IR 05000454/2023010
| ML23108A332 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/19/2023 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DORS/ERPB |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023010 | |
| Download: ML23108A332 (1) | |
Text
SUBJECT:
BYRON STATION - BYRON UNIT 1 LICENSE RENEWAL PHASE 1 REPORT 05000454/2023010
Dear David Rhoades:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Byron Station. On March 24, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Byron Station.
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 III; and the NRC Resident Inspector at Byron Station.
April 19, 2023 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, Néstor J. Féliz Adorno, Chief Engineering and Reactor Projects Branch Division of Operating Reactor Safety Docket No. 05000454 License No. NPF-37
Enclosure:
As stated
Inspection Report
Docket Number:
05000454
License Number:
Report Number:
Enterprise Identifier:
I-2023-010-0022
Licensee:
Constellation Energy Generation, LLC
Facility:
Byron Station
Location:
Byron, IL
Inspection Dates:
March 06, 2023 to March 24, 2023
Inspectors:
M. Domke, Reactor Inspector
Approved By:
Néstor J. Féliz Adorno, Chief
Engineering and Reactor Projects Branch
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Byron Unit 1 License Renewal Phase 1 at Byron Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Conduct One-Time Qualified Selective Leaching Examinations for License Renewal Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000454/2023010-01 Open/Closed
[H.5] - Work Management 71003 The inspectors identified a Green finding with an associated Non-Cited Violation (NCV) for the licensee failure to follow procedure ER-BY-700-401, revision 0. This procedure was established for performing one-time selective leaching inspections of safety-related and augmented-quality systems, structures, and components. Contrary to this procedure, the licensee did not perform qualified examinations with certified personnel and calibrated hardness testers. In addition, the licensee did not conduct hardness testing, chipping, or scraping. This failure did not assure that intended component functions would be maintained consistent with the current licensing basis through the period of extended operation. While the finding involved safety-related and augmented-quality components, the associated NCV only involved safety-related components.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
71003 - Post-Approval Site Inspection for License Renewal Post-Approval Site Inspection for License Renewal
- (1) The inspectors conducted a phase 1 license renewal inspection. The following attributes of aging management programs and commitments were reviewed by inspectors:
One-Time Inspection of American Society of Mechanical Engineers (ASME)
Code Class 1 Small-Bore Piping (Commitment 22)o This inspection sample included field observation of calibration and acquisition activities for ultrasonic examination data on components 1CVA3B-2/W83 elbow-to-pipe weld, 1CVA3B-2/W84 pipe-to-elbow weld, 1CVA3B-2/W85 elbow-to-pipe weld, and 1CVA3B-2/W86 pipe-to-coupler weld.
Selective Leaching (Commitment 21)o Inspectors performed record reviews for all completed one-time selective leaching examinations on components within emergency diesel generator, essential service water, and fire protection systems.
Protective Coating Monitoring and Maintenance Program (Commitment 36)o On March 8, 2023, the inspectors observed a Unit 1 inner containment liner Service Level I coating examination performed by the licensee.
Buried and Underground Piping (Commitment 28)o Inspectors reviewed completed work orders for a sample of components in-scope of license renewal activities. Inspectors conducted detailed reviews related to sub-commitment 28.7.a. for water intrusion to underground essential service water vaults housing, in part, components 0SX138A and 0SX138B.
Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Commitment 42)o Inspectors reviewed Action Tracking Item ATI01367499-42-01 which tracks the evaluation of results of License Renewal AMP XI.E6 Cable Connections. Work order tasks for license renewal cable testing are currently scheduled between April 3, 2023, and June 1, 2026. Issue Report (IR) 4560037 currently tracks scheduling of these work orders prior to the period of extended operation.
INSPECTION RESULTS
Failure to Conduct One-Time Qualified Selective Leaching Examinations for License Renewal Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000454/2023010-01 Open/Closed
[H.5] - Work Management 71003 The inspectors identified a Green finding with an associated Non-Cited Violation (NCV) for the licensee failure to follow procedure ER-BY-700-401, revision 0. This procedure was established for performing one-time selective leaching inspections of safety-related and augmented-quality systems, structures, and components. Contrary to this procedure, the licensee did not perform qualified examinations with certified personnel and calibrated hardness testers. In addition, the licensee did not conduct hardness testing, chipping, or scraping. This failure did not assure that intended component functions would be maintained consistent with the current licensing basis through the period of extended operation. While the finding involved safety-related and augmented-quality components, the associated NCV only involved safety-related components.
