IR 05000333/2023010
| ML23299A052 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/26/2023 |
| From: | Erin Carfang NRC/RGN-I/DORS, RGN |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023010 | |
| Preceding documents: |
|
| Download: ML23299A052 (1) | |
Text
October 26, 2023
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000333/2023010
Dear David Rhoades:
On October 5, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Alex Sterio, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available. One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
No NRC-identified or self-revealing findings were identified during this inspection.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant.
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-2023-010-0012
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
September 18, 2023 to October 5, 2023
Inspectors:
E. Eve, Senior Project Engineer
M. Hardgrove, Senior Project Engineer
K. Mangan, Senior Reactor Inspector
S. Veunephachan, 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 a biennial problem identification and resolution inspection at James A. FitzPatrick Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2023010-01 Open/Closed Not Applicable 71152B The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.73(a)(2)(i)(B) when Constellation did not submit a licensee event report (LER) within 60 days of discovery, a condition which was prohibited by the plants technical specifications (TS). Specifically, Constellation failed to notify the NRC when the emergency diesel generator (EDG) 'A' and 'C' tie breaker 71-10504 failed to close during planned surveillance testing, which resulted in the 'A' EDG subsystem to be declared inoperable for a duration that exceeded its TS completion time.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000333/2023-001-00 LER 2023-001-00 for James A. FitzPatrick Nuclear Power Plant, Primary Containment Isolation System Isolation due to Initiation of Main Condenser Fire Protection Foam System 71152B Closed
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of Constellations Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the safety-related 4kV breakers. The corrective actions for the following NCVs and findings were evaluated as part of the assessment: NCV 05000333/2021013-01, NCV
===05000333/2021040-01, NCV 05000333/2021004-01, NCV 05000333/2021014-01, NCV 05000333/2022401-01, NCV 05000333/2022001-01, NCV 05000333/2022010-01, NCV 05000333/2022002-01, NCV 05000333/2022004-01, and NCV 05000333/2023001-03.
- Operating Experience: The inspectors assessed the effectiveness of Constellations processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of Constellations identification and correction of problems identified through audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment.
- The inspectors reviewed the completed corrective actions to prevent recurrence that were open during the IP 95001 Supplemental Inspection (ML21308A407), dated November 8, 2021, associated with a White notice of violation in the Mitigating Systems Cornerstone. The inspectors verified these corrective actions had been completed as scheduled.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02)===
The inspectors evaluated the following LERs:
- (1) The circumstances surrounding this LER, including an NCV, are documented in Inspection Report 05000333/2023001. This LER is Closed.
INSPECTION RESULTS
Assessment 71152B Problem Identification and Resolution Program Effectiveness:
The inspectors determined that Constellation's problem identification and resolution program for FitzPatrick was generally effective and adequately supported nuclear safety and security.
Identification: The team reviewed a sample of issues that have been processed through Constellation's problem identification and resolution program since the last biennial team inspection, including conditions adverse to quality, NCVs of regulatory requirements and other documented findings. The team determined that, in general, the station identified issues and entered them into the corrective action program at a low threshold. However, the team identified a trend regarding leaks identified by the NRC and a trend for lack of timeliness for issues being entered into the corrective action program. Both observations are documented below.
Prioritization and Evaluation: Based on the samples reviewed, the team determined Constellation was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. Inspectors observed that at station corrective action program meetings, issues were generally screened and prioritized at the appropriate level and that corrective actions were assigned to address the issues. The team noted that Constellation revised their testing procedure for the turbine master trip solenoid valves after recognizing the failure rate evaluation was non-conservative. The observation is documented below.
Corrective Action: The team concluded that Constellation was generally effective in developing corrective actions that were appropriately focused to correct the identified problem. The inspectors also reviewed the corrective actions open at the time of completion of the documented IP 95001 Supplemental Inspection (ML21308A407), dated November 8, 2021.The corrective actions to prevent recurrence were to address a documented White finding in the Mitigating Systems cornerstone (ML21244A497) associated with a defective part that resulted in a high pressure coolant injection system pressure control valve failure. The inspectors verified these corrective actions had been completed as scheduled.
