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| issue date = 05/09/2018
| issue date = 05/09/2018
| title = Integrated Inspection Report 05000220/2018001 and 05000410/2018001
| title = Integrated Inspection Report 05000220/2018001 and 05000410/2018001
| author name = Catts M P
| author name = Catts M
| author affiliation = NRC/RGN-I/DRP/PB1
| author affiliation = NRC/RGN-I/DRP/PB1
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000220, 05000410
| docket = 05000220, 05000410
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406
{{#Wiki_filter:UNITED STATES May 9, 2018
-2713 May 9, 2018 Mr. Bryan Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555


SUBJECT: NINE MILE POINT NUCLEAR STATION
==SUBJECT:==
- INTEGRATED INSPECTION REPORT 05000220/2018001 AND 05000 410/20 18001
NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2018001 AND 05000410/2018001


==Dear Mr. Hanson:==
==Dear Mr. Hanson:==
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
, and other members of your staff. The results of this inspection are documented in the enclosed report. No NRC-identified or self
-revealing findings were identified during this inspection.


This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading
No NRC-identified or self-revealing findings were identified during this inspection.
-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Sincerely,/RA/ Michelle P. Catts , Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Numbers: 50-220 and 50-410 License Numbers: DPR-63 and NPF
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 Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.
-69  
 
Sincerely,
/RA/
Michelle P. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Numbers: 50-220 and 50-410 License Numbers: DPR-63 and NPF-69


===Enclosure:===
===Enclosure:===
Inspection Report 05000220/2018001 and 05000410/2018001 cc w/encl:
Inspection Report 05000220/2018001 and 05000410/2018001
Distribution via ListServ


ML18129A297 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME EMiller per telecon ARosebrook MCatts DATE 5/4/18 5/7/18 5/9/18 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF
==Inspection Report==
-69 Report Number s: 05000220/2018001 and 05000410/2018001 Enterprise Identifier:
Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2018001 and 05000410/2018001 Enterprise Identifier: I-2018-001-0046 Licensee: Exelon Generation Company, LLC (Exelon)
I-20 18-001-0046 Licensee: Exelon Generation Company, LLC (Exelon)
Facility: Nine Mile Point Nuclear Station, LLC (NMPNS)
Facility: Nine Mile Point Nuclear Station, LLC (NMPNS)
Units 1 and 2 Location: Oswego, New York Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors:
Units 1 and 2 Location: Oswego, New York Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: E. Miller, Senior Resident Inspector B. Sienel, Resident Inspector G. Stock, Resident Inspector, James A. FitzPatrick Nuclear Power Plant R. Rolph, Health Physicist Approved By: M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure
E. Miller, Senior Resident Inspector B. Sienel, Resident Inspector G. Stock, Resident Inspector, James A. FitzPatrick Nuclear Power Plant R. Rolph, Health Physicist Approved By:
M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects
 
2


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at


Exelon's performance at NMPNS Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
NMPNS Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.


Additiona l Tracking Item s  Type Issue number Title Report Section Status LER 05000220/2017-00 3 Automatic Reactor Scram due to Reactor Vessel Low Water Level 71153 Closed URI 05000220/2018001
Additional Tracking Items Type     Issue number             Title                           Report       Status Section LER     05000220/2017-003        Automatic Reactor Scram         71153        Closed due to Reactor Vessel Low Water Level URI     05000220/2018001-01       Potential Failure to Submit an 71111.20      Open 8-Hour Event Notification for a Valid Actuation of HPCI URI     05000410/2018001-02       Potential Inadequate 50.59     71111.18    Open Evaluation for TS 3.3.1.1 Bases Change
-01 Potential Failure to Submit an 8-Hour Event Notification for a Valid Actuation of HPCI 71111.20 Open URI 05000410/2018001
-02 Potential Inadequate 50.59 Evaluation for TS 3.3.1.1 Bases Change 7111 1.18  Open 3


=PLANT STATUS=
=PLANT STATUS=


Unit 1 began the inspection period at or near rated thermal power. On March 17, 2018, operators reduced reactor power to 12 percent and inserted a planned manual reactor scram for a planned maintenance outage.
Unit 1 began the inspection period at or near rated thermal power. On March 17, 2018, operators reduced reactor power to 12 percent and inserted a planned manual reactor scram for a planned maintenance outage. On March 19, 2018, operators commenced a reactor startup and raised Unit 1 to rated thermal power. On March 20, 2018, operators reduced reactor power to 70 percent to perform a control rod pattern adjustment. Unit 1 was restored to rated thermal power on March 21, 2018. On March 24, 2018, operators reduced power to 70 percent to perform a rod pattern adjustment. On March 25, 2018, operators restored reactor power to rated thermal power. Unit 1 remained at or near rated thermal for the remainder of the inspection period.


On March 19, 2018, operators commenced a reactor startup and raised Unit 1 to rated thermal power. On March 20, 2018, operators reduced reactor power to 70 percent to perform a control rod pattern adjustment. Unit 1 was restored to rated thermal power on March 21, 2018. On March 24, 2018, operators reduced power to 70 percent to perform a rod pattern adjustment. On March 25, 2018, operators restored reactor power to rated thermal power. Unit 1 remained at or near rated thermal for the remainder of the inspection period.
Unit 2 began the inspection period at or near rated thermal power. On February 2, 2018, operators reduced reactor power to 75 percent to perform a rod pattern adjustment. Operators restored power to rated thermal power on February 3, 2018. On February 24, 2018, operators reduced reactor power to 75 percent to perform turbine valve testing and a control rod pattern adjustment. On February 25, 2018, operators restored reactor power to rated thermal power.


Unit 2 began the inspection period at or near rated thermal power. On February 2, 2018 , operators reduced reactor power to 75 percent to perform a rod pattern adjustment. Operators restored power to rated thermal power on February 3, 2018
On March 22, 2018, Unit 2 began coastdown, after reaching the maximum power achievable due to fuel depletion as Unit 2 was at the end of this operating cycle. At the end of the inspection period Unit 2 was at 98 percent power. The maximum power will continue to decrease (coastdown) until the refueling outage, which is planned for the second quarter of
. On February 24, 2018, operators reduced reactor power to 75 percent to perform turbine valve testing and a control rod pattern adjustment. On February 25, 2018, operators restored reactor power to rated thermal power. On March 22, 2018
, Unit 2 began coastdown, after reaching the maximum power achievable due to fuel depletion as Unit 2 was at the end of this operating cycle. At the end of the inspection period Unit 2 was at 98 percent power. The maximum power will continue to decrease (coastdown) until the refueling outage, which is planned for the second quarter of  


==INSPECTION SCOPE==
==INSPECTION SCOPES==
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
-rm/doc-collections/insp
-manual/inspection
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light
-Water Reactor Inspection Program - Operations Phase.The inspectors performed plant status activities described in IMC 2515 Appendix D, "Plant Status" and conducted routine reviews using IP 71152, "Problem Identification and Resolution.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


==REACTOR SAFETY==
==REACTOR SAFETY==


==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection     Impending Severe Weather==
 
{{IP sample|IP=IP 71111.01|count=2}}
Impending Severe Weather (2 Sample s)
: (1) The inspectors evaluated readiness for impending severe weather conditions prior to heavy lake effect snow and high winds on January 4, 2018.
: (1) The inspectors evaluated readiness for impending severe weather conditions prior to heavy lake effect snow and high winds on January 4, 2018.
: (2) The inspectors evaluated readiness for impending severe weather conditions prior to heavy lake effect snow and high winds on January 12, 2018.
: (2) The inspectors evaluated readiness for impending severe weather conditions prior to heavy lake effect snow and high winds on January 12, 2018.


==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment   Partial Walkdown==
{{IP sample|IP=IP 71111.04|count=5}}


Partial Walkdown (5 Samples)  The inspectors evaluated system configuration s during partial walkdowns of the following systems/trains
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
:
: (1) Unit 1 11 emergency condenser (EC) on January 25, 2018
: (1) Unit 1 11 emergency condenser (EC)on January 25, 2018
: (2) Unit 1 12 liquid poison system following surveillance testing on January 29, 2018
: (2) Unit 1 12 liquid poison system following surveillance testing on January 29, 2018
: (3) Unit 2 high pressure core spray (HPCS) during reactor core isolation cooling (RCIC) planned maintenance on February 6, 2018
: (3) Unit 2 high pressure core spray (HPCS) during reactor core isolation cooling (RCIC)planned maintenance on February 6, 2018
: (4) Unit 2 'A' standby gas treatment (SBGT) system while 'B' SBGT system out of service for planned maintenance on March 6, 2018
: (4) Unit 2 A standby gas treatment (SBGT) system while B SBGT system out of service for planned maintenance on March 6, 2018
: (5) Unit 1 shutdown cooling on March 17, 2018
: (5) Unit 1 shutdown cooling on March 17, 2018


==71111.05A/Q - Fire Protection Annual/Quarterly==
==71111.05A/Q - Fire Protection Annual/Quarterly   Quarterly Inspection==
{{IP sample|IP=IP 71111.05A/Q|count=9}}


Quarterly Inspection (9 Samples)  The inspectors evaluated fire protection program implementation in the following selected areas:
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Unit 1 reactor building (RB) 261 foot elevation, fire area (FA) 1 on January 11, 2018
: (1) Unit 1 reactor building (RB) 261 foot elevation, fire area (FA) 1 on January 11, 2018
: (2) Unit 1 turbine building (TB)277 foot elevation, hydrogen seal oil skid, FA 5 on January 29, 2018
: (2) Unit 1 turbine building (TB) 277 foot elevation, hydrogen seal oil skid, FA 5 on January 29, 2018
: (3) Unit 2 RB 175 foot elevation, HPCS pump room, FA 4 on February 6, 2018
: (3) Unit 2 RB 175 foot elevation, HPCS pump room, FA 4 on February 6, 2018
: (4) Unit 2 RB 175 foot elevation, low pressure core spray (LPCS) pump room, FA 1 on February 6, 2018
: (4) Unit 2 RB 175 foot elevation, low pressure core spray (LPCS) pump room, FA 1 on February 6, 2018
: (5) Unit 2 RB 175 foot elevation, 'B' residual heat removal (RHR) pump room, FA 3 on February 6, 2018
: (5) Unit 2 RB 175 foot elevation, B residual heat removal (RHR) pump room, FA 3 on February 6, 2018
: (6) Unit 2 diesel building (DB) 261 foot elevation, Division I diesel generator, FA 28 on March 27, 2018
: (6) Unit 2 diesel building (DB) 261 foot elevation, Division I diesel generator, FA 28 on March 27, 2018
: (7) Unit 2 DB 261 foot elevation, Division II diesel generator, fire zone FA 29 on March 27, 2018
: (7) Unit 2 DB 261 foot elevation, Division II diesel generator, fire zone FA 29 on March 27, 2018
: (8) Unit 2 DB 261 foot elevation, HPCS diesel generator, FA 30 on March 27, 2018
: (8) Unit 2 DB 261 foot elevation, HPCS diesel generator, FA 30 on March 27, 2018
: (9) Unit 2 DB 261 foot elevation, Division 1 diesel generator control room , FA 28 on March 27, 2018  Annual Inspection (1 Sample)  The inspectors evaluated Unit 2 fire brigade performance during an actual event that involved a fire at a non-safety related moisture separator reheater pressure control valve on February 1, 2018
: (9) Unit 2 DB 261 foot elevation, Division 1 diesel generator control room, FA 28 on
.


==71111.07 - Heat Sink Performance==
===March 27, 2018    Annual Inspection (1 Sample)===
The inspectors evaluated Unit 2 fire brigade performance during an actual event that involved a fire at a non-safety related moisture separator reheater pressure control valve on February 1, 2018.


Heat Sink (1 Sample)  The inspectors evaluated Exelon's monitoring and maintenance of Unit 2 'B' RHR heat exchanger performance on February 8, 2018.
==71111.07 - Heat Sink Performance    Heat Sink==
{{IP sample|IP=IP 71111.07|count=1}}


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
The inspectors evaluated Exelons monitoring and maintenance of Unit 2 B RHR heat exchanger performance on February 8, 2018.