Description:
On March 8, 2023, NRC inspectors noted an examination performed on a gray cast iron component recorded no red or copper discoloration as the basis for refuting the presence of selective leaching. This examination was performed on component 0SX03CA-G34 gear reducer housing under work order (WO) 01874520-01.
Red or copper discoloration is a selective leaching concern typically observed in copper alloys. Selective leaching in gray cast iron produces a graphitic network of the iron matrix.
According to revision 0 of procedure ER-BY-400-701, the graphite is cathodic to iron, thereby providing a galvanic cell. The iron is dissolved, leaving a porous mass consisting of graphite, voids, and rust. The procedure also states that if the cast iron is in an environment that corrodes this metal rapidly, uniform corrosion can occur with a rapid loss of material strength which can go undetected since the corrosion appears superficial.
Revision 0 of procedure ER-BY-400-701 and WO 01874520-01 required certification in qualified visual test VT-3 and familiarization with procedure attachment 2, Background Discussion for the Selective Leaching Program, to perform this visual determination of selective leaching. In addition, the procedure required hardness testing with calibrated test equipment or other mechanical examination techniques such as chipping or scraping.
The examiner of WO 01874520-01 failed to obtain a calibrated hardness tester and perform hardness testing. The examiner documented scraping, but with an unspecified tool. Further investigation of selective leaching examination work orders revealed that:
Some examinations were performed on gray cast iron components less than the required 30 years of age, which was inconsistent with revision 1 of basis document BY-SSBD-SLI; Corporate selective leaching procedure did not align with site procedure for examination requirements;
The licensee failed to perform selective leaching examinations on correct essential service water components for work orders 01869737-01, 01869729-01, and 01869733-01;
The licensee failed to meet visual certification requirements for examiners for WOs 01874624-01, 01869733-01, 01869737-01, 01869729-01, 01869733-01, 01874593-01, 01869636-01, 01874595-01, 01874627-01, 01874629-01, 01869638-01, 01871917-01, 01871922-01, and 01871927-01;
The licensee failed to perform hardness testing or alternate mechanical examination techniques such as chipping and scraping for WOs 01874624-01, 01874520-01, 01869733-01, 01869737-01, 01869729-01, 01869733-01, 01874593-01, 01874595-01, 01874627-01, 01874629-01, 01871917-01, 01871922-01, and 01871927-01;
The licensee failed to obtain and verify measuring and testing equipment (M&TE) was in current calibration for WOs 01874624-01, 01869737-01, 01874627-01, 01874629-01, 01874520-01, 01871917-01, 01871922-01, and 01871927-01; and
The licensee failed to record selective leaching examination information for WOs 01869653-01 and 01874627-01.
At least 17 one-time selective leaching examinations were impacted involving fire protection (augmented quality), essential service water (safety-related), and emergency diesel generator (safety-related) components.
Corrective Actions: On March 16, 2023, the station determined that all selective leaching examinations performed to date will need to be reperformed.
Corrective Action References: AR04560819, AR04561699, AR04561980, AR04562231, AR04562281, AR04562289, AR04562292, AR04562509
Performance Assessment:
Performance Deficiency: The licensee failure to perform selective leaching examinations of fire protection, essential service water and emergency diesel generator components using examiners qualified as VT-3 and hardness testing with calibrated test equipment or other mechanical examination techniques such as chipping or scraping was contrary to revision 0 of procedure ER-BY-700-401 and was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the failure to perform qualified, one-time selective leaching examinations utilizing certified visual test VT-3 personnel, calibrated hardness testers, and hardness testing or chipping or scraping did not assure that the intended functions of the affected fire protection, essential service water and emergency diesel generator components would be maintained consistent with the current licensing basis through the period of extended operation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as Green or very low safety significance because the performance deficiency did not result in the loss of operability or functionality.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee did not implement a process to control and execute work activities associated with selective leaching examinations.
Enforcement:
Violation: Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, activities affecting quality to be accomplished in accordance with instructions, procedures, or drawings.
Revision 0 of procedure ER-BY-700-401, step 3.3.8, states, that personnel performing the visual inspection in support of this procedure are qualified to VT-3 requirements, and procedure step 3.3.3 states, M&TE is in current calibration (when hardness testing), and procedure step 4.1.4 states, perform both visual and hardness inspections, and procedure step 4.4.1 states, Perform alternate mechanical examination techniques such as chipping or scraping to determine if selective leaching has occurred as delineated in step 4.4.2 and 4.4.3.
