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#REDIRECT [[IR 05000333/2017001]]
{{Adams
| number = ML17128A109
| issue date = 05/08/2017
| title = James A. FitzPatrick Nuclear Power Plant - Integrated Inspection Report 05000333/2017001
| author name = Burritt A L
| author affiliation = NRC/RGN-I/DRP/PB5
| addressee name = Hanson B C
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000333
| license number = DPR-059
| contact person = Burritt A L
| document report number = IR 2017001
| document type = Inspection Report, Letter
| page count = 32
}}
See also: [[followed by::IR 05000333/2017001]]
 
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA  19406-2713
May 8, 2017
  Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2017001
Dear Mr. Hanson:
On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick).  On April 19, 2017, the NRC
inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President,
and other members of your staff.  The results of this inspection are documented in the enclosed
report. 
The NRC inspectors did not identify any finding or violation of more than minor significance.
 
 
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 the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Sincerely,
  /RA/  Arthur L. Burritt, Chief
Reactor Projects Branch 5
 
Division of Reactor Projects
Docket No.  50-333
License No.  DPR-59
 
Enclosure:
Inspection Report 05000333/2017001  w/Attachment:  Supplementary Information
cc w/encl:  Distribution via ListServ 
 
  ML17128A109
  SUNSI Review
  Non-Sensitive  Sensitive
Publicly Available Non-Publicly Available
OFFICE RI/DRP RI/DRP RI/DRP  NAME BSienel via email MDraxton ABurritt  DATE 5/4/17 5/4/17 5/8/17 
1  Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION I 
Docket No.  50-333
 
License No.  DPR-59
 
Report No.  05000333/2017001
 
Licensee:  Exelon Generation Company, LLC
Facility:  James A. FitzPatrick Nuclear Power Plant
 
  Location:  Scriba, NY
 
Dates:  January 1, 2017, through March 31, 2017
 
  Inspectors:  B. Sienel, Senior Resident Inspector
  J. Pfingsten, Resident Inspector
  G. Stock, Resident Inspector
  S. Anderson, Reactor Inspector    E. Burket, Reactor Inspector    R. Rolph, Health Physicist 
 
Approved By:  Arthur L. Burritt, Chief
  Reactor Projects Branch 5    Division of Reactor Projects
 
2  TABLE OF CONTENTS SUMMARY ...............................................................................................................................
..... 31.REACTOR SAFETY .............................................................................................................. 41R04Equipment Alignment .................................................................................................. 41R05Fire Protection ............................................................................................................. 51R08Inservice Inspection .................................................................................................... 51R11Licensed Operator Requalification Program and Licensed Operator Performance .... 81R12Maintenance Effectiveness ......................................................................................... 91R13Maintenance Risk Assessments and Emergent Work Control ................................... 91R15Operability Determinations and Functionality Assessments ..................................... 101R18Plant Modifications .................................................................................................... 111R19Post-Maintenance Testing ........................................................................................ 111R20Refueling and Other Outage Activities ...................................................................... 121R22Surveillance Testing .................................................................................................. 132.RADIATION SAFETY .......................................................................................................... 142RS1Radiological Hazard Assessment and Exposure Controls ........................................ 142RS3In-Plant Airborne Radioactivity Control and Mitigation .............................................. 152RS4Occupational Dose Assessment ............................................................................... 154.OTHER ACTIVITIES ............................................................................................................ 1
64OA1Performance Indicator Verification ............................................................................ 164OA2Problem Identification and Resolution ...................................................................... 174OA3Follow-Up of Events and Notices of Enforcement Discretion.................................... 194OA5Other Activities .......................................................................................................... 204OA6Meetings, Including Exit ............................................................................................ 21SUPPLEMENTARY INFORMATION ........................................................................................ A-1KEY POINTS OF CONTACT .................................................................................................... A-1LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2LIST OF ACRONYMS ............................................................................................................... A-9 
3  SUMMARY  IR 05000333/2017001; 01/01/2017 - 03/31/2017; James A. FitzPatrick Nuclear Power Plant (FitzPatrick); Routine Integrated Inspection Report.
This report covered a three-month period of inspection by resident inspectors and announced
baseline inspections performed by regional inspectors.  The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined
using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated October 28, 2016.  Cross-cutting aspects are determined using IMC 0310, "Aspects Within Cross-Cutting Areas," dated December 4, 2014.  All violations of NRC requirements are
dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016.  The
NRC's program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, "Reactor Oversight Process," Revision 6.
No findings were identified. 
4  REPORT DETAILS
Summary of Plant Status
FitzPatrick
began the inspection period operating at approximately 57 percent power, the maximum power achievable due to fuel depletion as the reactor was at the end of this operating
cycle.  Due to fuel depletion, power continued to decrease to approximately 54 percent on January 13, 2017.  On January 14, operators shut down the reactor to commence refueling
outage (RFO) 22.  Upon completion of refueling and maintenance activities, operators performed a reactor startup on February 23.  The generator was placed online February 25, 2017, ending RFO 22.  Operators increased reactor power to approximately 91 percent on
February 27.  On February 28, operators reduced power to approximately 54 percent for a
control rod pattern adjustment.  Operators increased power to approximately 100 percent on
March 1.  Operators reduced power to 89 percent for another rod pattern adjustment on March 2.  Power was restored to 100 percent later that day, where it remained for the rest of the inspection period. 
 
1. REACTOR SAFETY
  Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
 
1R04 Equipment Alignment   
Partial System Walkdowns (71111.04 - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
 
  'B' core spray system while protected for shutdown risk during RFO 22 on
January 18, 2017  'A' core spray system while protected for shutdown risk during RFO 22 on
January 26, 2017  Residual heat removal (RHR) shutdown cooling during RFO 22 on February 9, 2017  'A' RHR system during planned maintenance on the 'B' RHR system on
March  7,  2017
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected.  The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis
Report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports
(CRs), and the impact of ongoing work activities on redundant trains of equipment in
order to identify conditions that could have impacted the system's performance of its intended safety functions.  The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.  The inspectors examined the material condition of
the components and observed operating parameter
s of equipment to verify that there were no deficiencies.  The inspectors also reviewed whether the licensee had properly
identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization. 
5  b. Findings
No findings were identified.
1R05 Fire Protection 
Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material
condition and operational status of fire protection features.  The inspectors verified that
the licensee controlled combustible materials and ignition sources in accordance with
administrative procedures.  The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition.  The inspectors also verified that
 
station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures. 
 
  Turbine building, 272 foot elevation, fire zone TB-1 on January 20, 2017  Turbine building, 300 foot elevation and 292 foot elevation, fire zone TB-1 on
January 20, 2017  Relay room, fire area/zone VII/RR-1 on February 27, 2017  Reactor building, 272 foot elevation, fire area/zone IX/RB-1A on February 28, 2017  Reactor building, 300 foot elevation, fire area/zone VIII/RB-1C, IX/RB-1A, X/RB-1B
on March 16, 2017
b. Findings
No findings were identified.
1R08 Inservice Inspection  (71111.08G - 1 sample)
        a. Inspection Scope
From January 23 to 26, 2017, the inspectors conducted an inspection and review of
inservice examination activities in order to assess the effectiveness of the licensee's
program for monitoring degradation of the reactor coolant system boundary, risk-
significant piping and components, and containm
ent systems during FitzPatrick RFO 22.  The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in these systems where degradation would result in a significant increase in risk.
 
Non-Destructive Examination (NDE) and Welding Activities (Section 02.01)
The inspectors observed or reviewed the following NDE activities and completed data
records:
  Manual phased array ultrasonic testing (UT), volumetric inspection, American Society of Mechanical Engineers (ASME) Class 1, 24 inch 'A' RHR dissimilar 
6  metal weld 24-10-130, and 24 inch 'B' RHR dissimilar metal welds, 24-10-142
and 24-10-144  Visual testing (VT), visual inspection record, ASME International Welding Engineer (IWE) Examination Category E-A, general visual examination of
exterior containment surfac
es from elevations 272-369  VT inspection record and video review, ASME IWE Category E-A, general visual examination of torus below the water line surfaces
For each evaluation, the inspectors verified NDE activities were performed in
accordance with the 2001 Edition, 2003 Addenda, of the ASME Boiler and Pressure
Vessel (BPV) Code requirements.  The inspectors also verified the NDE activities met
the requirements contained in ASME Section XI, Mandatory Appendix VIII, Article VIII-2000 and the examination personnel were qualified in accordance with ASME Section XI, Mandatory Appendix VII.  The inspectors verified that indications and
defects, if present, were dispositioned in accordance with the ASME Code. 
 
For the general visual examinations, the inspectors ensured that difficult to access areas
or areas made visible by maintenance activities were included within the scope of the visual examination.  Additionally, the inspectors verified the basis for declaring some containment areas as inaccessible for visual examination by comparing the basis against previous containment visual examination records. 
 
The inspectors also performed a walk down of the accessible areas of the drywell to independently assess the condition of the drywell liner. 
The inspectors reviewed video of the VT, including VT-3, VT-1, and EVT-1; and results
of several components examined in accordance with the licensee's boiling water reactor
vessel and internals project in-vessel visual inspection program.  The inspectors verified
the activities were performed in accordance with the licensee's augmented inspection program and associated examination procedure.  The inspectors verified indications and defects, if present, were dispositioned in accordance with the licensee's procedures and
NRC requirements. 
Re-examination of an Indication Previously Accepted for Service after Analysis
A relevant linear indication was identified in integral attachment weld 24-29-626A pipe support saddle during the previous outage, RFO 21.  An analysis was performed and the
indication was accepted for continued service until the RFO 22 refueling outage. 
 
The inspectors reviewed the NDE summary reports for the VT, magnetic particle testing, and liquid penetrant testing for the relevant indication to verify the activities were performed in accordance with the 2001 Edition, 2003 Addenda, of the ASME BPV Code
requirements.  The inspectors also reviewed the engineering evaluation to verify the
analysis was consistent with the guidance in ASME Section XI, IWB-3132.3, Acceptance
 
by Analytical Evaluation.
Modification/Repair/Replacement Consisting of Welding on Pressure Boundary Risk Significant Systems
The inspectors reviewed the welding activity documentation and associated NDE results for the repair of the relevant indication previously identified on the ASME Class 1 main 
7  steam system integral attachment weld 24-29-626A.  The inspectors verified that the welding, NDE, and acceptance were performed in accordance with the 2001 Edition,
2003 Addenda of the ASME BPV Code requirements and the licensee's repair and replacement program.  Specifically, the inspectors verified the welding procedure specification contained the essential, and where applicable, the supplemental essential
variables, in conformance with ASME Section IX, QW-200, and that the weld variables
were within the range qualified by the supporting procedure qualification record as
required by ASME Code Section IX, QW-250.
 
Identification and Resolution of Problems (IMC 02.05)
The inspectors reviewed a sample of CRs which identified NDE indications, deficiencies,
and other nonconforming conditions since the previous RFO.  The inspectors verified
that nonconforming conditions were properly identified, characterized, evaluated, corrective actions identified and dispositioned, and appropriately entered into the CAP. 
b. Findings
Introduction.  The inspectors identified an unresolved item (URI) during the inspection and concluded that additional information was needed to determine if a performance
deficiency existed and if so, whether the issue is more than minor and/or involves a
violation of regulatory requirements.  Specifically, the inspectors noted a discrepancy in
the license renewal application for FitzPatrick and subsequent response to an audit
question regarding the existence and inspection of a moisture barrier in the drywell
between the concrete floor and metal liner. 
Description.  While evaluating drywell containment examination records, the inspectors reviewed FitzPatrick license renewal documents related to the drywell and identified an
issue for which more information is needed to determine whether there is a performance
deficiency.  Specifically, the inspectors noted that NUREG-1905, "Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant," (ML081510826) referenced a drywell floor moisture barrier in Section 3.5.2.1.1. 
However, during a drywell walkdown, the inspectors noted that no moisture barrier
existed on the drywell floor between the drywell liner and the concrete floor.  The
inspectors further noted that Section 3.5.2.2.1.4 of the initial license renewal application
(ML062160494) submitted in July 2006, described a moisture barrier that was to be inspected as part of the IWE Program and Structures Monitoring Program, and that in Amendment 9 to the license renewal application (ML071060390), an audit question
discussed the moisture barrier condition. 
 
The inspectors noted that this location in the drywell was visually inspected once per period in accordance with the licensee's Fourth Ten-Year Interval Inservice Inspection Program, SEP-ISI-007, and that inspection results have not shown significant liner
degradation.  Additionally, the licensee performs augmented UT thickness inspections of
the drywell liner interface in accordance with their augmented inspection program.
 
In response to the inspectors' concerns, the licensee entered this issue into the CAP as CR-JAF-2017-00906 for further evaluation.  For the first corrective action (CA 1) in the CR, the licensee reviewed inspection reports, design requirements, and drawings to
determine whether a moisture barrier previously existed between the containment
drywell liner and containment drywell concrete floor.  The licensee concluded on 
8  February 16, 2017, that the moisture barrier had never existed in that location.  The licensee has a planned corrective action (CA 2) to determine the appropriate actions to
address the apparent discrepancy in information with a due date of May 24, 2017.  The inspectors will review the licensee's conclusions and assessment of the issue and independently determine whether there is a performance deficiency and if so, whether
the issue is more than minor and/or involves a violation of regulatory requirements. 
Pending resolution, this issue is an URI. (URI 05000333/2017001-01, Drywell Moisture Barrier Description in License Renewal Application)
1R11 Licensed Operator Requalification Program and Licensed Operator Performance 
(71111.11Q - 2 samples)
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed a licensed operator simulator exam on March 22, 2017, which
included an earthquake and unisolable torus leak.  The inspectors evaluated operator
performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.  The inspectors assessed the clarity and effectiveness of communications,
implementation of actions in response to alarms and degrading plant conditions, and the
oversight and direction provided by the control room supervisor.  The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager
and the TS action statements entered by the crew.  Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance
problems. 
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
On January 14, 2017, the inspectors observed control room operators during the reactor
shutdown for RFO 22.
  Portions of the reactor shutdown including crew briefs; control rod insertion; removal of the main generator from service; and main turbine, nuclear
instrumentation, and rod worth minimizer testing were observed.  The inspectors
observed crew performance to verify that procedure use, crew communications, and coordination of activities between work groups met established expectations and
standards.
b. Findings
No findings were identified.
   
