Since the error rounded to the same value, it did not impact the discharge rate or the final result.
Constellation entered this issue into the corrective action program as IR 04691557.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that although not greater than minor significance, the failure to perform battery testing in accordance with written test procedures is a performance deficiency. Specifically, the inspectors independently evaluated the deficiency noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that the error did not change the battery discharge rate and subsequently did not change the test results. This was therefore not a deficiency of greater than minor significance and therefore is not subject to enforcement action in accordance with the NRCs enforcement policy.
Minor Performance Deficiency 71152A Minor Performance Deficiency: The inspectors reviewed Constellations corrective actions related to IR 04552202 regarding a missed battery testing surveillance. In February 2023, the NRC identified that the A LPCI battery testing frequency was not increased as required by TSs. This was documented in NCV 05000333/2023001-02.
Technical Specification Surveillance Requirement 3.8.4.4 states that the battery capacity testing should be increased when the battery shows degradation or has reached 85 percent of expected life.
The inspectors reviewed the LPCI battery modified performance test procedure, MST-071.25, to assess the adequacy of corrective actions. The revised procedure addressed test frequency adjustment due to degradation, but the criteria of 85% of expected life was not addressed. The test procedure does not clearly explain how to determine when each battery will exceed 85 percent of expected life. The test procedure also refers to 85% of service life which can be misleading since a battery manufacturer derates a batterys service life depending on the temperature at which the battery is operated. The derated life is the expected life or the service life expected for the application.
The NRC raised the issue of battery derating for temperature in 2017 with Constellation. In September 2021, IR 04445033 was issued by Constellation Corporate for all sites to evaluate battery temperatures to update the expected service life for each battery. In July 2020, IRs 04354324 and 04354325 were issued which stated that design engineering had determined the LPCI battery lives were expected to be 15 to 17 years instead of the non-derated 20 years. These IRs were closed to work orders to replace the batteries at FitzPatrick in 2022 and 2023, but the work orders were never completed. The inspectors requested the basis for the 15 to 17 year life and the basis for not replacing the batteries. Constellation was unable to determine the basis for the conclusion, so EC 639788, Technical Evaluation of A and B LPCI Battery Expected Life, was performed and determined that the two LPCI batteries will require increased testing, based on exceeding 85 percent of expected life in May and December 2023. Issue Report 04702553 was written to adjust the future testing frequency.
The inspectors confirmed that the LPCI batteries had not exceeded 85 percent of expected life. Constellation entered this issue into the corrective action program as IR 04691652.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that although not greater than minor significance, the failure to ensure the test program incorporates the requirements and acceptance criteria in applicable design documents is a performance deficiency. Specifically, the inspectors independently evaluated the deficiency noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that the error did not result in a missed surveillance. This was therefore not a deficiency of greater than minor significance and therefore is not subject to enforcement action in accordance with the NRCs enforcement policy.
Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: TS 3.8.3 Diesel Fuel Oil, Lube Oil and Starting Air requires that emergency diesel generator (EDG) fuel oil levels be maintained with a 7-day supply or greater when associated EDG subsystems are required to be OPERABLE. If the fuel oil level drops to a level greater than a 6-day supply but less than a 7-day supply, TS 3.8.3 (A) requires that the level be returned to greater than a 7-day supply within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the level is not returned to a greater than 7-day supply within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, TS 3.8.3 (F) requires that the associated EDG be declared inoperable immediately.
Contrary to the above, from June 20, 2022 through Sept 12, 2022 (84 days) and again from December 1, 2022 through March 27, 2023 (116 days), the 'B' EDG fuel oil level dropped below a 7-day supply level. The level was maintained above a 6-day level during these periods. Therefore, the 'B' EDG should have been declared inoperable during the referenced 84-and 116-day periods.
Significance/Severity: The inspectors determined this finding to be of very low safety significance (Green) in accordance with IMC 0609, Appendix A, Exhibit 2, because it
- (1) did not involve a deficiency affecting the design or qualification of a mitigating SSC that affected its operability or PRA functionality;
- (2) was not a degraded condition that represented a loss of the PRA function of a single train TS system for greater than its TS allowed outage time;
- (3) did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time;
- (4) did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;
- (5) did not represent a loss of a PRA system and/or function as defined in the Plant Risk Information Book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and
- (6) did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk significant in accordance with the licensees maintenance rule program for greater than 3 days.
Corrective Action References: IRs 04672634 and
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 30, 2023, the inspectors presented the dosimetry inspection results to Garrick Olson, Plant Manager, and other members of the licensee staff.