Assessment 71152B Operating Experience:
The inspectors reviewed operating experience captured in the corrective action program and sampled operating experience from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the licensee was generally performing the appropriate assessments for station applicability.
Assessment 71152B Self-Assessment and Audits:
The inspectors determined that the licensee was adequately performing self-assessments and audits in accordance with licensee procedures and implementing corrective actions as needed.
Assessment 71152B Safety Conscious Work Environment:
The team interviewed a total of 60 individuals: 36 in focus groups and 24 in one-on-one interviews. The purpose of these interviews was
- (1) to evaluate the willingness of the licensee staff to raise nuclear safety issues,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the licensee's safety conscious work environment. The personnel interviewed were randomly selected by the inspectors from the Engineering, Maintenance, Operations, Radiation Protection, Chemistry, and Security work groups. To supplement these discussions, the team interviewed the Employee Concerns Program (ECP) Coordinator to assess their perception of the site employees' willingness to raise nuclear safety concerns. The team also reviewed the ECP case log and select case files.
All individuals interviewed indicated that they would raise safety concerns. Most individuals felt that their management was receptive to receiving safety concerns and generally addressed them promptly, commensurate with the significance of the concern. Most interviewees indicated that they were adequately trained and proficient on initiating condition reports. Most interviewees were aware of the licensee's ECP, and all stated they would use the program if necessary and expressed confidence that their confidentiality would be maintained if they brought issues to the ECP. When asked whether there have been any instances where individuals experienced retaliation or other negative reaction for raising safety concerns, all individuals interviewed stated that they had neither experienced nor heard of an instance of retaliation at the site. The team determined that the processes in place to mitigate potential safety culture issues were adequately implemented.
Failure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2023010-01 Open/Closed
Not Applicable 71152B The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.73(a)(2)(i)(B) when Constellation did not submit a licensee event report (LER) within 60 days of discovery, a condition which was prohibited by the plants technical specifications (TS). Specifically, Constellation failed to notify the NRC when the emergency diesel generator (EDG) 'A' and 'C' tie breaker 71-10504 failed to close during planned surveillance testing, which resulted in the 'A' EDG subsystem to be declared inoperable for a duration that exceeded its TS completion time.
Description:
The team reviewed the corrective actions taken by Constellation following the failure of the EDG 'A' and 'C' tie breaker (IR 4669409). The purpose of the tie breaker is to close and connect the 'A' and 'C' EDGs to parallel the electrical outputs of the EDGs before they are connected to vital 4kv bus 10500. On April 12, 2023, Constellation performed ST-9BA - EDG A and C Full Load Test and ESW Pump Operability Test. During the surveillance test the EDG 'A' and 'C' tie breaker failed to close. Operators entered TS 3.8.1 AC Sources, Condition B for one EDG subsystem inoperable. Subsequently, the breaker was replaced, a surveillance test was completed satisfactorily, and the TS limiting condition of operation (LCO) was exited on April 13, 2023. Constellation's inspection of the breaker did not identify a cause and the breaker was sent to the breaker manufacturer for inspection. The manufacturer's analysis determined the most probable cause of the circuit breaker failure was due to an incorrectly installed spacer on the closing coil apparatus. The misaligned spacer did not allow the closing coil sleeve to seat properly in the cutout of the support. The analysis determined that the incorrect installation of the spacer and resulting improper seating of the closing coil sleeve resulted in the breaker being unable to close. NRC inspectors evaluated the performance deficiency associated with the breaker failure and documented an NCV in NRC inspection report 05000333/2023002 (ML23219A114).
The team reviewed the evaluation of the reportability of the event described in IR 4669409.
Constellation concluded that the event was not reportable because there was no firm evidence that the cause of the failure was present prior to the surveillance test failure. The team noted that the failure was caused by maintenance activities performed by FitzPatrick staff during the last breaker overhaul in June 2021. The team observed that there were multiple breaker operations prior to the breaker failure. However, the team noted that each breaker operation caused the closing coil apparatus/spacer assembly to rotate. The team concluded that the rotation during the last breaker operation resulted in placing the spacer in a position that blocked the closing action the next time the breaker was operated. The previous breaker operation occurred on March 13, 2023, a total of 30 days prior to the failure.
