IR 05000333/2024003
| ML24317A213 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/12/2024 |
| From: | Erin Carfang NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| EPID I-2024-003-0032 IR 2024003 | |
| Download: ML24317A213 (1) | |
Text
November 12, 2024
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2024003
Dear David Rhoades:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On October 30, 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.
Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 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-2024-003-0032
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
July 1, 2024 to September 30, 2024
Inspectors:
E. Miller, Senior Resident Inspector
V. Fisher, Resident Inspector
H. Anagnostopoulos, Senior Health Physicist
J. DeBoer, Senior Emergency Preparedness Inspector
M. Hardgrove, Senior Project Engineer
C. Kline, Senior Resident Inspector
J. Lilliendahl, Senior Emergency Response Coordinator
K. Mangan, Senior Reactor Inspector
B. Sienel, Resident Inspector
J. Tifft, Senior Reactor Inspector
A. Turilin, Reactor Inspector
Approved By:
Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at James A. FitzPatrick Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Post-Maintenance Test Results in Inoperable Control Room Emergency Ventilation System (CREVAS)
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2024003-01 Open/Closed
[H.12] - Avoid Complacency 71111.24 A finding of very low safety significance (Green) and an associated non-cited violation (NCV)of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI,
Test Control, was self-revealed on April 26, 2024, during functional testing of CREVAS.
Specifically, Constellation failed to adequately test temperature switch 70TS-109B following replacement in January 2023. As a result, the station did not identify a latent deficiency of 70TS-109B that caused CREVAS and the control room air conditioning (CRAC) systems to be inoperable.
Failure to Ensure the Alert and Notification System (ANS) Siren Program Complied with the Approved Federal Emergency Management Agency (FEMA) ANS Design Report Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000333/2024003-02 Open/Closed
[H.1] -
Resources 71114.02 The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) and 50.47(b)(5). Specifically, the licensee failed to ensure the ANS siren program complied with the approved FEMA ANS Design Report by ensuring that foliage growth did not adversely impact siren operation or limit access to the siren.
Water Accumulation in the High Pressure Coolant Injection (HPCI) Lube Oil System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000333/2024003-03 Open/Closed
[P.5] -
Operating Experience 71152A The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B,
Criterion XVI, "Corrective Action," for Constellations failure to identify and correct a condition adverse to quality associated with a HPCI steam leak. Specifically, following the inspectors identification of a HPCI turbine gland seal casing steam leak, Constellation failed to prevent water intrusion in the HPCI lube oil system. As a result, water accumulated in the HPCI lube oil reservoir causing the need for HPCI unavailability to replace the oil.
Five Safety Relief Valves Inoperable for Greater than Technical Specification (TS) Allowed Time Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2024003-04 Open/Closed Not Applicable 71152A A self-revealed Severity Level IV NCV of TS Limiting Condition for Operation (LCO) 3.4.3 was identified; however, the inspectors determined there was not a performance deficiency. TS LCO 3.4.3 requires that the safety function of nine safety relief valves shall be operable in Modes 1 2, and 3. While performing testing as required by Surveillance Requirement (SR)3.4.3.1, FitzPatrick staff determined the lift setpoints of five safety relief valves were outside the required lift setpoint of 1,145 +/- 34.3 psig.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000333/2021-001-01 Inadequate Protection Devices for DC Motor Field Shunt Cables Through Separate Fire Areas 71152A Closed LER 05000333/2022-003-00 Safety Relief Valves Lift Setpoint Found Out of Tolerance Low 71152A Closed LER 05000333/2022-003-01 Safety Relief Valves Lift Setpoint Found Out of Tolerance Low 71152A Closed LER 05000333/2022-003-02 Safety Relief Valves Lift Setpoint Found Out of Tolerance Low 71152A Closed
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On July 26, 2024, FitzPatrick began end-of-cycle coastdown. On August 12, 2024, operators reduced reactor power to 85 percent due to a feedwater heater tube leak. The same day, operators reduced reactor power to 80 percent after emergently removing the 'A' condensate booster pump due to a failed open minimum flow valve. Between August 14, 2024, and August 15, 2024, operators reduced reactor power from 80 percent to 75 percent with increasing feedwater heater tube leakage and to maintain condensate parameters. On August 15, 2024, operators reduced reactor power to 40 percent to isolate the 'A' feedwater heater string. The unit remained at 40 percent power until August 18, 2024, when operators restored extraction steam. Between August 18, 2024, and August 23, 2024, operators increased reactor power 45 percent to 51 percent. On September 3, 2024, operators commenced a power reduction and on September 4, 2024, operators removed FitzPatrick from service to commence refueling outage 26 (J1R26). On September 17, 2024, operators commenced a reactor startup following J1R26. On September 18, 2024, operators synced the unit to the grid. On September 19, 2024, the unit reached rated thermal power. On September 20, 2024, operators commenced a downpower to 86 percent power to perform a control rod pattern adjustment. The unit returned to rated thermal power the same day. On September 23, 2024, FitzPatrick experienced a turbine trip and reactor scram due to a grid disturbance. On September 24, 2024, operators commenced a reactor startup and synced to the grid the same day. On September 25, 2024, the unit reached rated thermal power. On September 25, 2024, after reaching rated thermal power, operators reduced reactor power to 75 percent to perform a control rod pattern adjustment. The unit was restored 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, 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 Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) 'B' core spray system on July 2, 2024