9  1R12 Maintenance Effectiveness  (71111.12Q - 2 samples)
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of
maintenance activities on structure, system, and component performance and reliability. 
The inspectors reviewed system health reports, CAP documents, maintenance WOs,
and maintenance rule basis documents to ensure that
the licensee was identifying and properly evaluating performance problems within the scope of the maintenance rule.  For each sample selected, the inspectors verified that the structure, system, or component was properly scoped into the maintenance rule in accordance with Title 10 of the
Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by licensee staff was reasonable.  As applicable, for structures, systems,
and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components to (a)(2).  Additionally, the inspectors ensured that licensee staff was identifying and addressing
common cause failures that occurred within and across maintenance rule system
boundaries.
 
  Main steam isolation valve (MSIV) local leak-rate test results during RFO 22  Residual heat removal service water (RHRSW) keep full service water supply line silt
buildup on January 25, 2017
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control  (71111.13 - 5 samples)
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the
maintenance and emergent work activities listed below to verify that the licensee
performed the appropriate risk assessments prior to removing equipment for work.  The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones.  As applicable for each activity, the inspectors verified that
licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and
that the assessments were accurate and complete.  When the licensee performed
emergent work, the inspectors verified that operations personnel promptly assessed and
managed plant risk.  The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment.  The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems,
when applicable, to verify risk analysis assumptions were valid, and applicable
 
requirements were met.
  66UC-22H, east crescent area unit cooler isolation following identification of increased erosion on January 3, 2017  Shutdown risk assessment for risk window 2/3 during RFO 22 on January 18, 2017 
10    Outage risk assessment during operation with a potential for draining the reactor vessel (OPDRV) window on January 23, 2017  Outage risk during emergent welding activities (OPDRV) on February 1, 2017  Planned maintenance on the 'A' low pressure coolant injection inverter the week of
March 20, 2017
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments  (71111.15 - 5 samples)
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and
systems:
  CR-JAF-2017-0575 concerning operability of the 'B' source range monitor on
January 26, 2017 CR-JAF-2017-0610 regarding operability of 10AOV68B after failing to fully stroke for surveillance testing on January 26, 2017 EC 69512 concerning RHR strainer functionality during the RFO 22 performance of ST-9CB with a temporary repair installed (before the temporary modification installation) on February 1, 2017  CR-JAF-2017-0848 regarding core cell 38-39 operability with a loose alignment pin and modified fuel support casting on February 7, 2017 CR-JAF-2017-0812 concerning RHR strainer operability with temporary modification installed for operating cycle 23 on February 14, 2017 The inspectors evaluated the technical adequacy of the operability determinations to
assess whether TS operability was properly justified and the subject component or
system remained available such that no unrecognized increase in risk occurred.  The
inspectors compared the operability and design criteria in the appropriate sections of the
TSs and UFSAR to the licensee's evaluations to determine whether the components or systems were operable.  The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations.  Where compensatory measures were required to maintain operability, the inspectors determined whether the measures
in place would function as intended and were properly controlled by the licensee. 
b. Findings
No findings were identified.
 
   
11  1R18 Plant Modifications  (71111.18 - 3 samples)
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether
the modifications affected the safety functions of systems that are important to safety.  The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance
capability of the affected systems. 
 
  Engineering change (EC) 66088, provide isolation between RHRSW and secondary
containment for work on 10MOV-89B on January 31, 2017  EC 69507, temporary RHR suction strainer shells on February 7, 2017
b. Findings
No findings were identified.
.2 Permanent Modifications 
a. Inspection Scope
The inspectors evaluated a permanent modification to replace 10MOV-89B, RHR heat
exchanger 'B' service water outlet isolation valve, implemented by EC 67365, 10 MOV-
89A/B replacement.
The inspectors verified that the design bases, licensing bases, and performance capability of the affected system were not degraded by the modification.  In addition, the inspectors reviewed modification documents associated with the upgrade and design change.  The inspectors also reviewed the successfully completed
surveillance test conducted to verify system operability following the valve replacement.
b. Findings
No findings were identified.
 
1R19 Post-Maintenance Testing  (71111.19 - 8 samples)
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed
below to verify that procedures and test activities adequately tested the safety functions
that may have been affected by the maintenance activity, that the acceptance criteria in
the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented.  The inspectors also walked
down the affected job site, observed the pre-job brief and post-job critique where
possible, confirmed work site cleanliness was maintained, and witnessed the test or
reviewed test data to verify quality control hold points were performed and checked, and that results adequately demonstrated restoration of the affected safety functions. 
12    WO 341278, 'B' standby liquid control relief valve replacement on January 21, 2017  WO 52473778, 'C' main steam line isolation valve, 29AOV-80C, actuator
replacement on January 27, 2017  WO 453213, Hydraulic control unit (HCU) 26-23 directional control valve
replacement on January 31, 2017  WO 403664, 'C' safety relief valve replacement on February 9, 2017  WO 396857, fuel cell 38-39 fuel support casting modification on February 9, 2017  WO 52607951, inspections and post-maintenance tests for multiple completed maintenance activities during ST-39H, reactor pressure vessel system leakage test and control rod drive Class 2 piping inservice test, on February 22, 2017  WO 457224,'A' reactor water recirculation pump motor generator voltage regulator
replacement on February 27, 2017  WO 466553, 'A' RHR suction strainer temporary modification installation on
February 10, 2017
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities  (71111.20 - 1 sample)
a. Inspection Scope
The inspectors reviewed the station's work schedule and outage risk plan for FitzPatrick RFO 22, conducted January 14 through February 25, 2017.  The inspectors reviewed the licensee's development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered.  During the outage, the inspectors observed portions of the shutdown
and cooldown processes and monitored controls associated with the following outage
activities:
  Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service  Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated
work or testing  Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting  Status and configuration of electrical systems and switchyard activities to ensure that
TSs were met  Monitoring of decay heat removal operations  Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system  Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss  Activities that could affect reactivity  Maintenance of secondary containment as required by TSs  Refueling activities, including fuel handling and 100 percent core verification  Fatigue management 
13    Tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation  Identification and resolution of problems related to RFO activities
b. Findings
No findings were identified.
1R22 Surveillance Testing  (71111.22 - 8 samples)
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of
selected risk-significant structures, syst
ems, and components to assess whether test results satisfied TSs, the UFSAR, and licensee procedure requirements.  The inspectors
verified that test acceptance criteria were clear, tests demonstrated operational
readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied.
 
Upon test completion, the inspectors considered whether the test results supported that
equipment was capable of performing the required safety functions.  The inspectors reviewed the following surveillance tests:
  ST-9BB, Emergency diesel generator 'B' and 'D' full load test and emergency service water pump operability test, on January  11,  2017  ST-1B, MSIV fast closure test (inservice test (IST)), on January 14, 2017  ST-39B-X7B, Type C leak test main steam line B MSIVs (IST), (inboard MSIV, 29AOV-80B), on January 17, 2017 (PCIV)  ST-39B-X7B, Type C leak test main steam line B MSIVs (IST), (outboard MSIV, 29AOV-86B), on January 17, 2017 (PCIV)  ST-6M, Standby liquid control recirculation injection test (IST), on January 21, 2017  ST-9CB, Emergency diesel generator 'B' and 'D' load sequencing test and 4KV emergency power system voltage relays instrument functional test, on February 2, 2017  ST-2HB, Low pressure coolant injection initiation logic system 'B' and reactor pressure vessel low pressure permissive logic systems 'A' and 'B' functional test, on
February 3, 2017  ST-29F, RPT/ARI logic functional and simulated automatic actuation test, on
February 7, 2017
b. Findings
No findings were identified.
   
14  2. RADIATION SAFETY 
  Cornerstone:  Occupational and Public Radiation Safety 
2RS1 Radiological Hazard Assessment and Exposure Controls  (71124.01 - 4 samples) 
a. Inspection Scope
The inspectors reviewed the licensee's performance in assessing and controlling radiological hazards in the workplace.  The inspectors used the requirements contained in 10 CFR Part 20, TSs, applicable regulatory guides (RGs), and the procedures
required by TSs as criteria for determining compliance.
 
Radiological Hazard Assessment (1 sample) The inspectors conducted independent radiation measurements during walkdowns of the
facility and reviewed the radiological survey program, air sampling and analysis,
continuous air monitor use, recent plant radiation surveys for radiological work activities, and any changes to plant operations since the last inspection to verify survey adequacy of any new radiological hazards for onsite workers or members of the public. Instructions to Workers (1 sample)
The inspectors reviewed high radiation area work permit controls and use, and observed containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements.  The inspectors reviewed several occurrences where a worker's electronic personal dosimeter alarmed.  The inspectors reviewed the licensee's evaluation of the incidents,
documentation in the CAP, and whether compensatory dose evaluations were
conducted when appropriate.  The inspectors verified follow-up investigations of actual radiological conditions for unexpected radiological hazards were performed.
Radiological Hazards Control and Work Coverage (1 sample)
The inspectors evaluated in-plant radiological conditions and performed independent
radiation measurements during facility walkdowns and observation of radiological work activities.  The inspectors assessed whether posted surveys; radiation work permits; worker radiological briefings and radiation protection job coverage; the use of continuous
air monitoring, air sampling, and engineering controls; and dosimetry monitoring were
consistent with the present conditions.  The inspectors examined the control of highly
activated or contaminated materials stored within the spent fuel pool and the posting and physical controls for selected high radiation areas, locked high radiation areas, and very high radiation areas to verify conformance with the occupational performance indicator.
 
 
15  Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample)  The inspectors evaluated radiation worker performance with respect to radiation protection work requirements.  The inspectors evaluated radiation protection technicians in performance of radiation surveys and in providing radiological job coverage. 
b. Findings 
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 sample) 
a. Inspection Scope
The inspectors reviewed the control of in-plant airborne radioactivity and the use of
respiratory protection devices in these areas.  The inspectors used the requirements in
10 CFR Part 20, RG 8.15, RG 8.25, NUREG/CR-0041, TSs, and procedures required by
TSs as criteria for determining compliance.
Inspection Planning The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring
systems associated with airborne radioactivity controls and respiratory protection
equipment staged for emergency use.  The inspectors also reviewed respiratory
protection program procedures and current performance indicators for unintended internal exposure incidents.
Engineering Controls (1 sample)
The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airbor
ne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm setpoints. 
 
b. Findings 
No findings were identified.
2RS4  Occupational Dose Assessment (71124.04 - 1 sample) 
a. Inspection Scope
The inspectors reviewed the monitoring, assessment, and reporting of occupational dose.  The inspectors used the requirements in 10 CFR Part 20, RGs, TSs, and
procedures required by TSs as criteria for determining compliance. 
 
Inspection Planning
The inspectors reviewed radiation protection program audits, National Voluntary Laboratory Accreditation Program dosimetry testing reports, and procedures associated
 
with dosimetry operations. 
16  Source Term Characterization (1 sample)
The inspectors reviewed the plant radiation characterization (including gamma, beta, alpha, and neutron) being monitored.  The inspectors verified the use of scaling factors to account for hard-to-detect radionuclides in internal dose assessments.
 
b. Findings
No findings were identified.
  4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification  (71151)
.1 Unplanned Power Changes (1 sample)
a. Inspection Scope
The inspectors reviewed the licensee's submittals for the Unplanned Power Changes performance indicator for the period of January 1, 2016, through December 31, 2016. To determine the accuracy of the performance indicator data reported during those
periods, inspectors used definitions and guidance contained in Nuclear Energy Institute
(NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"
Revision 7.  The inspectors reviewed the licensee's operator narrative logs, maintenance
 
planning schedules, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Safety System Functional Failures (1 sample) 
a. Inspection Scope
The inspectors reviewed the licensee's submittals for the safety system functional failures performance indicator for the period of January 1, 2016, through December 31, 2016.  To determine the accuracy of the performance indicator data reported during
those periods, inspectors used definitions and guidance contained in NEI Document 99-
02, Revision 7; and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 10
CFR 50.73."  The inspectors reviewed the licensee's operator narrative logs, operability
assessments, CRs, event reports and NRC inte
grated inspection reports to validate the accuracy of the submittals. 
b. Findings
No findings were identified.
   
