IR 05000333/2024002
| ML24220A039 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/07/2024 |
| From: | Erin Carfang Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024002 | |
| Download: ML24220A039 (1) | |
Text
August 7, 2024
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2024002
Dear David Rhoades:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On July 29, 2024, the NRC inspectors 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.
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 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-2024-002-0033
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
April 1, 2024 to June 30, 2024
Inspectors:
E. Miller, Senior Resident Inspector
V. Fisher, Resident Inspector
B. Sienel, Resident Inspector
H. Anagnostopoulos, Senior Health Physicist
E. Eve, Senior Project Engineer
T. Fish, Senior Operations Engineer
T. Hedigan, Operations Engineer
L. Sinclair, Operations Engineer
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
None.
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On May 3, 2024, operators reduced reactor power to 73 percent to perform control rod scram time testing and a control rod pattern adjustment. Reactor power was restored to rated thermal power the next day. On June 7, 2024, operators reduced reactor power to 73 percent to perform scram time testing, turbine valve testing, and a control rod pattern adjustment. Reactor power was restored to rated thermal power the next day. On June 29, 2024, operators reduced reactor power to 75 percent to remove control rods to all rods out in preparation for end of cycle coastdown. On June 30, 2024, reactor power was restored to rated thermal power. 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal warm temperatures on June 13, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Reactor core isolation cooling on April 17, 2024 (2)
'B' emergency service water (ESW) during 'A' ESW on May 6, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) East switchgear room, fire area/zone II/SW-2 on April 1, 2024
- (2) West switchgear room, fire area/zone IC/SW-1 on June 11, 2024
- (3) Reactor building 344', fire area/zone IX/RB-1A on June 12, 2024
- (4) Reactor building 326', fire area/zone IX/RB-1A on June 12, 2024
- (5) Reactor building 300', fire area/zone X/RB-1B, VIII/RC-1C on June 24, 2024
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated external flooding mitigation protections in the Manhole 1 during penetration seal repairs on May 9, 2024.
- (2) The inspectors evaluated external flooding mitigation protections in the Manhole 2 during penetration seal repairs on May 13, 2024.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered April - May, 2024, and the biennial written examinations completed May 2023.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification written examinations administered April - May 2023.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the licensee in administering requalification operating tests required by Title 10 of the Code of Federal Regulations (10 CFR) 55.59(a)(2) and that the licensee is effectively evaluating its licensed operators for mastery of training objectives.
Requalification Examination Security
The inspectors evaluated the ability of the licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-Examinations
The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
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 planned downpower to 70 percent to perform control rod scram time testing and a control rod sequence exchange on May 3, 2024; and during a planned downpower to 73 percent to perform scram time testing on June 7, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated an annual simulator examination with scenarios that included inadvertent safety system initiations, steam leaks in primary containment, and fuel failures on April 16, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Drywell continuous atmospheric monitors on April 12, 2024 (2)
'D' residual heat removal service water discharge check valve fouling on April 19, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (8 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 'A' low pressure coolant injection battery planned maintenance on April 10, 2024
- (2) Elevated risk during 'A' control room emergency ventilation system planned maintenance on April 18, 2024 (3)
'B' battery room temporary ventilation during planned maintenance on April 24, 2024 (4)93EDG-57B, 'B' emergency diesel generator gallery lube oil check valve leak on April 25, 2024
- (5) Elevated risk associated with 'B' ESW pipe replacement and planned valve maintenance on April 29, 2024
- (6) Elevated risk associated with 'A' ESW during pipe replacement and 'A' emergency diesel generator fuel oil storage tank inspection on May 6, 2024
- (7) Elevated risk associated with high pressure coolant injection out of service due to a pin hole leak near restricting orifice, RO-137A, associated turbine stop valve, HOV-1, on May 10, 2024