- (2) 'B' and 'D' emergency diesel generators on July 10, 2024
- (3) 'A' residual heat removal system in shutdown cooling mode on September 5, 2024
- (4) Decay heat removal system during refueling outage shutdown conditions on September 9, 2024
- (5) Spent fuel pool cooling system after spent fuel pool gates installed on September 19, 2024
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the residual heat removal service water system on July 17, 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) Radwaste building 250', fire area/zone XIX/RW-1 on August 21, 2024
- (2) Radwaste building 272' and 279', fire area/zone XIX/RW-1 on August 21, 2024
- (3) Drywell 256, 268 and 292, fire area/zone XIV/PC-1 on September 10, 2024
- (4) Main steam tunnel, fire area/zone IA/MG-1 on September 10, 2024
- (5) Turbine building 252', 272', and 300', fire area/zone IE/TB-1 on September 10, 2024
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (2 Samples)
The inspectors evaluated readiness and performance of:
(1)67UC-16B east electric bay unit cooler on July 29, 2024
- (2) Ultimate heat sink main condenser and intake on September 8, 2024
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
The inspectors evaluated boiling water reactor non-destructive testing by reviewing the following examinations from September 9-13, 2024:
(1)
- Phased Array Ultrasonic Examination of N2F Nozzle to Safe End Weld (1R26-ISI-VE-003)
- Ultrasonic Examination of the N-7 Nozzle to Shell Weld (J1R26-RPV-R5)
- Ultrasonic Examination of the N-7-IR Nozzle Inner Radius (J1R26-RPV-R6)
- Ultrasonic Examination of the B-3-2 Torus Shell Thickness (1R26-IWE-UT-001)
- Radiography Test of 23MOV14 field weld 1 (WO 05301128)
- High Pressure Cooling Injection, component 23MOV-14, GTAW and SMAW welding activities associated with the replacement of the Class 2 HPCI steam inlet isolation valve per WO 054301128 (weld No. 05301128-01-01). The post-welding NDE included radiograph (NDE WO 05301128)
- Visual VT-3 Examination of BWR Vent System Interior (Torus) (1R26-IWE-VT-002)
- Visual VT-3 Examination of BWR Vent System Exterior (Torus) (1R26-IWE-VT-003)
- General Visual Examination of Torus Interior RB 227 to 272 (Torus Shell Above Water) (1R26-IWE-VT-004)
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 and evaluated licensed operator performance in the control room during a reactor shutdown for refuel outage J1R26 on September 4, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed a simulator evaluation that included a reactor startup preparation on August 29, 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 on September 11, 2024
- (2) Torus internal structure on September 12, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 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) Emergent work on 'C' condensate booster pump following motor replacement associated with condensate feedwater system on August 14, 2024
- (2) Reactor cavity floodup on September 5, 2024
- (3) 'A' residual heat removal in shutdown cooling mode during reactor pressure vessel floodup on September 6, 2024
- (4) 'B' 125 volts direct current station battery out of service associated with electrical power system on September 6, 2024
- (5) Shutdown cooling capability window associated with decay heat removal system in service on September 9, 2024
- (6) Reactor cavity drain down on September 14, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (3) Degraded bolts on the intake impeller of 'B' emergency service water emergency service water pump, 46P-2B, on September 8, 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) Reactor building exhaust effluent radiation monitor rack sample pump, 17RM-452A, temporary pump on July 8, 2024
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)
- (1) The inspectors evaluated refueling outage J1R26 activities from September 3, 2024 to September 18, 2024.
- (2) The inspectors evaluated forced outage J1F25 activities from September 23, 2024 to September 24, 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) (4 Samples)
(1)70TS-109B, CREVAS temperature control switch following failure, on July 1, 2024
- (2) HPCI system following oil pressure control valve, 23PCV-12, replacement due to emergent oil leak on July 12, 2024 (3)23MOV-14, HPCI steam supply isolation valve following replacement, on September 18, 2024
Surveillance Testing (IP Section 03.01) (2 Samples)
- (2) MST-071.24, 125 VDC 'B' Station Battery Performance Test on September 26, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the licensee's maintenance and testing of the James A. FitzPatrick Nuclear Power Plant ANS on August 5-8, 2024, for the period of August 2022 to July 2024.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors evaluated the readiness of the Emergency Preparedness Organization on August 5-8, 2024, for the period of August 2022 to July 2024.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
- Evaluation 22-47, JAF Nuclear Power Plan Evacuation Time Estimates, EP-AA-1014, Addendum 2, Revision 1
- Evaluation 23-15, Radiological Emergency Plan Annex for James A.