17  4OA2 Problem Identification and Resolution  (71152 - 2 samples)
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, "Problem Identification and Resolution," the
 
inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify the licensee entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends.  In order to assist with the identification of repetitive
equipment failures and specific human performance issues for follow-up, the inspectors
performed a daily screening of items entered into the CAP and periodically attended CR
screening meetings.  The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, the licensee performed an
evaluation in accordance with 10 CFR Part 21.
 
b. Findings 
No findings were identified.
.2 Annual Sample:  Control Rod Unexpected Insertion to the Full in Position
a. Inspection Scope
The inspectors performed an in-depth review of the licensee's evaluation and corrective actions associated with CR-JAF-2016-01483 for the unexpected insertion of control rod
18-35 to the full in position.  The CR documented that on April 24, 2016, while
performing control rod operability testing for fully withdrawn control rods, control rod 18-
35 drifted in from position 48 to 00.  Operators entered Abnormal Operating Procedure 27 for a control rod drift and lowered power, ultimately to approximately 60 percent.  Maintenance replaced all four directional control valves (DCVs) with new valves and
finger filters on HCU 18-35.  Following replacement of the DCVs, control rod 18-35 was
stroke timed per surveillance test ST-20N and inserted to position 46 and withdrawn to
position 48 (full out) with no abnormalities. 
The inspectors assessed the licensee's problem identification threshold, problem analysis, extent of condition reviews, compensatory actions, and the prioritization and
timeliness of corrective actions to determine whether the licensee was appropriately
identifying, characterizing, and correcting problems associated with this issue and
whether the planned or completed corrective actions were appropriate.  The inspectors compared the actions taken to the requirements of the licensee's CAP and 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action."  In addition, the inspectors reviewed
documentation associated with this issue, including the apparent cause evaluation and
DCV replacement schedules, and interviewed engineering personnel to assess the
 
effectiveness of the implemented corrective actions to resolve the issue. 
b. Findings and Observations
No findings were identified. 
 
18  The inspectors determined that the licensee took appropriate actions to identify the direct and apparent causes of the issue.  The direct cause of the issue was that HCU 18-
35 DCVs failed to fully close when de-energized.  The apparent cause was determined
to be the use of a performance-based preventive maintenance (PM) strategy vice a time-based PM replacement for the DCVs.  This resulted in a condition that allowed a latent
equipment issue (age-related degradation) to exist that would have been replaced under a time-based PM strategy, resulting in the direct cause of the HCU 18-35 DCVs failing to
fully close when de-energized.  The licensee replaced all four DCVs with new valves and
finger filters on HCU 18-35 and stroked control rod 18-35 in a timely manner.
The licensee also performed an extent of condition review for the other control rods in
 
which the HCU contained DCVs that are greater than 20 years old.  The licensee
initiated a corrective action to replace all DCVs greater than 20 years old by RFO 23. 
During RFO 22, the licensee replaced 149 DCVs.  There are approximately 244 DCVs that will need to be replaced by the end of RFO 23.
  The inspectors determined the licensee's overall response to the issue was
 
commensurate with its safety significance, was timely, and the corrective actions taken and planned were reasonable.  Although there was an industry recommendation to
switch to a time-based program for DCV replacement, there was not a reasonable timeframe to replace the DCVs that were older than 20 years before this failure
occurred.  Therefore, there was no performance deficiency since the failure was not
reasonably foreseeable and preventable.
 
.3 Annual Sample:  Deferred Corrective Action Recovery
a. Inspection Scope
The inspectors performed a review of the licensee's processes used to recover
corrective action items, including deferred corrective maintenance and permanent modifications, following the decision not to permanently shut down FitzPatrick in January 2017.  In addition to confirming the adequacy of the processes used, this inspection was
performed to identify any risk significant systems significantly affected by deferrals to help inform future NRC inspections. 
The inspectors reviewed documentation associated with this issue and interviewed performance improvement, maintenance, work planning, and engineering personnel to assess the effectiveness of the implemented processes. 
b. Findings and Observations
No findings were identified. 
The inspectors determined that the licensee took appropriate actions to recover
corrective action items following the decision not to permanently shut down FitzPatrick. 
After Entergy announced the plan to decommission the plant, various corrective actions,
maintenance activities and surveillances were reviewed to determine whether they should continue to be performed or should be deferred or rescheduled until after the permanent shutdown date and ultimately not performed.  The licensee had determined
the list of systems which would be required during various phases of decommissioning
to base their scheduling decisions on.  Approximately twenty adverse condition 
19  corrective actions were approved for extension past the permanent shutdown date.  Following the decision to continue plant operation, these items were reassessed for
scheduling.  Approximately half of the items have been completed to date.  The inspectors determined the remaining items were appropriately scheduled commensurate with their safety significance.
 
Surveillances and PM tasks were not cancelled or extended past their late dates.  The
licensee is working to reestablish more ideal PM scheduling to get back into their
performance indicator target without the use of deep grace (close to late date) periods
for completion.
Permanent modifications were captured in the CAP if required to correct an adverse
condition.  System improvement modifications remained listed in the system health
reports, so no process was required to recover them.
The inspectors reviewed the current list of corrective maintenance and key system
health work orders.  No risk significant systems were adversely affected by deferrals.  The inspectors determined the licensee's process to recover corrective action items
following the decision not to decommission the plant was appropriate.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion  (71153 - 1 sample)
(Closed) Licensee Event Report (LER) 05000333/2016-003-00:  Simultaneous Opening of Secondary Containment Airlock Doors
On June 7, 2016, personnel inside and outside the secondary containment simultaneously opened both doors to the north reactor building, 272 foot elevation,
secondary containment airlock.  TS Surveillance Requirement (SR) 3.6.4.1.3 requires
that one secondary containment access door in each access opening is closed at all
times.  Both parties were aware of this requirement, and both withdrew and closed their respective doors within a period of approximately two seconds.  However, during the period that both doors were simultaneously open, TS SR 3.6.4.1.3 was not satisfied, and
 
therefore, secondary containment was inoperable per TS Limiting Condition for
Operation 3.6.4.1.  The limiting condition for operation action statement requires that
secondary containment be restored to operable status within four hours.  This condition
was met once one of the secondary containment access doors was closed.  However, because secondary containment is a single train system, this occurrence was reportable under 10 CFR 50.72 as a condition that at the time of discovery would have prevented
the fulfillment of the secondary containment safety function, even though the condition
existed for less than the TS allowed outage time. The inspectors noted that the subject secondary containment access is equipped with three sets of green and red position indication lights, one set on each entrance to the
airlock and the third set inside the airlock.  All the green lights are energized if both
airlock doors are closed.  However, if either door is opened, the green lights extinguish
and all the red lights are energized.  This scheme functions adequately to alert an
individual preparing to enter an airlock that another individual is already in the process of entering from the other side.  However, in the event that both doors are operated simultaneously, the indications for both individuals are as expected for a single door
being opened, and neither recognizes a problem exists until they are positioned to see
the other open door (at which point, it is too late).  Therefore, the inspectors determined 
20  that this event was not due to a human performance deficiency.  Given that secondary containment differential pressure
remained within specification, along with the short duration of the event, the inspectors determined that secondary containment had remained capable of performing its design function throughout the event.  Additionally, the issue was reported in a timely manner in accordance with the requirements of
10 CFR 50.72, so it did not constitute a traditional enforcement issue.  Because the
failure to comply with TS SR 3.6.4.1.3 was corrected within the allowed outage time, no
violation of regulatory requirements occurred.  Cameras and monitors have since been
installed on each side of the secondary containment airlock in question, enabling individuals to verify that the opposing door will not be simultaneously opened.  This LER is closed.
 
4OA5 Other Activities 
  Temporary Instruction (TI) 2515/192, "Inspection of the Licensee's Interim Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems" 
a. Inspection Scope
The objective of this performance-based TI is to verify implementation of interim
compensatory measures associated with an open phase condition (OPC) design
vulnerability in electric power system for operating reactors.  The inspectors conducted
an inspection to determine if FitzPatrick had implemented the following interim
compensatory measures.  These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability.  The inspectors verified the following:
  FitzPatrick had identified and discussed with plant staff the lessons learned from the OPC events at the U.S. operating plants including the Byron Station OPC event and its consequences.  This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC event. 
  FitzPatrick had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on offsite power sources credited for safe shutdown of the plant. 
 
  FitzPatrick had established and continues to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power
circuits to detect a visible OPC. 
  FitzPatrick had ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained.  As part of the maintenance and testing activities, FitzPatrick assessed and managed plant risk in accordance
 
with 10 CFR 50.65(a)(4) requirements. 
21  b. Findings and Observations
No findings of significance were identified.  The inspectors verified the criteria were met.  Information gained from this TI have been provided to the program office for further
review. 
4OA6 Meetings, Including Exit 
On April 19, 2017, the inspectors presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the FitzPatrick staff.  The inspectors verified that no proprietary information was retained by the inspectors or documented in this
 
report.
ATTACHMENT:  SUPPLEMENTARY INFORMATION 
A-1 Attachment SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
B. Sullivan, Site Vice President
T. Peter, General Manager, Plant Operations
C. Adner, Director, Manager Operations and Regulatory and Performance Improvement D. Bittinger, Manager, Design and Programs Engineering
W. Drews, Manager, Regulatory Assurance
K. Habayeb, Supervisor, Engineering
R. Heath, Manager, Radiation Protection J. Jones, Manager, Emergency Planning
 
D. Poulin, Director, Engineering
 
T. Redfearn, Manager, Security
 
M. Reno, Manager, Training
  LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened  05000333/2017001-01
  URI  Drywell Moisture Barrier Description in License Renewal Application (Section 1R08)
Closed  05000333/2016-003-00
 
05000333/TI 2515/192
LER  TI Concurrent Opening of Reactor Building Airlock
Doors (Section 4OA3)
Inspection of the Licensee's Interim
Compensatory Measures Associated with the
Open Phase Condition Design Vulnerabilities in
Electric Power Systems (Section 4OA5)
 
A-2  LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
Procedures AOP-19A, Loss of Switchgear L16, Revision 5
ODSO-4, Shift Turnover and Log Keeping, Revision 118 OP-13, RHR System, Revision 98 OP-13D, RHR - Shutdown Cooling, Revision 30
OP-14, Core Spray System, Revision 37
 
Condition Report CR-JAF-2017-0396
 
Drawings FM-20A, Flow Diagram RHR System 10, Revision 72
FM-20B, Flow Diagram RHR System 10, Revision 62 FM-23A, Flow Diagram Core Spray System 14, Revision 49
Section 1R05: Fire Protection
Procedures JAF-RPT-04-00478, JAF Fire Hazards Analysis, Revision 2 JAF-RPT-04-00478, JAF Fire Hazards Analysis, Revision 2 PFP-PWR12, Relay Room Elevation 286' Fire Area VII/Fire Zone RR-1, Revision 5
PFP-PWR20, Reactor Building - East / Elevation 272' Fire Area/Zone IX/RB-1A, Revision 5
PFP-PWR21, Reactor Building - West / Elevation 272' Fire Area/Zone X/RB-1B, Revision 5
PFP-PWR24, Reactor Building - East, Elevation 300' Fire Area/Fire Zone - 8/RB-1C, 9RB-1A, Revision 5 PFP-PWR25, Reactor Building - West, Elevation 300' Fire Area/Fire Zone - X/RB-1B, Revision 3 PFP-PWR45, Turbine Building, Elevation 272', Fire Area/Zone IE/TB-1, Revision 06
PFP-PWR46, Turbine Building, Elevation 272', Fire Area/Zone IE/TB-1, OR-2, Revision 04
PFP-PWR48, Turbine Building, Elevation 300', Fire Area/Zone IE/TB-1, Revision 04
Drawings FPSSK-2, Fire Area/Zone Arrangement Plan El 272'-0", Revision 3
FPSSK-3, Fire Area/Zone Arrangement Plan El 300'-0", Revision 3
Section 1R08: Inservice Inspection
Procedures CEP-NDE-0505, Ultrasonic Thickness Examination, Revision 4 CEP-NDE-0901, VT-1 Examination, Revision 4
PQR 015, Manual Gas Tungsten Arc Welding (GTAW), Revision 1 PQR 024, Manual Gas Tungsten and Shielded Metal Arc Welding (GTAW and SMAW), Revision 1 PRO-ISI-IVVI-0001-GFIT1, Procedure for In-Vessel Visual Inspection (IVVI) of the James A. Fitzpatrick BWR 4 RPV Internals, Revision 2 SEP-ISI-007, ASME Section XI Fourth 10-Year Interval Inservice Inspection Program Plan, Revision 7 SI-UT-130, Procedure for the Phased Array Ultrasonic Examination of Dissimilar Metal Welds, Revision 3 
A-3  WPS-CS-1/1-A, Welding Procedure Specification, Revision 0 WPS-CS-1/1-B, Welding Procedure Specification, Revision 0
Condition Reports CR-JAF-2014-04909  CR-JAF-2014-06304  CR-JAF-2014-06884
CR-JAF-2014-07232  CR-JAF-2015-01099  CR-JAF-2015-03000
CR-JAF-2017-00480  CR-JAF-2017-00667  CR-JAF-2017-00706 CR-JAF-2017-00812  CR-JAF-2017-00822  CR-JAF-2017-00906 CR-JAF-2017-00910
 
Work Order 0039397101, Repair Linear Flaw in ISI Weld 24-29-626A, January 26, 2017
NDE Summary Reports 3036-NTHBIR, Closure Head Vent Nozzle IR, January 22, 2017
ISI-VT-16-012, IWE General Exam RB 272-300, January 23, 2017
ISI-VT-16-013, IWE General Exam RB 300-326, January 23, 2017 ISI-VT-17-017, VT-3 Pressure Retaining Bolting, January 26, 2017
ISI-VT-17-023, VT-3 Torus Supports, January 23, 2017
JAF-RHR-130, FitzPatrick DMW RHR 24-10-130, January 29, 2017
JAF-RHR-142, FitzPatrick DMW RHR 24-10-142, January 30, 2017
JAF-RHR-144, FitzPatrick DMW RHR 24-10-144, January 30, 2017
 
