IR 05000333/2024001
| ML24130A007 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/09/2024 |
| From: | Erin Carfang NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024001 | |
| Download: ML24130A007 (1) | |
Text
May 9, 2024
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2024001
Dear David Rhoades:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On April 18, 2024, 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.
No findings or violations of more than minor significance were identified during this inspection.
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-2024-001-0049
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
January 1, 2024 to March 31, 2024
Inspectors:
Eric D. Miller, Senior Resident Inspector
Eric C. Miller, Reactor Inspector
B. Sienel, Resident Inspector
H. Anagnostopoulos, Senior 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.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000333/2023-002-00 Reactor Protection System Electric Power Monitoring System Trip Caused Primary Containment Isolation 71153 Closed LER 05000333/2023-002-01 Reactor Protection System Electric Power Monitoring System Trip Caused Primary Containment Isolation 71153 Closed
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On March 1, 2024, operators reduced reactor power to 73 percent to perform a planned control rod pattern adjustment, turbine valve testing, and control rod scram time testing. Following completion of the planned activities, operators restored power to rated thermal power on March 2, 2024. 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, 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
Impending Severe Weather (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated readiness for impending adverse weather for a high wind warning on January 8, 2024.
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' and 'D' emergency diesel generators (EDGs) on February 7, 2024
- (2) 'A' and 'C' EDGs on February 12, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection (IP Section 03.01) (6 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) Auxiliary boiler yard south on January 2, 2024
- (2) Crescent area east, elevation 227' and 242', fire area/zone XVI/RB-1E on January 2, 2024
- (3) Reactor building east, elevation 272', fire area/zone IX/RB-1A, on January 2, 2024
- (4) Reactor building east, elevation 300', fire areas/zones IX/RB-1A and VIII/RB-1C, on January 2, 2024
- (5) Standby gas filter room, elevation 272', fire area/zone XX/SG-1, on January 2, 2024
- (6) Turbine building north, elevation 272', fire area/zone IE/TB-1, on March 14, 2024
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 January 29, 2024.
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 'C' EDG troubleshooting on January 17, 2024, and during a planned downpower to approximately 72 percent for a control rod sequence exchange and turbine valve testing on March 1, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed a simulator evaluation that included the loss of one 115 kilovolt power line, a stuck open safety relief valve, and an earthquake on January 9, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Fire suppression system on March 26, 2024
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 'C' EDG output breaker 'A' phase generator differential relay 93-87-A-1EDGC07 on January 16, 2024
Aging Management (IP Section 03.03) (1 Sample)
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) Handhole 1 near the main stack on January 23, 2024
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) Unplanned maintenance following the 'C' EDG failure to load and opening of the output breaker during a surveillance on January 16, 2024
- (2) Elevated risk during 'D' EDG planned maintenance on January 31, 2024
- (3) Elevated risk during 'B' low pressure coolant injection (LPCI) battery maintenance on February 14, 2024
- (4) Elevated risk during planned reactor core isolation cooling (RCIC) system maintenance on February 20, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Average power range monitor 'B' following identification of elevated value on January 17, 2024
- (2) Impact of anticipated transient without scram overpressure analysis on high pressure coolant injection (HPCI) discharge valve opening differential pressure on February 8, 2024
- (3) 'D' EDG speed switch following component replacement on February 12, 2024
- (4) 'C' EDG electrical load indication drifting on February 12, 2024
- (5) RCIC system turbine high oil particulate on March 19, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Fire protection system blank flange installation during fire piping leak outside the standby gas treatment system room on January 17, 2024
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) (9 Samples)
(1)6-inch fire piping, 6-WF-151-156, following an underground leak outside the standby gas treatment room, on January 11, 2024
- (2) 'C' EDG following troubleshooting of 71-10512 breaker trip during monthly test, on January 16, 2024 (3)4160 volt breaker 71-10612 (S/N0224A8987-008) following racking screw shutter failure to close, on February 2, 2024
- (4) 'D' EDG following planned maintenance, on February 5, 2024
- (5) Emergency service water (ESW) following planned 'D' EDG jacket water cooler outlet expansion joint replacement, on February 5, 2024
- (6) LPCI battery room fire damper, 66DMP-F1B, following planned preventive maintenance on February 12, 2024
- (7) RCIC following planned maintenance, on February 23, 2024
- (8) Control rod 26-23 following water accumulator replacement, on March 2, 2024
- (9) Reactor protection system (RPS) following control valve fast closure scram trip logic relay 05A-K8C replacement, on March 2, 2024
Surveillance Testing (IP Section 03.01) (6 Samples)
- (1) ISP-100A-RPS, RPS Instrument Functional Test/Calibration, on January 18, 2024
- (3) MST-071.25, LPCI Battery Modified Performance Test, on February 13, 2024
- (4) MST-013.01, RCIC Turbine Mechanical Overspeed Trip Test and Adjustment, on February 22, 2024
- (5) ST-1L, Main Turbine Control Valve Instrument Channel and Valve Operability Check, on March 2, 2024
- (6) ST-DB, Secondary Containment Train B Leak Test, on March 22, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
- (1) The inspectors evaluated the conduct of a routine emergency response drill that involved an inadvertent start of the HPCI system, an anticipated transient without scram, and a reactor coolant leak, on January 30, 2024.