FitzPatrick, EP-AA-1014, Revision 5
This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the maintenance of the Emergency Preparedness Program on August 5-8 for the period of August 2022 to July
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Contamination controls for electron capture radionuclides per RP-AA-300-1002 for work on the 'B' moisture separator re-heater
- (2) Removal of torus de-sludging vacuum hoses from the torus underwater diving contamination area
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Source verification of the calibration of the 'B' drywell hi-range (accident) radiation monitor
- (2) Repairs to the 'B' moisture separator re-heater, RWP JF-1-2024-00807
- (3) Cut out and replacement of the 23MOV-14 valve, RWP JF-1-2024-00621
- (4) Removal and repair or replacement of traversing incore probe indexers in the drywell, RWP JF-1-2024-00544
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
- (1) 'B' moisture separator re-heater work area on the turbine building 300' elevation
- (2) West demineralizer room on the 252' elevation of the turbine building
- (3) Dive ladder for entrance into the torus water during de-sludging work inside the torus (reactor building)
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Portable high-efficiency particulate air unit established in the turbine building on the 300' elevation in support of entry into the B moisture separator/re-heater unit for repairs.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) For the period of July 1, 2023 through June 30, 2024
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) For the period of July 1, 2023 through June 30, 2024
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) 04780282 - Water Accumulation in the High Pressure Coolant Injection Lube Oil System
- (2) IR 04442380 - Perform Extent of Condition to Review Alternating Current Circuits for Appendix R Compliance
- (3) IR 04527149 - Safety Relief Valve Set Points Found to be Low Out of Technical Specification Allowed Range
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Follow up (IP Section 03.01)
- (1) The inspectors evaluated a reactor scram due to grid disturbance, and the licensee's performance, on September 23, 2024.
Event Report (IP Section 03.02) (2 Samples)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
- (1) Licensee Event Reports (LERs) 05000333/2022-003-00, 05000333/2022-003-01, and
===05000333/2022-003-02, Safety Relief Valves Lift Setpoint Found Out of Tolerance Low (ADAMS Accession Nos. ML22334A225, ML23118A227, and ML23251A149, respectively). The inspection conclusions associated with these LERs are documented in this report under Inspection Results. These LERs are Closed.
- (2) LER 05000333/2021-001-01, Inadequate Protection Devices for DC Motor Field Shunt Cables Through Separate Fire Areas (ADAMS Accession No. ML23010A180).
The circumstances surrounding this LER are documented in Inspection Report 2021014 (ADAMS Accession No. ML22140A054). This LER is Closed.
Personnel Performance (IP Section 03.03)===
- (1) The inspectors evaluated feedwater heater 7A tube leak, and the licensee's performance, on August 12, 2024.
- (2) The inspectors evaluated a reactor scram due to a grid disturbance on September 23, 2024.
Notice of Enforcement Discretion (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensee's actions surrounding Notice of Enforcement Discretion No. EA-24-113, which can be accessed at http://www.nrc.gov/reading-rm/doc-collections/enforcement/notices/noedreactor.html, associated with an inoperable rod worth minimizer and TS 3.3.2.1, "Control Rod Block Instrumentation,"
Condition C on September 23,
INSPECTION RESULTS
Inadequate Post-Maintenance Test Results in Inoperable Control Room Emergency Ventilation System (CREVAS)
Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000333/2024003-01 Open/Closed
[H.12] - Avoid Complacency 71111.24 A finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, was self-revealed on April 26, 2024, during functional testing of CREVAS. Specifically, Constellation failed to adequately test temperature switch 70TS-109B following replacement in January 2023. As a result, the station did not identify a latent deficiency of 70TS-109B that caused CREVAS and the CRAC systems to be inoperable.
Description:
The CREVAS system provides temperature and humidity control for the main control room. The control room is served by two full capacity redundant units consisting of air handling-cooling units, recirculation exhaust fans, special filter trains, and emergency control room supply fans. Should the control room experience temperature greater than 98 degrees Fahrenheit, several dampers will automatically modulate to help circulate airflow and lower the temperature. Temperature sensors are in place as part of the control logic. Temperature switch 70TS-109B is one such temperature sensor. The component is a gas filled thermometer with a tube filled neutral gas. This gas will expand upon the influence of temperature changes on the stem. A temperature increase will prompt an increase in pressure of the gas. When the increased pressure reaches the temperature setpoint, it will then deflect the end of the Bourdon tube, triggering activation of the switch.
On January 12, 2023, while performing routine preventive maintenance on 70TS-109B, the switch would not activate without mechanical agitation and would not reset when pushing the reset button. As a result, the station replaced the temperature switch. As part of post-maintenance testing, the station performed a successful calibration and declared the temperature switch operable.
On April 26, 2024, Constellation staff performed ST-18, Main Control Room Emergency Fan and Damper Operability Test, an 18-month routine surveillance test to satisfy TS SR 3.7.3.1 to demonstrate operability of the CREVAS system. Step 8.10.7 directs the staff to trip the temperature switch by applying heat to the sensor using a heat gun. The switch failed to trip during the step. Operators entered an unplanned 7-day LCO allowed outage time (AOT)associated with TS 3.7.3 for CREVAS and 30-day AOT for TS 3.7.4, "Control Room Air Conditioning (CRAC) System."