Miscellaneous J.A. FitzPatrick RO21 Final Report, Fall 2014, Inservice Inspection - FAC, Volume 1 LO-JAFLO-2016-00035, Pre-NRC ISI Snaps
hot Assessment, December 5, 2016 OE-NOE-2015-00096-CA-12, NRC Information Notice 2015-04, Fatigue in Branch Connection Welds, Revision 0 OE-NOE-2016-00145 CA#00012, NRC-RIS-2016-07 Containment Shell or Liner Moisture Barrier Inspection, Revision 0 WPQ-EN-0229-08536, Welding Performance Qualification, December 22, 2016
 
Section 1R11: Licensed Operator Requalification Program
Procedures OP-65, Startup and Shutdown Procedure, Revision 121 ST-5C, IRM-APRM Instrument Range Overlap Check, completed January 14, 2017
 
Section 1R12: Maintenance Effectiveness
Procedures
EN-DC-205, Maintenance Rule Monitoring, Revision 6
EN-DC-206, Maintenance Rule (a)(1) Process, Revision 3
 
Condition Reports CR-JAF-2014-4381  CR-JAF-2015-3924*  CR-JAF-2016-0263*
CR-JAF-2016-0324*  CR-JAF-2016-0610  CR-JAF-2016-1671*
CR-JAF-2016-2356  CR-JAF-2016-2411*  CR-JAF-2016-3831*
CR-JAF-2016-4815*
  CR-JAF-2017-0309*  CR-JAF-2017-0310* CR-JAF-2017-0501*  CR-JAF-2017-0768  CR-JAF-2017-0886* CR-JAF-2017-0920*  CR-JAF-2017-0942  CR-JAF-2017-1108* CR-JAF-2017-2033
*Maintenance Rule Functional Failure Evaluations also reviewed for Condition Reports 
A-4    Work Orders
451680 466890
Miscellaneous
JAF-RPT-MST-02480, Maintenance Rule Basis Document System 029 Main Steam, Revision 9 
JAF-RPT-MULTI-02294, Maintenance Rule Basi
s Document for Service Water Systems including System 10 (RHRSW), 46 (Normal SW), and 46-ESW (Emergency SW),
Revision 12 Maintenance Rule (a)(1) Action Plan for System 29, February 6, 2017
System Health Report for Main Steam System 3Q-2016
Section 1R13: Maintenance Risk Assessments and Emergent Work Control
Procedures AP-10.09, Outage Risk Assessment, Revision 35 AP-10.10, On-Line Risk Assessment, Revision 9 EN-WM-104, On-Line Risk Assessment, Revision 12
ODSO-4, Shift Turnover and Log Keeping, Revision 118
OP-43C, LPCI Independent Power Supply System, Revision 23
 
Condition Reports (* NRC Identified) CR-JAF-2017-0465*
CR-JAF-2016-4882
 
Miscellaneous R22 Revision 1 Risk Assessment Based on Schedule, December 29, 2016
Section 1R15: Operability Determinations and Functionality Assessments
Procedures EN-NE-G-0032, BWR Primary System Loose Parts Analysis Considerations, Revision 1 ST-39J, Leak Testing of RHR and Core Spray Testable Check Valves (IST), Revision 18
Condition Reports CR-JAF-2012-6414  CR-JAF-2014-5302  CR-JAF-2017-0610
CR-JAF-2017-0812  CR-JAF-2017-0848  CR-JAF-2017-0851 
CR-JAF-2017-0997
Work Orders
00396857
52606738
Drawing FM-20A, Flow Diagram RHR System 10, Revision 47
 
Miscellaneous ALION-CAL-SI-9389-002, Design Pressure for Strainer "Clamshell" Cover Modules, Revision 2
 
EC 69400 EC 69507, Temporary RHR suction strainer shells EC 69558, Enlarge alignment slot on fuel support casting for cell location 38-39 to allow for FSC assembly in proper orientation over guide pin in core plate 
A-5  EC 69571 JAF-194295-RP01, RHR Strainer Module Repair Report, Revision 0
Section 1R18: Plant Modifications
Procedures EN-DC-117, Post Modification Testing and Special Instructions, Revision 8 ST-2XB, RHR Service Water Loop B Quarterly Operability Test (IST), Revision 13 ST-41D, Remote Valve Position Indication Verification Online (IST), Revision 20
 
Condition Report (* NRC identified)
2017-2018* 
Work Order
00327815
Drawings FM-20B, Flow Diagram Residual Heat Removal System 10, Revision 72
FP-37E, Service Water Piping Reactor Building Sh-5, Revision 22
FP-37F, Service Water Piping Reactor Building Sh-6, Revision 13
 
Miscellaneous EC 66231, Provide Isolation between RHRSW and Secondary Containment for Work on
10MOV-89A EC 66088, Provide Isolation between RHRSW and Secondary Containment for Work on
10MOV-89B Engineering Change 67365, 10MOV-89A/B Replacement, Revision 0
 
Section 1R19: Post-Maintenance Testing
Procedures EN-WM-107, Post Maintenance Testing, Revision 5
ESP-68.001, Leak Rate Test of Automatic Depressurization System (ADS) Pneumatic Supply
Check Valves, Revision 5 IMP-02-184.8, Recirculating MG Set Voltage Regulator Tuning**, completed 2/27/17 MP-003.11, HCU Directional Control Valves 03SOV-120 through 123, Revision 18
RAP-7.3.39, Channel-Control Blade Interference Monitoring, completed 2/9/17 
ST-2AL, RHR Loop A Quarterly Operability Test (IST), Revision 36
ST-2AM, RHR Loop B Quarterly Operability Test (IST), completed 2/22/17
ST-6HB, Standby Liquid Control B Side Quarterly Operability Test (IST), completed 1/21/17 ST-20N, Control Rod Exercise/Timing/Stall Flow Test, completed 2/4/17
ST-22A, ADS Simulated Automatic Actuation Test, Revision 24
ST-22K, Manual Safety Relief Valve Operation System Test (IST), Revision 5
ST-39B, Type B and C LLRT of Containment Penetrations (IST), Revision 36
ST-39B-X7C, Type C Leak Test Main Steam Line C MSIVs (IST), Revision 15 ST-39H, RPV System Leakage Test and Control Rod Drive Class 2 Piping Inservice Test (ISI)**, Revision 34 ST-43G, Remote Shutdown Panel 25ASP-5 Component Operation and Isolation Verification, Revision 6
Condition Reports CR-JAF-2017-0409 CR-JAF-2017-1501 CR-JAF-2017-1549 CR-JAF-2017-1670  CR-JAF-2017-1676 CR-JAF-2017-1678 CR-JAF-2017-1684 CR-JAF-2017-1686 
A-6  CR-JAF-2017-1689 CR-JAF-2017-1694
Work Orders
00341278 00396857 00403664 00453213 00456762 00457224
 
00465534 00466391 00466553 52607951
  Section 1R20: Refueling and Other Outage Activities
Procedures EN-OM-123, Fatigue Management Program, Revision 13
ESP-65.001, Drywell Inspection, Revision 4
ODSO-4, Shift Turnover and Log Keeping, Revision 118 OP-9, Main Turbine, Revision 58 OP-11A, Main Generator, Transformers and Isolated Bus Phase Cooling, Revision 52
OP-13D, RHR-Shutdown Cooling, Revision 29
OP-21, Emergency Service Water (ESW), Revision 38
OP-30A, Refueling Water Level Control, Revision 18 OP-65, Startup and Shutdown Procedure, Revision 121 OSP-66.001, Management of Refueling Activities, Revision 8
RAP-7.4.01, Control Rod Scram Time Evaluation**, Revision 28
ST-2AN, RHR Loop A Monthly Operability Test, Revision 16
ST-2AO, RHR Loop B Monthly Operability Test, Revision 16
ST-24J, RCIC [Reactor Core Isolation Cooling] Flow Rate and Inservice Test (IST), Revision 45 ST-26J, Heatup and Cooldown Temperature Checks, Revision 24 TOP-416, Transferring from A RFP to B RFP While On the Low Flow Control Valve, Revision 0
 
Condition Reports CR-JAF-2017-0706  CR-JAF-2017-0738  CR-JAF-2017-0812 CR-JAF-2017-0848  CR-JAF-2017-1142  CR-JAF-2017-1146
Miscellaneous System Window Closeout Checklist for 11SLC (1R22-0071), January 22, 2017
System Window Closeout Checklist for 'B' RHR (R22-0022), February 2, 2017
 
Section 1R22: Surveillance Testing
Procedures CEP-APJ-001, Primary Containment Leakage Rate Testing (10CFR50 Appendix J) Program
Plan, Revision 3 MST-011.11, Standby Liquid Control Explosive Valves (IST), Revision 14 OP-25, Control Rod Drive Hydraulic System, Revision 88
OP-22, Diesel Generator Emergency Power, Revision 61
ST-1B, MSIV Fast Closure Test (IST), Revision 26
ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI), Revision 8
ST-6N, Reverse Closure Test of SLC Injection Line Check Valves (IST), Revision 0 ST-9BB, EDG B and D Full Load Test and ESW Pump Operability Test, Revision 15 ST-9CB, EDG B and D Load Sequencing Test and 4KV Emergency Power System Voltage Relays Instrument Functional Test**, Revision 3 ST-29F, RPT/ARI Logic Functional and Simulated Automatic Actuation Test, Revision 17
ST-39B, Type B and C LLRT of Containment Penetrations (IST), Revision 36 ST-39B-X7B, Type C Leak Test Main Steam Line B MSIVs (IST), Revision 14 ST-43H, Circuit Breaker 10614 Remote Shutdown Operation and Isolation Verification, Revision 11 
A-7    Condition Reports CR-JAF-2017-0310 CR-JAF-2017-0425
CR-JAF-2017-1292
 
Work Orders
52698422
52733249
Drawing FM-21A, Flow Diagram Standby Liquid Control System 11, Revision 37
Miscellaneous Updated FSAR Section 4.6, Main Steam Isolation Valves
Updated FSAR Section 8.6, Emergency AC Power System
 
Section 2RS1: Radiological Hazard Assessment and Exposure Controls
Procedures EN-RP-100, Radiation Worker Expectations, Revision 11
EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 12
EN-RP-102, Radiological Control, Revision 5 EN-RP-105, Radiological Work Permits, Revision 16 EN-RP-106-01, Radiological Survey Guidelines, Revision 3
EN-RP-108, Radiation Protection Posting, Revision 18
EN-RP-121, Radioactive Material Control, Revision 13
EN-RP-141-01, Job Coverage Using Remote Monitoring Technology, Revision 6 EN-RP-152, Conduct of Radiation Protection, Revision 1
Condition Reports CR-JAF-2016-00607  CR-JAF-2016-00650  CR-JAF-2016-04668
CR-JAF-2016-05190  CR-JAF-2017-00627  CR-JAF-2017-00637
 
RWPs and ALARA Plans  RWP  ALARA Plan
20170514 17-0514
 
20170609 17-0609
 
20170701 17-0701
20170944 17-0944
Surveys JAF-1701-0325  JAF-1701-0376  JAF-1701-0397
JAF-1701-0455  JAF-1701-0495  JAF-1701-0520
JAF-1701-0532  JAF-1701-0568  JAF-1701-0577 JAF-1701-0582  JAF-1701-0601  JAF-1701-0740 JAF-1701-0757  JAF-1701-0639  JAF-1701-0659
JAF-1701-0667  JAF-1701-0698  JAF-1701-0720
JAF-1701-0721  JAF-1701-0722  JAF-1701-0723
JAF-1701-0724  JAF-1701-0725  JAF-1701-0726 JAF-1701-0732  JAF-1701-0733  JAF-1701-0735 JAF-1701-0736  JAF-1701-0737  JAF-1701-0744
JAF-1701-0752  JAF-1701-0778  JAF-1701-0789 
A-8  JAF-1701-0798
Miscellaneous Air Sample 17106, 17111, 17137, 17139, 17142, 17147, 17150, 17182
 
Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation
Procedure EN-RP-131, Air Sampling, Revision 15
Section 4OA2: Problem Identification and Resolution
Procedure EN-LI-118, Cause Evaluation Process, Revision 22
Condition Reports CR-JAF-2010-08458 CR-JAF-2016-01483
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
Condition Reports CR-JAF-2015-4146CR-JAF-2016-1996
Section 4OA5: Other Activities
Procedures AOP-72, 115 KV Grid Loss, Instability, or Degradation, Revision 11
OP-44A, 115 KV System, Revision 22
 
Condition Reports CR-HQN-2012-0847
CR-JAF-2012-1016 CR-JAF-2005-5180
Work Orders
00456356 52692025 52693298 
Miscellaneous EC 48543, Provide Open Phase Detection and Protection for 115KV Switchyard - Parent EC, Revision 0 LER 050005333-2005-006-00, Inoperable 115 KV Line in Excess of Technical Specification
Allowed Out of Service Time
   