- (8) Elevated risk during unplanned maintenance due to water found in the high pressure coolant injection lube oil supply tank, 23-TK1, on June 25, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) High pressure coolant injection turbine governor control valve, HOV-2, steam leak on April 19, 2024 (2)
'B' residual heat removal shutdown cooling corrosion at elbow near weld over high pressure coolant injection turbine on April 22, 2024 (3)
'C' emergency diesel generator air start motor oil lubricator due to oil leak on April 23, 2024
- (4) Control rods 30-43, 38-11, and 38-27 following slow scram time testing results on May 6, 2024 (5)
'A' emergency diesel generator bulge in fuel oil storage tank on May 8, 2024
- (6) High pressure coolant injection system lube oil sump indicates high water content and particulate count on June 12, 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 (PMT) (IP Section 03.01) (5 Samples)
(1)93EDG-57B, 'B' emergency diesel generator gallery lube oil supply check valve following replacement on April 25, 2024 (2)70TS-109B, 'B' control room temperature switch following replacement on May 2, 2024 (3)93EDG-57A, 'A' emergency diesel generator gallery lube oil supply check valve following cap torque check and internal inspection on May 7, 2024
- (4) High pressure coolant injection system following pipe replacement with pin hole leak near restricting orifice, RO-137A, on drain piping associated with turbine stop valve, HOV-1, on May 11, 2024
- (5) Control room emergency ventilation air system damper, 70MOD-106A, following motor replacement on May 24, 2024
Surveillance Testing (IP Section 03.01) (1 Sample)
- (1) RAP-7.4.01, Control Rod Scram Time Evaluation on June 7, 2024
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
- (1) Functional Test of FLEX-DG2 on June 3, 2024
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (1 Sample)
- (1) The inspectors observed and evaluated a simulator scenario that included declaration of an Alert due to high drywell temperature on June 11,
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) Whole body count for EID C41465
- (2) Whole body count for EID 990312
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Declared pregnant worker Nxxxxx, Cxxxxx
- (2) Declared pregnant worker Fxxxxxx, Pxxxx
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) For the period of January 1, 2023 through December 31, 2023
BI02: RCS Leak Rate Sample (IP Section 02.11) (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) Issue Report (IR) 04681926 - Non-Functional Plant Processing Computer Sequence of Events Recorder
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the FitzPatrick corrective action program for trends that might be indicative of a more significant safety issue.
71153 - Follow-Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated the 'B' emergency diesel generator, 93EDG-57B, gallery lube oil supply check valve failure, and the licensee's performance, on April 25, 2024.
- (2) The inspectors evaluated a high pressure coolant injection system pin hole leak on drain piping near restricting orifice, RO-137A, associated with turbine stop valve, HOV-1, and the licensee's performance, on May 9, 2024.
- (3) The inspectors evaluated a -45 volts direct current (VDC) ground on the 125 VDC 'A' station battery, and the licensee's performance, on June 4, 2024.
Reporting (IP Section 03.05) (1 Sample)
(1)
'D' emergency diesel generator cylinder cooling water leak found after replacement during planned maintenance on January 30,
INSPECTION RESULTS
Minor Performance Deficiency 71152A Sequence of Event (SOE) Log Does Not Generate the Expected Report Due to Inadequate Programming of SOE Points and Inadequate Testing
Minor Performance Deficiency: While performing an inspection for the September 26, 2022, scram due to inadequate Mode Switch performance, inspectors identified that the SOE log did not generate the expected report with all predefined points. The SOE log is designed to capture four minutes of data before and six minutes after the automatic trigger for all predefined analog and digital points. Constellation entered the issue into the corrective action program as IR 04681926 on June 1, 2023. The inspectors reviewed the associated work order assignments, emergency and plant information system (EPIC) design criteria, Constellation software verification and validation requirements, and interviewed Constellation staff.
In 2020, Constellation implemented the James A. FitzPatrick EPIC Plant Processing Computer (PPC) Replacement Project, referred to as R*Time, under engineering change EC-622769. The EPIC system requirements specification, NRT-JAF-18-0031, describes the committed functions for post-trip review as follows: The Post Trip Log, Sequence of Events Log and Transient Recording and Analysis functions of the EPIC system are part of the systems and functions used in Post Trip Review in accordance with Generic Letter 83-28, Required Actions Based on Generic Implications of Salem ATWS Events, which requires that licensees have a capability to record, recall, and display data and information to permit diagnosing the cause of unscheduled reactor shutdown prior to restart and for ascertaining the proper functioning of safety-related equipment.