Operator Requalification (2 Sample s)
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance    Operator Requalification==
{{IP sample|IP=IP 71111.11|count=2}}
: (1) The inspectors observed a Unit 1 simulator evaluation that involved the loss of an electrical bus (PB 1671A), the trip of a turbine building closed loop cooling pump with the failure of the standby pump to automatically start, and loss of coolant accident on January 30, 2018
: (1) The inspectors observed a Unit 1 simulator evaluation that involved the loss of an electrical bus (PB 1671A), the trip of a turbine building closed loop cooling pump with the failure of the standby pump to automatically start, and loss of coolant accident on January 30, 2018
: (2) The inspectors observed a Unit 2 simulator evaluation that involved the loss of an instrument air compressor, the failure of a service water pump, the failure of an electro
: (2) The inspectors observed a Unit 2 simulator evaluation that involved the loss of an instrument air compressor, the failure of a service water pump, the failure of an electro-hydraulic control system pressure control valve, and a loss of coolant accident on
-hydraulic control system pressure control valve, and a loss of coolant accident on February 6, 2018 Operator Performance (2 Sample s)
 
===February 6, 2018   Operator Performance (2 Samples)===
: (1) The inspectors observed Unit 1 operations personnel during a transfer from the mechanical pressure regulator to the electronic pressure regulator during motor generator (MG) set 167 planned maintenance on February 22, 2018, and during a reactor shutdown for a planned maintenance outage on March 17, 2018
: (1) The inspectors observed Unit 1 operations personnel during a transfer from the mechanical pressure regulator to the electronic pressure regulator during motor generator (MG) set 167 planned maintenance on February 22, 2018, and during a reactor shutdown for a planned maintenance outage on March 17, 2018
: (2) The inspectors observed Unit 2 operations personnel during a downpower to 75 percent for a control rod pattern adjustment on February 2 and 3, 2018
: (2) The inspectors observed Unit 2 operations personnel during a downpower to 75 percent for a control rod pattern adjustment on February 2 and 3, 2018


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness    Routine Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12|count=2}}


Routine Maintenance Effectiveness (2 Samples)  The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
: (1) Unit 2 instrument air compressors on March 27, 2018
: (1) Unit 2 instrument air compressors on March 27, 2018
: (2) Unit 2 turbine building sumps week of March 29, 2018
: (2) Unit 2 turbine building sumps week of March 29, 2018
Line 128: Line 117:
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=9}}
{{IP sample|IP=IP 71111.13|count=9}}
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) Unit 2 planned 'F' service water pump and motor replacement on January 23, 2018
: (1) Unit 2 planned F service water pump and motor replacement on January 23, 2018
: (2) Unit 2 planned Division 2 unit cooler 2HVY*UC2B thermal performance testing on January 30, 2018
: (2) Unit 2 planned Division 2 unit cooler 2HVY*UC2B thermal performance testing on January 30, 2018
: (3) Unit 2 planned RCIC maintenance on February 6, 2018
: (3) Unit 2 planned RCIC maintenance on February 6, 2018
Line 137: Line 127:
: (7) Unit 2 failure of 2SFC*HV6A, spent fuel pool cooling suction cross connection valve on March 7, 2018
: (7) Unit 2 failure of 2SFC*HV6A, spent fuel pool cooling suction cross connection valve on March 7, 2018
: (8) Unit 1 planned 12 reactor recirculation pump seal flush on March 13, 2018
: (8) Unit 1 planned 12 reactor recirculation pump seal flush on March 13, 2018
: (9) Unit 2 planned 'B' reserve station transformer maintenance on March 26, 2018
: (9) Unit 2 planned B reserve station transformer maintenance on March 26, 2018


==71111.15 - Operability Determinations and Functionality==
==71111.15 - Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15|count=7}}


Assessments (7 Samples)  The inspectors evaluated the following operability determinations and functionality assessments:
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) Unit 1 EDG 103 low governor oil level on January 8, 2017
: (1) Unit 1 EDG 103 low governor oil level on January 8, 2017
: (2) Unit 2 RCIC operability during maintenance on an associated room cooler on January 22, 2018
: (2) Unit 2 RCIC operability during maintenance on an associated room cooler on January 22, 2018
Line 147: Line 138:
: (4) Unit 2 RCIC due to governor valve steam leak on February 8, 2018
: (4) Unit 2 RCIC due to governor valve steam leak on February 8, 2018
: (5) Unit 2 Three element feedwater level control system following unexpected reactor water level transient on February 9, 2018
: (5) Unit 2 Three element feedwater level control system following unexpected reactor water level transient on February 9, 2018
: (6) Unit 2 HPCS pipe integrity based on operating experience related to the use of Style 'CG' Flexitallic gaskets on February 22, 2018
: (6) Unit 2 HPCS pipe integrity based on operating experience related to the use of Style CG Flexitallic gaskets on February 22, 2018
: (7) Unit 2 step change in reactor recirculation 'B' seal temperatures following a downpower on February 26, 2018
: (7) Unit 2 step change in reactor recirculation B seal temperatures following a downpower on February 26, 2018


==71111.18 - Plant Modifications==
==71111.18 - Plant Modifications==
{{IP sample|IP=IP 71111.18|count=2}}
{{IP sample|IP=IP 71111.18|count=2}}
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) Procedure Change Request (PCR)-17-03717, Unit 2 Procedure Change to N2
: (1) Procedure Change Request (PCR)-17-03717, Unit 2 Procedure Change to N2-OSP-RPS-Q001, RPS Turbine Stop Valve (TSV) Closure Logic, Control Valve Fast Closure Scram Functional Tests and Turbine Valve Cycling on February 12, 2018 (Permanent Modification)
-OSP-RPS-Q001, RPS Turbine Stop Valve (TSV) Closure Logic, Control Valve Fast Closure Scram Functional Tests and Turbine Valve Cycling on February 12, 2018 (Permanent Modification)
: (2) Action Request (AR) 04044602-02, Unit 2 TS 3.3.1.1 Bases Change for Turbine Stop Valve and main steam isolation valve (MSIV) Testing on February 28, 2018 (Permanent Modification)
: (2) Action Request (AR) 04044602-02, Unit 2 TS 3.3.1.1 Bases Change for Turbine Stop Valve and main steam isolation valve (MSIV) Testing on February 28, 2018 (Permanent Modification)


==71111.19 - Post Maintenance Testing==
==71111.19 - Post Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=6}}
{{IP sample|IP=IP 71111.19|count=6}}
The inspectors evaluated the following post maintenance tests:
The inspectors evaluated the following post maintenance tests:
: (1) Unit 1 11 shutdown cooling pump breaker preventive maintenance on January 11, 2018
: (1) Unit 1 11 shutdown cooling pump breaker preventive maintenance on January 11, 2018
Line 165: Line 157:
: (4) Unit 2 spent fuel pool cooling pump suction cross connect valve, SFC*HV6A, corrective maintenance on March 13, 2018
: (4) Unit 2 spent fuel pool cooling pump suction cross connect valve, SFC*HV6A, corrective maintenance on March 13, 2018
: (5) Unit 1 11 feedwater low flow control valve on March 17, 2018
: (5) Unit 1 11 feedwater low flow control valve on March 17, 2018
: (6) Unit 1 MSIV 01
: (6) Unit 1 MSIV 01-01 following packing replacement on March 18, 2018
-01 following packing replacement on March 18, 2018


==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==
{{IP sample|IP=IP 71111.20|count=1}}
{{IP sample|IP=IP 71111.20|count=1}}
: (1) The inspectors evaluated Unit 2 N2R16 pre-outage activities during the first quarter of 2018 (Partial sample)
: (1) The inspectors evaluated Unit 2 N2R16 pre-outage activities during the first quarter of 2018 (Partial sample)
: (2) The inspectors evaluated Unit 1 planned maintenance outage activities from March 17 , 2018 through March 20, 2018
: (2) The inspectors evaluated Unit 1 planned maintenance outage activities from March 17, 2018 through March 20, 2018


==71111.22 - Surveillance Testing==
==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:   Routine==
 
{{IP sample|IP=IP 71111.22|count=5}}
The inspectors evaluated the following surveillance tests:
: (1) N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test, on February 5, 2018
Routine (5 Samples)
: (1) N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test , on February 5, 2018
: (2) N1-ST-M1B, Liquid Poison Pump 12 Operability Test, on March 6, 2018
: (2) N1-ST-M1B, Liquid Poison Pump 12 Operability Test, on March 6, 2018
: (3) N1-ST-Q1D, CS 122 Pump and Valve Operability Test, on March 12, 2018
: (3) N1-ST-Q1D, CS 122 Pump and Valve Operability Test, on March 12, 2018
: (4) N1-ST-V3, Rod Worth Minimizer Operability Test Average Power Range Monitor/Intermediate Range Monitor Overlap Verification on March 19, 2018
: (4) N1-ST-V3, Rod Worth Minimizer Operability Test Average Power Range Monitor/Intermediate Range Monitor Overlap Verification on March 19, 2018
: (5) N1-PM-V7, Turbine Trip Test s, on March 20, 2018 I nservice (2 Samples)
: (5) N1-PM-V7, Turbine Trip Tests, on March 20, 2018
: (1) N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and American Society of Mechanical Engineers XI Functional Test and Analysis
 
, on February 8, 2018
===Inservice (2 Samples)===
: (2) N2-OSP-EGS-M@002, Diesel Generator and Diesel Start Valve Operability Test , Division III
: (1) N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and American Society of Mechanical Engineers XI Functional Test and Analysis, on February 8, 2018
, on February 28, 2018 Reacto r Coolant System Leak Detection (1 Sample)
: (2) N2-OSP-EGS-M@002, Diesel Generator and Diesel Start Valve Operability Test, Division III, on February 28, 2018
: (1) CY-NM-170-341, Primary Containment Sampling and Analysis, Unit 1, on January 25, 2018


==71114.06 - Drill Evaluation==
===Reactor Coolant System Leak Detection (1 Sample)===
: (1) CY-NM-170-341, Primary Containment Sampling and Analysis, Unit 1, on        January 25, 2018


Training Evolution (2 Samples
==71114.06 - Drill Evaluation Training Evolution==
)
{{IP sample|IP=IP 71114.06|count=2}}
: (1) The inspectors observed a Unit 1 simulator evaluation that involved the loss of an electrical bus (PB 1671A), the trip of a turbine building closed loop cooling pump with the failure of the standby pump to automatically start, and a loss of coolant accident on January 30, 2018
: (1) The inspectors observed a Unit 1 simulator evaluation that involved the loss of an electrical bus (PB 1671A), the trip of a turbine building closed loop cooling pump with the failure of the standby pump to automatically start, and a loss of coolant accident on January 30, 2018
: (2) The inspectors observed a Unit 2 simulator evaluation that involved the loss of an instrument air compressor, the failure of a service water pump, the failure of an electro
: (2) The inspectors observed a Unit 2 simulator evaluation that involved the loss of an instrument air compressor, the failure of a service water pump, the failure of an electro-hydraulic control system pressure control valve, and a loss of coolant accident on February 6,
-hydraulic control system pressure control valve, and a loss of coolant accident on February 6, 2018 RADIATION SAFET Y
 
==RADIATION SAFETY==


==71124.06 - Radioactive Gaseous and Liquid Effluent Treatment==
==71124.06 - Radioactive Gaseous and Liquid Effluent Treatment   Walkdowns and Observations==
{{IP sample|IP=IP 71124.06|count=1}}


Walkdowns and Observations (1 Sample)
The inspectors walked down the gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design.
The inspectors walked down the gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design
.
Calibration and Testing Program (Process and Effluent Monitors)
(1 Sample)
The inspectors evaluated Exelon's gaseous and liquid effluent monitor instrument calibration and testing.


Sampling and Analyses (1 Sample)
Calibration and Testing Program (Process and Effluent Monitors) (1 Sample)
The inspectors evaluated Exelons gaseous and liquid effluent monitor instrument calibration and testing.
 
===Sampling and Analyses (1 Sample)===
The inspectors evaluated radioactive effluent sampling and analysis activities.
The inspectors evaluated radioactive effluent sampling and analysis activities.


Instrumentation and Equipment (1 Sample)
===Instrumentation and Equipment (1 Sample)===
The inspectors reviewed radioactive effluent discharge system surveillance test results and reviewed the methodology used to determine the radioactive effluent stack and vent flow rates based on Technical Specifications/Off Site Dose Calculation Manual (TS/ODCM) acceptance criteria.
The inspectors reviewed radioactive effluent discharge system surveillance test results and reviewed the methodology used to determine the radioactive effluent stack and vent flow rates based on Technical Specifications/Off Site Dose Calculation Manual (TS/ODCM)acceptance criteria.


Dose Calculations (1 Sample)
===Dose Calculations (1 Sample)===
The inspectors reviewed several liquid and gaseous discharge permits to evaluate public dose calculations (monthly, quarterly, and annual) and the annual radiological effluent release reports for 2015 and 2016
The inspectors reviewed several liquid and gaseous discharge permits to evaluate public dose calculations (monthly, quarterly, and annual) and the annual radiological effluent release reports for 2015 and


==OTHER ACTIVITIES==
==OTHER ACTIVITIES - BASELINE==
- BASELINE  71151 - Performance Indicator Verification (5 Samples)  The inspectors verified Exelon's performance indicator submittals listed below:
 
: (1) Units 1 and 2, Reactor Coolant System Leakage
===71151 - Performance Indicator Verification ===
, from January 1, 2017 through December 31, 2017
{{IP sample|IP=IP 71151|count=5}}
The inspectors verified Exelons performance indicator submittals listed below:
: (1) Units 1 and 2, Reactor Coolant System Leakage, from January 1, 2017 through December 31, 2017
: (2) Units 1 and 2, Reactor Coolant System Specific Activity from January 1, 2017 through December 31, 2017
: (2) Units 1 and 2, Reactor Coolant System Specific Activity from January 1, 2017 through December 31, 2017
: (3) Site Radiological Effluent TS/ODCM Radiological Effluent Occurrences from October 1, 2016 through December 31, 2017
: (3) Site Radiological Effluent TS/ODCM Radiological Effluent Occurrences from October 1, 2016 through December 31, 2017


==71152 - Problem Identification and Resolution==
==71152 - Problem Identification and Resolution   Annual Follow-up of Selected Issues==
{{IP sample|IP=IP 71152|count=1}}


Annual Follow
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
-up of Selected Issue s (1 Sample)  The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
: (1) Issue Report (IR) 04049445, Unit 1 - September 6, 2017 scram due to lowering reactor water level when the feedwater level control system experienced a failure of a feedwater flow/steam flow error signal input.
: (1) Issue Report (IR) 04049445 , Unit 1 - September 6, 2017 scram due to lowering reactor water level when the feedwater level control system experienced a failure of a feedwater flow/steam flow error signal input.


