IR 05000220/2022001: Difference between revisions

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==Dear Mr. Rhoades:==
==Dear Mr. Rhoades:==
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, Units 1 and 2. On April 21, 2022, 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.
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, Units 1 and 2. On April 21, 2022, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, a nd other members of your staff. The results of this inspection are documented in the enclosed report.


No findings or violations of more than minor significance were identified during this inspection.
No findings or violations of more than minor significance 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 at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
This letter, its enclosure, and your response (if any) will be m ade available for public inspection and copying at http://www.nrc.gov/reading-rm /adam s.h tm l and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely, Digitally signed by Erin E.
Sincerely, Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reac to r Safety


Carfang Erin E. Carfang Date: 2022.04.29 08:25:48-04'00'
Docket Nos. 05000220 and 05000410 License Nos. DPR-63 and NPF-69
Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Docket Nos. 05000220 and 05000410 License Nos. DPR-63 and NPF-69


===Enclosure:===
===Enclosure:===
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==Inspection Report==
==Inspection Report==
Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2022001 and 05000410/2022001 Enterprise Identifier: I-2022-001-0049 Licensee: Constellation Energy Generation, LLC Facility: Nine Mile Point Nuclear Station, Units 1 and 2 Location: Oswego, NY Inspection Dates: January 1, 2022 to March 31, 2022 Inspectors: G. Stock, Senior Resident Inspector C. Kline, Resident Inspector B. Sienel, Resident Inspector N. Floyd, Senior Reactor Inspector S. Haney, Senior Project Engineer C. Hobbs, Reactor Inspector S. Wilson, Senior Health Physicist Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Enclosure
Docket Numbers: 05000220 and 05000410
 
License Numbers: DPR-63 and NPF -69
 
Report Num bers: 05000220/2022001 and 05000410/2022001
 
Enterprise Identifier: I-2022- 001-0049
 
Licensee: Constellation Energy Generation, LLC
 
Facility: Nine Mile Point Nuclear Station, Units 1 and 2
 
Location: Oswego, NY
 
Inspection Dates: January 1, 2022 to March 31, 2022
 
Inspectors: G. Stock, Senior Resident Inspector C. Kline, Resident Inspector B. Sienel, Resident Inspector N. Floyd, Senior Reactor Inspector S. Haney, Senior Project Engineer C. Hobbs, Reactor Inspector S. Wilson, Senior Health Physicist
 
Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety
 
Enclosure


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Nine Mile Point Nuclear Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees performance by conducting an integrated inspection at Nine Mile Point Nuclear Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to h ttps://www.nrc.gov/reactors/operating/oversight.html for more information.


===List of Findings and Violations===
===List of Findings and Violations===
No findings or violations of more than minor significance were identified.


No findings or violations of more than minor significance were identified.
Additional Tracking Ite ms


===Additional Tracking Items===
None.
None.


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Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 1 operated at or near rated thermal power for the entire inspection period.


Unit 2 began the inspection period at rated thermal power. On January 7, 2022, the unit was downpowered to 78 percent to perform planned control rod channel interference testing and a control rod pattern adjustment, and returned to rated thermal power on January 8, 2022.
Unit 2 began the inspection period at rated thermal power.


On January 28, 2022, the unit began end-of-cycle coastdown. On February 11, 2022, the unit was downpowered to 85 percent to avoid a known oscillation region during end-of-cycle coastdown. On March 7, 2022, the unit was shut down for a planned refueling outage. Startup was commenced on March 25, 2022, and rated thermal power was reached on March 29, 2022. Later that day, the unit was downpowered to 80 percent for a planned rod pattern adjustment. During the downpower, a main turbine control valve malfunction required an additional downpower to 60 percent. The unit returned to rated thermal power on March 31, 2022, and remained at or near rated thermal power for the remainder of the inspection period.
On January 7, 2022, the unit was downpowered to 78 percent to perform planned control r od channel interference testing and a control rod pattern adjustment, and returned to rated thermal power on January 8, 2022.
 
On January 28, 2022, the unit began end-of-cycle coastdown.
 
On February 11, 2022, the unit was downpowered to 85 percent to avoid a known oscillation region during end-of-cycle coastdown. On March 7, 2022, the unit was shut down for a planned refueling outage.
 
Startup was commenced on March 25, 2022, and rated thermal power was reached on March 29, 2022.
 
Later that day, the unit was downpowered to 80 percent for a planned rod pattern adjustment. During the downpower, a main turbine control valve malfunction required an additional downpower to 60 percent.
 
The unit returned to rated thermal power on March 31, 2022, and remained at or near rated thermal power for the remainder of the inspection period.