Contrary to the above, the licensee failed to accomplish activities affecting quality in accordance with instructions, procedures, or drawings on safety-related essential service water and emergency diesel generator components as evidenced by the following examples:
On May 7, 2020, during the performance WO 01874520 on an essential service water component, the licensee did not use M&TE that was in current calibration and conduct hardness testing or other mechanical examination techniques;
On June 29, 2021, during the performance of WO 01874624 on an emergency diesel generator component, the licensee did not use a selective leaching examiner who was VT-3 qualified, use required M&TE that was in current calibration, and conduct hardness testing or other mechanical examination techniques;
On March 10, 2022, during the performance of WO 01869737 on an essential service water component, the licensee did not use a selective leaching examiner who was VT-3 qualified, use required M&TE that was in current calibration, and conduct hardness testing or other mechanical examination techniques;
On April 1, 2022, during the performance of WO 01869729 on an essential service water component, the licensee did not use a selective leaching examiner who was VT-3 qualified and conduct hardness testing or other mechanical examination techniques;
On June 8, 2022, during the performance of WO 01869733 on an essential service water component, the licensee did not use a selective leaching examiner who was VT-3 qualified and conduct hardness testing or other mechanical examination techniques;
On October 5, 2022, during the performance of WO 01874593 and WO 01874595 on 2 emergency diesel generator components, the licensee did not use a selective leaching examiner who was VT-3 qualified and conduct hardness testing or other mechanical examination techniques; and
On October 6, 2022, during the performance of WO 01874627 and WO 01874629 on 2 emergency diesel generator components, the licensee did not use a selective leaching examiner who was VT-3 qualified, use required M&TE that was in current calibration, and conduct hardness testing or other mechanical examination techniques.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On March 24, 2023, the inspectors presented the Exit meeting inspection results to Harris Welt, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04163108
Water Intrusion into 0SX138A Valve Pit
08/09/2018
04186397
Need WR (Work Request) for Sealing 0SX138B Valve Pit
10/22/2018
04360987
0SX138A Valve Pit Repairs Could Not Be Completed
08/04/2020
04427315
Corrosion on 0SX138A
06/03/2021
04427323
Water Intrusion Into 0SX138A Valve Pit -New Tarp Needed
06/03/2021
04430176
Exam Results for Selective Leaching for 1DG01KB-X1
06/18/2021
04453016
NRC ID: PM Frequency for 0SX138A/B Vault Inspections
10/14/2021
04464417
NRC ID: Request Engineering Analysis on Degraded
0SX138A Bolting
2/02/2021
04464431
NRC ID: Application of Buried Pipe and System Health on
0SX138A
2/02/2021
Corrective Action
Documents
04474134
0SX138B Coating and Bolt Replacement
01/27/2022
04560037
LR Cable Inspection Schedule Needs to Be Adjusted
03/07/2023
04560819
NRC ID: Selective Leaching Exam Performed on Newer
Component
03/09/2023
04561699
NRC ID: Disconnect in Selective Leaching Procedure
03/13/2023
04561980
SL Exams for FP Strainers are Invalid Due to Age
03/14/2023
04562231
License Renewal SL (Selective Leaching) Exams Done on
Incorrect Part of SX Fan
03/15/2023
04562281
NRC ID: Selective Leaching WO 1869653 Issues
03/15/2023
04562289
NRC ID: Selective Leaching WOs (Work Orders) Did Not
Document M&TE (Measuring and Test Equipment) Used
03/15/2023
04562292
NRC ID: Selective Leaching WOs (Work Orders) -Procedure
Usage
03/15/2023
04562509
NRC ID: Selective Leaching Exams Need to Be Reperformed
03/16/2023
Corrective Action
Documents
Resulting from
Inspection
04562851
NRC: Requested Clean/Coat 0SX138B per IR 4474134 Not
Complete
