ML25133A164
| ML25133A164 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/13/2025 |
| From: | Jason Schussler Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2025001 | |
| Download: ML25133A164 (1) | |
See also: IR 05000220/2025001
Text
May 13, 2025
David P. Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - INTEGRATED
INSPECTION REPORT 05000220/2025001 AND 05000410/2025001
Dear David Rhoades:
On March 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Nine Mile Point Nuclear Station, Units 1 and 2. On May 1, 2025, the NRC inspectors
discussed the results of this inspection with Tim Peter, Site Vice President, 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 I; the Director, Office of Enforcement; and the NRC Resident Inspector at
Nine Mile Point Nuclear Station, Units 1 and 2.
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 Nine Mile Point Nuclear Station, Units 1 and 2.
D. Rhoades
2
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 Nos. 05000220 and 05000410
License Nos. DPR-63 and NPF-69
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
JASON
SCHUSSLER
Digitally signed by JASON
SCHUSSLER
Date: 2025.05.13
15:04:10 -04'00'
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RI/DORS
RI/DORS
RI/DORS
NAME
BSienel for CKline
DBeacon
JSchussler
DATE
5/13/25
5/8/25
5/12/25
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000220 and 05000410
License Numbers:
Report Numbers:
05000220/2025001 and 05000410/2025001
Enterprise Identifier: I-2025-001-0054
Licensee:
Constellation Energy Generation, LLC
Facility:
Nine Mile Point Nuclear Station, Units 1 and 2
Location:
Oswego, NY
Inspection Dates:
January 1, 2025 to March 31, 2025
Inspectors:
C. Kline, Senior Resident Inspector
B. Sienel, Resident Inspector
H. Anagnostopoulos, Senior Health Physicist
D. Beacon, Senior Project Engineer
C. Borman, Health Physicist
A. Turilin, Reactor Inspector
Approved By:
Jason E. Schussler, Chief
Projects Branch 1
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Nine Mile Point Nuclear Station, Units 1
and 2, 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
Locked High Radiation Area (LHRA) Controls Not in Accordance with Technical Specifications
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Occupational
Radiation Safety
Green
Open/Closed
[H.12] - Avoid
Complacency
The inspectors identified a Green finding and associated non-cited violation (NCV) of
Technical Specification 6.7.2.a when Constellation failed to lock or provide continuous
surveillance to an LHRA.
Additional Tracking Items
Type
Issue Number
Title
Report Section
Status
Supplement to Licensee
Event Report (LER)
05000410/ 2024-002-00,
Turbine Trip due to Failed
Breaker
Closed
3
PLANT STATUS
Unit 1 began the inspection period at approximately 88 percent rated thermal power in response
to a fuel defect. On January 17, 2025, operators reduced power to approximately 64 percent for
a planned rod pattern adjustment and condenser leakage testing. Power was returned to
approximately 89 percent on January 20, 2025. Between January and March 2025, reactor
power was adjusted in small increments, as needed, to maintain operating parameters within
thermal limits for the fuel as a result of the locally suppressed fuel defect. On March 1, 2025, the
unit was downpowered from 83 to 80 percent to remove a recirculating pump from service in
preparation for a refueling outage. Power was restored to approximately 83 percent on
March 5, 2025, when the unit commenced coastdown for refueling outage N1R28. On
March 16, 2025, operators downpowered the unit and shut it down on March 17, 2025, to begin
N1R28. The unit remained shut down for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. On March 7, 2025, operators
reduced power to 80 percent for planned control rod scram time testing and a sequence
exchange. Power was returned to rated thermal power on March 8, 2025. On March 26, 2025,
operators reduced power to approximately 80 percent following moisture separator reheater
issues. Following restoration of equipment, operators restored power to 100 percent on
March 30, 2025, where it remained for the rest of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel to assess licensee performance and compliance with Commission rules
and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk-
significant systems from impending severe weather for lake icing conditions on
January 9, 2025.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
4
(1)
Unit 1 containment spray system 122 on January 7, 2025
(2)
Unit 1 core spray system 111 on March 18, 2025
(3)
Unit 1 shutdown cooling system on March 18, 2025
(4)
Unit 1 emergency diesel generator (EDG) 102 on March 22, 2025
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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)
Unit 2 service water pump room 'B', fire area 60, on January 6, 2025
(2)
Unit 2 radwaste building 261', fire area 59, on January 22, 2025
(3)
Unit 1 screenhouse building 261', fire area 13, on February 3, 2025
(4)
Unit 2 north auxiliary bay 175', fire area 1, on March 12, 2025
(5)
Unit 1 reactor building southwest 198' to 237', core spray 11 area, fire area 2, on
March 18, 2025
(6)
Unit 1 reactor building southeast 198' to 237', core spray 12 area, fire area 1, on
March 18, 2025
(7)
Unit 1 turbine building 240' to 261', main steam isolation valve room and steam
tunnel, fire area 5, on March 19, 2025
(8)
Unit 1 turbine building condenser bays 250' to 277', fire area 5, on March 20, 2025
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated readiness and performance of emergency cooling heat
exchangers on March 16, 2025.