Additional Drill and/or Training Evolution (1 Sample)
The inspectors evaluated:
- (1) The inspectors observed and evaluated a simulator scenario that included the declaration of an alert due to high drywell pressure on January 9,
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Accessible portions of the control room emergency ventilation air supply system
- (2) Accessible portions of the technical support center ventilation system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation system:
- (1) Portable high-efficiency particulate air unit staged for use in the reactor building, elevation 326', decontamination room #0097005
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours (IP Section 02.01)===
- (1) For the period of January 1, 2023 through December 31, 2023
IE03: Unplanned Power Changes per 7000 Critical Hours (IP Section 02.02) (1 Sample)
- (1) For the period of January 1, 2023 through December 31, 2023
IE04: Unplanned Scrams with Complications (IP Section 02.03) (1 Sample)
- (1) For the period of January 1, 2023 through December 31, 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 04681889 - 'B' RPS Motor Generator (MG) Set Trip and Partial Primary Containment Isolation
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 05000333/2023-002-00 and LER 05000333/2023-002-01, Reactor Protection System Electric Power Monitoring System Trip Caused Primary Containment Isolation (ADAMS Accession Nos ML23164A230 and ML23226A139, respectively). The inspectors reviewed the updated LER submittals. The inspection conclusions associated with these LERs are documented in this report under Inspection Results.
These LERs are Closed.
Reporting (IP Section 03.05) (1 Sample)
- (1) 'D' EDG speed switch found not working during planned maintenance on January 30,
INSPECTION RESULTS
Minor Performance Deficiency 71152A
'B' RPS MG Set Failure Due to Inadequate Maintenance Instruction and Inadequate Preventive Maintenance Strategy
Minor Performance Deficiency: On April 14, 2023, May 25, 2023, and May 31, 2023, the B RPS MG set tripped due to an electrical power assembly overvoltage condition. Constellation entered the issue into the corrective action program as IR 04670001 and completed a corrective action program evaluation (CAPE) based on being classified as a Significance Level 2. The inspectors reviewed the CAPE, associated maintenance work orders, failure modes and effects analyses, laboratory failure analyses, and interviewed Constellation staff.
The RPS provides timely protection against the onset and consequences of conditions that threaten the integrity of the fuel cladding or the reactor coolant pressure boundary. The RPS consists of power supplies with associated control and indicating equipment, sensors, relays, and bypass circuitry to shut down (scram) the reactor. The RPS MG sets provide 120 volts alternating current to RPS buses A and B. Alternate source transformers also provide a backup source of power. The power supply for the RPS is arranged so that loss of one supply neither causes nor prevents a reactor scram.
Constellation determined the overvoltage trips on April 14, 2023 and May 25, 2023 were due to insufficient guidance provided in the 1P potentiometer wiping preventive maintenance work orders to detect and prevent failures. During maintenance troubleshooting it was identified that the potentiometer exhibited erratic resistance when tested at the station using a Simpson meter and at PowerLabs. The erratic performance was attributed to a poor electrical connection, likely between the wiper and winding, and oxidation. During Constellation review of the current preventive maintenance work order it was identified that the procedure steps were ineffective to determine potentiometer health. Specifically, in addition, the type of meter was not specified and a reading was not being taken during full rotation of the potentiometer.
It was determined that a Simpson-like meter should be used, and the potentiometer resistance should be measured across the full rotation to determine if high-resistance spots exist on the potentiometer.
In addition, Constellation determined the cause of the trip on May 31, 2023, to be a failed K2 relay that was not replaced in a timely manner. A preventive maintenance change request, PMRQ #342666-02, had been implemented to replace the K2 relay on a 10-year frequency following a trip of the MG set in 1998 which resulted in issuance of LER 0500033398-014, Relay Failure Causes Trip of RPS Power Supply and Engineered Safeguards Feature (ESF)
Actuation. However, Constellation staff identified that a preventive maintenance task was cancelled during a value-based maintenance implementation assessment in April 2021.
Title 10 CFR Part 50, Appendix B Criterion V, Instructions, Procedures, and Drawings, requires 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. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to this, on April 14, 2023, and May 25, 2023 it was identified that the work instruction to perform the RPS MG set potentiometer preventive maintenance was not adequate to detect a degraded condition. Specifically, a reading was not being taken during full rotation of the potentiometer or with the correct equipment. As a result, Constellation staff failed to identify erratic resistance and oxidation on the potentiometer prior to failure.