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


On February 1, 2022, the operating license for Nine Mile Point Nuclear Station, held by Exelon Generation Company, LLC, was transferred to Constellation Energy Generation, LLC (Constellation). While some or all of the inspections documented in this report were performed while the license was held by Exelon Generation Company, LLC, this report will refer to the licensee as Constellation throughout.
On February 1, 2022, the operating license for Nine Mile Point Nuclear Station, held by Exelon Generation Company, LLC, was transferred to Constellation Energy Generation, LLC (Constellation). While some or all of the inspections documented in this report w ere performed while the license was held by Exelon Generation Company, LLC, this report will refer to the licensee as Constellation throughout.


==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==
===Impending Severe Weather Sample (IP Section 03.02) (1 Sample)===
===Impending Severe Weather Sample (IP Section 03.02) (1 Sample)===
: (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-             significant systems due to a winter storm warning on March 11, 2022.
: (1) The inspectors evaluated the adequacy of the overall preparations to protect risk -
 
significant systems due to a winter storm warning on March 11, 2022.
==71111.04 - Equipment Alignment==


==71111.04 - Equipm ent Alignment==
===Partial Walkdown Sample (IP Section 03.01) (7 Samples)===
===Partial Walkdown Sample (IP Section 03.01) (7 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
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==71111.05 - Fire Protection==
==71111.05 - Fire Protection==
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (9 Sam ples)


===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (9 Samples)===
The inspectors evaluated the implementation of the fire protection program by con ducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
: (1) Unit 2 radwaste building 261/265, condensate storage building, fire area 55, on February 1, 2022
: (1) Unit 2 radwaste building 261/265, condensate storage building, fire area 55, on February 1, 2022
: (2) Unit 2 reactor building 289, fire areas 34 and 35, on February 10, 2022
: (2) Unit 2 reactor building 289, fire areas 34 and 35, on February 10, 2022
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==71111.06 - Flood Protection Measures==
==71111.06 - Flood Protection Measures==
===Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)===
===Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)===
: (1) The inspectors evaluated internal flooding mitigation protections in the Unit 1 cable           spreading room on February 28, 2022.
: (1) The inspectors evaluated internal flooding mitigation protections in the Unit 1 cable spreading room on February 28, 2022.


==71111.07A - Heat Exchanger/Sink Performance==
==71111.07A - Heat Exchanger/Sink Performance==
===Annual Review (IP Section 03.01) (1 Sample)===
===Annual Review (IP Section 03.01) (1 Sample)===
The inspectors evaluated readiness and performance of:
The inspectors evaluated readiness and performance of:
: (1) Unit 2 'B' residual heat removal heat exchanger
: (1) Unit 2 'B' residual heat removal heat exchanger
==71111.08G - Inservice Inspection Activities (BWR)==
==71111.08G - Inservice Inspection Activities (BWR)==
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding


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{{IP sample|IP=IP 71111.08G|count=1}}
{{IP sample|IP=IP 71111.08G|count=1}}
: (1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation, and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from March 7 to March 17, 2022:
: (1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation, and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from March 7 to March 17, 2022:
* Automated phased array ultrasonic testing of the N1B reactor recirculation nozzle to safe-end dissimilar metal weld, 2RPV-KB02 (NDE Report N2R18-APR-02).
* Automated phased array ultrasonic testing of the N1B reactor recirculation nozzle to safe-end dissimilar metal weld, 2RPV -KB02 (NDE Report N2R18-APR-02).
* Automated phased array ultrasonic testing of the N4E reactor feedwater nozzle to safe-end dissimilar metal weld, 2RPV-KB21 (NDE Report N2R18-APR-09).
* Automated phased array ultrasonic testing of the N4E reactor feedwater nozzle to safe-end dissimilar metal weld, 2RPV -KB21 (NDE Report N2R18-APR-09).
* Manual ultrasonic testing of the reactor water cleanup system pipe-to-pipe and valve-to-pipe welds, 2WCS-09-14-FW039 / -FW040 (NDE Reports
* Manual ultrasonic testing of the reactor water cleanup system pipe-to-pipe and valve-to-pipe welds, 2W CS-09-14-FW039 / - FW040 (NDE Reports


{{a|2R18}}
{{a|2R18}}
==2R18 -ISI-UT-002 / -003).
 