71153 - Follow-up of Events and Notices of Enforcement Discretion Events (1 Sample)  The inspectors evaluated response to the following event:
===71153 - Follow-up of Events and Notices of Enforcement Discretion     Events ===
: (1) Unit 2 - Notice of Unusual Event declaration for a fire in the turbine building on February 1, 2018  Licensee Event Reports (1 Sample)  The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx
{{IP sample|IP=IP 71153|count=1}}
:
The inspectors evaluated response to the following event:
: (1) Licensee Event Report (LER)05000220/2017
: (1) Unit 2 - Notice of Unusual Event declaration for a fire in the turbine building on
-00 3 , Automatic Reactor Scram due to Reactor Vessel Low Water Level , on September 6, 2017.


See Section 71152 for additional details.
===February 1, 2018    Licensee Event Reports (1 Sample)===
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
: (1) Licensee Event Report (LER) 05000220/2017-003, Automatic Reactor Scram due to Reactor Vessel Low Water Level, on September 6, 2017. See Section 71152 for additional details.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Unresolved Item (URI) 05000 22 0/ 2018001-01  (Open) Potential Failure to Submit an 8
Unresolved Item Potential Failure to Submit an 8-Hour Event                   71111.20 (URI)          Notification for a Valid Actuation of HPCI               Refueling and 05000220/                                                                  Other Outage 2018001-01                                                                  Activities (Open)
-Hour Event Notification for a Valid Actuation of HPCI 71111.20 Refueling and Other Outage Activities Description
:  On March 18, 2018
, at 1:18 a.m., during the Unit 1 maintenance outage while the unit was in cold shutdown, operators received multiple low level alarms on the GEMAC 11 and 12 level indications. Operators responded by adjusting reactor water cleanup reject flow and the feedwater minimum flow control valve to raise reactor water level. Upon the operators making the adjustment to reactor water level, the feedwater low flow control valve was slow to respond, but eventually opened more rapidly, and the increased flow from feedwater resulted in a rapid rise in reactor water level. At 1:28 a.m., indicated reactor water level rose to the 95
-inch trip setpoint for the 11 and 12 Yarway level indication instruments, resulting in a turbine trip and HPCI initiation signal. The HPCI pumps were tagged out and thus did not inject, and the turbine was offline for the shutdown.


The 11 and 12 Yarway level indication instruments provide reactor protection system logic inputs for reactor vessel water level; however, the Yarway level indication instruments are not density compensated. Therefore , under cold shutdown conditions, actual reactor ves sel water level was lower than indicated water level on the 11 and 12 Yarways
=====Description:=====
. During cold shutdown conditions
On March 18, 2018, at 1:18 a.m., during the Unit 1 maintenance outage while the unit was in cold shutdown, operators received multiple low level alarms on the GEMAC 11 and 12 level indications. Operators responded by adjusting reactor water cleanup reject flow and the feedwater minimum flow control valve to raise reactor water level. Upon the operators making the adjustment to reactor water level, the feedwater low flow control valve was slow to respond, but eventually opened more rapidly, and the increased flow from feedwater resulted in a rapid rise in reactor water level. At 1:28 a.m., indicated reactor water level rose to the 95-inch trip setpoint for the 11 and 12 Yarway level indication instruments, resulting in a turbine trip and HPCI initiation signal. The HPCI pumps were tagged out and thus did not inject, and the turbine was offline for the shutdown.
, the GEMAC level instruments
, which are calibrated to cold shutdown conditions
, provide an accurate indication of actual reactor vessel water level. The GEMAC instruments both indicated well below the trip setpoint of 95 inches (indicated ~72 inches)when the turbine trip and HPCI initiation signal were received. Exelon determined that this event was not reportable under 10 CFR 50.72.


Title 10 CFR 50.72(b)(3)(iv)(A) states, "Any event or condition that results in valid actuation of any of the systems listed in paragraph (b)(3)(iv)(B) of this section, except when the actuation results from and is part of a pre
The 11 and 12 Yarway level indication instruments provide reactor protection system logic inputs for reactor vessel water level; however, the Yarway level indication instruments are not density compensated. Therefore, under cold shutdown conditions, actual reactor vessel water level was lower than indicated water level on the 11 and 12 Yarways. During cold shutdown conditions, the GEMAC level instruments, which are calibrated to cold shutdown conditions, provide an accurate indication of actual reactor vessel water level. The GEMAC instruments both indicated well below the trip setpoint of 95 inches (indicated ~72 inches) when the turbine trip and HPCI initiation signal were received. Exelon determined that this event was not reportable under 10 CFR 50.72.
-planned sequence during testing or reactor operation.


  (B) The systems to which the requirements of paragraph (b)(3)(iv)(A) of this section apply are:
Title 10 CFR 50.72(b)(3)(iv)(A) states, Any event or condition that results in valid actuation of any of the systems listed in paragraph (b)(3)(iv)(B) of this section, except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation.
 
(B) The systems to which the requirements of paragraph (b)(3)(iv)(A) of this section apply are:
: (5) BWR reactor core isolation cooling system; isolation condenser system; and feedwater coolant injection system.
: (5) BWR reactor core isolation cooling system; isolation condenser system; and feedwater coolant injection system.


Planned Closure Action(s): The inspectors requested the 10 CFR 50.72 subject matter experts at the Office of Nuclear Reactor Regulation (NRR) and Office of General Council (OGC) to review whether this was a valid actuation and thus reportable. The inspectors are opening an unresolved item (URI)to determine if a performance deficiency exists.
Planned Closure Action(s): The inspectors requested the 10 CFR 50.72 subject matter experts at the Office of Nuclear Reactor Regulation (NRR) and Office of General Council (OGC) to review whether this was a valid actuation and thus reportable. The inspectors are opening an unresolved item (URI) to determine if a performance deficiency exists.


Licensee Action(s): Licensee entered the concern into their corrective action program, and communicated with NRC Region I and NRR Staff.
Licensee Action(s): Licensee entered the concern into their corrective action program, and communicated with NRC Region I and NRR Staff. Exelons position is that the event was not reportable.


Exelon's position is that the event was not reportable
Corrective Action Reference: IR 04116336 NRC Tracking Number: 05000220/2018001-01 URI         Potential Inadequate 50.59 Evaluation for TS 3.3.1.1           71111.18 05000410/      Bases Change                                                  Plant 2018001-02                                                                      Modifications (Open)
. Corrective Action Reference
: IR 04116336 NRC Tracking Number:
05000 220/2018001-01 URI 05000410/ 2018001-02 (Open) Potential Inadequate 50.59 Evaluation for TS 3.3.1.1 Bases Change 71111.18 Plant Modifications Description
:  On February 23, 2018, Exelon personnel performed a 50.59 Screening for a change to Unit 2 TS Bases 3.3.1.1 , Reactor Protection System (RPS) Instrumentation
, for MSIV and TSV surveillance testing. Exelon personnel performed this activity to address operating experience associated with the use of a test box that prevents a scram signal during RPS surveillance testing for TS 3.3.1.1 Function 5 MSIV
- Closure and Function 8 TSV
- Closure.


TS Bases B 3.3.1.1, C.1, Revision 1 was revised to state, in part, "For Function 5 (MSIV
=====Description:=====
- Closure), this would require both trip systems to have at least one channel associated with the MSIVs for each main steam line in one Trip Logic Channel (not necessarily the same main steam lines for both trip systems), Operable or in trip (or the associated trip system in trip). For Function 8 (Turbine Stop Valve
On February 23, 2018, Exelon personnel performed a 50.59 Screening for a change to Unit 2 TS Bases 3.3.1.1, Reactor Protection System (RPS) Instrumentation, for MSIV and TSV surveillance testing. Exelon personnel performed this activity to address operating experience associated with the use of a test box that prevents a scram signal during RPS surveillance testing for TS 3.3.1.1 Function 5 MSIV - Closure and Function 8 TSV -
- Closure), this would require both trip systems to have the channels for one Trip Logic Channel, Operable or in trip (or the associated trip system in trip)."    The inspectors questioned whether the change to TS Bases B 3.3.1.1 resulted in a change to the implementation of TS 3.3.1.1
Closure.
. A licensee is permitted to make changes to their Technical Specification Bases documents without NRC review and approval. However, in certain cases, such as a change to the Technical Specification Bas e s that would change how the associate d Technical Specification is applied, NRC review and approval would be required.


Planned Closure Action(s):  The inspectors sent written questions to request assistance from NRR to determine whether this change to the TS Bases reasonably would have required NRC review and approval. The inspectors are opening a URI to determine if this is violation of 10 CFR 50.59 and if it is more than minor.
TS Bases B 3.3.1.1, C.1, Revision 1 was revised to state, in part, For Function 5 (MSIV -
Closure), this would require both trip systems to have at least one channel associated with the MSIVs for each main steam line in one Trip Logic Channel (not necessarily the same main steam lines for both trip systems), Operable or in trip (or the associated trip system in trip).


Licensee Action: Documented NRC's concern as AR 04055602. Exelon's position is the change would not affect how TS 3.3.1.1 , or its note
For Function 8 (Turbine Stop Valve - Closure), this would require both trip systems to have the channels for one Trip Logic Channel, Operable or in trip (or the associated trip system in trip).
, is applied and therefore NRC review was not required.


Corrective Action Reference
The inspectors questioned whether the change to TS Bases B 3.3.1.1 resulted in a change to the implementation of TS 3.3.1.1. A licensee is permitted to make changes to their Technical Specification Bases documents without NRC review and approval. However, in certain cases, such as a change to the Technical Specification Bases that would change how the associated Technical Specification is applied, NRC review and approval would be required.
:  AR 04055602  NRC Tracking Number:
05000410/2018001-02  Observations and Minor Violations 71152 A Problem Identification and Resolution The inspectors performed a review of IR 04049445 to review Exelon's cause evaluation associated with a Unit 1 reactor scram on low reactor water level on September 6, 2017. The inspectors also reviewed Exelon's Post Transient Review, operating procedures, drawings, Control Room Logs, sequence of events recorder data, plant computer data, and conducted interviews with Exelon staff.


The inspectors identified two performance deficiencies that were determined to be minor in accordance with IMC 0612, Appendix B, Issue Screening, associated with Exelon's Post Transient Review. The purpose of a Post Transient Review is to make a prompt determination if plant equipment responded as designed and that plant operators responded appropriately to the transient or event and any potential non
Planned Closure Action(s): The inspectors sent written questions to request assistance from NRR to determine whether this change to the TS Bases reasonably would have required NRC review and approval. The inspectors are opening a URI to determine if this is violation of 10 CFR 50.59 and if it is more than minor.
-conforming conditions identified.
: (1) OP-AA-108-114, Post Transient Review, Revision 13, Section E "Safety Assessment," Criteria 10 states "High level isolation(s)" with a check box for either "Yes" or "No."  During the inspectors review
, it was identified through review of plant computer data and drawings that Nine Mile Point Unit 1 received an expected signal for a feedwater pump trip on high reactor water level at 95 inches. The inspectors found that operators performing the Post Transient Review in accordance with OP
-AA-108-114 made a determination that the feedwater pump trip on high reactor water level was not considered an isolation.


The inspectors determined that the procedure lacked clarity in providing operators a means to determine if the plant responded in accordance with its design basis. The inspectors determined that although operators did not accurately check the box "Yes" that the feedwater pump high reactor water level trip occurred, it did not result in any consequence to the plants operation following the Post Transient Review; and it was determined that the trip did function as expected, therefore this performance deficiency for an inadequate procedure is minor.
Licensee Action: Documented NRCs concern as AR 04055602. Exelons position is the change would not affect how TS 3.3.1.1, or its note, is applied and therefore NRC review was not required.
: (2) The inspectors also reviewed IR 04050697, which documented a question from the inspectors following the reactor scram on September 6, 2017
, concerning feedwater computer point s becoming erratic just prior to the Unit 1 reactor scram. Exelon subsequently performed additional evaluation, and was able to show that the failure of the computer points were unrelated to the cause of the scram, which was the failure of the feedwater flow/steam flow mismatch card. Exelon determined the computer point failures to be related to maintenance being performed on a power supply that failed in the turbine performance calculation cabinet under work order C93638038. The inspectors agreed with this conclusion.


The inspectors determined that Exelon failed to establish documentation to support or refute a potential cause in accordance with Procedure MA-AA-716-004, Conduct of Troubleshooting, Revision 15, as part of Section 4.5 for "Simple Troubleshooting."  The result was a failure to provide the cause evaluation team enough information to assess the issue for a potential cause. Specifically, Procedure PI-AA-125-1003, Corrective Action Program Evaluation Manual Section 4.3.5 states that "investigators should gather information and data relating to the event."  The inspectors found that this potential failure was not explored under the Simple Troubleshooting process for establishing a "failure mode/cause table," and subsequently resulted in the inspectors questioning if this should have been evaluated by the cause evaluation team. This showed that the depth of investigation was inadequate to ensure all potential causes associated with a potential scram were explored. The inspectors determined the performance deficiency for failure to follow Procedures MA-AA-716-004 and PI-AA-125-1003 is minor because following the inspectors' questions, Exelon was able to provide additional information to refute relationship to the cause of the scram
Corrective Action Reference: AR 04055602 NRC Tracking Number: 05000410/2018001-02 Observations and Minor Violations                              71152 A Problem Identification and Resolution The inspectors performed a review of IR 04049445 to review Exelons cause evaluation associated with a Unit 1 reactor scram on low reactor water level on September 6, 2017. The inspectors also reviewed Exelons Post Transient Review, operating procedures, drawings, Control Room Logs, sequence of events recorder data, plant computer data, and conducted interviews with Exelon staff.
. Observations and LER Closure 71153  Follow-up of Events and Notices of Enforcement Discretion LER 05000220/2017
-003, Automatic Reactor Scram due to Reactor Vessel Low Water Level, on September 6, 2017
. Exelon determined the root cause of the Unit 1 event was an equipment failure associated with a power supply within the proportional amplifier PAM-ID23E, which is part of the three element feedwater control system. This failure was not within Exelon's ability to foresee and prevent; therefore, there was no performance deficiency associated with the instrument failure. The inspectors did not identify any findings associated with this event.