In addition, Technical Specification 5.4.1(a), Procedures, requires in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in Regulatory Guide 1.33, Appendix A, November 1972. Regulatory Guide 1.33, Appendix A,Section I.1 states, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Regulatory Guide 1.33, Appendix A,Section I.2 states, in part, that preventive maintenance schedules should be developed to specify inspection or replacement of parts that have a specific lifetime. Procedure ER-AA-200, Preventive Maintenance Program, Revision 6, 4.3.4 states, PCM (precision-centered maintenance) Templates may not provide the complete Maintenance Strategy for all Critical or Non-Critical Components. As such, it is the responsibility of the SSME (station subject matter expert) or Strategic Engineer to ensure there is an effective Maintenance Strategy for all Critical or Non-Critical Components based on failure history, vendor recommendations, industry operating experience (OPEX), and engineering judgement. Contrary to this, following a preventive maintenance change in April 2021, the B RPS MG set K2 relay replacement that was a result of station OPEX was cancelled. As a result, a failure occurred on May 31, 2023.
Screening: The inspectors determined the performance deficiency was minor. Constellations failure to address the inadequate preventive maintenance work order and the failure to incorporate OPEX into the maintenance strategy for the B RPS MG set are minor because although they resulted in a partial primary containment isolation, it did not cause any adverse consequences. Specifically, the loss of reactor water cleanup due to the partial containment isolation did not result in chemistry parameters going outside of specification.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 14, 2024, the inspectors presented the radiation protection inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
- On April 18, 2024, the inspectors presented the integrated inspection results to Garrick Olson, Plant Manager, and other members of the licensee staff.
THIRD PARTY REVIEWS
Inspectors reviewed the April 2023 Institute of Nuclear Power Operations evaluation report that was issued in January 2024.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Severe Weather
FLEX Equipment Inventory and Inspection
OP-AA-108-111-
1001
Severe Weather and Natural Disaster Guidelines
Procedures
Emergency Service Water
Diesel Generator Emergency Power
Diesel Generator Room Ventilation
Fire Plans
Auxiliary Boiler Yard South
Crescent Area - East/Elevation 227', 242', Fire Area/Fire Zone
XVII/RB-1E
Reactor Building - East/Elevation 272', Fire Area/Zone IX/RB-
1A
Standby Gas Filter Room, Elevation 272', Fire Area XX/Fire
Zone SG-1
Reactor Building - East/Elevation 300', Fire Area/Zone IX/RB-
1A, VIII/RB-1C
Turbine Building North/Elevation 272', Fire Area/Zone IE/TB-1
Procedures
Fire Drill Performance
71111.11Q Miscellaneous
FPC26-7.0
Reactivity Maneuver Plan
Corrective Action
Documents
04725680
04731298
Miscellaneous
Maintenance Rule Basis Document for the Fire Protection
System
Procedures
ER-JF-450
James A. FitzPatrick Structures Monitoring Program
Warehouse Operations
Procurement Engineering Process and Responsibilities
Procedures
Protected Equipment Program
Corrective Action
Documents
04742564
04750416
04758855
Corrective Action
04739682
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
Engineering
Changes
638106
TRACG ATWS for FitzPatrick
Miscellaneous
Design Basis Document for the High Pressure Coolant
Injection System
Ref No. 7684756
RCIC Turbine Oil Sample Analysis Report
2/23/2024
Procedures
MA-AA-716-230-
1001
Oil Analysis Interpretation Guideline
APRM Calibration
Engineering
Evaluations
EC-JAF-001
Fire Protection System Blank Flange Maintenance Rule 90
Technical Evaluation
Corrective Action
Documents
04502173
04731298
04740913
04756007
Corrective Action
Documents
Resulting from
Inspection
04754609
Drawings
Flow Diagram Fire Protection Water Piping System 76
Procedures
RPS Instrument Functional Test/Calibration (ATTS)
RCIC Turbine Mechanical Overspeed Trip Test and
Adjustment
LPCI Battery Modified Performance Test
Control Rod Scram Time Evaluation
Main Turbine Control Valve Instrument Channel and Valve
Operability Check
Main Turbine Control Valve Instrument Channel Check,
Operability Check, and Fast Closure Response Time Test
HPCI Quick-Start, Inservice, and Transient Monitoring Test
(IST)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Heat Detector Functional Test - Water Spray Curtain Boundary
Number 1
Heat Detector Functional Test - Stairwell Water Spray
Boundary Number 5
Heat Detector Functional Test - Stairwell Water Spray
Boundaries Numbers 6 and 8
EDG 'B' and 'D' Full Load Test and ESW Pump Operability
Test
EDG 'B' and 'D' Full Load Test and ESW Pump Operability
Test
Secondary Containment Train B Leak Test
Work Orders
04862365
05026034
266595
05353967
05386050
05422788
05424364
05431139
05439385
05439969
Procedures
Emergency Classification and Protective Action
Recommendations
Emergency Response Organization (ERO)/Emergency
Response Facility (ERF) Activation and Operation
Control Room Operations
71151
Corrective Action
Documents
Resulting from
Inspection
04749739
71152A
Corrective Action
Documents
04680732
04681889
Procedures
Issue Identification and Screening Process
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action Program (CAP) Procedure
Corrective Action Program Evaluation Manual
Corrective Action
Documents
04742576
Work Orders
05468181