The team reviewed NUREG-1022, Revision 3, Event Report Guidelines 10 CFR 50.72 and 50.73, which states, in part, An LER is required if a condition existed for a time longer than permitted by the TS (i.e., greater than the total allowed restoration and shutdown outage time) even if the condition was not discovered until after the allowable time had elapsed and the condition was rectified immediately upon discovery. (For the purpose of this discussion, it is assumed that there was firm evidence that a condition prohibited by TS existed before discovery, for a time longer than permitted by TS.). The inspectors noted that this issue was similar to NUREG 1022 Section 3.2.2 - Conditions Prohibited by Tech Specs, Example 1, which states in part:
Subsequent review indicated that the component was assembled improperly during maintenance conducted 30 days previously and the post maintenance test was not adequate to identify the error. Thus, there was firm evidence that the standby component had been inoperable for the entire 30 days.
Therefore, the team concluded there was firm evidence that the breaker was inoperable 30 days prior to the surveillance and, therefore, Constellation operated the plant in violation of TS 3.8.1 AC Sources LCO B. Condition B states that with one EDG inoperable, the EDG shall be restored to operable status within 14 days. Condition C states that if the Completion Time of Condition A cannot be met, then the unit shall be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Therefore, an LER was required.
Corrective Actions: Constellation has a planned corrective action to submit an LER for this issue.
Corrective Action References: 04707644, 04711358
Performance Assessment:
The NRC determined that this violation was associated with a previously documented finding assessed using the significance determination process.
Enforcement:
The Reactor Oversight Processs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance.
Severity: The inspectors determined the failure to report, within 60 days of discovery, that a condition prohibited by the plants TS existed, was a violation of 10 CFR 50.73(a)(2)(i)(B). In accordance with the example in Section 6.9.d.9 of the NRC Enforcement Policy, a failure to make a report required by 10 CFR 50.73 is a SL IV violation. Because the violation is a traditional enforcement violation, no cross-cutting aspect was assigned.
Violation: Title 10 CFR 50.73 (a)(1) requires, in part, that the licensee submit an LER for any event of the type described in this paragraph within 60 days after discovery of the event. Title 10 CFR 50.73 (a)(2)(i)(B) requires, in part, that the licensee shall report any operation or condition which was prohibited by the plants technical specifications. Contrary to the above, Constellation failed to report by June 11, 2023 that the aforementioned event met the reporting requirements of 10 CFR 50.73(a)(2)(i)(B).
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Trend with NRC Identifying Material Condition Issues in Plant Equipment 71152B The team performed a search of the licensee's corrective action program from July 1, 2021 to September 18, 2023 and noted an increasing trend in plant and material condition issues identified by the NRC. For example, at least 28 leaks (water, air, or oil) were identified in risk-significant and safety-related systems such as the emergency diesel generators, residual heat removal, high pressure coolant injection, reactor core isolation cooling, and emergency service water. In one case, through wall leaks identified by NRC inspectors in the emergency service water system required piping replacement. The station has opportunities as part of their own processes to identify these conditions. Inspectors noted that OP-AA-101-111, Roles and Responsibilities of On-Shift Personnel, Section 4.8.2, states "Perform thorough general inspections of assigned areas looking for potential material condition issues. Deficiencies shall be properly documented and reported." Additionally, the inspectors observed that OP-AA-102-102, General Area Checks and Operator Field Rounds, Section 4.4.4, states, "Operator field rounds should include a general area check for oil, steam, or water leaks."
The inspectors noted the following issues reports documenting leaks identified by the NRC:
04476529, 04478538, 04478546, 04480173, 04481566, 04487966, 04492897, 04498019, 04498022, 04505324, 04505326, 04505939, 04505972, 04525511, 04527791, 04530052, 04535918, 04542254, 04542259, 04551229, 04686717, 04686716, 04690443, 04697522, 04700995, 04699435, 04702273, and 04706492.