This LER is closed.
The inspectors identified two performance deficiencies that were determined to be minor in accordance with IMC 0612, Appendix B, Issue Screening, associated with Exelons Post Transient Review. The purpose of a Post Transient Review is to make a prompt determination if plant equipment responded as designed and that plant operators responded appropriately to the transient or event and any potential non-conforming conditions identified.
: (1) OP-AA-108-114, Post Transient Review, Revision 13, Section E Safety Assessment, Criteria 10 states High level isolation(s) with a check box for either Yes or No. During the inspectors review, it was identified through review of plant computer data and drawings that Nine Mile Point Unit 1 received an expected signal for a feedwater pump trip on high reactor water level at 95 inches. The inspectors found that operators performing the Post Transient Review in accordance with OP-AA-108-114 made a determination that the feedwater pump trip on high reactor water level was not considered an isolation. The inspectors determined that the procedure lacked clarity in providing operators a means to determine if the plant responded in accordance with its design basis. The inspectors determined that although operators did not accurately check the box Yes that the feedwater pump high reactor water level trip occurred, it did not result in any consequence to the plants operation following the Post Transient Review; and it was determined that the trip did function as expected, therefore this performance deficiency for an inadequate procedure is minor.
: (2) The inspectors also reviewed IR 04050697, which documented a question from the inspectors following the reactor scram on September 6, 2017, concerning feedwater computer points becoming erratic just prior to the Unit 1 reactor scram. Exelon subsequently performed additional evaluation, and was able to show that the failure of the computer points were unrelated to the cause of the scram, which was the failure of the feedwater flow/steam flow mismatch card. Exelon determined the computer point failures to be related to maintenance being performed on a power supply that failed in the turbine performance calculation cabinet under work order C93638038. The inspectors agreed with this conclusion.


==EXIT MEETING S AND DEBRIEFS==
The inspectors determined that Exelon failed to establish documentation to support or refute a potential cause in accordance with Procedure MA-AA-716-004, Conduct of Troubleshooting, Revision 15, as part of Section 4.5 for Simple Troubleshooting. The result was a failure to provide the cause evaluation team enough information to assess the issue for a potential cause. Specifically, Procedure PI-AA-125-1003, Corrective Action Program Evaluation Manual Section 4.3.5 states that investigators should gather information and data relating to the event. The inspectors found that this potential failure was not explored under the Simple Troubleshooting process for establishing a failure mode/cause table, and subsequently resulted in the inspectors questioning if this should have been evaluated by the cause evaluation team. This showed that the depth of investigation was inadequate to ensure all potential causes associated with a potential scram were explored. The inspectors determined the performance deficiency for failure to follow Procedures MA-AA-716-004 and PI-AA-125-1003 is minor because following the inspectors questions, Exelon was able to provide additional information to refute relationship to the cause of the scram.
The inspectors verified no proprietary information was retained or documented in this report
.


On April 25, 2018, the inspector s presented the quarterly resident inspection results to Mr. Pete r Orphanos, Site Vice President , and other members of the Exelon staff.
Observations and LER Closure                                  71153 Follow-up of Events and Notices of Enforcement Discretion LER 05000220/2017-003, Automatic Reactor Scram due to Reactor Vessel Low Water Level, on September 6, 2017. Exelon determined the root cause of the Unit 1 event was an equipment failure associated with a power supply within the proportional amplifier PAM-ID23E, which is part of the three element feedwater control system. This failure was not within Exelons ability to foresee and prevent; therefore, there was no performance deficiency associated with the instrument failure. The inspectors did not identify any findings associated with this event. This LER is closed.
 
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
* On April 25, 2018, the inspectors presented the quarterly resident inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the Exelon staff.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


71111.01 Procedures
71111.01
Procedures
N1-OP-64, Meteorological Monitoring, Revision 01700
N1-OP-64, Meteorological Monitoring, Revision 01700
N2-OP-102, Meteorological Monitoring, Revision 02200
N2-OP-102, Meteorological Monitoring, Revision 02200
71111.04 Pr ocedures C-18018-C, Reactor Shutdown Cooling Piping &
71111.04
Instrumentation Diagram, Revision 32
Procedures
C-18018-C, Reactor Shutdown Cooling Piping & Instrumentation Diagram, Revision 32
N1-OP-4, Shutdown Cooling System, Revision 04600
N1-OP-4, Shutdown Cooling System, Revision 04600
N 1-OP-13, Emergency Cooling System, Revision 04100
N1-OP-13, Emergency Cooling System, Revision 04100
N1-PM-Q9, Lubrication of Plant Equipment, Revision
N1-PM-Q9, Lubrication of Plant Equipment, Revision 01600
01600 N1-ST-Q8B, Liquid Poison Pump 12 and Check Valve Operability Test, Revision 01200
N1-ST-Q8B, Liquid Poison Pump 12 and Check Valve Operability Test, Revision 01200
N 2-OP-33, High Pressure Core Spray System, Revision 01500
N2-OP-33, High Pressure Core Spray System, Revision 01500
N2-OP-33, Lineups, High Pressure Core Spray System, Revision 00100
N2-OP-33, Lineups, High Pressure Core Spray System, Revision 00100
N2-OP-61B, Standby Gas Treatment System, Revision 01500
N2-OP-61B, Standby Gas Treatment System, Revision 01500
N2-OP-61B, Lineups, Standby Gas Treatment System  
N2-OP-61B, Lineups, Standby Gas Treatment System - Lineups, Revision 00100
- Lineups, Revision 00100
Issue Reports
Issue Reports 02016743  02051624 02052658 0 2700451  Drawing C-18017-C, Sheet 1, Emergency Cooling System Piping & Instrumentation
2016743            02051624             02052658             02700451
Diagram, Revision 56 71111.05 Procedures
Drawing
N1-P FP-0101, Unit 1 Pre
C-18017-C, Sheet 1, Emergency Cooling System Piping & Instrumentation Diagram,
-Fire Plans, Revision 00500
Revision 56
N2-FPI-PFP-0201, Unit 2 Pre
71111.05
-Fire Plans, Revision 5
Procedures
N1-PFP-0101, Unit 1 Pre-Fire Plans, Revision 00500
N2-FPI-PFP-0201, Unit 2 Pre-Fire Plans, Revision 5
N2-FPM-FPE-A001, Maintenance and Inspection, Portable Fire Extinguishers, Revision 01500
N2-FPM-FPE-A001, Maintenance and Inspection, Portable Fire Extinguishers, Revision 01500
N2-PFP-DG261-2, Division I Diesel Generator
N2-PFP-DG261-2, Division I Diesel Generator-261 Elevation, Revision 01
-261' Elevation, Revision 01
N2-PFP-DG261-3, Division II Diesel Generator-261 Elevation, Revision 01
N2-PFP-DG261-3, Division II Diesel Generator
N2-PFP-DG261-4, HPCS Diesel Generator-261 Elevation, Revision 01
-261' Elevation, Revision 01
N2-PFP-DG261-4, HPCS Diesel Generator
-261' Elevation, Revision 01
OP-AA-201-009, Control of Transient Combustibles, Revision 20
OP-AA-201-009, Control of Transient Combustibles, Revision 20
OP-NM-201-005, Firefighting, Revisio
OP-NM-201-005, Firefighting, Revision 00200
n 00200  Issue Reports
Issue Reports
04099955 04099960 Miscellaneous
04099955       04099960
Miscellaneous
DCD-805, Nine Mile Point Unit 1 NFPA 805 Design Criteria, Revision 1
DCD-805, Nine Mile Point Unit 1 NFPA 805 Design Criteria, Revision 1
Unit 2 UFSAR Section 9, Revision 22
Unit 2 UFSAR Section 9, Revision 22
71111.07A Procedure N2-TTP-RHS-4Y002, Residual Heat Removal System Heat Exchanger (2RHS*E1B)
71111.07A
Procedure
N2-TTP-RHS-4Y002, Residual Heat Removal System Heat Exchanger (2RHS*E1B)
Performance Monitoring (Suppression Pool Cooling Mode), Revision 00300
Performance Monitoring (Suppression Pool Cooling Mode), Revision 00300
Work Order
Work Order
C90813331
C90813331
71111.11 Procedures
71111.11
Procedures
N1-OP-31, Tandem Compound Reheat Turbine, Revision 04700
N1-OP-31, Tandem Compound Reheat Turbine, Revision 04700
N1-OP-43C, Plant Shutdown, Revision 02400
N1-OP-43C, Plant Shutdown, Revision 02400
N2-OP-101D, Power Changes, Revision 02500
N2-OP-101D, Power Changes, Revision 02500
Miscellaneous
Miscellaneous
2100-SIMEVLS03B, EVL
2100-SIMEVLS03B, EVL-3 DMS-RL3 Evaluated Scenario 2, January 12, 2018
-3 DMS-RL3 Evaluated Scenario 2, January 12, 2018
Reactivity Maneuver Plan NM2C16-15, Control Rod Pattern Change, approved
Reactivity Maneuver Plan NM2C16
January 30, 2018
-15, Control Rod Pattern Change, approv
71111.12
ed January 30, 2018 71111.12 Procedures
Procedures
Maintenance Rule a(1) Action Plan for NMP 2
Maintenance Rule a(1) Action Plan for NMP 2-IAS-F01(A) [IR 02697332], Revisions 0, 1, and 2
-IAS-F01(A) [IR 02697332], Revisions 0, 1, and 2
Maintenance Rule a(1) Determination for 2-IAS-F01(A) [IR 02697332], dated August 4, 2016
Maintenance Rule a(1)
Maintenance Rule System Basis Document for NMP 2 Instrument Air (IAS) on March 3, 2018
Determination for 2
Maintenance Rule Functional Failure Evaluations for IRs
-IAS-F01(A) [IR 02697332], dated August 4, 2016
2509894            02638306             02639296             02673914     02693332
Maintenance Rule System Basis Document for NMP 2 Instrument Air (IAS) on March
03965289             04038793             04042841             04044296     04051369
3, 2018 Maintenance Rule Functio nal Failure Evaluations for IRs 02509894  02638306 02639296 02673914 02693332 03965289 04038793 04042841 04044296 04051369 04052532 04096304 04105106 04116231 71111.13 Procedures
04052532             04096304             04105106             04116231
71111.13
Procedures
N1-OP-1, Nuclear Steam Supply System, Revision 07300
N1-OP-1, Nuclear Steam Supply System, Revision 07300
N1-SOP-21.1, Fire In
N1-SOP-21.1, Fire In Plant, Revision 01401
Plant, Revision 01401
N2-OP-38, Spent Fuel Pool Cooling and Cleanup System, Revision 02400
N2-OP-38, Spent Fuel Pool Cooling and Cleanup System, Revision 02400
N2-OP-58, Screenwell Building and Fire Pump Rooms Ventilation Systems, Revision 00402
N2-OP-58, Screenwell Building and Fire Pump Rooms Ventilation Systems, Revision 00402
N2-PRA-006, Nine Mile Point Unit 2 Probabilistic Risk Assessment Dependency Matrix Notebook, Revision 1
N2-PRA-006, Nine Mile Point Unit 2 Probabilistic Risk Assessment Dependency Matrix
Notebook, Revision 1
OP-AA-108-117, Protected Equipment Program, Revision 005
OP-AA-108-117, Protected Equipment Program, Revision 005
OP-NM-102-106, Operator Response Time Program at Nine Mile Point, Revision 7
OP-NM-102-106, Operator Response Time Program at Nine Mile Point, Revision 7
OP-NM-108-117, Protected Equipment Program at Nine Mile Point, Revision 05000
OP-NM-108-117, Protected Equipment Program at Nine Mile Point, Revision 05000
Issue Report
Issue Report
0411 2080  Miscellaneous
04112080
Maintenance Rule Basis Document for NMPNS 2 Screenwell Building Ventilation , viewed February 26, 2018
Miscellaneous
71111.15 Procedures
Maintenance Rule Basis Document for NMPNS 2 Screenwell Building Ventilation, viewed
February 26, 2018
71111.15
Procedures
N2-EOP-HC, EOP Hard Cards Procedure, Revision 00800
N2-EOP-HC, EOP Hard Cards Procedure, Revision 00800
N2-OP-29, Reactor Recirculation System, Revision 02700
N2-OP-29, Reactor Recirculation System, Revision 02700
Line 379: Line 360:
N2-SOP-02, Station Blackout/Extended Loss of AC Power Support Procedure, Revision 001100
N2-SOP-02, Station Blackout/Extended Loss of AC Power Support Procedure, Revision 001100
N2-SOP-29.1, Reactor Recirculation Pump Seal Failure, Revision 00500
N2-SOP-29.1, Reactor Recirculation Pump Seal Failure, Revision 00500
NMP-2-2018-0055, Risk Assessment ODM for 1/2
NMP-2-2018-0055, Risk Assessment ODM for 1/2-inch Reactor Level Step [Increase], Revision 0
-inch Reactor Level Step [Increase], Revision 0
 