Constellation replaced 70TS-109B and completed ST-18 surveillance testing successfully on May 3, 2024. Further investigation of 70TS-109B by Constellation staff resulted in the discovery of a leak allowing the gas to escape the Bourdon tube and prevent proper operation. The leak was coming from a crack in the brazed connection where with capillary connects to the switch. The station performed a work group evaluation associated with IR 04769671 and determined that the station should have performed ST-18 to verify proper function of 70TS-109B. Procedure MA-AA-716-012, Post Maintenance Test, Step 4.2.2 states, a satisfactory test verifies a particular component or system is able to perform its intended function, the original deficiency has been corrected, and no new or related problems were created by the maintenance activity or configuration change. Attachment 1, Control Circuits Test Matrix, lists Auto Functional in addition to calibration. The station determined that if ST-18 had been performed following installation in January 2023, the component deficiency would have been detected.
Corrective Actions: Constellation replaced the temperature switch and performed ST-18 to ensure proper temperature switch operation. The station also generated a task to ensure model work orders associated with the control room temperature switches include a functional test following any calibration.
Corrective Action References: IR 04769671
Performance Assessment:
Performance Deficiency: Constellation failed to perform an adequate post-maintenance test following temperature switch replacement.
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. Specifically, Constellation failed to adequately test 70TS-109B following replacement in January 2023. As a result, the station did not identify a latent deficiency of 70TS-109B that caused CREVAS and the CRAC systems to be inoperable.
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 3, Section D, "Control Room," because the performance deficiency did not represent a degradation of the radiological barrier function for the control room and did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, Constellation failed to adequately test 70TS-109B following replacement in January 2023. As a result, the station did not identify a latent deficiency of 70TS-109B that caused CREVAS and the CRAC systems to be inoperable.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," states, in part, that a test program shall be established to assure that all testing required to demonstrate that SSCs will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, Constellation failed to adequately test 70TS-109B following replacement on January 12, 2023. As a result, the station did not identify a latent deficiency of 70TS-109B that caused CREVAS and the CRAC systems to be inoperable until the switch was replaced and successfully tested on May 4, 2024.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Ensure the Alert and Notification System (ANS) Siren Program Complied with the Approved Federal Emergency Management Agency (FEMA) ANS Design Report Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness
Green NCV 05000333/2024003-02 Open/Closed
[H.1] -
Resources 71114.02 The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) and 50.47(b)(5). Specifically, the licensee failed to ensure the ANS siren program complied with the approved FEMA ANS Design Report by ensuring that foliage growth did not adversely impact siren operation or limit access to the siren.
Description:
Nine Mile Point and James A. FitzPatrick nuclear power plants are located along the southeastern shore of Lake Ontario, in the town of Scriba, New York. The 10-mile plume exposure emergency planning zone (EPZ) is defined by an irregularly shaped area and includes Lake Ontario and the Oswego River. The area surrounding the site is relatively flat.
The county is predominately rural, containing woodlands, wetlands, and inactive agricultural lands. The ANS consists of 40 American Signal T-128 sirens mounted on 60-foot galvanized steel poles located throughout the 10-mile EPZ.
The NRC inspectors selected a sample size of eight sirens to inspect for overall material condition during the emergency preparedness program inspection on August 7, 2024. The inspectors identified six out of those eight sirens which appeared to have foliage and growth within 25 feet of the siren head: Sirens 01, 08, 21, 22, 28, and 37. In addition, the inspectors reviewed 2023 maintenance records for the 40 sirens in the EPZ and identified a total of 19 sirens in which the foliage appears to be within the specified distance of 25 feet from the siren head based upon photographs: Sirens 01, 02, 03, 04, 06, 08, 10, 12, 13, 15, 21, 22, 23, 28, 29, 31, 35, 36, and 37.
The design report states that the maintenance program also includes monitoring tree growth at each siren site to assure that nearby foliage is below the top of the mounting pole, so it does not interfere with near-field siren sound propagation (e.g., tree growth is at least 25 feet away or below the siren horn), and does not cause excessive radio frequency scatter (i.e.,
pine needles), as well as not provide ready access to siren control boxes by squirrels or other vermin. Constellation failed to incorporate this standard into their work order packages.
Corrective Actions: Constellation staff entered the issue into the corrective action program for further review and analysis. They initiated actions to perform an extent of condition review to evaluate the condition of the sirens with respect to foliage growth and have contracted with their vendor to trim the foliage growth back so that the sirens meet the requirements specified in the FEMA ANS Design Report. The licensee has also implemented their approved backup method of notifying the public called Hyper-Reach.
