IR 05000333/2025041
| ML25065A041 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 03/06/2025 |
| From: | Jason Schussler Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| EA-24-088 IR 2024090 | |
| Download: ML25065A041 (1) | |
Text
March 6, 2025
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - 95001 SUPPLEMENTAL INSPECTION REPORT 05000333/2025041 AND FOLLOW-UP ASSESSMENT LETTER
Dear David Rhoades:
On January 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection using Inspection Procedure 95001, "Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs, and discussed the results of this inspection and the implementation of your corrective actions with Alex Sterio, Site Vice President, and other members of your staff.
The NRC performed this inspection to review your stations actions in response to a White finding in the Mitigating Systems cornerstone which was documented and finalized in NRC Inspection Report 05000333/2024090 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24299A214). On January 3, 2025, you informed the NRC that your station was ready for the supplemental inspection (ML25003A148).
The NRC determined that your staffs evaluation identified the cause of the White finding.
Specifically, the root cause analysis for the White finding identified two root causes. The first root cause determined that Maintenance leadership did not enforce compliance with the Constellation Management Model processes during the planning of the work order to repair a leak on the B emergency diesel generator (EDG) lube oil gallery supply check valve. As a result, the risk and potential consequences associated with installation of a gasket was not recognized, and work order instructions did not contain sufficient detail to install the gasket successfully to prevent the inoperability of the B EDG. Additionally, the work order was set to Ready status prior to an engineering product being completed. The second root cause identified Engineering leadership did not reinforce the use of technical rigor or enforce compliance with Constellation Management Model processes during the development of the engineering product for a leak on the B EDG lube oil gallery supply check valve. As a result, the addition of a gasket was not identified as a configuration change, the risk and potential consequences associated with the repair strategy were not recognized, applicable design considerations and impacts were not evaluated, and no torque value was specified. Corrective actions to preclude repetition are discussed in detail in the enclosed inspection report.
Overall, the NRC determined that Constellations problem identification, causal analyses, and corrective actions sufficiently addressed the performance issues that led to the White finding.
All inspection objectives, as described in Inspection Procedure 95001, were met, and this inspection is, therefore, closed. With the closure of this White finding, and as a result of our continuous review of plant performance, the NRC has updated its assessment of James A. FitzPatrick Nuclear Power Plant. Based on successful completion of the supplemental inspection, and issuance of this inspection report, James A. FitzPatrick Nuclear Power Plant has transitioned to the licensee response column of the NRC Action Matrix (Column 1) as of the date of the exit and regulatory performance meeting for this inspection on January 30, 2025.
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, Jason E. Schussler, 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-2025-041-0000
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. Fitzpatrick Nuclear Power Plant
Location:
Scriba, NY
Inspection Dates:
January 27, 2025 to January 30, 2025
Inspectors:
C. Dukehart, Resident Inspector
S. Flangan, Resident Inspector
Approved By:
Jason E. Schussler, 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 Inspection Procedure (IP) 95001 supplemental 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 NOV 05000333/2024011-01
'B' Emergency Diesel Generator Gallery Lube Oil Supply Check Valve Failure 95001 Closed
INSPECTION SCOPES
This inspection was conducted using IP 95001 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. The inspection sample was declared complete when the IP requirements and objectives were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
95001 - Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response)
Inputs
The inspectors reviewed and selectively challenged aspects of Constellations problem identification, causal analysis, and corrective actions to ensure the causes of the White performance issue were correctly identified and corrective actions were adequate to promptly and effectively address and preclude repetition. The White finding and related Notice of Violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Technical Specification (TS) 3.8.1, AC Sources-Operating, was associated with the failure to establish and implement appropriate work instructions for performing maintenance that can affect the performance of the safety-related B emergency diesel generator (EDG). Consequently, on April 24, 2024, the B EDG failed while performing surveillance testing due to the failure of the gallery lube oil supply check valve and the resultant 2.3 gallons per minute (gpm) lube oil leak that developed. The preliminary White finding and apparent violation was documented in NRC Inspection Report 05000333/2024011 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML24262A197). The final significance determination of the White finding and Notice of Violation was documented in NRC Inspection Report 05000333/2024090 (ML24299A214).
Constellation performed and documented an initial root cause analysis (RCA) in Issue Report (IR) 04804023 and revised the RCA in IR 04833191. The NRC inspectors review of the James A. Fitzpatrick Nuclear Power Plant White performance issue and the associated assessment are documented below.