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination (NDE) and Welding
Activities (IP Section 03.01) (1 Sample)
The inspectors evaluated boiling water reactor non-destructive testing by reviewing the
following examinations from March 17-21, 2025:
(1)
Manual ultrasonic examination of the weld overlay weld (N2E-WOL 32-WD-
080/32) of the N2E recirculation inlet nozzle safe end-to-nozzle DM weld (32-
WD-208) prior to full structural weld overlay (25-NMP-1 UT-001).
Manual ultrasonic testing of the N6B-to-inner safe end weld 40-WD-080
Liquid penetrant examination of the weld overlay weld (N2E DM weld prior to
overlay) (25-NMP-1 PT-001).
Welding activities associated with the full structural weld overlay of the N2E
recirculation inlet nozzle weld 32-WD-208 under Work Order (WO)
5
C93904254. The post welding NDE included dye penetrant testing (NDE
Reports 25-NMP-1 PT-002 and 25-NMP-1 PT-003) and ultrasonic testing
(25-NMP-1 UT-002).
Ultrasonic examination of the N2E (32-WD-208). The inspectors reviewed the
ultrasonic examination record (1R27-ISI-VE-019) and dye penetrant
examination records (NDE Reports NMP1-PT-23-033, -035, -038, -040) and
associated evaluation (Engineering Change Package ECP-23-000156-CN-
001) for relevant indications from the previous outage that the licensee
evaluated and accepted for continued service.
Ultrasonic examination of the N1A (32-WD-002) and N1B (32-WD-045). The
inspectors reviewed the ultrasonic examination record (NDE Reports 1R27-
ISI-VE-030 and 1R27-ISI-VE-031) and associated evaluation (ECP-23-
000156-CN-001) for relevant indications from the previous outage that the
licensee evaluated and accepted for continued service.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
(1)
The inspectors observed and evaluated Unit 1 licensed operator performance in the
control room during a power reduction to 25 percent for plant shutdown for refueling
outage N1R28 on March 16, 2025.
(2)
The inspectors observed and evaluated Unit 2 licensed operator performance in the
control room during a power reduction to 80 percent for control rod scram time testing
on March 7 and 8, 2025.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)
(1)
The inspectors observed a Unit 1 simulator evaluation that included plant shutdown,
feed pump 12 failure, pressure regulator failure, and shutdown cooling valve out of
position on March 11, 2025.