Corrective Action References: IRs 04792661 and 04792666
Performance Assessment:
Performance Deficiency: The inspectors determined that the siren maintenance was not in compliance with the requirements in the FEMA ANS Design Report, which is a performance deficiency that was reasonably within the ability of the licensee to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the licensee failed to ensure that tree growth did not adversely affect siren operation or limit access as specified in the approved design report.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness SDP. The performance deficiency was determined to have very low safety significance (Green) because the licensee's ANS maintenance programs did not degrade the system for a significant period of time since the time of discovery.
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, Constellation failed to ensure adequate oversight of the maintenance the vendor performed to ensure it was conforming with the FEMA-approved design report.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(5) requires, in part, the means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ have been established.Section IV.D.3 of Appendix E to 10 CFR Part 50 requires, in part, the licensee demonstrate the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ, and that the design objective of the prompt public ANS shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within approximately 15 minutes. To do this, Nine Mile Point and FitzPatrick implement the program in the Nine Mile Point Generating Station and James A FitzPatrick Nuclear Power Plant Public Alert Notification System Report (ANS), dated February 2017, Revision 2, which describes siren design, testing, and maintenance activities. The design report states that the maintenance program also includes monitoring tree growth at each siren site to assure that nearby foliage is below the top of the mounting pole, so it does not interfere with near-field siren sound propagation (e.g., tree growth is at least 25 feet away or below the siren horn), and does not cause excessive radio frequency scatter (i.e., pine needles), as well as not provide ready access to siren control boxes by squirrels or other vermin.
Contrary to the above, since August 7, 2024, the licensee failed to ensure that foliage and tree growth was not at least 25 feet away from the siren horns and did not adversely impact siren operation, or limit access, to ensure the sirens were performing in accordance with the FEMA-approved design report.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Water Accumulation in the High Pressure Coolant Injection (HPCI) Lube Oil System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000333/2024003-03 Open/Closed
[P.5] -
Operating Experience 71152A The inspectors identified a Green finding and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for Constellations failure to identify and correct a condition adverse to quality associated with a HPCI steam leak. Specifically, following the inspectors identification of a HPCI turbine gland seal casing steam leak, Constellation failed to prevent water intrusion in the HPCI lube oil system. As a result, water accumulated in the HPCI lube oil reservoir causing the need for HPCI unavailability to replace the oil.
Description:
The HPCI steam supply admission valve (23MOV-14) has experienced leakage since October 2020. This resulted in Constellation establishing an adverse condition monitoring plan (ACMP) to confirm system response and determine when action is needed.
As part of the ACMP, operators monitor turbine casing temperatures, assess oil quality, and ensure condensate is draining properly.
On May 6, 2024, the inspectors identified steam leaking from both inboard and outboard HPCI turbine gland seal housings. The inspectors shared their assessment with operations management. Although water leakage was already occurring from both gland seal housings as documented in IR 04731389, steam had not been previously identified. The station did not enter the newly identified steam leakage into the corrective action program.
The inspectors identified known operating experience as documented in BWROG-TP-14-016, HPCI RCIC System Improvement Committee, HPCI Steam Admission Valve Leakage, Revision 0, dated November 2014. The operating experience describes similar issues with steam leaking past the HPCI turbine gland seal housing, impinging on the outboard bearing housing of the turbine. It results in steam entering the bearing housing, condensing, and causing water to accumulate in the oil. It may eventually lead to impact on the bearings, reduction gear box, and governor to corrode over time. This has been known to be especially true where turbine insulation has been installed too closely to the gland seals since the insulation directs the steam toward the bearing housing.
On May 16, 2024, operations generated IR 04774697. The IR was classified as Level 4 and Class D. The station assessed operability and determined that although steam may impinge on the bearing housing, oil in the water would not result in inoperability. As a result, the licensee did not take additional actions to address the potential for water to enter the HPCI lube oil system.
On June 12, 2024, the station received the results of a May 30, 2024, HPCI oil sample, which indicated elevated water content of 1569 ppm. Prior monthly results did not indicate the presence of water. The sample result exceeded their ACMP of 1000 ppm limit; to increase testing frequency. As a result, the licensee did not take additional actions to address the potential for water to enter the HPCI lube oil system. A subsequent sample was obtained on June 12, 2024, that indicated 2200 ppm. On June 13, 2024, the station declared HPCI inoperable and entered in Condition C of TS 3.5.1 at 7:00 AM to replace the HPCI system lube oil and risk was Action Green.
Title 10 CFR Part 50, Appendix B, Criterion XVI states in part, measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The inspectors determined that Constellation failed to adequately identify and correct a condition adverse to quality associated with HPCI turbine gland seal steam leaks identified by the inspectors on May 6, 2024, and by operators on May 16, 2024. As a result of failure to take any action, the steam entered the HPCI turbine bearing housing and the main lube oil reservoir, which was not detected until the next monthly oil sample taken on May 30, 2024, with results being obtained on June 12, 2024.
Corrective Actions: The HPCI lube oil was replaced and the HPCI turbine insulation was reconfigured to prevent steam from being trapped and entering the HPCI turbine bearing housing and lube oil reservoir. The HPCI system was restored to operable on June 14, 2024, and risk returned to Green. Oil samples were taken over the following week were satisfactory.