03/17/2023
M-42 Sheet 1B
Diagram of Essential Service Water
M-42 Sheet 6
Diagram of Essential Service Water
BF
71003
Drawings
M-900 Sheet 9
Outdoor Piping Section Essential Service Water at Cooling
Tower
V
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ND-48858-01
Sheet 1
48" W/S Valve 150# ANSI Flangeless with Manual Act. -MA-
080 & NAMCO Switch
C
365231
Establish Tube Plugging Criteria for Eddy Current Testing for
1/2DG01KA/B, 1/2P01AA/B/C/D, 0/1CC01A, 0WO01CA/B,
1/2VA01/2/3/4/6SA/B and 1/2VA08S Heat Exchangers
CN-PAFM-12-53
License Renewal Environmental Fatigue Screening
Evaluation for Byron and Braidwood Stations Units 1 and 2
Engineering
Evaluations
WDI-TJ-1124
Technical Justification for the Ultrasonic Inspection for
Thermal Fatigue in Small-Bore Socket Welded Pipe
2012-413
Ultrasonic Thickness Examination for Component
0SX01AB-48"
11/01/2012
2015-195
Ultrasonic Thickness Examination for Component
0SX01AA-48"
10/10/2015
NDE Reports
2019-079
Ultrasonic Thickness Examination 0SX1616A/B
07/17/2019
BB-PBD-AMP-
XI.M33
Selective Leaching
BB-PBD-AMP-
XI.M35
One-Time Inspection of ASME Code Class 1 Small-Bore
Piping
BB-PBD-AMP-
XI.M41
Buried and Underground Piping
BY-SSBD-SLI
Selective Leaching Inspection Sample Basis Document
EPRI-SW-PA-1
Procedure for Encoded Phased Array Ultrasonic Examination
of Small-Bore Socket Fillet Welds
Heat Exchanger Electromagnetic Testing Methodology
ER-BY-700-401
Guidance for Performing Selective Leaching Inspections
Procedures
WDI-STD-1180
Procedure for the Ultrasonic Examination of Small-Bore
Socket Welded Pipe for Thermal and Vibration Fatigue
01863616-01
EWP MM LR Remove Corrosion Apply Protective Coating
0SX161A
09/11/2017
01863619-01
LR Coat SX Pipes in Blowdown Vault
04/16/2018
01863619-01
LR Coat SX Pipes in Blowdown Vault: EWP -MM LR Remove
Corrosion/Apply Protective Coating 0SX161B: 0SX161B: V15
04/23/2018
Work Orders
01869636-01
LR-EP-Inspect 1FP04M FP Strainer Body (Selective
Leaching)
08/23/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
01869638-01
LR-EP-INSPECT 1FP05M FP Strainer Body (Selective
Leaching)
08/23/2022
01869653-01
LR-EP-INSP 0VI03C RAD & RSD CTRL RM UNIT (Selective
Leaching)
05/31/2019
01869729-01
LR-EP-INSP 0SX03CA 0A SXCT Fan (Selective Leaching)
04/01/2022
01869733-01
LR-EPP-INSP 0SX03CB SXCT Fan (Selective Leaching)
06/08/2022
01869737-01
LR-EP-INSP 0SX03CC 0C SXCT Fan (Selective Leaching)
03/10/2022
01871917-01
EP-LR INSP 2FP120A ISO Valve (Selective Leaching)
2/24/2023
01871922-01
LR-EP-INSP 2FP120C ISO Valve (Selective Leaching)
2/24/2023
01871927-01
LR-EP-INSP 2FP120E ISO Valve (Selective Leaching)
2/24/2023
01874520-01
LR-EP-Selective Leaching Exam on 0SX03CA-G34 SX CT
Gear Reducer
05/07/2020
01874593-01
LR-EP-Selective Leaching Exam on 2DG01KA-Y1 Upper Oil
Cooler
10/03/2022
01874595-01
LR-EP-Selective Leaching Exam on 2DG01KA-X1 JW Upper
Cooler
10/03/2022
01874624-01
ST LR-EP-SELECTIVE LEACH EXAM ON 1DG01KB-X1 JW
UPPER COOLER
06/16/2021
01874627-01
LR-EP-Selective Leaching Exam on 2DG01KA-X1 JW Upper
Cooler
10/06/2022
01874629-01
LR-EP-Selective Leaching Exam on 2DG01KA-X2 JW Lower
Cooler
10/06/2022
04691154-01
(EWP) MM: 0SX79AB-6" UT Line for Wall Thickness (LR)
07/16/2019
04977366-04
EPP LR -Inspection of 0A SXCT 0SX138A Pit
03/31/2020
05052048-01
EWP LR MM SUPP for Removing SX Valve Pit Plugs -
0SX138A -AUTOGEN
08/04/2020
05166970-04
EPP LR -Inspection of 0A SXCT 0SX138A Pit
11/02/2021
202381
PP -Level 2 Coating 0SX138A Flange Bolting and Valve
05/06/2022
206523-04
EPP LR -Inspection of 0A SXCT 0SX138A Pit
2/01/2022
221326-01
EWP LR -SUPP Removing SX Valve Pit Plug for 0SX138B
AutoGE
2/23/2022
234601-04
EPP LR -Inspection of 0A SXCT 0SX138A Pit
05/08/2022
262184-01
EWP LR MM SUPP for Removing SX Valve Pit Plugs
0SX138A-AUTOGEN
08/05/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
287561-04
EPP LR -Inspection of 0A SXCT 0SX138A Pit
11/03/2022
05316880-04
EPP LR -Inspection of 0A SXCT 0SX138A Pit
01/24/2023