Issue Reports
Issue Reports
2040819 04056662 04092089 04092221 04095919 04102652 04102837   Drawings 0005321052005H, 2.5
2040819             04056662           04092089             04092221
-inch through 4
04095919             04102652           04102837
-inch Swing
Drawings
Check Valve Bolted Bonnet Forged, Revision H.00 PID-33A, Piping & Instrumentation Diagram High Pressure Core Spray System, Revision 18
0005321052005H, 2.5-inch through 4-inch Swing Check Valve Bolted Bonnet Forged,
PID-33B, Piping &
Revision H.00
Instrumentation Diagram High Pressure Core Spray
PID-33A, Piping & Instrumentation Diagram High Pressure Core Spray System, Revision 18
System, Revision 15
PID-33B, Piping & Instrumentation Diagram High Pressure Core Spray System, Revision 15
PID-35A, Piping & Instrumentation
PID-35A, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 17
Diagram Reactor Core Isolation Cooling, Revision 17
PID-35B, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 15
PID-35B, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 15
PID-35C, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 29
PID-35C, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 29
Miscellaneous
Miscellaneous
NRC Inspection Report 05000397/2017008, "Columbia Generating Station  
NRC Inspection Report 05000397/2017008, Columbia Generating Station - NRC Special
- NRC Special Inspection Report"
Inspection Report
71111.18 Procedure N2-OSP-RPS-Q001, RPS Turbine Stop Valve Closure Logic, Control Valve Fast Closure Scram Functional Tests and
71111.18
Turbine Valve Cycling, Revision 00700
Procedure
Drawings 0007.225-001-007, Elementary Diagram Reactor Protection System, Revision 8
N2-OSP-RPS-Q001, RPS Turbine Stop Valve Closure Logic, Control Valve Fast Closure Scram
Functional Tests and Turbine Valve Cycling, Revision 00700
Drawings
0007.225-001-007, Elementary Diagram Reactor Protection System, Revision 8
0007.225-001-008, Elementary Diagram Reactor Protection System, Revision 8
0007.225-001-008, Elementary Diagram Reactor Protection System, Revision 8
0007.225-001-009, Elementary Diagram Reactor Protection System, Revision 9
0007.225-001-009, Elementary Diagram Reactor Protection System, Revision 9
Line 406: Line 387:
0007.225-001-013, Elementary Diagram Reactor Protection System, Revision 3
0007.225-001-013, Elementary Diagram Reactor Protection System, Revision 3
Miscellaneous
Miscellaneous
04044602-02/Revision to Unit 2 Bases B3.3.1.1, Unit 2 PCR-17-03717, Eliminated Two TSV Stroking, Need to Bypass RCS EOC
04044602-02/Revision to Unit 2 Bases B3.3.1.1, Unit 2
-RPT Channels and Low Power TT Bypass of All Four Channels At The Same Time, Revision 1
PCR-17-03717, Eliminated Two TSV Stroking, Need to Bypass RCS EOC-RPT Channels and
71111.19 Procedures
Low Power TT Bypass of All Four Channels At The Same Time, Revision 1
71111.19
Procedures
CC-AA-201, Plant Barrier Control Program, Revision 011
CC-AA-201, Plant Barrier Control Program, Revision 011
CC-NM-201-1001, Plant Barrier Control Program Implementation, Revision 0
CC-NM-201-1001, Plant Barrier Control Program Implementation, Revision 0
N1-OP-4, Shutdown Cooling System, Revision 04600
N1-OP-4, Shutdown Cooling System, Revision 04600
N2-OSP-ICS-Q001, RCIC Valve Operability Test, Revision 00600 N2-OSP-SFC-Q001, Spent Fuel Pool Cooling Cleanup Pump and Valve Operability Test, Revision 00700
N2-OSP-ICS-Q001, RCIC Valve Operability Test, Revision 00600
N2-OSP-SFC-Q001, Spent Fuel Pool Cooling Cleanup Pump and Valve Operability Test,
Revision 00700
S-EPM-GEN-063, MOV Diagnostic Testing, Revision 01000
S-EPM-GEN-063, MOV Diagnostic Testing, Revision 01000
Issue Reports
Issue Reports
04082313 04082686 04112080 Work Orders
04082313     04082686     04112080
C92753269 C93013263 C3098917 C93607398 C93658702 C93659934
Work Orders
C92753269             C93013263           C3098917             C93607398
C93658702             C93659934
Miscellaneous
Miscellaneous
N2-CRM-008, Technical Specification 3.0.9 Evaluation of Residual Heat Removal Division I and II Pump Room Barrier Penetrations to Support Maintenance, Revision 0
N2-CRM-008, Technical Specification 3.0.9 Evaluation of Residual Heat Removal Division I and
71111.20 Procedures
II Pump Room Barrier Penetrations to Support Maintenance, Revision 0
ER-AA-370-1002, Review of Reactor Pressure Vessel Pressure
71111.20
-Temperature Limit Curves, Revision 0
Procedures
ER-AA-370-1002, Review of Reactor Pressure Vessel Pressure-Temperature Limit Curves,
Revision 0
MA-AA-796-024, Scaffold Installation, Inspection, and Removal, Revision 11
MA-AA-796-024, Scaffold Installation, Inspection, and Removal, Revision 11
N1-OP-4, Shutdown Cooling System, Revision 04600
N1-OP-4, Shutdown Cooling System, Revision 04600
N1-OP-43A, Plant Startup, Revision 04700
N1-OP-43A, Plant Startup, Revision 04700
N1-OP-43C, Plant Shutdown, Revision 02400
N1-OP-43C, Plant Shutdown, Revision 02400
N2-FHP-014, Movement of New Fuel and Control Rod Blades into the Spent Fuel Pool, Revision 01200
N2-FHP-014, Movement of New Fuel and Control Rod Blades into the Spent Fuel Pool,
Revision 01200
N2-FHP-026, Moving Fuel and Blade Guides within the Spent Fuel Pool, Revision 00500
N2-FHP-026, Moving Fuel and Blade Guides within the Spent Fuel Pool, Revision 00500
S-MMP-FHP-100, Receiving, Inspection, and Storage of New Fuel, Revision 01300
S-MMP-FHP-100, Receiving, Inspection, and Storage of New Fuel, Revision 01300
Drawings C-23093-C, Sheet 3, Interconnection Diagram Auxiliary Control Cabinet IS60, Revision 16
Drawings
C-23093-C, Sheet 3, Interconnection Diagram Auxiliary Control Cabinet IS60, Revision 16
C-23091-C, Sheet 3, Interconnection Diagram Auxiliary Control Cabinet IS59, Revision 23
C-23091-C, Sheet 3, Interconnection Diagram Auxiliary Control Cabinet IS59, Revision 23
Miscellaneous
Miscellaneous
Adverse Condition Monitoring and Contingency Plan (ACMP) for Unit 1 Unidentified Leak Rate (IR 04058998), Revision 5
Adverse Condition Monitoring and Contingency Plan (ACMP) for Unit 1 Unidentified Leak Rate
      (IR 04058998), Revision 5
ACMP for Unit 1 12 Recirculation Pump Seal Pressures (IR 04085756), Revision 0
ACMP for Unit 1 12 Recirculation Pump Seal Pressures (IR 04085756), Revision 0
Reactivity Maneuver Plan NM1C23
Reactivity Maneuver Plan NM1C23-SU-1, approved March 6, 2018
-SU-1, approved March 6, 2018
71111.22
71111.22 Procedures
Procedures
CY-NM-170-341, Primary Containment Sampling and Analysis, Unit 1, Revision 3
CY-NM-170-341, Primary Containment Sampling and Analysis, Unit 1, Revision 3
ER-AB-331-1006, BWR Reactor Coolant System Leakage Monitoring and Action Plan, Revision 2 N1-PM-V7, Turbine Trip Tests, Revision 00800
ER-AB-331-1006, BWR Reactor Coolant System Leakage Monitoring and Action Plan,
Revision 2
N1-PM-V7, Turbine Trip Tests, Revision 00800
N1-ST-M1B, Liquid Poison Pump 12 Operability Test, Revision 01100
N1-ST-M1B, Liquid Poison Pump 12 Operability Test, Revision 01100
N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test, Revision 01900
N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test, Revision 01900
N1-ST-Q1D, CS 122 Pump and Valve Operability Test, Revision 01800
N1-ST-Q1D, CS 122 Pump and Valve Operability Test, Revision 01800
N1-ST-V3, Rod Worth Minimizer Operability Test APRM/IRM Overlap Verification, Revision 01301
N1-ST-V3, Rod Worth Minimizer Operability Test APRM/IRM Overlap Verification,
N2-OSP-EGS-M@002, Diesel Generator and Diesel Start Valve Operability Test  
Revision 01301
- Division III, Revision 02001
N2-OSP-EGS-M@002, Diesel Generator and Diesel Start Valve Operability Test - Division III,
N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and ASME XI Functional Test and Analysis, Revision 01400
Revision 02001
N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and
ASME XI Functional Test and Analysis, Revision 01400
Issue Reports
Issue Reports
4109552  04111549 04111560 04111970 04114129 04114298 04114374 Work Orders
04109552            04111549             04111560             04111970     04114129
C93588959 C93595862 C93597294 C93599399 C93607235 C93625379
04114298             04114374
71124.06 Procedures
Work Orders
C93588959           C93595862             C93597294           C93599399
C93607235           C93625379
71124.06
Procedures
CY-AA-110-200, Sampling, Revision 13
CY-AA-110-200, Sampling, Revision 13
CY-NM-170-370, Emergency Condenser Shell Sampling and Analysis, Revision 1
CY-NM-170-370, Emergency Condenser Shell Sampling and Analysis, Revision 1
Line 461: Line 461:
N2-CSP-RMS-M350, Noble Gas Dose Rate and Dose Calculations, Revision 00401
N2-CSP-RMS-M350, Noble Gas Dose Rate and Dose Calculations, Revision 00401
N2-CSP-RMS-M351, Particulate, Iodine, and Tritium Dose Calculations, Revision 00500
N2-CSP-RMS-M351, Particulate, Iodine, and Tritium Dose Calculations, Revision 00500
N2-RSP-RMS-R113, Channel Calibration Test of the Service Water Effluent Line Process Radiation Monitors 2SWP*CAB146A and 2SWP*CAB146B, Revision 00800
N2-RSP-RMS-R113, Channel Calibration Test of the Service Water Effluent Line Process
N2-RSP-RMS-R103, Channel Calibration
Radiation Monitors 2SWP*CAB146A and 2SWP*CAB146B, Revision 00800
Test of the Standby Gas Treatment System Exhaust Process Radiation Monitors, Revision 06
N2-RSP-RMS-R103, Channel Calibration Test of the Standby Gas Treatment System Exhaust
N2-RSP-RMS-R100, Operating Cycle Channel Calibration of the Flow System on the DRMS Gaseous and Gaseous/Particulate Process Radiation Monitors, Revision s 00400 and 00 301  Issue Reports
Process Radiation Monitors, Revision 06
03954212 03954220 03966022 04020451 04055754 04073565 04079813 04087090 04088525 04089912 04091186 04091505 04093367 04093715 Effluent Monitor Calibrations
N2-RSP-RMS-R100, Operating Cycle Channel Calibration of the Flow System on the DRMS
Unit 1 Stack
Gaseous and Gaseous/Particulate Process Radiation Monitors,
2-07   C93501578 05/17/2016
Revisions 00400 and 00301
C93592938 01/22/2018
Issue Reports
2-08   C93396860 10/19/2016
03954212               03954220             03966022             04020451     04055754
C93563705 09/21/2017
04073565               04079813             04087090             04088525     04089912
2-11   C92112402 04/16/2015
04091186               04091505             04093367             04093715
C93250934 06/21/2017
Effluent Monitor Calibrations
2-12   C93503983 07/19/2017
Unit 1 Stack 112-07                 C93501578     05/17/2016     C93592938   01/22/2018
C93593700 01/22/2018
2-08             C93396860     10/19/2016     C93563705   09/21/2017
Unit 1 SW RAM-72-406 C92835534 06/25/2015
2-11             C92112402     04/16/2015     C93250934   06/21/2017
C93479647 07/11/2017
2-12             C93503983     07/19/2017     C93593700   01/22/2018
Unit 2 SW 2SWP*CAB146A
Unit 1 SW       RAM-72-406         C92835534     06/25/2015     C93479647   07/11/2017
C92801632 02/17/2016 C93502206 08/17/2017
Unit 2 SW       2SWP*CAB146A       C92801632     02/17/2016     C93502206   08/17/2017
2SWP*CAB146B
2SWP*CAB146B       C92753095     04/01/2016     C93491426   01/05/2018
C92753095 04/01/2016
Unit 2 SBGT GTS-CAB105             C91448928     06/14/2013     C92326679   12/17/2015
C93491426 01/05/2018
Unit 2 SBGT GTS-CAB105             C92049982     07/11/2014     C92763391   10/14/2016
Unit 2 SBGT
GTS-CAB105 C91448928 06/14/2013
C92326679 12/17/2015
Unit 2 SBGT
GTS-CAB105 C92049982 07/11/2014
C92763391 10/14/2016
Miscellaneous
Miscellaneous
NMPNS 2015 Annual Radioactive Effluent Release Report, May 13, 2016
NMPNS 2015 Annual Radioactive Effluent Release Report, May 13, 2016
NMPNS 2016 Annual Radioactive Effluent Release Report, April 28, 2017
NMPNS 2016 Annual Radioactive Effluent Release Report, April 28, 2017
NMPNS Errata/Correction to the 2015 Annual Radioactive Effluent Release Report, April 28, 2017 71151 Procedures
NMPNS Errata/Correction to the 2015 Annual Radioactive Effluent Release Report,
LS-AA-2090, Monthly Data Elements for NRC Reactor Coolant System Specific Activity, Revision 004
April 28, 2017
71151
Procedures
LS-AA-2090, Monthly Data Elements for NRC Reactor Coolant System Specific Activity,
Revision 004
LS-AA-2100, Monthly Data Elements for NRC Reactor Coolant System Leakage, Revision 005
LS-AA-2100, Monthly Data Elements for NRC Reactor Coolant System Leakage, Revision 005
Miscellaneous
Miscellaneous
NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7
NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7
 