Corrective Action References: IR 04780282
Performance Assessment:
Performance Deficiency: The licensee failed to identify and correct a condition adverse to quality.
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, Constellation's failed to identify and take adequate corrective action associated with HPCI turbine insulation configuration to prevent condensation intrusion from a steam supply valve leak. As a result, water accumulated in the HPCI lube oil reservoir and caused unavailability to replace the degraded oil.
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
- (1) 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) 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.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, Constellation's failed to take adequate corrective action based on industry operating experience associated with HPCI turbine insulation configuration to prevent condensation intrusion from a steam supply valve leak. As a result, water accumulated in the HPCI lube oil reservoir and caused unavailability to replace the degraded oil.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, from May 6, 2024, through June 12, 2024, Constellation failed to identify and take adequate corrective action associated with HPCI turbine steam leak to prevent condensation intrusion into the lube oil reservoir. As a result, water accumulated in the HPCI lube oil reservoir and caused unavailability to replace the degraded oil.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Five Safety Relief Valve Inoperable for Greater than Technical Specification (TS) Allowed Time Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2024003-04 Open/Closed
Not Applicable 71152A A self-revealed Severity Level IV NCV of TS LCO 3.4.3 was identified; however, the inspectors determined there was not a performance deficiency. TS LCO 3.4.3 requires that the safety function of nine safety relief valves shall be operable in Modes 1 2, and 3. While performing testing as required by SR 3.4.3.1, FitzPatrick staff determined the lift setpoints of five safety relief valves were outside the required lift setpoint of 1,145 +/- 34.3 psig.
Description:
The inspectors reviewed LER 05000333/2022-003-03, "Safety Relief Valves Lift Setpoint Found Out of Tolerance Low," to determine if performance deficiencies and/or violations of NRC regulatory requirements had occurred. In September 2022, operators shutdown the unit to begin a scheduled refueling outage. Constellation removed and tested five safety relief valves in accordance with TS SR 3.4.3.1 and American Society of Mechanical Engineering (ASME) Code testing requirements. Constellation had the valve tested at an offsite facility. During testing, one valve relief setpoint was determined to be lower than the TS allowable value (tested value of 1094 pounds per square inch gauge [psig]
versus a TS lower limit of 1110.7 psig). The inspectors noted that the relief valve's analyzed lower TS setpoint was to minimize the possibility of an inadvertent lift of the relief valve during operation and the analyzed high lift setpoint, 1179.3 psig, was to ensure reactor vessel pressure safety limits were not exceeded. Due to the test failure, additional valves were tested as required by the ASME Code. During subsequent testing, two additional valves' lift setpoints were found low out of tolerance (1100 and 1105 psig, respectively) resulting in ASME Code requirements to test all 11 safety relief valves. Test results for all the valves determined the five valves' lift points were below the TS setpoints (1109, 1094, 1105, 1100, and 1099 psig, respectively). The inspectors noted that all 11 valves were replaced with certified valves in accordance with TS and ASME Code requirements. Based on the test results, the inspectors concluded that Constellation operated FitzPatrick in violation of TS 3.4.3 because the valves had been inoperable for a period greater than the allowed TS completion time.
The inspectors noted that Constellation's apparent cause evaluation found that the lower setpoint lift was most likely caused by a combination of setpoint drift, bellows metallurgical properties, and high cycling of some valves during previous testing. Constellation staff did not identify a common root cause for the failures. The inspector's review noted that setpoint drift is a known cause for valves to lift at lower or higher setpoints, and there was some operating experience that indicated the new valve bellows material property could slightly change, resulting in slightly lower lift points, but the magnitude of the effect was uncertain. The inspectors determined that there was no performance deficiency because it was not reasonable for Constellation to foresee and correct the safety valves being outside the TS limits while the valve was installed while the unit was in Mode 1, 2, and 3.
Corrective Actions: Constellation staff replaced the valves with previously tested safety relief valves. Additionally, Constellation staff submitted a TS amendment to expand the acceptance criteria for as found testing of the valves to +3/-5 percent, which was approved by the NRC on June 26, 2024 (ADAMS Accession No. ML24136A116).
Corrective Action References: IR 04527149
Performance Assessment:
None. The NRC determined this violation was not reasonably foreseeable and preventable by the licensee and therefore is not a performance deficiency.
Enforcement:
The Reactor Oversight Process's SDP does not specifically consider a violation of requirements with no performance deficiency in its assessment of licensee performance. Therefore, it is necessary to address this violation, which does not include an identified performance deficiency, using traditional enforcement rather than assign a color (e.g., Green).
Section 6.1.d of the NRC Enforcement Policy provides examples of Severity Level IV violations. Section 6.1.d.1 states, in part, that "failure to comply with the allowances for limiting condition for operation and surveillance requirement applicabilities in Technical Specification, Section 3.0, is an example of a Severity Level IV violation.