(2)
The inspectors observed a Unit 2 simulator evaluation that included a feedwater
heater tube leak, the loss of an offsite power line, and a small break loss of coolant
accident on January 28, 2025.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structure,
system, and component (SSC) remains capable of performing its intended function:
(1)
Unit 1 main steam tunnel structural monitoring on March 19, 2025
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to
ensure the following SSC remains capable of performing its intended function:
6
(1)
Commercial grade dedication of Unit 2 control building chiller compressor oil on
January 25, 2025
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 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)
Unit 2 elevated risk during service water pump 'E' and service water strainer 'E'
system outage window on January 13, 2025
(2)
Unit 1 elevated risk due to liquid poison pump 12 breaker trip during retest on
January 27, 2025
(3)
Unit 1 elevated risk while the Unit 1 and Unit 2 diesel fire pumps were out of service
on February 3, 2025
(4)
Unit 1 elevated risk due to Unit 2 diesel fire pump system outage window on
February 19, 2025
(5)
Unit 1 elevated risk due to failure of EDG 102 circulating oil pump during surveillance
testing March 10, 2025
(6)
Unit 1 elevated risk during reactor cavity flood up during refueling outage N1R28 on
March 19, 2025
(7)
Unit 1 elevated risk during reactor cavity drain down during refueling outage N1R28
on March 28, 2025
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
Unit 1 containment spray pump 122 isolation valve failure to open on January 7, 2025
(2)
Unit 1 liquid poison pump 12 following a breaker trip during surveillance testing on
January 28, 2025
(3)
Unit 2 Division II standby diesel generator following a step change in start time during
planned surveillance on March 3, 2025
(4)
Unit 1 EDG 102 following an oil leak identified on circulating oil pump on
March 24, 2025
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Partial)
(1)
The inspectors evaluated Unit 1 refueling outage N1R28 activities from March 16 to
March 31, 2025.
7
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) (3 Samples)
(1)
N2-TTP-HVC-@103, Performance Evaluation Test for Unit Cooler 2HVAC *UC103A
and B, on 103A unit cooler on January 7, 2025
(2)
Unit 1 liquid poison pump 12 run following breaker replacement on January 27, 2025
(3)
Unit 2 service water pump 'B' following pump and strainer preventive maintenance on
February 20, 2025
Surveillance Testing (IP Section 03.01) (5 Samples)
(1)
N1-ST-Q8B, Liquid Poison Pump 12 and Check Valve Operability Test, on
January 2, 2025
(2)
N2-PM-M1, Reactor Core Isolation Cooling Overspeed Trip Device Test, on
February 5, 2025
(3)
N2-OSP-ICS-Q@002, Reactor Core Isolation Cooling Pump and Valve Operability
Test and System Integrity Test and ASME XI Functional Test and Analysis, on
February 6, 2025
(4)
N1-ST-V8, Main Steam Feedwater Shutdown Cooling Emergency Cooling Head Vent
Valve Cold Shutdown Operability Test, on March 17, 2025
(5)
N1-ST-C1B, Liquid Poison System 12 Functional Test Using Demineralized Water
with Squib Valve Plugs Removed, on March 25, 2025
Inservice Testing (IST) (IP Section 03.01) (3 Samples)
(1)
N1-ST-V19, Emergency Cooling System Heat Removal Capability Test, on
March 16, 2025
(2)
N1-ST-R9B, Core Spray 12 Operability Testing Using Demineralized (CST) Water, on
March 19, 2025
(3)
N1-ST-SA6, Drywell/Torus and Torus/Reactor Building Vacuum Reliefs Test, on
March 21, 2025
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (2 Samples)
(1)
N1-ST-TYC-001, Main Steam Isolation Valve Type C Leak Rate Tests, Section 6.8
(MSIV 01-03), on March 19, 2025
(2)
N1-ST-TYC-001, Main Steam Isolation Valve Type C Leak Rate Tests, Section 6.10
(MSIV 01-04), on March 19, 2025
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
(1)
On February 11, 2025, the inspectors evaluated a Unit 1 emergency preparedness
drill which included Alert and Site Area Emergency event declarations.
8
Additional Drill and/or Training Evolution (1 Sample)
(1)
On January 28, 2025, the inspectors evaluated a Unit 2 simulator evaluation which
included the declaration of an Alert.
