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| {{#Wiki_filter:ENCLOSURE 3 | | {{#Wiki_filter: |
| NOTICE OF VIOLATION
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| Exelon Generation Company, LLC Docket No. 50-333
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| James A. FitzPatrick Nuclear Power Plant License No. DPR-59 EA-20-138
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| During an NRC review in response to a contested violation conducted from June 3, 2021,
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| through September 3, 2021, violations of NRC requirements were identified. In accordance with
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| the NRC Enforcement Policy, the violations are listed below:
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| Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states,
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| in part, that activities affecting quality shall be prescribed by documented instructions,
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| procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished
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| in accordance with these instructions, procedures, or drawings.
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| Title 10 CFR Part 50, Appendix B, Criterion XV, Nonconforming Materials, Parts, or
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| Components, states, in part, that measures shall be established to control materials, parts, or
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| components which do not conform to requirements in order to prevent their inadvertent use or
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| installation. These measures shall include, as appropriate, procedures for identification,
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| documentation, segregation, disposition, and notification to affected organizations.
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| Exelon Procedure SM-AA-102, Warehouse Operations, Revision 23, prescribes activities
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| affecting quality and measures to control nonconforming components. Procedure SM-AA-102,
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| Attachment 1, step 1.10.6, states Items that are on hold at one site can be released to another
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| site while on hold only if an action item is created at the receiving site to track resolution of the
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| item before the transfer occurs, and the item is added to the receiving sites hold tag log. A hold
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| tag shall be attached to the item upon receipt of the transfer at the receiving site.
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| FitzPatrick Technical Specification (TS 3.5.1) requires, in part, that the HPCI system be
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| operable in Modes 1, 2 and 3 with reactor steam dome pressure >150 psig. If the HPCI system
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| is determined to be inoperable, it shall be returned to an operable status within 14 days. If not
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| restored to an operable status, the unit shall be shut down and in Mode 3 within 12 hours.
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| Contrary to the above, from December 16, 2017, to April 10, 2020, activities affecting quality
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| were not accomplished in accordance with procedures for controlling a nonconforming
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| component and a nonconforming component was not controlled in accordance with documented
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| procedures. Specifically, Exelon failed to initiate an action item at FitzPatrick to track resolution
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| of a nonconforming Pressure Control Valve (PCV) before its transfer occurred, did not add it to
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| the receiving sites hold tag log, and did not attach a hold tag upon receipt. As a result, on
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| December 16, 2017, Exelon did not identify that the PCVs diaphragm required replacement and
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| installed the nonconforming PCV in the High Pressure Coolant Injection (HPCI) system.
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| Consequently, the HPCI system was rendered inoperable prior to April 10, 2020, for a period
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| longer than its TS allowed outage time, and the unit was not shut down and placed in Mode 3
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| within 12 hours in accordance with requirements.
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| These violations are categorized collectively as a problem and are associated with a White
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| Significance Determination Process finding.
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| Notice of Violation 2
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| No response to this Notice of Violation is required since the NRC previously received adequate
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| responses as documented in a letter dated February 26, 2021 (ML21057A190). If you wish to
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| provide additional information for the NRC to consider, you should notify the Region I Regional
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| Administrator verbally within 10 days of receipt of this Notice of Violation, followed by a written
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| response submitted within 30 days of the date of the notification to the U.S. Nuclear Regulatory
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| Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
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| Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is
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| the subject of this Notice. This reply should be clearly marked as a "Reply to a Notice of
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| Violation; EA-20-138". If you do not notify the Region I Regional Administrator within 10 days of
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| receipt, this Notice of Violation will be considered final.
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| Your response, if made, will be made available electronically for public inspection in the NRC
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| Public Document Room or from the NRCs document system (ADAMS), accessible from the
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| NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
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| include any personal privacy, proprietary, or safeguards information so that it can be made
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| available to the public without redaction. If personal privacy or proprietary information is
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| necessary to provide an acceptable response, then please provide a bracketed copy of your
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| response that identifies the information that should be protected and a redacted copy of your
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| response that deletes such information. If you request withholding of such material, you must
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| specifically identify the portions of your response that you seek to have withheld and provide in
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| detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
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| create an unwarranted invasion of personal privacy or provide the information required by
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| 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
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| information). If safeguards information is necessary to provide an acceptable response, please
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| provide the level of protection described in 10 CFR 73.21.
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| In accordance with 10 CFR 19.11, the licensee may be required to post this Notice within two
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| working days of receipt.
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| Dated this 3rd day of September 2021.
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| }} | | }} |