A-9  LIST OF ACRONYMS
 
10 CFR  Title 10 of the
Code of Federal Regulations ASME  American Society of Mechanical Engineers
BPV  boiler and pressure vessel
CAP  corrective action program CR  condition report DCV  directional control valve
EC  engineering change 
HCU  hydraulic control unit
IMC  Inspection Manual Chapter IST  inservice test IWE  International Welding Engineer
LER  licensee event report
MSIV  main steam isolation valve
NDE  non-destructive examination NEI  Nuclear Energy Institute NRC  Nuclear Regulatory Commission
OPC  open phase condition
OPDRV  operation with a potential for draining the reactor vessel
PM  preventive maintenance
RFO  refuel outage RG  regulatory guide RHR  residual heat removal
RHRSW  residual heat removal service water
RPV  reactor pressure vessel
SR  surveillance requirement TI  temporary instruction TS  technical specification
UFSAR  Updated Final Safety Analysis Report
URI  unresolved item
UT  ultrasonic testing
VT  visual testing WO  work order
}}

Revision as of 01:40, 21 January 2019

James A. FitzPatrick Nuclear Power Plant - Integrated Inspection Report 05000333/2017001
ML17128A109
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 05/08/2017
From: Burritt A L
NRC/RGN-I/DRP/PB5
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Burritt A L
References
IR 2017001
Download: ML17128A109 (32)


See also: IR 05000333/2017001

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713

May 8, 2017

Mr. Bryan C. Hanson

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2017001

Dear Mr. Hanson:

On March 31, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). On April 19, 2017, the NRC

inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President,

and other members of your staff. The results of this inspection are documented in the enclosed

report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

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 the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,

/RA/ Arthur L. Burritt, Chief

Reactor Projects Branch 5

Division of Reactor Projects

Docket No. 50-333

License No. DPR-59

Enclosure:

Inspection Report 05000333/2017001 w/Attachment: Supplementary Information

cc w/encl: Distribution via ListServ

ML17128A109

SUNSI Review

Non-Sensitive Sensitive

Publicly Available Non-Publicly Available

OFFICE RI/DRP RI/DRP RI/DRP NAME BSienel via email MDraxton ABurritt DATE 5/4/17 5/4/17 5/8/17

1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No. 50-333

License No. DPR-59

Report No. 05000333/2017001

Licensee: Exelon Generation Company, LLC

Facility: James A. FitzPatrick Nuclear Power Plant

Location: Scriba, NY

Dates: January 1, 2017, through March 31, 2017

Inspectors: B. Sienel, Senior Resident Inspector

J. Pfingsten, Resident Inspector

G. Stock, Resident Inspector

S. Anderson, Reactor Inspector E. Burket, Reactor Inspector R. Rolph, Health Physicist

Approved By: Arthur L. Burritt, Chief

Reactor Projects Branch 5 Division of Reactor Projects

2 TABLE OF CONTENTS SUMMARY ...............................................................................................................................

..... 31.REACTOR SAFETY .............................................................................................................. 41R04Equipment Alignment .................................................................................................. 41R05Fire Protection ............................................................................................................. 51R08Inservice Inspection .................................................................................................... 51R11Licensed Operator Requalification Program and Licensed Operator Performance .... 81R12Maintenance Effectiveness ......................................................................................... 91R13Maintenance Risk Assessments and Emergent Work Control ................................... 91R15Operability Determinations and Functionality Assessments ..................................... 101R18Plant Modifications .................................................................................................... 111R19Post-Maintenance Testing ........................................................................................ 111R20Refueling and Other Outage Activities ...................................................................... 121R22Surveillance Testing .................................................................................................. 132.RADIATION SAFETY .......................................................................................................... 142RS1Radiological Hazard Assessment and Exposure Controls ........................................ 142RS3In-Plant Airborne Radioactivity Control and Mitigation .............................................. 152RS4Occupational Dose Assessment ............................................................................... 154.OTHER ACTIVITIES ............................................................................................................ 1

64OA1Performance Indicator Verification ............................................................................ 164OA2Problem Identification and Resolution ...................................................................... 174OA3Follow-Up of Events and Notices of Enforcement Discretion.................................... 194OA5Other Activities .......................................................................................................... 204OA6Meetings, Including Exit ............................................................................................ 21SUPPLEMENTARY INFORMATION ........................................................................................ A-1KEY POINTS OF CONTACT .................................................................................................... A-1LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-1LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2LIST OF ACRONYMS ............................................................................................................... A-9

3 SUMMARY IR 05000333/2017001; 01/01/2017 - 03/31/2017; James A. FitzPatrick Nuclear Power Plant (FitzPatrick); Routine Integrated Inspection Report.

This report covered a three-month period of inspection by resident inspectors and announced

baseline inspections performed by regional inspectors. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined

using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated October 28, 2016. Cross-cutting aspects are determined using IMC 0310, "Aspects Within Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are

dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016. The

NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, "Reactor Oversight Process," Revision 6.

No findings were identified.

4 REPORT DETAILS

Summary of Plant Status

FitzPatrick

began the inspection period operating at approximately 57 percent power, the maximum power achievable due to fuel depletion as the reactor was at the end of this operating

cycle. Due to fuel depletion, power continued to decrease to approximately 54 percent on January 13, 2017. On January 14, operators shut down the reactor to commence refueling

outage (RFO) 22. Upon completion of refueling and maintenance activities, operators performed a reactor startup on February 23. The generator was placed online February 25, 2017, ending RFO 22. Operators increased reactor power to approximately 91 percent on

February 27. On February 28, operators reduced power to approximately 54 percent for a

control rod pattern adjustment. Operators increased power to approximately 100 percent on

March 1. Operators reduced power to 89 percent for another rod pattern adjustment on March 2. Power was restored to 100 percent later that day, where it remained for the rest of the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment

Partial System Walkdowns (71111.04 - 4 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

'B' core spray system while protected for shutdown risk during RFO 22 on

January 18, 2017 'A' core spray system while protected for shutdown risk during RFO 22 on

January 26, 2017 Residual heat removal (RHR) shutdown cooling during RFO 22 on February 9, 2017 'A' RHR system during planned maintenance on the 'B' RHR system on

March 7, 2017

The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the Updated Final Safety Analysis

Report (UFSAR), technical specifications (TSs), work orders (WOs), condition reports

(CRs), and the impact of ongoing work activities on redundant trains of equipment in

order to identify conditions that could have impacted the system's performance of its intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of

the components and observed operating parameter

s of equipment to verify that there were no deficiencies. The inspectors also reviewed whether the licensee had properly

identified equipment issues and entered them into the corrective action program (CAP) for resolution with the appropriate significance characterization.

5 b. Findings

No findings were identified.

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material

condition and operational status of fire protection features. The inspectors verified that

the licensee controlled combustible materials and ignition sources in accordance with

administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that

station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Turbine building, 272 foot elevation, fire zone TB-1 on January 20, 2017 Turbine building, 300 foot elevation and 292 foot elevation, fire zone TB-1 on

January 20, 2017 Relay room, fire area/zone VII/RR-1 on February 27, 2017 Reactor building, 272 foot elevation, fire area/zone IX/RB-1A on February 28, 2017 Reactor building, 300 foot elevation, fire area/zone VIII/RB-1C, IX/RB-1A, X/RB-1B

on March 16, 2017

b. Findings

No findings were identified.

1R08 Inservice Inspection (71111.08G - 1 sample)

a. Inspection Scope

From January 23 to 26, 2017, the inspectors conducted an inspection and review of

inservice examination activities in order to assess the effectiveness of the licensee's

program for monitoring degradation of the reactor coolant system boundary, risk-

significant piping and components, and containm

ent systems during FitzPatrick RFO 22. The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in these systems where degradation would result in a significant increase in risk.

Non-Destructive Examination (NDE) and Welding Activities (Section 02.01)

The inspectors observed or reviewed the following NDE activities and completed data

records:

Manual phased array ultrasonic testing (UT), volumetric inspection, American Society of Mechanical Engineers (ASME) Class 1, 24 inch 'A' RHR dissimilar

6 metal weld 24-10-130, and 24 inch 'B' RHR dissimilar metal welds, 24-10-142

and 24-10-144 Visual testing (VT), visual inspection record, ASME International Welding Engineer (IWE) Examination Category E-A, general visual examination of

exterior containment surfac

es from elevations 272-369 VT inspection record and video review, ASME IWE Category E-A, general visual examination of torus below the water line surfaces

For each evaluation, the inspectors verified NDE activities were performed in

accordance with the 2001 Edition, 2003 Addenda, of the ASME Boiler and Pressure

Vessel (BPV) Code requirements. The inspectors also verified the NDE activities met

the requirements contained in ASME Section XI, Mandatory Appendix VIII, Article VIII-2000 and the examination personnel were qualified in accordance with ASME Section XI, Mandatory Appendix VII. The inspectors verified that indications and

defects, if present, were dispositioned in accordance with the ASME Code.

For the general visual examinations, the inspectors ensured that difficult to access areas

or areas made visible by maintenance activities were included within the scope of the visual examination. Additionally, the inspectors verified the basis for declaring some containment areas as inaccessible for visual examination by comparing the basis against previous containment visual examination records.

The inspectors also performed a walk down of the accessible areas of the drywell to independently assess the condition of the drywell liner.

The inspectors reviewed video of the VT, including VT-3, VT-1, and EVT-1; and results

of several components examined in accordance with the licensee's boiling water reactor

vessel and internals project in-vessel visual inspection program. The inspectors verified

the activities were performed in accordance with the licensee's augmented inspection program and associated examination procedure. The inspectors verified indications and defects, if present, were dispositioned in accordance with the licensee's procedures and

NRC requirements.

Re-examination of an Indication Previously Accepted for Service after Analysis

A relevant linear indication was identified in integral attachment weld 24-29-626A pipe support saddle during the previous outage, RFO 21. An analysis was performed and the

indication was accepted for continued service until the RFO 22 refueling outage.

The inspectors reviewed the NDE summary reports for the VT, magnetic particle testing, and liquid penetrant testing for the relevant indication to verify the activities were performed in accordance with the 2001 Edition, 2003 Addenda, of the ASME BPV Code

requirements. The inspectors also reviewed the engineering evaluation to verify the

analysis was consistent with the guidance in ASME Section XI, IWB-3132.3, Acceptance

by Analytical Evaluation.

Modification/Repair/Replacement Consisting of Welding on Pressure Boundary Risk Significant Systems

The inspectors reviewed the welding activity documentation and associated NDE results for the repair of the relevant indication previously identified on the ASME Class 1 main

7 steam system integral attachment weld 24-29-626A. The inspectors verified that the welding, NDE, and acceptance were performed in accordance with the 2001 Edition,

2003 Addenda of the ASME BPV Code requirements and the licensee's repair and replacement program. Specifically, the inspectors verified the welding procedure specification contained the essential, and where applicable, the supplemental essential

variables, in conformance with ASME Section IX, QW-200, and that the weld variables

were within the range qualified by the supporting procedure qualification record as

required by ASME Code Section IX, QW-250.

Identification and Resolution of Problems (IMC 02.05)

The inspectors reviewed a sample of CRs which identified NDE indications, deficiencies,

and other nonconforming conditions since the previous RFO. The inspectors verified

that nonconforming conditions were properly identified, characterized, evaluated, corrective actions identified and dispositioned, and appropriately entered into the CAP.

b. Findings

Introduction. The inspectors identified an unresolved item (URI) during the inspection and concluded that additional information was needed to determine if a performance

deficiency existed and if so, whether the issue is more than minor and/or involves a

violation of regulatory requirements. Specifically, the inspectors noted a discrepancy in

the license renewal application for FitzPatrick and subsequent response to an audit

question regarding the existence and inspection of a moisture barrier in the drywell

between the concrete floor and metal liner.

Description. While evaluating drywell containment examination records, the inspectors reviewed FitzPatrick license renewal documents related to the drywell and identified an

issue for which more information is needed to determine whether there is a performance

deficiency. Specifically, the inspectors noted that NUREG-1905, "Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant," (ML081510826) referenced a drywell floor moisture barrier in Section 3.5.2.1.1.

However, during a drywell walkdown, the inspectors noted that no moisture barrier

existed on the drywell floor between the drywell liner and the concrete floor. The

inspectors further noted that Section 3.5.2.2.1.4 of the initial license renewal application

(ML062160494) submitted in July 2006, described a moisture barrier that was to be inspected as part of the IWE Program and Structures Monitoring Program, and that in Amendment 9 to the license renewal application (ML071060390), an audit question

discussed the moisture barrier condition.

The inspectors noted that this location in the drywell was visually inspected once per period in accordance with the licensee's Fourth Ten-Year Interval Inservice Inspection Program, SEP-ISI-007, and that inspection results have not shown significant liner

degradation. Additionally, the licensee performs augmented UT thickness inspections of

the drywell liner interface in accordance with their augmented inspection program.

In response to the inspectors' concerns, the licensee entered this issue into the CAP as CR-JAF-2017-00906 for further evaluation. For the first corrective action (CA 1) in the CR, the licensee reviewed inspection reports, design requirements, and drawings to

determine whether a moisture barrier previously existed between the containment

drywell liner and containment drywell concrete floor. The licensee concluded on

8 February 16, 2017, that the moisture barrier had never existed in that location. The licensee has a planned corrective action (CA 2) to determine the appropriate actions to

address the apparent discrepancy in information with a due date of May 24, 2017. The inspectors will review the licensee's conclusions and assessment of the issue and independently determine whether there is a performance deficiency and if so, whether

the issue is more than minor and/or involves a violation of regulatory requirements.

Pending resolution, this issue is an URI. (URI 05000333/2017001-01, Drywell Moisture Barrier Description in License Renewal Application)

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11Q - 2 samples)

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed a licensed operator simulator exam on March 22, 2017, which

included an earthquake and unisolable torus leak. The inspectors evaluated operator

performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications,

implementation of actions in response to alarms and degrading plant conditions, and the

oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager

and the TS action statements entered by the crew. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance

problems.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Performance in the Main Control Room

a. Inspection Scope

On January 14, 2017, the inspectors observed control room operators during the reactor

shutdown for RFO 22.