71152
71152 Procedures:
Procedures:
OP-AA-108-114, Post Transient Review, Revision 13
OP-AA-108-114, Post Transient Review, Revision 13
N1-EOP-2, RPV Control  
N1-EOP-2, RPV Control - Flowchart Revision 01600
- Flowchart Revision 01600
N1-SOP-1, Reactor Scram, Revision 02500
N1-SOP-1, Reactor Scram, Revision 02500
N1-SOP-16.1, Feedwater System Failures, Revision 01000
N1-SOP-16.1, Feedwater System Failures, Revision 01000
N1-ARP-A2, Control Room Panel A2, Revision
N1-ARP-A2, Control Room Panel A2, Revision 01100
01100  Drawings: C-19859-C, Sheet 1, Trip Diagram Reactor Protection System, Revision 21
Drawings:
C-19859-C, Sheet 1, Trip Diagram Reactor Protection System, Revision 21
C-18015-C, Reactor Vessel Instrumentation P&I Diagram, Revision 42
C-18015-C, Reactor Vessel Instrumentation P&I Diagram, Revision 42
C-23223-C, Sheet 2, Connection Diagram Transducer Cabinet #11, Revision 10
C-23223-C, Sheet 2, Connection Diagram Transducer Cabinet #11, Revision 10
C-18005-C, Sheet 1, Feedwater Flow High Pressure P&I Diagram, Revision 51
C-18005-C, Sheet 1, Feedwater Flow High Pressure P&I Diagram, Revision 51
C-23077-C, Sheet 2, Elementary Wiring Diagram Feedwater Control System, Revision 25
C-23077-C, Sheet 2, Elementary Wiring Diagram Feedwater Control System, Revision 25
F-45399-C, Sheet 3, Connection Schedule Plant Process Computer Cabinet PNL
F-45399-C, Sheet 3, Connection Schedule Plant Process Computer Cabinet PNL-IU45,
-IU45,   Revision 2
Revision 2
Issue Reports:
Issue Reports:
04049445 0405 0697  Work Orders:
04049445       04050697
C93638038 71153: Procedures:
Work Orders:
C93638038
71153:
Procedures:
OP-AA-108-114, Post Transient Review, Revision 13
OP-AA-108-114, Post Transient Review, Revision 13
N1-EOP-2, RPV Control  
N1-EOP-2, RPV Control - Flowchart Revision 01600
- Flowchart Revision 01600
N1-SOP-1, Reactor Scram, Revision 02500
N1-SOP-1, Reactor Scram, Revision 02500
N1-SOP-16.1, Feedwater System Failures, Revision 01000
N1-SOP-16.1, Feedwater System Failures, Revision 01000
N1-ARP-A2, Control Room Panel A2, Revision 01100
N1-ARP-A2, Control Room Panel A2, Revision 01100
Drawings: C-19859-C, Sheet 1, Trip Diagram Reactor Protection System, Revision 21
Drawings:
C-19859-C, Sheet 1, Trip Diagram Reactor Protection System, Revision 21
C-18015-C, Reactor Vessel Instrumentation P&I Diagram, Revision 42
C-18015-C, Reactor Vessel Instrumentation P&I Diagram, Revision 42
C-23223-C, Sheet 2, Connection Diagram Transducer Cabinet #11, Revision 10
C-23223-C, Sheet 2, Connection Diagram Transducer Cabinet #11, Revision 10
C-18005-C, Sheet 1, Feedwater Flow High Pressure P&I Diagram, Revision 51
C-18005-C, Sheet 1, Feedwater Flow High Pressure P&I Diagram, Revision 51
C-23077-C, Sheet 2, Elementary Wiring Diagram Feedwater Control System, Revision 25
C-23077-C, Sheet 2, Elementary Wiring Diagram Feedwater Control System, Revision 25
F-45399-C, Sheet 3, Connection Schedule Plant Process Computer Cabinet PNL
F-45399-C, Sheet 3, Connection Schedule Plant Process Computer Cabinet PNL-IU45,
-IU45,   Revision 2 Issue Reports:
Revision 2
04049445 04050697 Work Orders:
Issue Reports:
04049445       04050697
Work Orders:
C93638038
C93638038
}}
}}

Latest revision as of 22:20, 18 December 2019

Integrated Inspection Report 05000220/2018001 and 05000410/2018001
ML18129A297
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 05/09/2018
From: Michelle Catts
Reactor Projects Branch 1
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2018001
Download: ML18129A297 (20)


Text

UNITED STATES May 9, 2018

SUBJECT:

NINE MILE POINT NUCLEAR STATION - INTEGRATED INSPECTION REPORT 05000220/2018001 AND 05000410/2018001

Dear Mr. Hanson:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, LLC (NMPNS), Units 1 and 2. On April 25, 2018, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Michelle P. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Numbers: 50-220 and 50-410 License Numbers: DPR-63 and NPF-69

Enclosure:

Inspection Report 05000220/2018001 and 05000410/2018001

Inspection Report

Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2018001 and 05000410/2018001 Enterprise Identifier: I-2018-001-0046 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: Nine Mile Point Nuclear Station, LLC (NMPNS)

Units 1 and 2 Location: Oswego, New York Inspection Dates: January 1, 2018 to March 31, 2018 Inspectors: E. Miller, Senior Resident Inspector B. Sienel, Resident Inspector G. Stock, Resident Inspector, James A. FitzPatrick Nuclear Power Plant R. Rolph, Health Physicist Approved By: M. Catts, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at

NMPNS Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

Additional Tracking Items Type Issue number Title Report Status Section LER 05000220/2017-003 Automatic Reactor Scram 71153 Closed due to Reactor Vessel Low Water Level URI 05000220/2018001-01 Potential Failure to Submit an 71111.20 Open 8-Hour Event Notification for a Valid Actuation of HPCI URI 05000410/2018001-02 Potential Inadequate 50.59 71111.18 Open Evaluation for TS 3.3.1.1 Bases Change

PLANT STATUS

Unit 1 began the inspection period at or near rated thermal power. On March 17, 2018, operators reduced reactor power to 12 percent and inserted a planned manual reactor scram for a planned maintenance outage. On March 19, 2018, operators commenced a reactor startup and raised Unit 1 to rated thermal power. On March 20, 2018, operators reduced reactor power to 70 percent to perform a control rod pattern adjustment. Unit 1 was restored to rated thermal power on March 21, 2018. On March 24, 2018, operators reduced power to 70 percent to perform a rod pattern adjustment. On March 25, 2018, operators restored reactor power to rated thermal power. Unit 1 remained at or near rated thermal for the remainder of the inspection period.

Unit 2 began the inspection period at or near rated thermal power. On February 2, 2018, operators reduced reactor power to 75 percent to perform a rod pattern adjustment. Operators restored power to rated thermal power on February 3, 2018. On February 24, 2018, operators reduced reactor power to 75 percent to perform turbine valve testing and a control rod pattern adjustment. On February 25, 2018, operators restored reactor power to rated thermal power.

On March 22, 2018, Unit 2 began coastdown, after reaching the maximum power achievable due to fuel depletion as Unit 2 was at the end of this operating cycle. At the end of the inspection period Unit 2 was at 98 percent power. The maximum power will continue to decrease (coastdown) until the refueling outage, which is planned for the second quarter of

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection Impending Severe Weather

(1) The inspectors evaluated readiness for impending severe weather conditions prior to heavy lake effect snow and high winds on January 4, 2018.
(2) The inspectors evaluated readiness for impending severe weather conditions prior to heavy lake effect snow and high winds on January 12, 2018.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 1 11 emergency condenser (EC) on January 25, 2018
(2) Unit 1 12 liquid poison system following surveillance testing on January 29, 2018
(3) Unit 2 high pressure core spray (HPCS) during reactor core isolation cooling (RCIC)planned maintenance on February 6, 2018
(4) Unit 2 A standby gas treatment (SBGT) system while B SBGT system out of service for planned maintenance on March 6, 2018
(5) Unit 1 shutdown cooling on March 17, 2018

71111.05A/Q - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 reactor building (RB) 261 foot elevation, fire area (FA) 1 on January 11, 2018
(2) Unit 1 turbine building (TB) 277 foot elevation, hydrogen seal oil skid, FA 5 on January 29, 2018
(3) Unit 2 RB 175 foot elevation, HPCS pump room, FA 4 on February 6, 2018
(4) Unit 2 RB 175 foot elevation, low pressure core spray (LPCS) pump room, FA 1 on February 6, 2018
(5) Unit 2 RB 175 foot elevation, B residual heat removal (RHR) pump room, FA 3 on February 6, 2018
(6) Unit 2 diesel building (DB) 261 foot elevation, Division I diesel generator, FA 28 on March 27, 2018
(7) Unit 2 DB 261 foot elevation, Division II diesel generator, fire zone FA 29 on March 27, 2018
(8) Unit 2 DB 261 foot elevation, HPCS diesel generator, FA 30 on March 27, 2018
(9) Unit 2 DB 261 foot elevation, Division 1 diesel generator control room, FA 28 on

March 27, 2018 Annual Inspection (1 Sample)

The inspectors evaluated Unit 2 fire brigade performance during an actual event that involved a fire at a non-safety related moisture separator reheater pressure control valve on February 1, 2018.

71111.07 - Heat Sink Performance Heat Sink

The inspectors evaluated Exelons monitoring and maintenance of Unit 2 B RHR heat exchanger performance on February 8, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

(1) The inspectors observed a Unit 1 simulator evaluation that involved the loss of an electrical bus (PB 1671A), the trip of a turbine building closed loop cooling pump with the failure of the standby pump to automatically start, and loss of coolant accident on January 30, 2018
(2) The inspectors observed a Unit 2 simulator evaluation that involved the loss of an instrument air compressor, the failure of a service water pump, the failure of an electro-hydraulic control system pressure control valve, and a loss of coolant accident on

February 6, 2018 Operator Performance (2 Samples)

(1) The inspectors observed Unit 1 operations personnel during a transfer from the mechanical pressure regulator to the electronic pressure regulator during motor generator (MG) set 167 planned maintenance on February 22, 2018, and during a reactor shutdown for a planned maintenance outage on March 17, 2018
(2) The inspectors observed Unit 2 operations personnel during a downpower to 75 percent for a control rod pattern adjustment on February 2 and 3, 2018

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 2 instrument air compressors on March 27, 2018
(2) Unit 2 turbine building sumps week of March 29, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 2 planned F service water pump and motor replacement on January 23, 2018
(2) Unit 2 planned Division 2 unit cooler 2HVY*UC2B thermal performance testing on January 30, 2018
(3) Unit 2 planned RCIC maintenance on February 6, 2018
(4) Unit 1 planned 12 emergency condenser surveillance testing on February 15, 2018
(5) Unit 1 planned 12 liquid poison surveillance testing on March 6, 2018
(6) Unit 2 planned Division 2 SBGT system maintenance on March 6, 2018
(7) Unit 2 failure of 2SFC*HV6A, spent fuel pool cooling suction cross connection valve on March 7, 2018
(8) Unit 1 planned 12 reactor recirculation pump seal flush on March 13, 2018
(9) Unit 2 planned B reserve station transformer maintenance on March 26, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 EDG 103 low governor oil level on January 8, 2017
(2) Unit 2 RCIC operability during maintenance on an associated room cooler on January 22, 2018
(3) Unit 2 2CSH*V7, HPCS minimum flow return line discharge check valve based on associated 10 CFR Part 21 Event Notification #53177 on February 7, 2018
(4) Unit 2 RCIC due to governor valve steam leak on February 8, 2018
(5) Unit 2 Three element feedwater level control system following unexpected reactor water level transient on February 9, 2018
(6) Unit 2 HPCS pipe integrity based on operating experience related to the use of Style CG Flexitallic gaskets on February 22, 2018
(7) Unit 2 step change in reactor recirculation B seal temperatures following a downpower on February 26, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Procedure Change Request (PCR)-17-03717, Unit 2 Procedure Change to N2-OSP-RPS-Q001, RPS Turbine Stop Valve (TSV) Closure Logic, Control Valve Fast Closure Scram Functional Tests and Turbine Valve Cycling on February 12, 2018 (Permanent Modification)
(2) Action Request (AR) 04044602-02, Unit 2 TS 3.3.1.1 Bases Change for Turbine Stop Valve and main steam isolation valve (MSIV) Testing on February 28, 2018 (Permanent Modification)