Violation: TS LCO 3.4.3 requires that the safety function of nine safety relief valves shall be operable in Modes 1 2, and 3. SR 3.4.3.1 requires verification that the safety function lift setpoint of the required safety relief valves is 1,145 +/- 34.3 psig. Following testing, lift settings shall be within +/- 1 percent. TS 3.4.3, Condition A, requires if one or more valves are inoperable, to 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 />.
Contrary to the above, for a period of time between October 2020 and September 2022, five safety valve lift setpoint were below the TS allowable value, causing them to be inoperable and the required actions of TS 3.4.3 were not performed within the required completion times.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Extent of Condition for Fire Protection Hot Short Analysis - Alternating Current (AC) Circuits 71152A The inspectors evaluated the AC extent of condition (EOC) review for FitzPatrick IR 04259118, which identified direct current control circuits that were not properly protected from a hot short condition. The inspectors reviewed the results from a Sargent and Lundy (S&L) report which evaluated 27 AC circuits for protection from the hot short condition out of hundreds of AC circuits. Constellation determined two circuits were not properly protected, which required further evaluation.
The inspectors questioned how Constellation identified these 27 circuits for further evaluation with S&L and whether all in-scope AC circuits were considered in the EOC review. The inspectors encountered communication difficulties with site personnel. FitzPatrick was unable to demonstrate through documentation how the EOC was performed. S&L acknowledged they did not document any work to support use of their methodology and conclusions reached.
Procedure PI-AA-125-1003, Corrective Action Program Evaluation Manual, Revision 7 section 4.4.1.3 states to "Determine the extent of condition. Evaluate similar components on the other train and unit, or similar equipment, processes, procedures, programs, or organizations, or similar situations to determine the extent of the problem. In addition, section 4.5.1 states Proper documentation of all investigations is required to ensure that all aspects of the analysis are clearly understood and support specified retention requirements.
Screening: The inspectors determined the performance deficiency was minor. Contrary to these requirements of PI-AA-125-1003, the inspectors were unable to independently confirm this EOC screening was performed due to the lack of documentation and inconsistent communication. The inspectors performed an independent review of a sample of AC circuits using appropriate screening criteria. No discrepancies were found during this review. As a result, the inspectors determined that although there was not adequate supporting information, the issue was determined to be minor because the results of the inspectors' independent assessment did not reveal discrepant results.
Observation: Safety Relief Valve Set Points Found to be Low Out of TS Allowed Range 71152A The inspectors reviewed the corrective actions completed by Constellation staff following the identification that five safety relief valves setpoints were below TS and ASME Code limits.
The safety relief valves provide a safety function to relieve vessel overpressure in accordance with the transient analysis and a low lift setpoint to prevent inadvertent safety relief valve actuation. The deficiencies were identified during testing at an offsite facility in September - October 2022. Following identification of initial valve failures, additional valves were tested which resulted in all 11 safety relief valves being tested. The valves were replaced with valves whose setpoints were within lift setpoint limits prior to unit returning to power operations. Constellation staff reported the testing results to the NRC in LER 2022-003-02, "Safety Relief Valves Lift Setpoint Found Out of Tolerance Low."
Constellation staff entered the issue into their corrective action program, inspected the valves, and performed setpoint adjustments to restore acceptable lift setpoints. Additionally, Constellation staff completed an engineering analysis with support from the testing facility to determine potential causes and appropriate corrective actions. The inspectors reviewed the conclusions of the analysis and corrective actions. The inspectors found that Constellation staff did not identify a cause for the low lift setpoints; however, the inspectors noted that corrective actions included a revised pressure transient analysis and a TS amendment (ADAMS Accession No. ML23209A003) to expand the as-found acceptance limits for the valves. The license amendment request was approved by the NRC on June 26, 2024 (ADAMS Accession No. ML24136A116).
The inspectors reviewed the as-found and as-left testing of the safety relief valves performed between 2018-2024. The inspectors found that in all but one test the as-found lift pressures were lower than as-left setpoint testing which was performed prior to installing the valves in the unit. Additionally, the inspectors identified there was a variation in the recorded temperature of the first stage pilot valve during testing (385-427 F). The inspectors questioned if this variation in temperature impacted the lift setpoint of the valves. The pilot valve spring assembly causes the valve to lift at the lift setpoint. In response, Constellation staff documented the inspectors' concerns in IR 04796215, and performed an engineering evaluation concluding the temperature variation identified for the pilot valve spring and bellows had minimal impact on the setpoint.