Portions of the reactor shutdown including crew briefs; control rod insertion; removal of the main generator from service; and main turbine, nuclear

instrumentation, and rod worth minimizer testing were observed. The inspectors

observed crew performance to verify that procedure use, crew communications, and coordination of activities between work groups met established expectations and

standards.

b. Findings

No findings were identified.

9 1R12 Maintenance Effectiveness (71111.12Q - 2 samples)

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of

maintenance activities on structure, system, and component performance and reliability.

The inspectors reviewed system health reports, CAP documents, maintenance WOs,

and maintenance rule basis documents to ensure that

the licensee was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the structure, system, or component was properly scoped into the maintenance rule in accordance with Title 10 of the

Code of Federal Regulations (10 CFR) 50.65 and verified that the (a)(2) performance criteria established by licensee staff was reasonable. As applicable, for structures, systems,

and components classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these structures, systems, and components to (a)(2). Additionally, the inspectors ensured that licensee staff was identifying and addressing

common cause failures that occurred within and across maintenance rule system

boundaries.

Main steam isolation valve (MSIV) local leak-rate test results during RFO 22 Residual heat removal service water (RHRSW) keep full service water supply line silt

buildup on January 25, 2017

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the

maintenance and emergent work activities listed below to verify that the licensee

performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that

licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and

that the assessments were accurate and complete. When the licensee performed

emergent work, the inspectors verified that operations personnel promptly assessed and

managed plant risk. The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the station's probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the TS requirements and inspected portions of redundant safety systems,

when applicable, to verify risk analysis assumptions were valid, and applicable

requirements were met.

66UC-22H, east crescent area unit cooler isolation following identification of increased erosion on January 3, 2017 Shutdown risk assessment for risk window 2/3 during RFO 22 on January 18, 2017

10 Outage risk assessment during operation with a potential for draining the reactor vessel (OPDRV) window on January 23, 2017 Outage risk during emergent welding activities (OPDRV) on February 1, 2017 Planned maintenance on the 'A' low pressure coolant injection inverter the week of

March 20, 2017

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15 - 5 samples)

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions based on the risk significance of the associated components and

systems:

CR-JAF-2017-0575 concerning operability of the 'B' source range monitor on

January 26, 2017 CR-JAF-2017-0610 regarding operability of 10AOV68B after failing to fully stroke for surveillance testing on January 26, 2017 EC 69512 concerning RHR strainer functionality during the RFO 22 performance of ST-9CB with a temporary repair installed (before the temporary modification installation) on February 1, 2017 CR-JAF-2017-0848 regarding core cell 38-39 operability with a loose alignment pin and modified fuel support casting on February 7, 2017 CR-JAF-2017-0812 concerning RHR strainer operability with temporary modification installed for operating cycle 23 on February 14, 2017 The inspectors evaluated the technical adequacy of the operability determinations to

assess whether TS operability was properly justified and the subject component or

system remained available such that no unrecognized increase in risk occurred. The

inspectors compared the operability and design criteria in the appropriate sections of the

TSs and UFSAR to the licensee's evaluations to determine whether the components or systems were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures

in place would function as intended and were properly controlled by the licensee.

b. Findings

No findings were identified.

11 1R18 Plant Modifications (71111.18 - 3 samples)

.1 Temporary Modifications

a. Inspection Scope

The inspectors reviewed the temporary modifications listed below to determine whether

the modifications affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance

capability of the affected systems.

Engineering change (EC) 66088, provide isolation between RHRSW and secondary

containment for work on 10MOV-89B on January 31, 2017 EC 69507, temporary RHR suction strainer shells on February 7, 2017

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a permanent modification to replace 10MOV-89B, RHR heat

exchanger 'B' service water outlet isolation valve, implemented by EC 67365, 10 MOV-

89A/B replacement.

The inspectors verified that the design bases, licensing bases, and performance capability of the affected system were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change. The inspectors also reviewed the successfully completed

surveillance test conducted to verify system operability following the valve replacement.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19 - 8 samples)

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed

below to verify that procedures and test activities adequately tested the safety functions

that may have been affected by the maintenance activity, that the acceptance criteria in

the procedure were consistent with the information in the applicable licensing basis and/or design basis documents, and that the test results were properly reviewed and accepted and problems were appropriately documented. The inspectors also walked

down the affected job site, observed the pre-job brief and post-job critique where

possible, confirmed work site cleanliness was maintained, and witnessed the test or

reviewed test data to verify quality control hold points were performed and checked, and that results adequately demonstrated restoration of the affected safety functions.

12 WO 341278, 'B' standby liquid control relief valve replacement on January 21, 2017 WO 52473778, 'C' main steam line isolation valve, 29AOV-80C, actuator

replacement on January 27, 2017 WO 453213, Hydraulic control unit (HCU) 26-23 directional control valve

replacement on January 31, 2017 WO 403664, 'C' safety relief valve replacement on February 9, 2017 WO 396857, fuel cell 38-39 fuel support casting modification on February 9, 2017 WO 52607951, inspections and post-maintenance tests for multiple completed maintenance activities during ST-39H, reactor pressure vessel system leakage test and control rod drive Class 2 piping inservice test, on February 22, 2017 WO 457224,'A' reactor water recirculation pump motor generator voltage regulator

replacement on February 27, 2017 WO 466553, 'A' RHR suction strainer temporary modification installation on

February 10, 2017

b. Findings

No findings were identified.

1R20 Refueling and Other Outage Activities (71111.20 - 1 sample)

a. Inspection Scope

The inspectors reviewed the station's work schedule and outage risk plan for FitzPatrick RFO 22, conducted January 14 through February 25, 2017. The inspectors reviewed the licensee's development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown

and cooldown processes and monitored controls associated with the following outage

activities:

Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable TSs when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated

work or testing Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that

TSs were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by TSs Refueling activities, including fuel handling and 100 percent core verification Fatigue management

13 Tracking of startup prerequisites, walkdown of the drywell (primary containment) to verify that debris had not been left which could block the emergency core cooling system suction strainers, and startup and ascension to full power operation Identification and resolution of problems related to RFO activities

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22 - 8 samples)

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of

selected risk-significant structures, syst

ems, and components to assess whether test results satisfied TSs, the UFSAR, and licensee procedure requirements. The inspectors

verified that test acceptance criteria were clear, tests demonstrated operational

readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied.

Upon test completion, the inspectors considered whether the test results supported that

equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

ST-9BB, Emergency diesel generator 'B' and 'D' full load test and emergency service water pump operability test, on January 11, 2017 ST-1B, MSIV fast closure test (inservice test (IST)), on January 14, 2017 ST-39B-X7B, Type C leak test main steam line B MSIVs (IST), (inboard MSIV, 29AOV-80B), on January 17, 2017 (PCIV) ST-39B-X7B, Type C leak test main steam line B MSIVs (IST), (outboard MSIV, 29AOV-86B), on January 17, 2017 (PCIV) ST-6M, Standby liquid control recirculation injection test (IST), on January 21, 2017 ST-9CB, Emergency diesel generator 'B' and 'D' load sequencing test and 4KV emergency power system voltage relays instrument functional test, on February 2, 2017 ST-2HB, Low pressure coolant injection initiation logic system 'B' and reactor pressure vessel low pressure permissive logic systems 'A' and 'B' functional test, on

February 3, 2017 ST-29F, RPT/ARI logic functional and simulated automatic actuation test, on

February 7, 2017

b. Findings

No findings were identified.

14 2. RADIATION SAFETY

Cornerstone: Occupational and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01 - 4 samples)

a. Inspection Scope

The inspectors reviewed the licensee's performance in assessing and controlling radiological hazards in the workplace. The inspectors used the requirements contained in 10 CFR Part 20, TSs, applicable regulatory guides (RGs), and the procedures

required by TSs as criteria for determining compliance.

Radiological Hazard Assessment (1 sample) The inspectors conducted independent radiation measurements during walkdowns of the

facility and reviewed the radiological survey program, air sampling and analysis,

continuous air monitor use, recent plant radiation surveys for radiological work activities, and any changes to plant operations since the last inspection to verify survey adequacy of any new radiological hazards for onsite workers or members of the public. Instructions to Workers (1 sample)

The inspectors reviewed high radiation area work permit controls and use, and observed containers of radioactive materials and assessed whether the containers were labeled and controlled in accordance with requirements. The inspectors reviewed several occurrences where a worker's electronic personal dosimeter alarmed. The inspectors reviewed the licensee's evaluation of the incidents,

documentation in the CAP, and whether compensatory dose evaluations were

conducted when appropriate. The inspectors verified follow-up investigations of actual radiological conditions for unexpected radiological hazards were performed.

Radiological Hazards Control and Work Coverage (1 sample)

The inspectors evaluated in-plant radiological conditions and performed independent

radiation measurements during facility walkdowns and observation of radiological work activities. The inspectors assessed whether posted surveys; radiation work permits; worker radiological briefings and radiation protection job coverage; the use of continuous

air monitoring, air sampling, and engineering controls; and dosimetry monitoring were

consistent with the present conditions. The inspectors examined the control of highly

activated or contaminated materials stored within the spent fuel pool and the posting and physical controls for selected high radiation areas, locked high radiation areas, and very high radiation areas to verify conformance with the occupational performance indicator.

15 Radiation Worker Performance and Radiation Protection Technician Proficiency (1 sample) The inspectors evaluated radiation worker performance with respect to radiation protection work requirements. The inspectors evaluated radiation protection technicians in performance of radiation surveys and in providing radiological job coverage.

b. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation (71124.03 - 1 sample)

a. Inspection Scope

The inspectors reviewed the control of in-plant airborne radioactivity and the use of

respiratory protection devices in these areas. The inspectors used the requirements in

10 CFR Part 20, RG 8.15, RG 8.25, NUREG/CR-0041, TSs, and procedures required by

TSs as criteria for determining compliance.

Inspection Planning The inspectors reviewed the UFSAR to identify ventilation and radiation monitoring

systems associated with airborne radioactivity controls and respiratory protection

equipment staged for emergency use. The inspectors also reviewed respiratory

protection program procedures and current performance indicators for unintended internal exposure incidents.

Engineering Controls (1 sample)

The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airbor

ne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm setpoints.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment (71124.04 - 1 sample)

a. Inspection Scope

The inspectors reviewed the monitoring, assessment, and reporting of occupational dose. The inspectors used the requirements in 10 CFR Part 20, RGs, TSs, and

procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed radiation protection program audits, National Voluntary Laboratory Accreditation Program dosimetry testing reports, and procedures associated

with dosimetry operations.

16 Source Term Characterization (1 sample)

The inspectors reviewed the plant radiation characterization (including gamma, beta, alpha, and neutron) being monitored. The inspectors verified the use of scaling factors to account for hard-to-detect radionuclides in internal dose assessments.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Unplanned Power Changes (1 sample)

a. Inspection Scope

The inspectors reviewed the licensee's submittals for the Unplanned Power Changes performance indicator for the period of January 1, 2016, through December 31, 2016. To determine the accuracy of the performance indicator data reported during those

periods, inspectors used definitions and guidance contained in Nuclear Energy Institute

(NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline,"

Revision 7. The inspectors reviewed the licensee's operator narrative logs, maintenance

planning schedules, CRs, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Safety System Functional Failures (1 sample)

a. Inspection Scope

The inspectors reviewed the licensee's submittals for the safety system functional failures performance indicator for the period of January 1, 2016, through December 31, 2016. To determine the accuracy of the performance indicator data reported during

those periods, inspectors used definitions and guidance contained in NEI Document 99-

02, Revision 7; and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 10

CFR 50.73." The inspectors reviewed the licensee's operator narrative logs, operability

assessments, CRs, event reports and NRC inte

grated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

17 4OA2 Problem Identification and Resolution (71152 - 2 samples)

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, "Problem Identification and Resolution," the

inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify the licensee entered issues into the CAP at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive

equipment failures and specific human performance issues for follow-up, the inspectors

performed a daily screening of items entered into the CAP and periodically attended CR

screening meetings. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, the licensee performed an

evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified.

.2 Annual Sample: Control Rod Unexpected Insertion to the Full in Position

a. Inspection Scope

The inspectors performed an in-depth review of the licensee's evaluation and corrective actions associated with CR-JAF-2016-01483 for the unexpected insertion of control rod

18-35 to the full in position. The CR documented that on April 24, 2016, while

performing control rod operability testing for fully withdrawn control rods, control rod 18-

35 drifted in from position 48 to 00. Operators entered Abnormal Operating Procedure 27 for a control rod drift and lowered power, ultimately to approximately 60 percent. Maintenance replaced all four directional control valves (DCVs) with new valves and

finger filters on HCU 18-35. Following replacement of the DCVs, control rod 18-35 was

stroke timed per surveillance test ST-20N and inserted to position 46 and withdrawn to

position 48 (full out) with no abnormalities.

The inspectors assessed the licensee's problem identification threshold, problem analysis, extent of condition reviews, compensatory actions, and the prioritization and

timeliness of corrective actions to determine whether the licensee was appropriately

identifying, characterizing, and correcting problems associated with this issue and

whether the planned or completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of the licensee's CAP and 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action." In addition, the inspectors reviewed

documentation associated with this issue, including the apparent cause evaluation and

DCV replacement schedules, and interviewed engineering personnel to assess the

effectiveness of the implemented corrective actions to resolve the issue.

b. Findings and Observations

No findings were identified.

