ML25238A001
| ML25238A001 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/26/2025 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2025011 | |
| Download: ML25238A001 (1) | |
Text
August 26, 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 - FIRE PROTECTION TEAM INSPECTION REPORT 05000220/2025011 AND 05000410/2025011
Dear David Rhoades:
On August 7, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, Units 1 and 2, and 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.
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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Glenn T. Dentel, Chief Engineering Branch 2 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 GLENN DENTEL Digitally signed by GLENN DENTEL Date: 2025.08.26 07:14:49 -04'00'
ML25238A001 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DORS RI/DORS NAME BPinson GDentel DATE 8/25/2025 8/25/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers:
05000220 and 05000410 License Numbers:
DPR-63 and NPF-69 Report Numbers:
05000220/2025011 and 05000410/2025011 Enterprise Identifier: I-2025-011-0029 Licensee:
Constellation Nuclear Facility:
Nine Mile Point Nuclear Station, Units 1 and 2 Location:
Oswego, NY Inspection Dates:
July 14, 2025 to August 07, 2025 Inspectors:
E. Chen, Reactor Inspector L. Cline, Senior Resident Inspector J. Cunningham, Reactor Inspector D. McHugh, Reactor Inspector B. Pinson, Senior Reactor Inspector Approved By:
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team inspection at Nine Mile Point Nuclear 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 Ensure Credited Recovery Actions Associated with Station Batteries Were Feasible Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000220/2025011-01 Open/Closed None (NPP) 71111.21N.
05 The inspection team identified a Green finding and associated non-cited violation (NCV) of the Nine Mile Point Unit 1 Operating License Condition 2.D.(7) for failure to implement and maintain in effect all provisions of the approved fire protection program (FPP). Specifically, recovery actions (RAs) credited in the Nine Mile Point FPP were not fully implemented into operational guidance and discrepancies were identified in station procedures associated with time sensitive actions (TSAs).
Additional Tracking Items None.
3 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.
REACTOR SAFETY 71111.21N.05 - Fire Protection Team Inspection (FPTI)
Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01) (6 Samples)
The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis or safe shutdown analysis.
(1)
Unit 1 Electromagnetic Relief Valves (2)
Unit 1 Gaseous Suppression (CO2 and Halon)
(3)
Unit 1 125 Volt DC Station Batteries (4)
Unit 2 Fire Detection System (5)
Unit 2 Reactor Core Isolation Cooling System (6)
Unit 2 High Pressure Core Spray Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)
The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees FPP contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.
(1)
Units 1 and 2 Fire Brigade (2)
Unit 1 Fire Probabilistic Risk Analysis Configuration Control Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors verified the following:
- a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.
- b. The adequacy of the design modification, if applicable.
- c. Assumptions and performance capability stated in the safe shutdown analysis have not been degraded through changes or modifications.
- d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, fire hazards analysis, and safe shutdown analysis were updated consistent with the
4 FPP or design change.
- e. Post-fire system specification document operating procedures, such as abnormal operating procedures, affected by the modification were updated.
(1)
Repairs associated with Unit 1 Fire Main Break (IR 04874362)
INSPECTION RESULTS Failure to Ensure Credited Recovery Actions Associated with Station Batteries Were Feasible Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000220/2025011-01 Open/Closed None (NPP) 71111.21N.0 5
The inspection team identified a Green finding and associated non-cited violation (NCV) of the Nine Mile Point Unit 1 Operating License Condition 2.D.(7) for failure to implement and maintain in effect all provisions of the approved fire protection program (FPP). Specifically, recovery actions (RAs) credited in the Nine Mile Point FPP were not fully implemented into operational guidance and discrepancies were identified in station procedures associated with time sensitive actions (TSAs).
==
Description:==
National Fire Protection Association (NFPA) 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, Section 4.2.4.1.6, "Operations Guidance," specifies that "guidance shall be provided to plant personnel that details the credited success paths for each fire area, including the performance of recovery actions." During the licensee's transition to implementation of a FPP in accordance with NFPA 805, a license amendment request (LAR) was submitted that detailed specific RAs that the licensee was taking credit for in dispositioning identified Variances in Fire Deterministic Requirements (VFDRs). Subsequently, the NRC reviewed and approved the LAR in a Safety Evaluation Report, dated June 30, 2014 (ADAMS Accession Number: ML14126A003). Some of the credited RAs involved load shedding various electrical loads in order to extend 125VDC battery capacity during some fire scenarios.
Inspectors reviewed the LAR and the associated Safety Evaluation Report to identify the credited RAs, and determined that the current operations procedures for fire scenarios did not contain adequate guidance to ensure that the RAs would occur. Procedures N1-SOP-21.1, "Fire in Plant," Revision 19, and N1-SOP-21.2, "Control Room Evacuation," Revision 18, are the two main procedures that operators would be directed to during fire scenarios. The two procedures do contain guidance for load shedding in some scenarios, but not all credible scenarios. Specifically, operators would only be directed to load shed if there was a station blackout scenario, or if there was a fire in specific areas and there was damage to specific electrical power boards. The identified VFDRs in the LAR for which the RAs were credited may not always result in a station blackout or damage to the specific power boards identified in the station procedures.