Constellation reviewed the SOE logs that were generated on September 26, 2022, and compared them to the requirements in NRT-JAF-18-0031, System Requirements Spec (SYRS). The review found 29 points that were not properly configured to allow the SOE log to capture them if their associated events should occur. This review was documented in IR 04681926, Assignment 02 on June 21, 2023. The reviewer recommended at a minimum to perform a database change to update the points to activate the SOE logging.
IR 04681926, Assignment 03, completed on April 27, 2024, determined that the SOE log report from the initiating event at 00:58:31 contained values for 10 digital R*Time points that were properly configured to store their changes of state in the SOE log but did not list the changes of state for several other points that were known to have changed state after the trip.
It was determined that all the points that did not record expected data were configured to not record data into the R*Time sequence of events file. Constellation performed a database update to set the missing data points to record their sequence of events data by reconfiguring the computer point settings.
Additionally, Constellation performed a validation that the SOE log task trigger value in the production database was set correctly after the 2024 software update. Currently IR 04681926, Assignment 04 is due October 23, 2024, and requires a review of the effectiveness of the SOE log generation during the next applicable plant event, e.g., the fall 2024 refuel outage. The inspectors noted that this does not describe how or what testing will be done to perform the effectiveness review.
The inspectors reviewed the work order activities that tested the SOE log. Work Order 05016992-16, EC-622769 Perform Applications Testing for Mod SOE Log Phase 2, Step 4.4 states, Verify the SOE LOG point list is correct per the Project Standards Definition (PSD) Appendix F Table 10-7. This step was signed as performed on November 5, 2021.
The verify step is blank. There is a handwritten note that states, SOE GRP missing last 33 points in Appendix F. This is likely due to there only being 125 points per group. Need to determine if points need to be deleted In the work order documentation, it states SOE Phase 2 Sat. There is no reference to a work order activity to address the missing SOE points.
The inspectors reviewed the work order activities that tested the plant trip log Work Order 05016992-19, EC-622769 Perform Applications Testing for Mod Perform Logging Sat Testing. Step 4.3.21 states, Verify the information on the log appears correct for plant conditions. This step was signed as performed on August 26, 2021. There is a handwritten note that states, All values listed as unavailable. In the work order documentation, it states "Logging Sat." There is no reference to a work order activity to address the missing post trip log data.
While EPIC is not classified as safety-related, the post-trip log, SOE log, and transient recording and analysis functions of the EPIC system are part of the systems and functions used in post-trip review in accordance with Generic Letter 83-28. This is a licensee committed function and is described in Section 7.16.2.7 of the Final Safety Analysis Report: The EPIC provides post-scram analysis logging of the sequence of event actuated changes for alarm inputs on reactor scram trip devices and logging of stored data before and after a reactor scram for selected analog and digital inputs.
Procedure CC-AA-107-1001, "Post Modification Acceptance Testing," Revision 7 requires adequate post modification. Specifically, Attachment 2, Table I-N requires post modification testing for annunciators and sequence of events recorders. The EPIC modification testing should have prevented the SOE log from being nonfunctional and based on documentation in the work orders it was reasonably foreseeable to identify and correct, therefore the SOE log being nonfunctional is a performance deficiency.
Screening: The inspectors determined the performance deficiency was minor. The inspectors evaluated the performance deficiency in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, determined the issue was of minor significance because although the inadequate testing resulted in a nonfunctioning SOE logger, it did not cause any adverse consequences. Specifically, the loss of function did not cause any safety-related equipment malfunctions to go undetected after the reactor scram on September 26, 2022.