- On October 26, 2023, the inspectors presented the integrated inspection results to Garrick Olson, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
Flow Diagram Residual Heat Removal System 10
Drawings
Flow Diagram Residual Heat Removal System 10
Drawings
Flow Diagram Core Spray System 14
Procedures
Residual Heat Removal System
100
Procedures
Core Spray System
Drawings
East Cable Tunnel/Elevation 258' Fire Area/Zone II/CT-2
Fire Plans
Relay Room Elevation 286', Fire Area VII/Fire Zone RR-1
Fire Plans
Main Control Room and Control Room HVAC Equipment
Rooms, Elevation 300', Fire Area 7/Fire Zone CR-1
Fire Plans
Reactor Building, Elevation 369', Fire Area 9/Fire Zone RB-
1A
Procedures
Portable Fire Extinguisher Inspection Procedure 71111.05
Procedures
Portable Fire Extinguisher Inspection Procedure 71111.05
Procedures
Fire Door Maintenance
Procedures
Fire Drill Performance
71111.11Q Procedures
71111.11Q Procedures
Offgas Recombiner Trouble
71111.11Q Procedures
Offgas System
Corrective Action
Documents
04692122
Procedures
Warehouse Operations
Procedures
Procurement Engineering Process and Responsibilities
Work Orders
05385648
Corrective Action
Documents
04694668
Procedures
Main Turbine 24VDC Master Trip A and B Solenoid Test
Procedures
Protected Equipment Program
Work Orders
05385629
Calculations
JAF-CALC-RCIC-
04454
Voltage for Electrical Backseating of 13MOV-15
Corrective Action
04528860
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Corrective Action
Documents
04683608
Corrective Action
Documents
04690443
Corrective Action
Documents
04690575
Corrective Action
Documents
04691010
Corrective Action
Documents
04692122
Corrective Action
Documents
04706824
Corrective Action
Documents
04707325
Miscellaneous
ACMP for 02RV-71L First Stage Temperature
1, 2 and 3
Miscellaneous
Design Basis Document for the Reactor Core Isolation
Cooling System
Miscellaneous
Design Basis Document for the Electrical Distribution
Systems 4160V and 600V AC Power Systems
Procedures
Electrically Backseating 13MOV-15
Procedures
A LPCI MOV Independent Power Supply Test
Procedures
RHR Service Water Loop B Quarterly Operability Test (IST)
Work Orders
05301117
Work Orders
CR-JAF-2001-
03670
Corrective Action
Documents
04682023
Corrective Action
Documents
04693857
Corrective Action
Documents
04705353
Corrective Action
Documents
04700995
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Resulting from
Inspection
Procedures
CREVAS B Operability Test
Procedures
RCIC Flow Rate and Inservice Test (IST)
Procedures
Core Spray Initiation Logic System 'A' Functional Test
Procedures
Core Spray Loop A Quarterly Operability Test (IST)
Procedures
HPCI Quick Start, Inservice, and Transient Monitoring Test
(IST)
Work Orders
04959109
Work Orders
05353482
Work Orders
05372625
Work Orders
05387170
71151
Corrective Action
Documents
04672886
71151
Corrective Action
Documents
04678583
71151
Corrective Action
Documents
Resulting from
Inspection
04709081
71151
04714037
04714496
71151
Miscellaneous
Regulatory Assessment Performance Indicator Guideline
71151
Procedures
Reactor Oversight Program MSPI Bases Document
71151
Procedures
Monthly Data Elements for NRC ROP Indicator - Safety
System Functional Failures
71151
Procedures
Mitigating System Performance Index Data Acquisition and
Reporting
Calculations
JAF-CALC-
ELEC-01857
419V DC LPCI Power Supply System 3A and 3B Sizing
Calculation
Corrective Action
Documents
04077089
Corrective Action
Documents
04497226
Corrective Action
04502415
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Corrective Action
Documents
04552202
Corrective Action
Documents
Resulting from
Inspection
04691557
Corrective Action
Documents
Resulting from
Inspection
04691648
Corrective Action
Documents
Resulting from
Inspection
04691652
Corrective Action
Documents
Resulting from
Inspection
04702553
Corrective Action
Documents
04692867
Corrective Action
Documents
04699182
Procedures
Unplanned Power Change
Procedures
Unexpected Change in Core Flow
Procedures
APRM Upscale
Procedures
Exelon Nuclear Radiological Emergency Plan Annex for
James A. FitzPatrick Station
Procedures
Addendum 1
James A. FitzPatrick Nuclear Power Plant On-Shift Staffing
Technical Basis
Procedures
Feedwater System
Procedures
Plant Power Changes
Work Orders
04694369