In addition, various discrepancies with OP-NM-102-106, Operator Response Time Program At Nine Mile Point, were identified. Some of these discrepancies were associated with Time Critical Actions and TSA times that did not align with other validated actions. In some cases, different performance times were used for identical or similar actions. The station re-validated the affected times, but in some cases, needed to make adjustments to support other design basis assumptions.
5 Corrective Actions: The station documented the issues in the corrective action program, initiated actions to revise operations procedures, and validated that the relevant TSA performance times remained within design basis assumptions.
Corrective Action References: IRs 04882668, 04884321, and 04888627 Performance Assessment:
Performance Deficiency: The inspection team determined that the failure to implement all credited RAs into operations guidance and to ensure that TSA information was accurate and validated was a performance deficiency and within the licensee's ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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, lack of guidance for operators to perform load shedding of some equipment in the event of a fire in some fire areas did not ensure a successful safe shutdown path was available. Failure to perform load shedding in these non-station blackout fire scenarios that affect charging capability could challenge station battery capacity prior to the connection of portable battery chargers, and could impact the ability to maintain safe shutdown conditions. Additionally, the licensee had to modify assumptions to ensure that station battery charging could be reimplemented within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time required by the design basis assumptions.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Table 3, the inspectors determined the finding affected ability to reach or maintain system specification document conditions in event of a fire. Therefore, screening under IMC 0609, Appendix F, Fire Protection Significance Determination Process, was required. The inspectors performed a Phase 1 Significance Determination Process screening for this issue using Step 1.5.1, "Screen by Licensee Fire PRA-based Risk Evaluation. The licensee completed a risk-based evaluation which indicated a delta-core damage frequency (CDF) of less than 1E-6/year. A Region I senior reactor analyst reviewed the licensees fire probabilistic risk assessment (PRA) evaluation and confirmed the finding to be of very low safety significance (Green).
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Nine Mile Point Nuclear Station, Unit 1 License Condition 2.D.(7) required the licensee to implement and maintain in effect all provisions of the approved FPP that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), NFPA Standard NFPA 805," as approved in the Safety Evaluation Report dated June 30, 2014.
Section 4.2.4.1.6, Operations Guidance, of NFPA 805 stated in part, "guidance shall be provided to plant personnel that details the credited success paths for each fire area,
6 including the performance of recovery actions."
Contrary to the above, as of August 7, 2025, operations guidance did not ensure that required RAs would occur under all postulated fire scenarios as credited in the licensee's licensing basis. Specifically, RAs credited in the Nine Mile Point FPP were not fully implemented into operational guidance and discrepancies were identified in station procedures associated with TSAs.
Enforcement Action: This violation is being treated as a non-cited violation, 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 August 7, 2025, the inspectors presented the fire protection team inspection results to Tim Peter, Site Vice President, and other members of the licensee staff.
7 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 71111.21N.05 Calculations FPEE0-03-002 Evaluation of Interim Action Taken to Prevent Personnel Injury from CO2 Revision 1 FPEE0-08-001 Alternative Methods for Determining the Liquid Level of Halon in Storage Cylinders Revision 0 Corrective Action Documents Resulting from Inspection 04881581 04881989 04882001 04882642 04882668 04882670 04882945 04882967 04882987 04884321 04885854 04886524 04887530 04888627 Engineering Changes ECP-18-000689-MV-001 125VDC Distribution System Analysis Revision 0 Miscellaneous High Pressure Injection System Health Report 04/10/2025 Procedures N1-FRE-F001 Fire Risk Evaluation Revision 3 N1-FST-FPG-SA001 Halon Tank Agent Content Check Revision 00900 N1-HRA-F001 Human Reliability Analysis (HRA)
Revision 6 N1-ISP-001-018 Electromatic Relief Valve Pressure Switch Calibration Revision 00600 N1-PRA-005.05 125VDC Power System Notebook Revision 3 N1-PRM-F001 Fire PRA Notebook Plant Response Model (PRM)
Revision 3 N1-SOP-21.1 Fire In Plant Revision 19 N1-SOP-21.2 Control Room Evacuation Revision 18
8 Inspection Procedure Type Designation Description or Title Revision or Date N2-OSP-RSS-R001 RCIC Remote Shutdown System Test Revision 8 OP-AA-102-106 Operator Response Time Program Revision 9 OP-NM-102-106 Operator Response Time Program at Nine Mile Point Revision 18 OP-NM-102-106 Operator Response Time Program at Nine Mile Point Revision 17 SP-PIS-36-90A/F Electromatic Relief Valves 111, 112, 113, 121, 122 and 123 Pressure Switches Setpoint Calculation Revision 0 Work Orders C93667369