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)
Surveys of potentially contaminated material leaving the radiologically controlled area
(RCA)
(2)
Workers exiting the RCA at Unit 1 during refueling outage N1R28
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)
Nozzle N2E welding (RWP NM-1-25-00546)
(2)
Pre-flush radiation surveys on isolation valve-33-04 inside the reactor water cleanup
room (RWP NM-1-25-00601)
(3)
Unit 1 moisture separator moving to equipment storage pit inside reactor cavity
(RWP NM-1-25-00905)
(4)
Unit 1 dryer separator strong back lift (RWP NM-1-25-905)
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:
(1)
Unit 1 fuel pool surge room
(2)
Unit 1 cleanup demineralizer 12 room
(3)
Locked HRA for traversing in-core probe drive mechanisms
9
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
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation
system:
(1)
Unit 1 control room emergency ventilation system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation system:
(1)
Portable high efficiency particulate air filtration unit and associated charcoal adsorber
unit affixed to combined intermediate valves on the main turbine floor
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1)
The inspectors evaluated the licensees use and maintenance of self-contained
breathing apparatuses.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1)
Unit 1 for the period January 1, 2024 through December 31, 2024
(2)
Unit 2 for the period January 1, 2024 through December 31, 2024
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
(2 Samples)
(1)
Unit 1 for the period January 1, 2024 through December 31, 2024
(2)
Unit 2 for the period January 1, 2024 through December 31, 2024
10
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 1 for the period January 1, 2024 through December 31, 2024
(2)
Unit 2 for the period January 1, 2024 through December 31, 2024
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following LERs:
(1)
LER 05000410/2024-002-01, Unit 2 Automatic Reactor Scram on Turbine Trip due to
Failed Breaker (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML25009A027). The inspectors reviewed the updated LER
submittal. The previous LER submittal was reviewed in Inspection Report 05000410/2024004. This LER is Closed.
INSPECTION RESULTS
Locked High Radiation Area (LHRA) Controls Not in Accordance with Technical
Specifications
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Occupational
Radiation Safety
Green
Open/Closed
[H.12] - Avoid
Complacency
The inspectors identified a Green finding and associated NCV of Technical Specification 6.7.2.a when Constellation failed to lock or provide continuous surveillance to an LHRA.
Description: On March 18, 2025, the inspectors performed inspection activities associated
with HRA and LHRA controls. During a routine reactor building walkdown, the inspectors
entered a cubicle that contains the emergency escape drywell hatch and discovered that the
handwheels to open the hatch were not locked or continuously guarded to prevent
unauthorized access as required. This escape hatch provides a means of entry or exit
into/from the reactor drywell enclosure which may typically exhibit dose rates in excess of 1.0
rem per hour at 30 cm from the source and must be controlled as an LHRA as detailed in the
technical specifications. The inspectors found that the escape hatch was conspicuously
posted as required, and that the posting was supplemented with flashing red lights. The
inspectors immediate response included guarding the area and calling for radiation
protection staff to take immediate control of the escape hatch.
The inspectors ascertained that Constellation radiation protection staff had chosen to employ
an alternative access control procedure to secure the escape hatch, as described in
Technical Specification 6.7.2.f. Technical Specification 6.7.2.f states in part, Such individual
areas that are within a larger area where no enclosure exists for the purpose of locking and
where no enclosure can reasonably be constructed around the individual area need not be
controlled by a locked door or gate, nor continuously guarded, but shall be barricaded,
conspicuously posted, and a clearly visible flashing light shall be activated at the area as a
warning device.
11
The inspectors determined that the licensees use of the alternate access control method was
inappropriate and contrary to Technical Specification 6.7.2.f because the cubicle which
encloses the escape hatch was equipped with a locking gate that could have been used as
designed to prevent unauthorized access to the drywell escape hatch. Use of the locking gate
would have properly allowed for unimpeded exit from the drywell in the event of an
emergency exit in the drywell.
Corrective Actions: Constellation immediately restored compliance with technical
specifications by providing continuous surveillance to prevent unauthorized access via the
posting of a door guard.
Corrective Action References: IR 04846820
Performance Assessment:
Performance Deficiency: Technical Specification 6.7.2.a. states, in part, that each entryway to
an LHRA shall be conspicuously posted as a HRA and shall be provided with a locked or
continuously guarded door or gate that prevents unauthorized entry. Contrary to this
requirement, Constellation failed to lock or provide continuous direct or electronic surveillance
to an LHRA that could prevent unauthorized entry. A door or gate already existed and could
be efficiently implemented. Therefore, use of the alternative access control provided in
Technical Specification 6.7.2.f was not appropriate. This was reasonably within
Constellations ability to foresee and correct and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Program and Process attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation.
Significance: The inspectors assessed the significance of the finding using IMC 0609,
Appendix C, Occupational Radiation Safety SDP. The inspectors determined that the finding
was of very low safety significance (Green) because: (1) it did not involve as-low-as
reasonably achievable planning or work controls, (2) there was no overexposure, (3) there
was no substantial potential for an overexposure, and (4) the ability to assess dose was not
compromised.