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Unit 1 11 shutdown cooling pump breaker preventive maintenance on January 11, 2018
(2) Unit 2 emergency core cooling system flood penetration breach for modification on January 22, 2018
(3) Unit 2 RCIC valve breaker preventive maintenance on February 6, 2018
(4) Unit 2 spent fuel pool cooling pump suction cross connect valve, SFC*HV6A, corrective maintenance on March 13, 2018
(5) Unit 1 11 feedwater low flow control valve on March 17, 2018
(6) Unit 1 MSIV 01-01 following packing replacement on March 18, 2018

71111.20 - Refueling and Other Outage Activities

(1) The inspectors evaluated Unit 2 N2R16 pre-outage activities during the first quarter of 2018 (Partial sample)
(2) The inspectors evaluated Unit 1 planned maintenance outage activities from March 17, 2018 through March 20, 2018

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test, on February 5, 2018
(2) N1-ST-M1B, Liquid Poison Pump 12 Operability Test, on March 6, 2018
(3) N1-ST-Q1D, CS 122 Pump and Valve Operability Test, on March 12, 2018
(4) N1-ST-V3, Rod Worth Minimizer Operability Test Average Power Range Monitor/Intermediate Range Monitor Overlap Verification on March 19, 2018
(5) N1-PM-V7, Turbine Trip Tests, on March 20, 2018

Inservice (2 Samples)

(1) N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and American Society of Mechanical Engineers XI Functional Test and Analysis, on February 8, 2018
(2) N2-OSP-EGS-M@002, Diesel Generator and Diesel Start Valve Operability Test, Division III, on February 28, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) CY-NM-170-341, Primary Containment Sampling and Analysis, Unit 1, on January 25, 2018

71114.06 - Drill Evaluation Training Evolution

(1) The inspectors observed a Unit 1 simulator evaluation that involved the loss of an electrical bus (PB 1671A), the trip of a turbine building closed loop cooling pump with the failure of the standby pump to automatically start, and a loss of coolant accident on January 30, 2018
(2) The inspectors observed a Unit 2 simulator evaluation that involved the loss of an instrument air compressor, the failure of a service water pump, the failure of an electro-hydraulic control system pressure control valve, and a loss of coolant accident on February 6,

RADIATION SAFETY

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walkdowns and Observations

The inspectors walked down the gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design.

Calibration and Testing Program (Process and Effluent Monitors) (1 Sample)

The inspectors evaluated Exelons gaseous and liquid effluent monitor instrument calibration and testing.

Sampling and Analyses (1 Sample)

The inspectors evaluated radioactive effluent sampling and analysis activities.

Instrumentation and Equipment (1 Sample)

The inspectors reviewed radioactive effluent discharge system surveillance test results and reviewed the methodology used to determine the radioactive effluent stack and vent flow rates based on Technical Specifications/Off Site Dose Calculation Manual (TS/ODCM)acceptance criteria.

Dose Calculations (1 Sample)

The inspectors reviewed several liquid and gaseous discharge permits to evaluate public dose calculations (monthly, quarterly, and annual) and the annual radiological effluent release reports for 2015 and

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified Exelons performance indicator submittals listed below:

(1) Units 1 and 2, Reactor Coolant System Leakage, from January 1, 2017 through December 31, 2017
(2) Units 1 and 2, Reactor Coolant System Specific Activity from January 1, 2017 through December 31, 2017
(3) Site Radiological Effluent TS/ODCM Radiological Effluent Occurrences from October 1, 2016 through December 31, 2017

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Issue Report (IR) 04049445, Unit 1 - September 6, 2017 scram due to lowering reactor water level when the feedwater level control system experienced a failure of a feedwater flow/steam flow error signal input.

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

The inspectors evaluated response to the following event:

(1) Unit 2 - Notice of Unusual Event declaration for a fire in the turbine building on

February 1, 2018 Licensee Event Reports (1 Sample)

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000220/2017-003, Automatic Reactor Scram due to Reactor Vessel Low Water Level, on September 6, 2017. See Section 71152 for additional details.

INSPECTION RESULTS

Unresolved Item Potential Failure to Submit an 8-Hour Event 71111.20 (URI) Notification for a Valid Actuation of HPCI Refueling and 05000220/ Other Outage 2018001-01 Activities (Open)

Description:

On March 18, 2018, at 1:18 a.m., during the Unit 1 maintenance outage while the unit was in cold shutdown, operators received multiple low level alarms on the GEMAC 11 and 12 level indications. Operators responded by adjusting reactor water cleanup reject flow and the feedwater minimum flow control valve to raise reactor water level. Upon the operators making the adjustment to reactor water level, the feedwater low flow control valve was slow to respond, but eventually opened more rapidly, and the increased flow from feedwater resulted in a rapid rise in reactor water level. At 1:28 a.m., indicated reactor water level rose to the 95-inch trip setpoint for the 11 and 12 Yarway level indication instruments, resulting in a turbine trip and HPCI initiation signal. The HPCI pumps were tagged out and thus did not inject, and the turbine was offline for the shutdown.

The 11 and 12 Yarway level indication instruments provide reactor protection system logic inputs for reactor vessel water level; however, the Yarway level indication instruments are not density compensated. Therefore, under cold shutdown conditions, actual reactor vessel water level was lower than indicated water level on the 11 and 12 Yarways. During cold shutdown conditions, the GEMAC level instruments, which are calibrated to cold shutdown conditions, provide an accurate indication of actual reactor vessel water level. The GEMAC instruments both indicated well below the trip setpoint of 95 inches (indicated ~72 inches) when the turbine trip and HPCI initiation signal were received. Exelon determined that this event was not reportable under 10 CFR 50.72.

Title 10 CFR 50.72(b)(3)(iv)(A) states, Any event or condition that results in valid actuation of any of the systems listed in paragraph (b)(3)(iv)(B) of this section, except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation.

(B) The systems to which the requirements of paragraph (b)(3)(iv)(A) of this section apply are:

(5) BWR reactor core isolation cooling system; isolation condenser system; and feedwater coolant injection system.

Planned Closure Action(s): The inspectors requested the 10 CFR 50.72 subject matter experts at the Office of Nuclear Reactor Regulation (NRR) and Office of General Council (OGC) to review whether this was a valid actuation and thus reportable. The inspectors are opening an unresolved item (URI) to determine if a performance deficiency exists.

Licensee Action(s): Licensee entered the concern into their corrective action program, and communicated with NRC Region I and NRR Staff. Exelons position is that the event was not reportable.

Corrective Action Reference: IR 04116336 NRC Tracking Number: 05000220/2018001-01 URI Potential Inadequate 50.59 Evaluation for TS 3.3.1.1 71111.18 05000410/ Bases Change Plant 2018001-02 Modifications (Open)

Description:

On February 23, 2018, Exelon personnel performed a 50.59 Screening for a change to Unit 2 TS Bases 3.3.1.1, Reactor Protection System (RPS) Instrumentation, for MSIV and TSV surveillance testing. Exelon personnel performed this activity to address operating experience associated with the use of a test box that prevents a scram signal during RPS surveillance testing for TS 3.3.1.1 Function 5 MSIV - Closure and Function 8 TSV -

Closure.

TS Bases B 3.3.1.1, C.1, Revision 1 was revised to state, in part, For Function 5 (MSIV -

Closure), this would require both trip systems to have at least one channel associated with the MSIVs for each main steam line in one Trip Logic Channel (not necessarily the same main steam lines for both trip systems), Operable or in trip (or the associated trip system in trip).

For Function 8 (Turbine Stop Valve - Closure), this would require both trip systems to have the channels for one Trip Logic Channel, Operable or in trip (or the associated trip system in trip).

The inspectors questioned whether the change to TS Bases B 3.3.1.1 resulted in a change to the implementation of TS 3.3.1.1. A licensee is permitted to make changes to their Technical Specification Bases documents without NRC review and approval. However, in certain cases, such as a change to the Technical Specification Bases that would change how the associated Technical Specification is applied, NRC review and approval would be required.

Planned Closure Action(s): The inspectors sent written questions to request assistance from NRR to determine whether this change to the TS Bases reasonably would have required NRC review and approval. The inspectors are opening a URI to determine if this is violation of 10 CFR 50.59 and if it is more than minor.

Licensee Action: Documented NRCs concern as AR 04055602. Exelons position is the change would not affect how TS 3.3.1.1, or its note, is applied and therefore NRC review was not required.

Corrective Action Reference: AR 04055602 NRC Tracking Number: 05000410/2018001-02 Observations and Minor Violations 71152 A Problem Identification and Resolution The inspectors performed a review of IR 04049445 to review Exelons cause evaluation associated with a Unit 1 reactor scram on low reactor water level on September 6, 2017. The inspectors also reviewed Exelons Post Transient Review, operating procedures, drawings, Control Room Logs, sequence of events recorder data, plant computer data, and conducted interviews with Exelon staff.

The inspectors identified two performance deficiencies that were determined to be minor in accordance with IMC 0612, Appendix B, Issue Screening, associated with Exelons Post Transient Review. The purpose of a Post Transient Review is to make a prompt determination if plant equipment responded as designed and that plant operators responded appropriately to the transient or event and any potential non-conforming conditions identified.

(1) OP-AA-108-114, Post Transient Review, Revision 13, Section E Safety Assessment, Criteria 10 states High level isolation(s) with a check box for either Yes or No. During the inspectors review, it was identified through review of plant computer data and drawings that Nine Mile Point Unit 1 received an expected signal for a feedwater pump trip on high reactor water level at 95 inches. The inspectors found that operators performing the Post Transient Review in accordance with OP-AA-108-114 made a determination that the feedwater pump trip on high reactor water level was not considered an isolation. The inspectors determined that the procedure lacked clarity in providing operators a means to determine if the plant responded in accordance with its design basis. The inspectors determined that although operators did not accurately check the box Yes that the feedwater pump high reactor water level trip occurred, it did not result in any consequence to the plants operation following the Post Transient Review; and it was determined that the trip did function as expected, therefore this performance deficiency for an inadequate procedure is minor.
(2) The inspectors also reviewed IR 04050697, which documented a question from the inspectors following the reactor scram on September 6, 2017, concerning feedwater computer points becoming erratic just prior to the Unit 1 reactor scram. Exelon subsequently performed additional evaluation, and was able to show that the failure of the computer points were unrelated to the cause of the scram, which was the failure of the feedwater flow/steam flow mismatch card. Exelon determined the computer point failures to be related to maintenance being performed on a power supply that failed in the turbine performance calculation cabinet under work order C93638038. The inspectors agreed with this conclusion.

The inspectors determined that Exelon failed to establish documentation to support or refute a potential cause in accordance with Procedure MA-AA-716-004, Conduct of Troubleshooting, Revision 15, as part of Section 4.5 for Simple Troubleshooting. The result was a failure to provide the cause evaluation team enough information to assess the issue for a potential cause. Specifically, Procedure PI-AA-125-1003, Corrective Action Program Evaluation Manual Section 4.3.5 states that investigators should gather information and data relating to the event. The inspectors found that this potential failure was not explored under the Simple Troubleshooting process for establishing a failure mode/cause table, and subsequently resulted in the inspectors questioning if this should have been evaluated by the cause evaluation team. This showed that the depth of investigation was inadequate to ensure all potential causes associated with a potential scram were explored. The inspectors determined the performance deficiency for failure to follow Procedures MA-AA-716-004 and PI-AA-125-1003 is minor because following the inspectors questions, Exelon was able to provide additional information to refute relationship to the cause of the scram.

Observations and LER Closure 71153 Follow-up of Events and Notices of Enforcement Discretion LER 05000220/2017-003, Automatic Reactor Scram due to Reactor Vessel Low Water Level, on September 6, 2017. Exelon determined the root cause of the Unit 1 event was an equipment failure associated with a power supply within the proportional amplifier PAM-ID23E, which is part of the three element feedwater control system. This failure was not within Exelons ability to foresee and prevent; therefore, there was no performance deficiency associated with the instrument failure. The inspectors did not identify any findings associated with this event. This LER is closed.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On April 25, 2018, the inspectors presented the quarterly resident inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the Exelon staff.