Objective 1: Ensure that the root and contributing causes of the White performance issue are understood
Under this objective, the inspectors reviewed the RCA the licensee conducted for the failure to establish and implement appropriate procedures and instructions for performing maintenance that can affect the performance of the B EDG, as documented in NRC Inspection Reports 05000333/2024011 and 05000333/2024090. The inspectors review consisted of an evaluation of the following:
- The licensees identification of the issue(s),
- When and how long the issue(s) existed,
- Prior opportunities for identification,
- Documentation of significant plant-specific consequences and compliance concerns,
- Use of systematic methodology to identify causes with a sufficient level of supporting detail,
- Consideration of prior occurrences, and
- Identification of extent of condition and extent of cause.
NRC Assessment: The team concluded that this objective was met.
The inspectors determined the licensee had prior opportunities to identify and address the conditions that led to the White finding. The RCA adequately assessed and addressed prior opportunities to identify the issues. The RCA appropriately understood the risk and compliance aspects of the White finding. The RCA identified two root causes and one contributing cause.
Root Cause 1 (RC1): Maintenance leadership did not enforce compliance with the Constellation Management Model processes during the planning of the work order to repair a leak on the B EDG lube oil gallery supply check valve. As a result, the risk and potential consequences associated with installation of a gasket was not recognized, and work order instructions did not contain sufficient detail to install the gasket successfully to prevent the inoperability of the B EDG. Additionally, the work order was set to Ready status prior to an engineering product being completed.
Root Cause 2 (RC2): Engineering leadership did not reinforce the use of technical rigor or enforce compliance with Constellation Management Model processes during the development of the engineering product for a leak on the B EDG lube oil gallery supply check valve. As a result, the addition of a gasket was not identified as a configuration change, the risk and potential consequences associated with the repair strategy were not recognized, applicable design considerations and impacts were not evaluated, and no torque value was specified.
Contributing
Cause:
Technical human performance (THU) practices were not effectively utilized by Maintenance and Engineering during the development of the work instructions and evaluation to address a leak. Specifically, gaps in Questioning Attitude, Challenge, and Validating Assumptions led to the failure to recognize that the installation of the gasket in a soft metal to metal application without a torque value could result in damage if overtightened.
a. Identification. The issues resulting in the White finding were identified by the licensee.
The licensees RCA noted that the event became self-revealing on April 24, 2024, during the performance of ST-43D, Remote Shutdown Panel 25ASP-3 Component Operation and Isolation Test. The EDG had developed a significant leak from the top of the 93EDG-57B check valve. The station estimated the leak rate as 2.3 gpm.
b. Exposure Time. The licensees RCA documented non-uniform compression of the cap during installation of a gasket to address a prior leak, which was installed on October 11, 2023, and existed until the failure on April 24, 2024.
c. Identification Opportunities. The licensee documented that there were multiple opportunities to identify the conditions leading to the White finding. The RCA captured multiple broken barriers which could have identified this issue prior to the failure of the 93EDG-57B lube oil gallery supply check valve. Specifically, an investigation into the cause of the leak revealed that the licensee failed to perform the following tasks: field walkdown, implementing engineering holds, appropriate 50.69 screening, fastener torque screening, independent review of the technical evaluation, peer review of the work order, and pre-job brief.
d. Risk and Compliance. The licensee's RCA documented significant plant-specific consequences and compliance concerns associated with the performance issue.
Specifically, The RCA documents that, the leak from the B EDG lube oil gallery supply check valve was due to a failed gasket. The failure of the gasket caused a 2.3 gallon per minute leak on April 24, 2024, resulting in declaring the B EDG inoperable and entry into TS Limiting Condition of Operation (LCO) 3.8.1 Condition B. The B EDG was restored to operable following maintenance on April 25, 2024. The RCA also documented the qualitative consequence of the event, including the White finding and Notice of Violation related to FitzPatricks performance deficiency for the failure to provide adequate qualitative or quantitative acceptance criteria in work instructions during maintenance activities on the B EDG.
e. Methodology. The licensees RCA documented that the root cause team utilized various investigation techniques to determine the root and contributing causes, including Event and Causal Factor (ECF) Chart, Barrier Analysis, Cause and Effect Analysis (Why Staircase), Performance Analysis, Safety Culture Component review, Interviews, Independent Vendor Analysis, TapRooT, Equipment Evaluation, Organizational Effectiveness Evaluation, and Task Analysis to gather data, identify the problem, and determined the root and contributing causes of the performance issue. The inspectors reviewed each of the documented method results and determined that the different methods provided a detailed, reliable, and scrutable evaluation. Also, the inspectors determined these analyses were performed with sufficient rigor and depth to identify the root and contributing causes.