18 The inspectors determined that the licensee took appropriate actions to identify the direct and apparent causes of the issue. The direct cause of the issue was that HCU 18-

35 DCVs failed to fully close when de-energized. The apparent cause was determined

to be the use of a performance-based preventive maintenance (PM) strategy vice a time-based PM replacement for the DCVs. This resulted in a condition that allowed a latent

equipment issue (age-related degradation) to exist that would have been replaced under a time-based PM strategy, resulting in the direct cause of the HCU 18-35 DCVs failing to

fully close when de-energized. The licensee replaced all four DCVs with new valves and

finger filters on HCU 18-35 and stroked control rod 18-35 in a timely manner.

The licensee also performed an extent of condition review for the other control rods in

which the HCU contained DCVs that are greater than 20 years old. The licensee

initiated a corrective action to replace all DCVs greater than 20 years old by RFO 23.

During RFO 22, the licensee replaced 149 DCVs. There are approximately 244 DCVs that will need to be replaced by the end of RFO 23.

The inspectors determined the licensee's overall response to the issue was

commensurate with its safety significance, was timely, and the corrective actions taken and planned were reasonable. Although there was an industry recommendation to

switch to a time-based program for DCV replacement, there was not a reasonable timeframe to replace the DCVs that were older than 20 years before this failure

occurred. Therefore, there was no performance deficiency since the failure was not

reasonably foreseeable and preventable.

.3 Annual Sample: Deferred Corrective Action Recovery

a. Inspection Scope

The inspectors performed a review of the licensee's processes used to recover

corrective action items, including deferred corrective maintenance and permanent modifications, following the decision not to permanently shut down FitzPatrick in January 2017. In addition to confirming the adequacy of the processes used, this inspection was

performed to identify any risk significant systems significantly affected by deferrals to help inform future NRC inspections.

The inspectors reviewed documentation associated with this issue and interviewed performance improvement, maintenance, work planning, and engineering personnel to assess the effectiveness of the implemented processes.

b. Findings and Observations

No findings were identified.

The inspectors determined that the licensee took appropriate actions to recover

corrective action items following the decision not to permanently shut down FitzPatrick.

After Entergy announced the plan to decommission the plant, various corrective actions,

maintenance activities and surveillances were reviewed to determine whether they should continue to be performed or should be deferred or rescheduled until after the permanent shutdown date and ultimately not performed. The licensee had determined

the list of systems which would be required during various phases of decommissioning

to base their scheduling decisions on. Approximately twenty adverse condition

19 corrective actions were approved for extension past the permanent shutdown date. Following the decision to continue plant operation, these items were reassessed for

scheduling. Approximately half of the items have been completed to date. The inspectors determined the remaining items were appropriately scheduled commensurate with their safety significance.

Surveillances and PM tasks were not cancelled or extended past their late dates. The

licensee is working to reestablish more ideal PM scheduling to get back into their

performance indicator target without the use of deep grace (close to late date) periods

for completion.

Permanent modifications were captured in the CAP if required to correct an adverse

condition. System improvement modifications remained listed in the system health

reports, so no process was required to recover them.

The inspectors reviewed the current list of corrective maintenance and key system

health work orders. No risk significant systems were adversely affected by deferrals. The inspectors determined the licensee's process to recover corrective action items

following the decision not to decommission the plant was appropriate.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153 - 1 sample)

(Closed) Licensee Event Report (LER) 05000333/2016-003-00: Simultaneous Opening of Secondary Containment Airlock Doors

On June 7, 2016, personnel inside and outside the secondary containment simultaneously opened both doors to the north reactor building, 272 foot elevation,

secondary containment airlock. TS Surveillance Requirement (SR) 3.6.4.1.3 requires

that one secondary containment access door in each access opening is closed at all

times. Both parties were aware of this requirement, and both withdrew and closed their respective doors within a period of approximately two seconds. However, during the period that both doors were simultaneously open, TS SR 3.6.4.1.3 was not satisfied, and

therefore, secondary containment was inoperable per TS Limiting Condition for

Operation 3.6.4.1. The limiting condition for operation action statement requires that

secondary containment be restored to operable status within four hours. This condition

was met once one of the secondary containment access doors was closed. However, because secondary containment is a single train system, this occurrence was reportable under 10 CFR 50.72 as a condition that at the time of discovery would have prevented

the fulfillment of the secondary containment safety function, even though the condition

existed for less than the TS allowed outage time. The inspectors noted that the subject secondary containment access is equipped with three sets of green and red position indication lights, one set on each entrance to the

airlock and the third set inside the airlock. All the green lights are energized if both

airlock doors are closed. However, if either door is opened, the green lights extinguish

and all the red lights are energized. This scheme functions adequately to alert an

individual preparing to enter an airlock that another individual is already in the process of entering from the other side. However, in the event that both doors are operated simultaneously, the indications for both individuals are as expected for a single door

being opened, and neither recognizes a problem exists until they are positioned to see

the other open door (at which point, it is too late). Therefore, the inspectors determined

20 that this event was not due to a human performance deficiency. Given that secondary containment differential pressure

remained within specification, along with the short duration of the event, the inspectors determined that secondary containment had remained capable of performing its design function throughout the event. Additionally, the issue was reported in a timely manner in accordance with the requirements of

10 CFR 50.72, so it did not constitute a traditional enforcement issue. Because the

failure to comply with TS SR 3.6.4.1.3 was corrected within the allowed outage time, no

violation of regulatory requirements occurred. Cameras and monitors have since been

installed on each side of the secondary containment airlock in question, enabling individuals to verify that the opposing door will not be simultaneously opened. This LER is closed.

4OA5 Other Activities

Temporary Instruction (TI) 2515/192, "Inspection of the Licensee's Interim Measures Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems"

a. Inspection Scope

The objective of this performance-based TI is to verify implementation of interim

compensatory measures associated with an open phase condition (OPC) design

vulnerability in electric power system for operating reactors. The inspectors conducted

an inspection to determine if FitzPatrick had implemented the following interim

compensatory measures. These compensatory measures are to remain in place until permanent automatic detection and protection schemes are installed and declared operable for OPC design vulnerability. The inspectors verified the following:

FitzPatrick had identified and discussed with plant staff the lessons learned from the OPC events at the U.S. operating plants including the Byron Station OPC event and its consequences. This includes conducting operator training for promptly diagnosing, recognizing consequences, and responding to an OPC event.

FitzPatrick had updated plant operating procedures to help operators promptly diagnose and respond to OPC events on offsite power sources credited for safe shutdown of the plant.

FitzPatrick had established and continues to implement periodic walkdown activities to inspect switchyard equipment such as insulators, disconnect switches, and transmission line and transformer connections associated with the offsite power

circuits to detect a visible OPC.

FitzPatrick had ensured that routine maintenance and testing activities on switchyard components have been implemented and maintained. As part of the maintenance and testing activities, FitzPatrick assessed and managed plant risk in accordance

with 10 CFR 50.65(a)(4) requirements.

21 b. Findings and Observations

No findings of significance were identified. The inspectors verified the criteria were met. Information gained from this TI have been provided to the program office for further

review.

4OA6 Meetings, Including Exit

On April 19, 2017, the inspectors presented the inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the FitzPatrick staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this

report.

ATTACHMENT: SUPPLEMENTARY INFORMATION

A-1 Attachment SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Sullivan, Site Vice President

T. Peter, General Manager, Plant Operations

C. Adner, Director, Manager Operations and Regulatory and Performance Improvement D. Bittinger, Manager, Design and Programs Engineering

W. Drews, Manager, Regulatory Assurance

K. Habayeb, Supervisor, Engineering

R. Heath, Manager, Radiation Protection J. Jones, Manager, Emergency Planning

D. Poulin, Director, Engineering

T. Redfearn, Manager, Security

M. Reno, Manager, Training

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened 05000333/2017001-01

URI Drywell Moisture Barrier Description in License Renewal Application (Section 1R08)

Closed 05000333/2016-003-00

05000333/TI 2515/192

LER TI Concurrent Opening of Reactor Building Airlock

Doors (Section 4OA3)

Inspection of the Licensee's Interim

Compensatory Measures Associated with the

Open Phase Condition Design Vulnerabilities in

Electric Power Systems (Section 4OA5)

A-2 LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures AOP-19A, Loss of Switchgear L16, Revision 5

ODSO-4, Shift Turnover and Log Keeping, Revision 118 OP-13, RHR System, Revision 98 OP-13D, RHR - Shutdown Cooling, Revision 30

OP-14, Core Spray System, Revision 37

Condition Report CR-JAF-2017-0396

Drawings FM-20A, Flow Diagram RHR System 10, Revision 72

FM-20B, Flow Diagram RHR System 10, Revision 62 FM-23A, Flow Diagram Core Spray System 14, Revision 49

Section 1R05: Fire Protection

Procedures JAF-RPT-04-00478, JAF Fire Hazards Analysis, Revision 2 JAF-RPT-04-00478, JAF Fire Hazards Analysis, Revision 2 PFP-PWR12, Relay Room Elevation 286' Fire Area VII/Fire Zone RR-1, Revision 5

PFP-PWR20, Reactor Building - East / Elevation 272' Fire Area/Zone IX/RB-1A, Revision 5

PFP-PWR21, Reactor Building - West / Elevation 272' Fire Area/Zone X/RB-1B, Revision 5

PFP-PWR24, Reactor Building - East, Elevation 300' Fire Area/Fire Zone - 8/RB-1C, 9RB-1A, Revision 5 PFP-PWR25, Reactor Building - West, Elevation 300' Fire Area/Fire Zone - X/RB-1B, Revision 3 PFP-PWR45, Turbine Building, Elevation 272', Fire Area/Zone IE/TB-1, Revision 06

PFP-PWR46, Turbine Building, Elevation 272', Fire Area/Zone IE/TB-1, OR-2, Revision 04

PFP-PWR48, Turbine Building, Elevation 300', Fire Area/Zone IE/TB-1, Revision 04

Drawings FPSSK-2, Fire Area/Zone Arrangement Plan El 272'-0", Revision 3

FPSSK-3, Fire Area/Zone Arrangement Plan El 300'-0", Revision 3

Section 1R08: Inservice Inspection

Procedures CEP-NDE-0505, Ultrasonic Thickness Examination, Revision 4 CEP-NDE-0901, VT-1 Examination, Revision 4

PQR 015, Manual Gas Tungsten Arc Welding (GTAW), Revision 1 PQR 024, Manual Gas Tungsten and Shielded Metal Arc Welding (GTAW and SMAW), Revision 1 PRO-ISI-IVVI-0001-GFIT1, Procedure for In-Vessel Visual Inspection (IVVI) of the James A. Fitzpatrick BWR 4 RPV Internals, Revision 2 SEP-ISI-007, ASME Section XI Fourth 10-Year Interval Inservice Inspection Program Plan, Revision 7 SI-UT-130, Procedure for the Phased Array Ultrasonic Examination of Dissimilar Metal Welds, Revision 3

A-3 WPS-CS-1/1-A, Welding Procedure Specification, Revision 0 WPS-CS-1/1-B, Welding Procedure Specification, Revision 0

Condition Reports CR-JAF-2014-04909 CR-JAF-2014-06304 CR-JAF-2014-06884

CR-JAF-2014-07232 CR-JAF-2015-01099 CR-JAF-2015-03000

CR-JAF-2017-00480 CR-JAF-2017-00667 CR-JAF-2017-00706 CR-JAF-2017-00812 CR-JAF-2017-00822 CR-JAF-2017-00906 CR-JAF-2017-00910

Work Order 0039397101, Repair Linear Flaw in ISI Weld 24-29-626A, January 26, 2017

NDE Summary Reports 3036-NTHBIR, Closure Head Vent Nozzle IR, January 22, 2017

ISI-VT-16-012, IWE General Exam RB 272-300, January 23, 2017

ISI-VT-16-013, IWE General Exam RB 300-326, January 23, 2017 ISI-VT-17-017, VT-3 Pressure Retaining Bolting, January 26, 2017

ISI-VT-17-023, VT-3 Torus Supports, January 23, 2017

[[::JAF-RHR-130|JAF-RHR-130]], FitzPatrick DMW RHR 24-10-130, January 29, 2017

[[::JAF-RHR-142|JAF-RHR-142]], FitzPatrick DMW RHR 24-10-142, January 30, 2017

[[::JAF-RHR-144|JAF-RHR-144]], FitzPatrick DMW RHR 24-10-144, January 30, 2017

Miscellaneous J.A. FitzPatrick RO21 Final Report, Fall 2014, Inservice Inspection - FAC, Volume 1 LO-JAFLO-2016-00035, Pre-NRC ISI Snaps

hot Assessment, December 5, 2016 OE-NOE-2015-00096-CA-12, NRC Information Notice 2015-04, Fatigue in Branch Connection Welds, Revision 0 OE-NOE-2016-00145 CA#00012, NRC-RIS-2016-07 Containment Shell or Liner Moisture Barrier Inspection, Revision 0 WPQ-EN-0229-08536, Welding Performance Qualification, December 22, 2016

Section 1R11: Licensed Operator Requalification Program

Procedures OP-65, Startup and Shutdown Procedure, Revision 121 ST-5C, IRM-APRM Instrument Range Overlap Check, completed January 14, 2017