Minor Performance Deficiency 71152S Semiannual Trend
Minor Performance Deficiency: The inspectors evaluated a sample of issues and events that occurred over the first and second quarters of 2024. The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Constellation staff for potential trends at a low threshold and resolved within the scope of the corrective action program.
The inspectors identified a trend associated with leaks from the high pressure coolant injection system due to leak-by on the 23MOV-14, the steam supply isolation valve. Although the 23MOV-14 has been leaking since October 2022, an increase in steam leaks began on April 18, 2024, which included a bonnet steam leak on the 23HOV-2, the high pressure coolant injection turbine control valve. On April 29, 2024, a steam leak from the gland seal exhaust fan housing was identified by the NRC inspectors. On May 9, 2024, a through-wall steam leak occurred on 23HOV-1 stop valve drain line at restricting orifice, RO-137A; and visible steam leaks from the turbine gland seal housing was identified by the NRC inspectors.
The station generated IRs for each of the issues except for the gland seal housing steam leak. Constellation determined that although steam was not emanating from the housing prior to this, a previous NRC-identified leak in the form of condensation was already documented on January 16, 2024. As a result of the inspectors observation, Constellation generated IR 04789238 to document the trend.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that Constellations failure to address the leak trend with a trend IR was minor because each issue was entered individually into the corrective action program and addressed. Based on the overall results of the semiannual trend review, the inspectors determined that Constellation had generally identified adverse trends before they could become more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, and determined them to be minor.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 29, 2024, the inspectors presented the integrated inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
- On June 20, 2024, the inspectors presented the occupational dose assessment 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
Procedures
Loss of 345 KV Breaker Air
WC-JF-107-1000
Seasonal Readiness T&RM for JAF
Drawings
Flow Diagram Reactor Core Isolation Cooling System 13
Flow Diagram Emergency Service Water System 46 and 15
Procedures
Reactor Core Isolation Cooling System
Emergency Service Water
Locked Equipment Program
Corrective Action
Documents
04737113
04761513
Fire Plans
Reactor Building-West/Elev. 300' Fire Area/Zone X/RB-1B,
VIII/RB-1C
Reactor Building/Elev. 326' Fire Area/Zone IX/RB-1A
Reactor Building/Elev. 344' Fire Area/Zone IX/ RB-1A
Switchgear Room East/Elev. 272'/Fire Area/Zone II/SW-2
Switchgear Room West/Elev. 272' Fire Area/Zone IC/SW-1
Miscellaneous
JAF-RPT-04-
00478
JAF Fire Hazards Analysis
Procedures
Portable Fire Extinguisher Inspection Procedure 71111.06
Corrective Action
Documents
04724689
Engineering
Changes
640742
Penetration Sealing Running from Manhole to Reactor
Building
Work Orders
04814225
05423867
71111.11Q Procedures
Plant Power Change
Corrective Action
Documents
04757177
04757730
Miscellaneous
Design Basis Document for Normal Service Water,
Emergency Service Water, and Residual Heat Removal
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Loss of Coolant
Hot Primary Containment Control
Corrective Action
Documents
04769343
04780282
Drawings
Flow Diagram Emergency Service Water System 46 and 15
Procedures
Battery Room Ventilation
Work Orders
05548735
Corrective Action
Documents
04764595
04767352
04768316
04771991
04771993
04771994
04772624
04780282
Work Orders
05548735
Corrective Action
Documents
04769343
04771790
04773079
04775980
Procedures
Control Room Ventilation Alternate Supply Air
001
Control Rod Scram Time Evaluation
Work Orders
05409880
05425251
05533124
05535132
05536807
05541608
71151
Miscellaneous
Regulatory Assessment Performance Indicator Guidance
Procedures
Collecting and Reporting of NRC ROP Performance
Indicator Data
Monthly Data Elements for NRC ROP Indicator - Reactor
Coolant System Specific Activity
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
04524574
04691926
Corrective Action
Documents
04731389
04767352
04770530
04773079
04780282
Corrective Action
Documents
04741820
04742576
04769343
04778705
Procedures
Direct Current Power System 'A' Ground Isolation
Work Orders
04694369
05468181