f. Level of Detail. The inspectors determined that the licensee's RCA was conducted to a level of detail in alignment with the significance and complexity of the White performance issue. Specifically, the licensee's RCA utilized a formal cause evaluation process to identify problems and determine corrective actions. The RCA was performed by a cross-disciplinary team of individuals with various backgrounds and levels of experience, including external subject matter experts in causal analysis. Additionally, the RCA was reviewed by a third party, as required by licensee procedures.
g. Operating Experience. The inspectors determined that the licensee's RCA considered prior occurrences of the performance issue and knowledge of prior operating experience. Specifically, the RCA included searches of industry databases, the licensee's corrective action program, and review of other internal and external operating experience.
h. Extent of Condition and
Cause.
The inspectors determined that the RCA appropriately identified the extent of condition and the extent of cause. Specifically, the RCA stated that the extent of condition applies to all other valves of this model at FitzPatrick.
Additionally, a sample of other safety-related valves will have their torque specification verified. For the extent of cause, all EDG maintenance procedures and a sample of other safety-related maintenance procedures were screened for the term wrench tight. The RCA also stated that an evaluation will be performed on leadership and technical products to screen for past issues where there have been gaps in the Constellation Management Model compliance and quality. The licensee conducted a review of the Safety Culture Attributes from NUREG2165 and identified 15 attributes that were applicable.
Objective 2: Ensure that the extent of condition and extent of cause of White performance issues are identified
Under this objective, the inspectors assessed the licensee's RCA, associated corrective actions, procedures, and work orders to evaluate the licensee's extent of condition and extent of cause.
NRC Assessment: The team concluded that this objective was met.
Extent of Condition and
Cause.
The inspectors determined that the licensees RCA identified the extent of condition and the extent of cause of the performance issue.
Specifically, the RCA determined that the extent of condition applied to the same model of check valves that were installed in all of the diesel generator engines at Fitzpatrick and the high pressure core injection (HPCI) fire foam system. As a result, the licensee developed actions to replace all of the gallery supply check valves to a stainless-steel model on the EDGs. Two of the four EDGs have had the valve replaced, with the remaining two scheduled to be replaced by the end of 2025. In addition, the extent of condition actions included inspection and consideration for the HPCI fire foam system valve as well taking a representative sample of safety-related valves in the EDG, HPCI, residual heat removal, and core spray systems to confirm appropriate torque values to have been set. For the extent of cause, the inspectors noted that the licensee developed corrective actions to assess the potential for instances of RC1, RC2, and the contributing cause to exist within other plant processes, programs, equipment, or human performance.
Objective 3: Ensure that completed corrective actions to address and preclude repetition of White performance issues are timely and effective
Under this objective, the inspectors assessed the appropriateness and timeliness of the licensee's corrective actions.
NRC Assessment: The team concluded that this objective was met. The inspectors noted that the two corrective actions to preclude repetition (CAPRs) were not complete at the time of this inspection. The inspectors critically assessed the two planned CAPRs to conclude that the planned corrective actions will be timely and have objective criteria to measure effectiveness. When complete, the NRC plans to inspect and assess the planned CAPRs identified in the Section regarding Objective 4.
a. Completed Corrective Actions to Preclude Repetition
1) At the time of the inspection, both CAPRs were planned for future implementation, and therefore had not yet been completed.
b. Other Completed Corrective Actions
1) Maintenance director to reinforce expectations via Read and Sign document that will be completed by all Maintenance personnel on the use of Constellation Management Model processes and THU tools required to ensure effective planning and oversight for work preparation to address gaps documented in the root cause (0480402361).
The inspectors reviewed closure documentation to confirm this corrective action was completed in January 2025.
2) Engineering director to reinforce expectations via Read and Sign document that will be completed by all Engineering personnel on the use of Constellation Management Model processes and THU tools required, and the importance of technical rigor, to ensure effective development of engineering technical products to address gaps documented root cause (0480402362).
The inspectors reviewed closure documentation to confirm this corrective action was completed in January 2025.
3) Implement a revision to MP093.11, EDG System Mechanical PM, to remove the section to open and inspect the internals of the lube oil gallery supply check valve (CA 0480402322).
The inspectors reviewed the maintenance procedure, MP-093.11, EDG System Mechanical PM, Rev. 58, to confirm this corrective action was completed in January 2025.