DOCUMENTS REVIEWED

71111.01

Procedures

N1-OP-64, Meteorological Monitoring, Revision 01700

N2-OP-102, Meteorological Monitoring, Revision 02200

71111.04

Procedures

C-18018-C, Reactor Shutdown Cooling Piping & Instrumentation Diagram, Revision 32

N1-OP-4, Shutdown Cooling System, Revision 04600

N1-OP-13, Emergency Cooling System, Revision 04100

N1-PM-Q9, Lubrication of Plant Equipment, Revision 01600

N1-ST-Q8B, Liquid Poison Pump 12 and Check Valve Operability Test, Revision 01200

N2-OP-33, High Pressure Core Spray System, Revision 01500

N2-OP-33, Lineups, High Pressure Core Spray System, Revision 00100

N2-OP-61B, Standby Gas Treatment System, Revision 01500

N2-OP-61B, Lineups, Standby Gas Treatment System - Lineups, Revision 00100

Issue Reports

2016743 02051624 02052658 02700451

Drawing

C-18017-C, Sheet 1, Emergency Cooling System Piping & Instrumentation Diagram,

Revision 56

71111.05

Procedures

N1-PFP-0101, Unit 1 Pre-Fire Plans, Revision 00500

N2-FPI-PFP-0201, Unit 2 Pre-Fire Plans, Revision 5

N2-FPM-FPE-A001, Maintenance and Inspection, Portable Fire Extinguishers, Revision 01500

N2-PFP-DG261-2, Division I Diesel Generator-261 Elevation, Revision 01

N2-PFP-DG261-3, Division II Diesel Generator-261 Elevation, Revision 01

N2-PFP-DG261-4, HPCS Diesel Generator-261 Elevation, Revision 01

OP-AA-201-009, Control of Transient Combustibles, Revision 20

OP-NM-201-005, Firefighting, Revision 00200

Issue Reports

04099955 04099960

Miscellaneous

DCD-805, Nine Mile Point Unit 1 NFPA 805 Design Criteria, Revision 1

Unit 2 UFSAR Section 9, Revision 22

71111.07A

Procedure

N2-TTP-RHS-4Y002, Residual Heat Removal System Heat Exchanger (2RHS*E1B)

Performance Monitoring (Suppression Pool Cooling Mode), Revision 00300

Work Order

C90813331

71111.11

Procedures

N1-OP-31, Tandem Compound Reheat Turbine, Revision 04700

N1-OP-43C, Plant Shutdown, Revision 02400

N2-OP-101D, Power Changes, Revision 02500

Miscellaneous

2100-SIMEVLS03B, EVL-3 DMS-RL3 Evaluated Scenario 2, January 12, 2018

Reactivity Maneuver Plan NM2C16-15, Control Rod Pattern Change, approved

January 30, 2018

71111.12

Procedures

Maintenance Rule a(1) Action Plan for NMP 2-IAS-F01(A) [IR 02697332], Revisions 0, 1, and 2

Maintenance Rule a(1) Determination for 2-IAS-F01(A) [IR 02697332], dated August 4, 2016

Maintenance Rule System Basis Document for NMP 2 Instrument Air (IAS) on March 3, 2018

Maintenance Rule Functional Failure Evaluations for IRs

2509894 02638306 02639296 02673914 02693332

03965289 04038793 04042841 04044296 04051369

04052532 04096304 04105106 04116231

71111.13

Procedures

N1-OP-1, Nuclear Steam Supply System, Revision 07300

N1-SOP-21.1, Fire In Plant, Revision 01401

N2-OP-38, Spent Fuel Pool Cooling and Cleanup System, Revision 02400

N2-OP-58, Screenwell Building and Fire Pump Rooms Ventilation Systems, Revision 00402

N2-PRA-006, Nine Mile Point Unit 2 Probabilistic Risk Assessment Dependency Matrix

Notebook, Revision 1

OP-AA-108-117, Protected Equipment Program, Revision 005

OP-NM-102-106, Operator Response Time Program at Nine Mile Point, Revision 7

OP-NM-108-117, Protected Equipment Program at Nine Mile Point, Revision 05000

Issue Report

04112080

Miscellaneous

Maintenance Rule Basis Document for NMPNS 2 Screenwell Building Ventilation, viewed

February 26, 2018

71111.15

Procedures

N2-EOP-HC, EOP Hard Cards Procedure, Revision 00800

N2-OP-29, Reactor Recirculation System, Revision 02700

N2-OP-52, Reactor Building Ventilation, Revision 01800

N2-SOP-01, Station Blackout/Extended Loss of AC Power, Revision 01500

N2-SOP-02, Station Blackout/Extended Loss of AC Power Support Procedure, Revision 001100

N2-SOP-29.1, Reactor Recirculation Pump Seal Failure, Revision 00500

NMP-2-2018-0055, Risk Assessment ODM for 1/2-inch Reactor Level Step [Increase], Revision 0

Issue Reports

2040819 04056662 04092089 04092221

04095919 04102652 04102837

Drawings

0005321052005H, 2.5-inch through 4-inch Swing Check Valve Bolted Bonnet Forged,

Revision H.00

PID-33A, Piping & Instrumentation Diagram High Pressure Core Spray System, Revision 18

PID-33B, Piping & Instrumentation Diagram High Pressure Core Spray System, Revision 15

PID-35A, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 17

PID-35B, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 15

PID-35C, Piping & Instrumentation Diagram Reactor Core Isolation Cooling, Revision 29

Miscellaneous

NRC Inspection Report 05000397/2017008, Columbia Generating Station - NRC Special

Inspection Report

71111.18

Procedure

N2-OSP-RPS-Q001, RPS Turbine Stop Valve Closure Logic, Control Valve Fast Closure Scram

Functional Tests and Turbine Valve Cycling, Revision 00700

Drawings

0007.225-001-007, Elementary Diagram Reactor Protection System, Revision 8

0007.225-001-008, Elementary Diagram Reactor Protection System, Revision 8

0007.225-001-009, Elementary Diagram Reactor Protection System, Revision 9

0007.225-001-010, Elementary Diagram Reactor Protection System, Revision 9

0007.225-001-011, Elementary Diagram Reactor Protection System, Revision 8

0007.225-001-013, Elementary Diagram Reactor Protection System, Revision 3

Miscellaneous

04044602-02/Revision to Unit 2 Bases B3.3.1.1, Unit 2

PCR-17-03717, Eliminated Two TSV Stroking, Need to Bypass RCS EOC-RPT Channels and

Low Power TT Bypass of All Four Channels At The Same Time, Revision 1

71111.19

Procedures

CC-AA-201, Plant Barrier Control Program, Revision 011

CC-NM-201-1001, Plant Barrier Control Program Implementation, Revision 0

N1-OP-4, Shutdown Cooling System, Revision 04600

N2-OSP-ICS-Q001, RCIC Valve Operability Test, Revision 00600

N2-OSP-SFC-Q001, Spent Fuel Pool Cooling Cleanup Pump and Valve Operability Test,

Revision 00700

S-EPM-GEN-063, MOV Diagnostic Testing, Revision 01000

Issue Reports

04082313 04082686 04112080

Work Orders

C92753269 C93013263 C3098917 C93607398

C93658702 C93659934

Miscellaneous

N2-CRM-008, Technical Specification 3.0.9 Evaluation of Residual Heat Removal Division I and

II Pump Room Barrier Penetrations to Support Maintenance, Revision 0

71111.20

Procedures

ER-AA-370-1002, Review of Reactor Pressure Vessel Pressure-Temperature Limit Curves,

Revision 0

MA-AA-796-024, Scaffold Installation, Inspection, and Removal, Revision 11

N1-OP-4, Shutdown Cooling System, Revision 04600

N1-OP-43A, Plant Startup, Revision 04700

N1-OP-43C, Plant Shutdown, Revision 02400

N2-FHP-014, Movement of New Fuel and Control Rod Blades into the Spent Fuel Pool,

Revision 01200

N2-FHP-026, Moving Fuel and Blade Guides within the Spent Fuel Pool, Revision 00500

S-MMP-FHP-100, Receiving, Inspection, and Storage of New Fuel, Revision 01300

Drawings

C-23093-C, Sheet 3, Interconnection Diagram Auxiliary Control Cabinet IS60, Revision 16

C-23091-C, Sheet 3, Interconnection Diagram Auxiliary Control Cabinet IS59, Revision 23

Miscellaneous

Adverse Condition Monitoring and Contingency Plan (ACMP) for Unit 1 Unidentified Leak Rate

(IR 04058998), Revision 5

ACMP for Unit 1 12 Recirculation Pump Seal Pressures (IR 04085756), Revision 0

Reactivity Maneuver Plan NM1C23-SU-1, approved March 6, 2018

71111.22

Procedures

CY-NM-170-341, Primary Containment Sampling and Analysis, Unit 1, Revision 3

ER-AB-331-1006, BWR Reactor Coolant System Leakage Monitoring and Action Plan,

Revision 2

N1-PM-V7, Turbine Trip Tests, Revision 00800

N1-ST-M1B, Liquid Poison Pump 12 Operability Test, Revision 01100

N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test, Revision 01900

N1-ST-Q1D, CS 122 Pump and Valve Operability Test, Revision 01800

N1-ST-V3, Rod Worth Minimizer Operability Test APRM/IRM Overlap Verification,

Revision 01301

N2-OSP-EGS-M@002, Diesel Generator and Diesel Start Valve Operability Test - Division III,

Revision 02001

N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and

ASME XI Functional Test and Analysis, Revision 01400

Issue Reports

04109552 04111549 04111560 04111970 04114129

04114298 04114374

Work Orders

C93588959 C93595862 C93597294 C93599399

C93607235 C93625379

71124.06

Procedures

CY-AA-110-200, Sampling, Revision 13

CY-NM-170-370, Emergency Condenser Shell Sampling and Analysis, Revision 1

CY-NM-210-331, Offgas Sampling (Unit 2), Revision 1

N1-CSP-M204, Liquid Release Dose Calculations, Revision 00502

N1-CSP-M350, Noble Gas Dose Calculations, Revision 00602

N1-CSP-M351, Particulate, Iodine, and Tritium Dose Calculations, Revision 00402

N1-RSP-11A, Calibration of the Service Water Discharge Monitor, Revision 01000

N1-RSP-13, Stack Radiation Monitor Calibration Check and Channel Test, Revision 00200

N2-CSP-LWS-M203, Monthly Liquid Dose Calculations, Revision 00101

N2-CSP-RMS-M350, Noble Gas Dose Rate and Dose Calculations, Revision 00401

N2-CSP-RMS-M351, Particulate, Iodine, and Tritium Dose Calculations, Revision 00500

N2-RSP-RMS-R113, Channel Calibration Test of the Service Water Effluent Line Process

Radiation Monitors 2SWP*CAB146A and 2SWP*CAB146B, Revision 00800

N2-RSP-RMS-R103, Channel Calibration Test of the Standby Gas Treatment System Exhaust

Process Radiation Monitors, Revision 06

N2-RSP-RMS-R100, Operating Cycle Channel Calibration of the Flow System on the DRMS

Gaseous and Gaseous/Particulate Process Radiation Monitors,

Revisions 00400 and 00301

Issue Reports

03954212 03954220 03966022 04020451 04055754

04073565 04079813 04087090 04088525 04089912

04091186 04091505 04093367 04093715

Effluent Monitor Calibrations

Unit 1 Stack 112-07 C93501578 05/17/2016 C93592938 01/22/2018

2-08 C93396860 10/19/2016 C93563705 09/21/2017

2-11 C92112402 04/16/2015 C93250934 06/21/2017

2-12 C93503983 07/19/2017 C93593700 01/22/2018

Unit 1 SW RAM-72-406 C92835534 06/25/2015 C93479647 07/11/2017

Unit 2 SW 2SWP*CAB146A C92801632 02/17/2016 C93502206 08/17/2017

2SWP*CAB146B C92753095 04/01/2016 C93491426 01/05/2018

Unit 2 SBGT GTS-CAB105 C91448928 06/14/2013 C92326679 12/17/2015

Unit 2 SBGT GTS-CAB105 C92049982 07/11/2014 C92763391 10/14/2016

Miscellaneous

NMPNS 2015 Annual Radioactive Effluent Release Report, May 13, 2016

NMPNS 2016 Annual Radioactive Effluent Release Report, April 28, 2017

NMPNS Errata/Correction to the 2015 Annual Radioactive Effluent Release Report,

April 28, 2017

71151

Procedures

LS-AA-2090, Monthly Data Elements for NRC Reactor Coolant System Specific Activity,

Revision 004

LS-AA-2100, Monthly Data Elements for NRC Reactor Coolant System Leakage, Revision 005

Miscellaneous

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7

71152

Procedures:

OP-AA-108-114, Post Transient Review, Revision 13

N1-EOP-2, RPV Control - Flowchart Revision 01600

N1-SOP-1, Reactor Scram, Revision 02500

N1-SOP-16.1, Feedwater System Failures, Revision 01000

N1-ARP-A2, Control Room Panel A2, Revision 01100

Drawings:

C-19859-C, Sheet 1, Trip Diagram Reactor Protection System, Revision 21

C-18015-C, Reactor Vessel Instrumentation P&I Diagram, Revision 42

C-23223-C, Sheet 2, Connection Diagram Transducer Cabinet #11, Revision 10

C-18005-C, Sheet 1, Feedwater Flow High Pressure P&I Diagram, Revision 51

C-23077-C, Sheet 2, Elementary Wiring Diagram Feedwater Control System, Revision 25

F-45399-C, Sheet 3, Connection Schedule Plant Process Computer Cabinet PNL-IU45,

Revision 2

Issue Reports:

04049445 04050697

Work Orders:

C93638038

71153:

Procedures:

OP-AA-108-114, Post Transient Review, Revision 13

N1-EOP-2, RPV Control - Flowchart Revision 01600

N1-SOP-1, Reactor Scram, Revision 02500

N1-SOP-16.1, Feedwater System Failures, Revision 01000

N1-ARP-A2, Control Room Panel A2, Revision 01100

Drawings:

C-19859-C, Sheet 1, Trip Diagram Reactor Protection System, Revision 21

C-18015-C, Reactor Vessel Instrumentation P&I Diagram, Revision 42

C-23223-C, Sheet 2, Connection Diagram Transducer Cabinet #11, Revision 10

C-18005-C, Sheet 1, Feedwater Flow High Pressure P&I Diagram, Revision 51

C-23077-C, Sheet 2, Elementary Wiring Diagram Feedwater Control System, Revision 25

F-45399-C, Sheet 3, Connection Schedule Plant Process Computer Cabinet PNL-IU45,

Revision 2

Issue Reports:

04049445 04050697

Work Orders:

C93638038