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, the licensee
traditionally controls LHRAs according to Technical Specification 6.7.2. However, in this
instance Constellation's use of the alternative access control as provided in Technical
Specification 6.7.2.f was not appropriate.
Enforcement:
Violation: Technical Specification 6.7.2.a requires that HRAs with dose rates greater than 1.0
rem/hour at 30 centimeters from the radiation source or from any surface penetrated by the
radiation to be equipped with entryways which are conspicuously posted as a HRA and are
provided with a locked or continuously guarded door or gate that prevents unauthorized entry.
Contrary to the above, on March 18, 2025, the inspectors identified that the emergency
drywell escape hatch would allow access to such dose rates but was not provided with a
locked or continuously guarded door or gate that prevents unauthorized entry.
12
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 May 1, 2025, the inspectors presented the integrated inspection results to Tim Peter,
Site Vice President, and other members of the licensee staff.
13
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
N1-OP-19
042
Corrective Action
Documents
Resulting from
Inspection
04848375
Procedures
N1-OP-2
Core Spray System
03900
N1-OP-4
Shutdown Cooling System
054
N1-OP-45
052
Fire Plans
N1-PFP-0101
Unit 1 Pre-Fire Plans
007
N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans
007
Procedures
N1-ST-V19
Emergency Cooling System - Heat Removal Capability Test
009
71111.08G Corrective Action
Documents
04564804
04565491
Corrective Action
Documents
Resulting from
Inspection
04846921
04849197
71111.11Q Procedures
N2-OSP-RMC-
@001
Control Rod Drive Scram Insertion Time Testing
028
Procedures
S-MRM-REL-
0102
Structural Monitoring Program
013
Procedures
N1-PM-34A
Reactor Cavity Flood Up
0
N1-PM-34B
Reactor Cavity Drain Down
002
Corrective Action
Documents
04832887
04842314
04858006
Corrective Action
Documents
Resulting from
Inspection
04848375
Operability
Evaluations
ENGDOC-25-
000001
12 Liquid Poison Pump (IR 04832887)
0
14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
N2-OSP-EGS-
M@001
Diesel Generator and Diesel Air Start Valve Operability Test
- Divisions I and II
026
Miscellaneous
N1R28 Shutdown Safety Management Plan
4
Procedures
N1-OP-43C
Plant Shutdown
032
Procedures
N1-ST-C1B
Liquid Poison System 12 Functional Test Using
Demineralized Water with Squib Valve Plugs Removed
002
N1-ST-Q8B
Liquid Poison Pump 12 and Check Valve Operability Test
016
N1-ST-R9B
Core Spray 12 Operability Testing Using Demineralized
(CST) Water
001
N1-ST-SA6
Drywell/Torus and Torus/Reactor Building Vacuum Reliefs
Test
006
N1-ST-TYC-001
Main Steam Isolation Valve Type C Leak Rate Tests
004
N1-ST-V8
Main Steam Feedwater Shutdown Cooling Emergency
Cooling Head Vent Valve Cold Shutdown Operability Test
014
N2-OSP-ICS-
Q@002
Reactor Core Isolation Cooling Pump and Valve Operability
Test and System Integrity Test and ASME XI Functional
Test and Analysis
019
N2-OSP-SWP-
Q002
Service Water Pump and Valve Operability Test
022
N2-PM-M1
Test of Reactor Core Isolation Cooling Overspeed Device
006
Work Orders
C93734222
C93903356
C93942856
C93951809
C93988189
C93988190
Corrective Action
Documents
04839118
Corrective Action
Documents
Resulting from
Inspection
04846820
Miscellaneous
Technical
Specifications
Technical Specifications for NMP Unit 1
50-220
15
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Controls for High and Locked High Radiation Areas
40
Radiation
Surveys
2025-236534
U1 Drywell 259-225 Elevations
03/17/2025
2025-236553
U1 Drywell 305 Elevation
03/17/2025
2025-236557
U1 Drywell 295 Elevation
03/17/2025
Self-Assessments White Paper
LHRA Compliance
03/2025