4) Implement a revision of CCAA404, Maintenance Specification: Application Selection, Evaluation and Control or Temporary Leak Repairs, to clarify that intrusive leak repairs do not apply to the temporary leak repair process (CA 0480402323).
The inspectors reviewed the procedure, CC-AA-404, Maintenance Specification:
Application Selection, Evaluation and Control of Temporary Leak Repairs, Rev. 12, to confirm this corrective action was competed in January 2025.
5) Implement a revision to MA-AA-716-010, Maintenance Planning, to add a step to MA-AA-716-010 to require documentation of verbal discussions between Engineering and Planning (CA 04804023-21)
The inspectors reviewed the procedure, MA-AA-716-010, Maintenance Planning, Rev. 36, to confirm this corrective action was competed in January 2025.
Objective 4: Ensure that pending corrective action plans direct prompt and effective actions to address and preclude repetition of White performance issues
Under this objective, the inspectors assessed the appropriateness and timeliness of the licensee's planned corrective actions.
NRC Assessment: The team concluded that this objective was met. The inspectors identified a minor weakness in accordance with IMC 2515, Appendix B, Supplemental Inspection Program, that the planned CAPR for RC-1 did not contain lessons learned from the RCA as Must Know Operating Experience mirroring the requirements for the Engineering department in Action Tracking Items 04804023-69 and 04804023-71. As a result, there was a vulnerability to the sustainability of the CAPR actions for Maintenance department leadership. The inspectors provided this minor weakness to the licensee who initiated IR 04833191 and Action Item 04829274-20 to incorporate the operating experience from the event into the Maintenance management qualification assignments. The inspectors determined that this issue was not of more than minor significance in accordance with IMC 0612, Issue Screening. When complete, the NRC plans to inspect and assess the planned CAPRs discussed below.
a. Planned Corrective Actions to Preclude Repetition
1) CAPR 04804023-19: Implement a series of training activities and behavioral monitoring methods that, when combined, reinforce the use of the Constellation Management Model processes, specifically with relation to the development of maintenance work packages (RC-1). The planned completion date of this CAPR is June 30, 2025. The inspectors determined the planned CAPR identified a corresponding effectiveness review that contained quantitative and qualitative measures of effectiveness.
2) CAPR 04804023-94: Implement a series of training activities and behavioral monitoring methods that, when combined, reinforce the use of technical rigor and Constellation Management Model processes, specifically with relation to the development of engineering technical products (RC-2). The planned completion date of this CAPR is June 30, 2025. The inspectors determined the planned CAPR identified a corresponding effectiveness review that contained quantitative and qualitative measures of effectiveness.
b. Other Planned Corrective Actions
1) Implement a revision to MAAA716010, Maintenance Planning, to add a step to MA-AA716010 to add a step to require the use of MAAA716010F03, Torque Required Screening, to determine if a torque value is required during the planning process. It is planned to be completed January 31, 2025 (CA 0480402320).
2) Present training covering an overview of the lessons learned from the event described in the RCA with a focus on enforcement of Constellation Management Model processes and the interface between Maintenance and Engineering during the development of a work packages. This includes, at a minimum, the use of engineering holds, Constellation Management Model THU tools, oversight tools, regulatory risks associated with safety-related systems, and how to address engineering input into work packages during the planning process to all Maintenance first line supervisors and above. It is planned to be completed March 28, 2025. The due date is based on timely training of the Maintenance leadership population (CA 0480402324).
3) Present training covering an overview of the lessons learned from the event described in the RCA with a focus on performance of Constellation Management Model processes and the interface between Maintenance and Engineering during the development of a work package. This includes, at a minimum, the use of engineering holds, Constellation Management Model THU tools, oversight tools, regulatory risks associated with safety-related systems, and how to address engineering input into work packages during the planning process to all Maintenance individual contributors. It is planned to be completed March 28, 2025. The due date is based on timely training of the Maintenance population (CA 0480402368).
4) Present training covering an overview of the lessons learned from the event described in the RCA with a focus on enforcement of Constellation Management Model processes and the interface between Maintenance and Engineering during the development of engineering technical products. This includes, at a minimum, emergent technical support requests, Constellation Management Model THU tools, oversight tools, regulatory risks associated with safety-related systems, and the importance of technical rigor to all Engineering managers and above. It is planned to be completed March 28, 2025. The due date is based on timely training of the Engineering leadership population (CA 0480402369).