Section 1R12: Maintenance Effectiveness

Procedures

EN-DC-205, Maintenance Rule Monitoring, Revision 6

EN-DC-206, Maintenance Rule (a)(1) Process, Revision 3

Condition Reports CR-JAF-2014-4381 CR-JAF-2015-3924* CR-JAF-2016-0263*

CR-JAF-2016-0324* CR-JAF-2016-0610 CR-JAF-2016-1671*

CR-JAF-2016-2356 CR-JAF-2016-2411* CR-JAF-2016-3831*

CR-JAF-2016-4815*

CR-JAF-2017-0309* CR-JAF-2017-0310* CR-JAF-2017-0501* CR-JAF-2017-0768 CR-JAF-2017-0886* CR-JAF-2017-0920* CR-JAF-2017-0942 CR-JAF-2017-1108* CR-JAF-2017-2033

  • Maintenance Rule Functional Failure Evaluations also reviewed for Condition Reports

A-4 Work Orders

451680 466890

Miscellaneous

JAF-RPT-MST-02480, Maintenance Rule Basis Document System 029 Main Steam, Revision 9

JAF-RPT-MULTI-02294, Maintenance Rule Basi

s Document for Service Water Systems including System 10 (RHRSW), 46 (Normal SW), and 46-ESW (Emergency SW),

Revision 12 Maintenance Rule (a)(1) Action Plan for System 29, February 6, 2017

System Health Report for Main Steam System 3Q-2016

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures AP-10.09, Outage Risk Assessment, Revision 35 AP-10.10, On-Line Risk Assessment, Revision 9 EN-WM-104, On-Line Risk Assessment, Revision 12

ODSO-4, Shift Turnover and Log Keeping, Revision 118

OP-43C, LPCI Independent Power Supply System, Revision 23

Condition Reports (* NRC Identified) CR-JAF-2017-0465*

CR-JAF-2016-4882

Miscellaneous R22 Revision 1 Risk Assessment Based on Schedule, December 29, 2016

Section 1R15: Operability Determinations and Functionality Assessments

Procedures EN-NE-G-0032, BWR Primary System Loose Parts Analysis Considerations, Revision 1 ST-39J, Leak Testing of RHR and Core Spray Testable Check Valves (IST), Revision 18

Condition Reports CR-JAF-2012-6414 CR-JAF-2014-5302 CR-JAF-2017-0610

CR-JAF-2017-0812 CR-JAF-2017-0848 CR-JAF-2017-0851

CR-JAF-2017-0997

Work Orders

00396857

52606738

Drawing FM-20A, Flow Diagram RHR System 10, Revision 47

Miscellaneous ALION-CAL-SI-9389-002, Design Pressure for Strainer "Clamshell" Cover Modules, Revision 2

EC 69400 EC 69507, Temporary RHR suction strainer shells EC 69558, Enlarge alignment slot on fuel support casting for cell location 38-39 to allow for FSC assembly in proper orientation over guide pin in core plate

A-5 EC 69571 [[::JAF-194295-RP01|JAF-194295-RP01]], RHR Strainer Module Repair Report, Revision 0

Section 1R18: Plant Modifications

Procedures EN-DC-117, Post Modification Testing and Special Instructions, Revision 8 ST-2XB, RHR Service Water Loop B Quarterly Operability Test (IST), Revision 13 ST-41D, Remote Valve Position Indication Verification Online (IST), Revision 20

Condition Report (* NRC identified)

2017-2018*

Work Order 00327815

Drawings FM-20B, Flow Diagram Residual Heat Removal System 10, Revision 72

FP-37E, Service Water Piping Reactor Building Sh-5, Revision 22

FP-37F, Service Water Piping Reactor Building Sh-6, Revision 13

Miscellaneous EC 66231, Provide Isolation between RHRSW and Secondary Containment for Work on

10MOV-89A EC 66088, Provide Isolation between RHRSW and Secondary Containment for Work on

10MOV-89B Engineering Change 67365, 10MOV-89A/B Replacement, Revision 0

Section 1R19: Post-Maintenance Testing

Procedures EN-WM-107, Post Maintenance Testing, Revision 5

ESP-68.001, Leak Rate Test of Automatic Depressurization System (ADS) Pneumatic Supply

Check Valves, Revision 5 IMP-02-184.8, Recirculating MG Set Voltage Regulator Tuning**, completed 2/27/17 MP-003.11, HCU Directional Control Valves 03SOV-120 through 123, Revision 18

RAP-7.3.39, Channel-Control Blade Interference Monitoring, completed 2/9/17

ST-2AL, RHR Loop A Quarterly Operability Test (IST), Revision 36

ST-2AM, RHR Loop B Quarterly Operability Test (IST), completed 2/22/17

ST-6HB, Standby Liquid Control B Side Quarterly Operability Test (IST), completed 1/21/17 ST-20N, Control Rod Exercise/Timing/Stall Flow Test, completed 2/4/17

ST-22A, ADS Simulated Automatic Actuation Test, Revision 24

ST-22K, Manual Safety Relief Valve Operation System Test (IST), Revision 5

ST-39B, Type B and C LLRT of Containment Penetrations (IST), Revision 36

ST-39B-X7C, Type C Leak Test Main Steam Line C MSIVs (IST), Revision 15 ST-39H, RPV System Leakage Test and Control Rod Drive Class 2 Piping Inservice Test (ISI)**, Revision 34 ST-43G, Remote Shutdown Panel 25ASP-5 Component Operation and Isolation Verification, Revision 6

Condition Reports CR-JAF-2017-0409 CR-JAF-2017-1501 CR-JAF-2017-1549 CR-JAF-2017-1670 CR-JAF-2017-1676 CR-JAF-2017-1678 CR-JAF-2017-1684 CR-JAF-2017-1686

A-6 CR-JAF-2017-1689 CR-JAF-2017-1694

Work Orders

00341278 00396857 00403664 00453213 00456762 00457224

00465534 00466391 00466553 52607951

Section 1R20: Refueling and Other Outage Activities

Procedures EN-OM-123, Fatigue Management Program, Revision 13

ESP-65.001, Drywell Inspection, Revision 4

ODSO-4, Shift Turnover and Log Keeping, Revision 118 OP-9, Main Turbine, Revision 58 OP-11A, Main Generator, Transformers and Isolated Bus Phase Cooling, Revision 52

OP-13D, RHR-Shutdown Cooling, Revision 29

OP-21, Emergency Service Water (ESW), Revision 38

OP-30A, Refueling Water Level Control, Revision 18 OP-65, Startup and Shutdown Procedure, Revision 121 OSP-66.001, Management of Refueling Activities, Revision 8

RAP-7.4.01, Control Rod Scram Time Evaluation**, Revision 28

ST-2AN, RHR Loop A Monthly Operability Test, Revision 16

ST-2AO, RHR Loop B Monthly Operability Test, Revision 16

ST-24J, RCIC [Reactor Core Isolation Cooling] Flow Rate and Inservice Test (IST), Revision 45 ST-26J, Heatup and Cooldown Temperature Checks, Revision 24 TOP-416, Transferring from A RFP to B RFP While On the Low Flow Control Valve, Revision 0

Condition Reports CR-JAF-2017-0706 CR-JAF-2017-0738 CR-JAF-2017-0812 CR-JAF-2017-0848 CR-JAF-2017-1142 CR-JAF-2017-1146

Miscellaneous System Window Closeout Checklist for 11SLC (1R22-0071), January 22, 2017

System Window Closeout Checklist for 'B' RHR (R22-0022), February 2, 2017

Section 1R22: Surveillance Testing

Procedures CEP-APJ-001, Primary Containment Leakage Rate Testing (10CFR50 Appendix J) Program

Plan, Revision 3 MST-011.11, Standby Liquid Control Explosive Valves (IST), Revision 14 OP-25, Control Rod Drive Hydraulic System, Revision 88

OP-22, Diesel Generator Emergency Power, Revision 61

ST-1B, MSIV Fast Closure Test (IST), Revision 26

ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI), Revision 8

ST-6N, Reverse Closure Test of SLC Injection Line Check Valves (IST), Revision 0 ST-9BB, EDG B and D Full Load Test and ESW Pump Operability Test, Revision 15 ST-9CB, EDG B and D Load Sequencing Test and 4KV Emergency Power System Voltage Relays Instrument Functional Test**, Revision 3 ST-29F, RPT/ARI Logic Functional and Simulated Automatic Actuation Test, Revision 17

ST-39B, Type B and C LLRT of Containment Penetrations (IST), Revision 36 ST-39B-X7B, Type C Leak Test Main Steam Line B MSIVs (IST), Revision 14 ST-43H, Circuit Breaker 10614 Remote Shutdown Operation and Isolation Verification, Revision 11

A-7 Condition Reports CR-JAF-2017-0310 CR-JAF-2017-0425

CR-JAF-2017-1292

Work Orders

52698422

52733249

Drawing FM-21A, Flow Diagram Standby Liquid Control System 11, Revision 37

Miscellaneous Updated FSAR Section 4.6, Main Steam Isolation Valves

Updated FSAR Section 8.6, Emergency AC Power System

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures EN-RP-100, Radiation Worker Expectations, Revision 11

EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 12

EN-RP-102, Radiological Control, Revision 5 EN-RP-105, Radiological Work Permits, Revision 16 EN-RP-106-01, Radiological Survey Guidelines, Revision 3

EN-RP-108, Radiation Protection Posting, Revision 18

EN-RP-121, Radioactive Material Control, Revision 13

EN-RP-141-01, Job Coverage Using Remote Monitoring Technology, Revision 6 EN-RP-152, Conduct of Radiation Protection, Revision 1

Condition Reports CR-JAF-2016-00607 CR-JAF-2016-00650 CR-JAF-2016-04668

CR-JAF-2016-05190 CR-JAF-2017-00627 CR-JAF-2017-00637

RWPs and ALARA Plans RWP ALARA Plan

20170514 17-0514

20170609 17-0609

20170701 17-0701

20170944 17-0944

Surveys [[::JAF-1701-0325|JAF-1701-0325]] [[::JAF-1701-0376|JAF-1701-0376]] [[::JAF-1701-0397|JAF-1701-0397]]

[[::JAF-1701-0455|JAF-1701-0455]] [[::JAF-1701-0495|JAF-1701-0495]] [[::JAF-1701-0520|JAF-1701-0520]]

[[::JAF-1701-0532|JAF-1701-0532]] [[::JAF-1701-0568|JAF-1701-0568]] [[::JAF-1701-0577|JAF-1701-0577]] JAF-1701-0582 [[::JAF-1701-0601|JAF-1701-0601]] [[::JAF-1701-0740|JAF-1701-0740]] JAF-1701-0757 [[::JAF-1701-0639|JAF-1701-0639]] [[::JAF-1701-0659|JAF-1701-0659]]

[[::JAF-1701-0667|JAF-1701-0667]] [[::JAF-1701-0698|JAF-1701-0698]] [[::JAF-1701-0720|JAF-1701-0720]]

[[::JAF-1701-0721|JAF-1701-0721]] [[::JAF-1701-0722|JAF-1701-0722]] [[::JAF-1701-0723|JAF-1701-0723]]

[[::JAF-1701-0724|JAF-1701-0724]] [[::JAF-1701-0725|JAF-1701-0725]] [[::JAF-1701-0726|JAF-1701-0726]] JAF-1701-0732 [[::JAF-1701-0733|JAF-1701-0733]] [[::JAF-1701-0735|JAF-1701-0735]] JAF-1701-0736 [[::JAF-1701-0737|JAF-1701-0737]] [[::JAF-1701-0744|JAF-1701-0744]]

[[::JAF-1701-0752|JAF-1701-0752]] [[::JAF-1701-0778|JAF-1701-0778]] [[::JAF-1701-0789|JAF-1701-0789]]

A-8 [[::JAF-1701-0798|JAF-1701-0798]]

Miscellaneous Air Sample 17106, 17111, 17137, 17139, 17142, 17147, 17150, 17182

Section 2RS3: In-Plant Airborne Radioactivity Control and Mitigation

Procedure EN-RP-131, Air Sampling, Revision 15

Section 4OA2: Problem Identification and Resolution

Procedure EN-LI-118, Cause Evaluation Process, Revision 22

Condition Reports CR-JAF-2010-08458 CR-JAF-2016-01483

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Condition Reports CR-JAF-2015-4146CR-JAF-2016-1996

Section 4OA5: Other Activities

Procedures AOP-72, 115 KV Grid Loss, Instability, or Degradation, Revision 11

OP-44A, 115 KV System, Revision 22

Condition Reports CR-HQN-2012-0847

CR-JAF-2012-1016 CR-JAF-2005-5180

Work Orders

00456356 52692025 52693298

Miscellaneous EC 48543, Provide Open Phase Detection and Protection for 115KV Switchyard - Parent EC, Revision 0 LER 050005333-2005-006-00, Inoperable 115 KV Line in Excess of Technical Specification

Allowed Out of Service Time

A-9 LIST OF ACRONYMS

10 CFR Title 10 of the

Code of Federal Regulations ASME American Society of Mechanical Engineers

BPV boiler and pressure vessel

CAP corrective action program CR condition report DCV directional control valve

EC engineering change

HCU hydraulic control unit

IMC Inspection Manual Chapter IST inservice test IWE International Welding Engineer

LER licensee event report

MSIV main steam isolation valve

NDE non-destructive examination NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission

OPC open phase condition

OPDRV operation with a potential for draining the reactor vessel

PM preventive maintenance

RFO refuel outage RG regulatory guide RHR residual heat removal

RHRSW residual heat removal service water

RPV reactor pressure vessel

SR surveillance requirement TI temporary instruction TS technical specification

UFSAR Updated Final Safety Analysis Report

URI unresolved item

UT ultrasonic testing

VT visual testing WO work order