Observation: Timeliness of Entering Issues into the Corrective Action Program 71152B The team noted seven examples of issues (IRs: 04698504, 04480173, 04434036, 04442251, 04442283, 04539840, 04464385) being entered into the corrective action program five or more days after the condition was identified. Four of the issues were identified by the NRC staff and three of those required operability determinations. The inspectors reviewed PI-AA-120, Issue Identification and Screening Process, and PI-AA-125, Corrective Action Program Procedure, and noted there was not a specific timeliness requirement for generation of issue reports. However, Step 4.4.2, of PI-AA-120, states that the operability determination should be completed within a 24-hour period. For the three operability determinations that were required, the component/system was determined to be operable.
Observation: Non-conservative Turbine Valve Failure Rate Evaluation 71152B General Design Criterion 4 (GDC 4), "Environmental and Missile Dynamic Effects Design Bases," of Appendix A to 10 CFR Part 50 requires that structures, systems, and components (SSCs) important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These SSCs shall be appropriately protected against dynamic effects including, among others, the effects of missiles. The NRC evaluates a particular plant design for turbine missiles using NUREG-0800, Section 3.5.1.3 (ML063600395). Table 3.5.1.3-1 provides guidance on recommended actions to be taken based upon turbine missile probability values. The inspectors observed that Constellation's main turbine missile generation missile probability analysis was based, in part, on the failure probability of the main turbine master trip solenoid valves (MTSV).
Constellation based the failure probability of the MTSV on internal and external operating experience. The team noted the test frequency of the MTSV was extended based on these analyses. The inspectors noted that in May 2022, Constellation found that their MTSVs had a higher failure rate than previously assumed in past evaluations (IR 04497489). The evaluation was revised using site specific operating experience for MTSV failures and the observed sluggishness of the MTSV plunger, which could impact the latency time during a trip. Prior to June 2022, testing did not have guidance for identifying sluggish response of the MTSVs. Test acceptance criteria was based on operators verifying indicating lights extinguished at the control room control panel. The inspectors noted that testing procedure ESP-9.003, Main Turbine 24 VDC Master Trip A and B Solenoid Test, was revised to verify local operation of the valves. The inspectors also noted that Constellation has planned actions during the next refueling outage to improve reliability of the MTSVs (IR 04691858).
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 5, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Calculations
Evaluate Increased Allowable Thrust Limit for 10MOV-25A
Disc, Stem, and Thrust Adapter w/ Bolts
Revision 0
JAF-CALC-20-
00005
Effects of Extending Turbine Valves and Overspeed
Protection System Test Intervals on Turbine Missile
Generation Probability,
Revision 3
Corrective Action
Documents
225392
259118
04372008
04384093
04418483
04421463
04424369
04468343
04486956
04491270
04495410
04497226
04500034
04500035
04500041
04526683
04526829
04546506
04549167
04549949
04550060
04668343
04669409
04680732
04693055
Corrective Action
04706492
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
04706577
04706580
04706796
04707056
04707627
Miscellaneous
NOSA-JAF-23-04
Engineering Programs Audit Report,
Dated
6/29/23
Procedures
Diverse and Flexible Coping Strategies (FLEX), Spent Fuel
Pool Instrumentation (SFPI), and Hardened Containment
Vent System (HCVS) Program Document
Revision 9
NRC Inspection Preparation and Response
Revision 27
Reportability Tables and Decision Trees
Revision 35
OP-AA-106-101-
1006
Operational Decision Making Process
Revision 24
Operating Experience Program
Revision 5
Corrective Action Program Evaluation Manual
Revision 7
Self-Assessments
Revision 5
Work Screening and Processing
Revision 20
Self-Assessments
22 Raw Water Self-Assessment-James A. FitzPatrick
Dated
6/23/22
04547007
Preparation for NRC Problem Identification and Resolution
(PI&R) Inspection at James A. FitzPatrick
Revision 0
Work Orders
04916716
05150143
05170604
05171769
209073
299002