5) Present training covering an overview of the lessons learned from the event described in the RCA with a focus on performance of Constellation Management Model processes and the interface between Maintenance and Engineering during the development of engineering technical products. This includes, at a minimum, emergent technical support requests, Constellation Management Model THU tools, oversight tools, regulatory risks associated with safety-related systems, and the importance of technical rigor to all Engineering individual contributors. It is planned to be completed March 28, 2025. The due date is based on timely training of the Engineering population (CA 0480402371).
6) Execute a dynamic learning activity that requires Engineering and Maintenance personnel to work together to utilize Constellation Management Model processes and address the gaps that contributed to the event described in the RCA. This includes, at a minimum, emergent technical support requests, Constellation Management Model THU tools, oversight tools, and the importance of technical rigor.
It is planned to be completed February 21, 2025. The due date is based on timely completion for the Engineering and Maintenance populations (CA 0480402393).
7) Document the replacement of the lube oil gallery supply check valves for all four EDGs. The completion of this corrective action documents the replacement of all four diesel check valves with the new stainlesssteel model. The overall corrective action is planned to be completed December 15, 2025, and the inspectors noted two of the four valve replacements was completed prior to January 30, 2025. The completion date is based on the scheduling of the maintenance windows for the EDGs (CA 0480402325).
The inspectors reviewed the licensee's planned CAPRs and corrective actions and determined they were appropriate to address the root causes of the White performance issue and were prioritized commensurate with the significance.
Conclusion
The inspectors determined that the licensees problem identification, causal analyses, and corrective actions sufficiently addressed the performance issues that led to the White finding.
The inspectors determined the corrective actions have been prioritized to meet regulatory compliance, in alignment with the significance, corrective actions taken were prompt and effective, and the Notice of Violation related to the supplemental inspection is sufficiently addressed. All inspection objectives, as described in IP 95001, were met. Scheduled corrective action items will be inspected as part of the ongoing NRC baseline inspection program.
Therefore, this inspection is closed.
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 30, 2025, the inspectors conducted an exit and regulatory performance meeting regarding the IP 95001 supplemental 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
95001
Corrective Action
Documents
NRC AV 05000333/2024011-01, EDG Lube Oil Check Valve
Failure
09/19/2024
Bolting Degradation on 46P-2B
09/08/2024
Work order doesnt meet QRT criteria
2/10/2024
Maintenance Procedure Review for Acceptance Criteria
11/04/2024
93EDG-57B (Lube Oil Gallery Check Valve) Failure
04/25/2024
Oil Leak Identified at 93EDG-57B
10/11/2023
NRC IDd IR - 95001 CAPR Sustainability Challenge
01/29/2025
Miscellaneous
Repair Oil Leak on 93EDG-57B
Revision 0
Install Gasket to Seal Bonnet Cap Leak on 93EDG-57B
Revision 0
PE Eval
91009571
Item Equivalency Evaluation: EMD 1/2 Swing Check Valve
Replacement
Revision 0
Procedures
Issue Identification and Screening Process
Revision 13
Corrective Action Program (CAP) Procedure
Revision 9
Root Cause Analysis Manual
Revision 8
Corrective Action Program Evaluation Manual
Revision 8
Effectiveness Review Manual
Revision 3
Investigation Techniques Manual
Revision 8
Self-Assessments
Revision 6
Benchmarking Activities
Revision 7
NRC Inspection Preparation and Response
Revision 27
Management Model Terminology and Direction
Revision 1
Maintenance Specification: Application Selection, Evaluation
and Control or Temporary Leak Repairs
Revision 12
Temporary Configuration Changes
Revision 32
Configuration Control Process Description
Revision 11
Design Input and Configuration Change Impact Screening
Revision 35
Configuration Change Control for Permanent Physical Plant
Changes
Revision 34
Quality Review Team (QRT)
Revision 10
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering Technical Evaluations
Revision 16
Technical Task Risk/Rigor Assessment, Pre-Job Brief,
Independent Third-Party Review, and Post-Job Review
Revision 13
HU-AA-1211-F01
Pre-Job Briefing Checklist
Revision 9
Maintenance Planning
Revision 36
MA-AA-716-010-
1000
Passport Work Planning Manual
Revision 5
MA-AA-716-010-
F03
Torque Required Screening
Revision 0
Quality Review Team (QRT) for Maintenance Work Planning
Revision 8
Torquing and Tightening of Bolted Connections
Revision 15
EDG System Mechanical PM*
Revision 58