Violations associated with this issue are discussed in the Results Section of this report.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 30, 2024, the inspectors presented the integrated inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
- On August 8, 2024, the inspectors presented the emergency preparedness program inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
- On September 12, 2024, the inspectors presented the radiation hazards inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
- On September 12, 2024, the inspectors presented the inservice inspection results to Mathew Rice, Senior Manager Program Engineering, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
04802394
Drawings
Flow Diagram Fuel Pool Cooling and Clean-Up System 10
Flow Diagram Residual Heat Removal, System 10
Flow Diagram Residual Heat Removal System 10
Flow Diagram Core Spray System 14
Miscellaneous
Maintenance
Rule Basis
Document
System 032
Decay Heat Removal System
Procedures
Core Spray System
Emergency Service Water (ESW)
Diesel Generator Emergency Power
Fuel Pool Cooling and Clean-Up System
Decay Heat Removal System
Diesel Generator Room Ventilation
Fire Plans
Drywell Elev. 256' Fire Area/Zone XIV/PC-1
Drywell Elev. 268' Fire Area/Zone XIV/PC-1
Drywell Elev. 292' Fire Area/Zone XIV/PC-1
Motor Generator Set Room Elevation 300', Fire Area 1A/Fire
Zone MG-1
Radwaste Building/Elev. 250' Fire Area/Zone XIX/RW-1
Radwaste/Elev. 272', 279' Fire Area/Zone XIX/RW-1
Condenser Pit /Elev. 244' Fire Area/Zone IE/TB-1
Turbine Building - North /Elev. 252' Fire Area/Zone IE/TB-1
Turbine Building - South /Elev. 252' Fire Area/Zone IE/TB-1
Turbine Oil Storage Room /Elev. 252' Fire Area/Zone IE/OR-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Turbine Building - North /Elev. 272' Fire Area/Zone IE/TB-1
Turbine Building - South /Elev. 272' Fire Area/Zone IE/TB-1
Foam & Miscellaneous Oil Storage Rooms /Elev. 272' Fire
Area/Zone IE/OR-3,FP-2
Turbine Building /Elev. 300' Fire Area/Zone IE/TB-1
Procedures
Service Water Heat Exchanger Inspection Guide
Work Orders
05310125
05310126
71111.08G Corrective Action
Documents
04051628
04174135
04175897
04450965
04525962
04526882
04799594
04800103
Engineering
Evaluations
637628
Evaluate Pitting of Drywell Liner at Concrete Interface 256
Elevation
NDE Reports
JAF-17-N-2F-SE
2/01/2017
Procedures
Radiographic (RT) Examination
GEH-UT-254
Procedure for the Automated Phased Array Ultrasonic
Examination of Dissimilar Metal Welds with the Topaz
Work Orders
05301128
Procedures
Structures Monitoring
Suppression Chamber and Drywell Deterioration Inspection
Drawings
25V DC One Line Diagram Sheet 1
Procedures
Reassembly of Reactor Vessel Following Refueling or
Maintenance
Refueling Water Level Control
Battery Room Ventilation
Drain Down of Reactor Cavity to Torus Using RHR Loop A in
Corrective Action
04786275
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
04000103
04500293
04770530
Work Orders
05165235
260279
Corrective Action
Documents
04774208
04796985
Engineering
Changes
28576
Procedurally Controlled Temporary Configuration Change
(PCTCC) for Ventilation System Alternate Monitor
Installation for High Range Effluent Monitors (SP-03.08HR)
Procedures
Temporary Configuration Changes
High Range Effluent Monitors
Reactor Building Gaseous Effluent Monitors
Procedures
Disassembly of Reactor Vessel for Refueling or Maintenance 49
Shutdown Operations
Corrective Action
Documents
04769671
04769734
05325243
Engineering
Changes
636754
Procedures
Station Battery B Modified Performance Test
RPV System Leakage Test
HPCI Quick-Start, Inservice, and Transient Monitoring Test
(IST)
Work Orders
04738808
04858359
04858869
05165235
05311162
05311441
05533124
2397244
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Resulting from
Inspection
04792661
Miscellaneous
Nine Mile Point Nuclear Generating Stations and James A.
FitzPatrick Nuclear Power Plant Public Alert and Notification
Design Report
Corrective Action
Documents
Resulting from
Inspection
04794927
Procedures
Exelon Nuclear Standardized Radiological Emergency Plan
Radiological Emergency Plan Annex for James A. Fitzpatrick 5
71151
Corrective Action
Documents
04678583
04714037
Corrective Action
Documents
Resulting from
Inspection
04709081
04714496
Miscellaneous
Reactor Oversight Program MSPI Basis Document
Regulatory Assessment Performance Indicator Guideline
Procedures
Reactor Oversight Program MSPI Bases Document
Monthly Data Elements for NRC ROP Indicator - Safety
System Functional Failures
Mitigating System Performance Index Data Acquisition and
Reporting
71152A
Corrective Action
Documents
04527149
04731389
04774697
04780282
Engineering
Changes
20602
Technical Manual Safety/Relief Valve Manual 0867F-001
Rev. 1
Miscellaneous
3002020842
EPRI - 2021 Nuclear Maintenance Application Center:
Safety and Relief Valve Testing and Maintenance Guide
Rev. 2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
NWS-T-115
NES Test Procedure for Constellation /FitzPatrick Target
Rock 9867F Main Steam Safety Relief Valves
Rev. 4
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Corrective Action Program Evaluation Manual
Corrective Action
Documents
04793211
04802610
04803930
04803957
04804251
Procedures
Loss of Feedwater Heating
Feedwater Heating and Associated Equipment
29