                * ==
==2R18 - ISI-UT-002 / -003).
*==
Visual examinations of the containment, including accessible portions of the drywell and suppression chamber metal liner (Work Order [WO] C93672957)
Visual examinations of the containment, including accessible portions of the drywell and suppression chamber metal liner (Work Order [WO] C93672957)
* Welding activities associated with the modification of the instrument air check valve, 2IAS*V450, under engineering change ECP-21-000088 (Work Order
* Welding activities associated with t he modification of the instrument air check valve, 2IAS*V450, under engineering change ECP -21- 000088 (Work Order
                    [WO] 93782709). This included liquid penetrant testing of two pipe-to-valve welds, FW-03 and FW-04 (NDE Report BOP-PT-22-004).
[WO] 93782709). This included liquid penetrant testing of two pipe-to-valve welds, FW-03 and FW-04 (NDE Report BOP-PT-22-004).
* Flaw evaluation of the embedded reflector identified during the spring 2020 refueling outage using automated phased array UT on the N2J reactor recirculation nozzle to safe-end dissimilar metal weld (NDE Report N2R17-APR-06). The flaw was determined to be acceptable for continued service.
* Flaw evaluation of the embedded reflector identified during the spring 2020 refueling outage using automated phased array UT on the N2J reactor recirculation nozzle to safe-end dissimilar metal weld (NDE Report N2R17-APR-06). The flaw was determined to be acceptabl e for continued service.


==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
 
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
: (1) The inspectors observed Unit 1 operations personnel during control rod exercising operability testing on March 5, 2022.
: (1) The inspectors observed Unit 1 operations personnel during control rod exercising operability testing on March 5, 2022.
: (2) The inspectors observed Unit 2 operations personnel during the plant shutdown for refueling outage N2R18 on March 6, 2022.
: (2) The inspectors observed Unit 2 operations personnel during the plant shutdown for refueling outage N2R18 on March 6, 2022.


===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)===
Licensed Operator Requalification Training /Examinations (IP Section 03.02) (2 Samples)
: (1) The inspectors observed a Unit 2 simulator evaluation that included an instrument air compressor failure, reactor core isolation cooling system inoperability, and a small loss of coolant accident with additional failures that required the depressurization of the reactor on January 25, 2022.
: (1) The inspectors observed a Unit 2 simulator evaluation that included an instrument air compressor failure, reactor core isolation cooling system inoperability, and a small loss of coolant accident with additional failures that required the depressurization of the reactor on January 25, 2022.
: (2) The inspectors observed a Unit 1 simulator evaluation that included the inadvertent opening of an electromatic relief valve, a loss of offsite power, an emergency diesel generator failure to start, and a steam leak in the drywell on February 2, 2022.
: (2) The inspectors observed a Unit 1 simulator evaluation that included the inadvertent opening of an electromatic relief valve, a loss of offsite power, an emergency di esel generator failure to start, and a steam leak in the drywell on February 2, 2022.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
===Maintenance Effectiveness (IP Section 03.01) (1 Sample)===
===Maintenance Effectiveness (IP Section 03.01) (1 Sample)===
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
The inspectors evaluated the effectiveness of maintenance to ensure the f ollowing structures, systems, and components (SSCs) remain capable of performing their intended function:
: (1) Unit 2 Division I emergency diesel generator jacket water pump
: (1) Unit 2 Division I emergency diesel generator jacket water pump


==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
Risk Assessment and Management Sample (IP Section 03.01) (9 Sam ples)


===Risk Assessment and Management Sample (IP Section 03.01) (9 Samples)===
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
: (1) Unit 2 elevated risk during planned 'B' residual heat removal pump maintenance on January 4, 2022
: (1) Unit 2 elevated risk during planned 'B' residual heat removal pump maintenance on January 4, 2022
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: (4) Unit 2 elevated risk during planned Division I emergency diesel generator maintenance on February 22, 2022
: (4) Unit 2 elevated risk during planned Division I emergency diesel generator maintenance on February 22, 2022
: (5) Unit 2 elevated risk during emergent work on the 'B' service water pump on March 2, 2022
: (5) Unit 2 elevated risk during emergent work on the 'B' service water pump on March 2, 2022
: (6) Unit 2 elevated risk during a planned 115-kilovolt Line 5 outage on March 6, 2022
: (6) Unit 2 elevated risk during a planned 115 -kilovolt Line 5 outage on March 6, 2022
: (7) Unit 2 elevated risk during a planned reactor cavity flood-up on March 8, 2022
: (7) Unit 2 elevated risk during a planned reactor cavity flood-up on March 8, 2022
: (8) Unit 2 elevated risk during planned maintenance on SWP*MOV66B, cooling water to Division II emergency diesel generator, on March 10-12, 2022
: (8) Unit 2 elevated risk during planned maintenance on SWP*MOV66B, cooling water to Division II emergency diesel generator, on March 10- 12, 2022
: (9) Unit 2 elevated risk during a planned reactor cavity draindown on March 22, 2022
: (9) Unit 2 elevated risk during a planned reactor cavity draindown on March 22, 2022


==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessme nts==
Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)


===Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)===
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
: (1) Unit 2 Division I emergency diesel generator slow start on January 3, 2022
: (1) Unit 2 Division I emergency diesel generator slow start on January 3, 2022
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: (5) Unit 1 emergency diesel generator 103 starting flywheel chipped tooth on February 15, 2022
: (5) Unit 1 emergency diesel generator 103 starting flywheel chipped tooth on February 15, 2022
: (6) Unit 1 containment spray raw water 122 rate set valve unable to operate on February 24, 2022
: (6) Unit 1 containment spray raw water 122 rate set valve unable to operate on February 24, 2022
: (7) Unit 1 core spray topping pump 111 pump-bearing oil leak on March 2, 2022
: (7) Unit 1 core spray topping pump 111 pump -bearing oil leak on March 2, 2022
: (8) Unit 2 Division III diesel under voltage relay failure to reset after testing on March 4, 2022
: (8) Unit 2 Division III diesel under voltage relay failure to reset after testing on March 4, 2022
: (9) Unit 2 main steam isolation valve slow fast closure times on March 7, 2022
: (9) Unit 2 main steam isolation valve slow fast closure times on March 7, 2022


==71111.18 - Plant Modifications==
==71111.18 - Plant Modifications==
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)


Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(3 Samples)
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) Permanent Modification: ECP-21-000437, Unit 2 Division II Emergency Diesel Generator Governor Booster
: (1) Perm anent Modification: ECP-21-000437, Unit 2 Division II Emergency Diesel Generator Governor Booster
: (2) Permanent Modification: ECP-21-000454, Unit 2 Digital Electro-Hydraulic Control (DEHC) Low Pass Filter Modification
: (2) Permanent Modification: ECP-21-000454, Unit 2 Digital Electro-Hydraulic Control (DEHC) Low Pass Filter Modification
: (3) Permanent Modification: ECP-21-000088, Unit 2 PCIV [primary containment isolation valve] Supply Nitrogen Line Primary Containment Inboard Isolation Re-Design
: (3) Perm anent Modification: ECP-21-000088, Unit 2 PCIV [primary containment isolation valve] Supply Nitrogen Line Primary Containment Inboard Isolation Re-Design


==71111.19 - Post-Maintenance Testing==
==71111.19 - Post-Maintenance Testing==
Post-Maintenance Test Sample (IP Section 03.01) (5 Sam ples)


===Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)===
The inspectors evaluated the following post -maintenance testing activities to verify system operability and/or functionality:
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
: (1) Unit 2 Division I emergency diesel generator jacket water pump following replacement on February 23, 2022
: (1) Unit 2 Division I emergency diesel generator jacket water pump following replacement on February 23, 2022
: (2) Unit 2 'B' service water pump following a failure to start on March 2, 2022
: (2) Unit 2 'B' service water pump following a failure to start on March 2, 2022
: (3) Unit 2 Division II emergency diesel generator following governor oil booster installation on March 21, 2022
: (3) Unit 2 Division II emergency diesel generator following governor oil bo oster installation on March 21, 2022
: (4) Unit 2 'B' residual heat removal system following heat exchanger inspection on March 25, 2022
: (4) Unit 2 'B' residual heat removal system following heat exchanger inspectio n on March 25, 2022
: (5) Unit 2 drywell nitrogen supply system following solenoid operated valve replacement on March 28, 2022
: (5) Unit 2 drywell nitrogen supply system following solenoid operated valve replacement on March 28, 2022


==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==
===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)===
===Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)===
: (1) The inspectors evaluated Unit 2 refueling outage N2R18 from March 6 to           March 27, 2022.
: (1) The inspectors evaluated Unit 2 refueling outage N2R18 from March 6 to March 27, 2022.


==71111.22 - Surveillance Testing==
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:


===Surveillance Tests (other) (IP Section 03.01) (8 Samples)===
===Surveillance Tests (other) (IP Section 03.01) (8 Samples)===
: (1) N1-ST-M4A, Emergency Diesel Generator 102 and PB 102 Operability Test, on January 24, 2022
: (1) N1-ST-M4A, Emergency Diesel Generator 102 and PB 102 Operability Test, on January 24, 2022
: (2) N2-OSP-CSL-Q@002, LPCS [low pressure core spray] Pump and Valve Operability and System Integrity Test, on February 28, 2022
: (2) N2-OSP-CSL-Q@00 2, LPCS [low pressure core spray] Pump and Valve Operability and System Integrity Test, on February 28, 2022
: (3) N1-ST-Q1A, Core Spray 111 Pump, Valve and Shutdown Cooling Water Seal Check Valve Operability Test, on March 1, 2022
: (3) N1-ST-Q1A, Core Spray 111 Pump, Valve and Shutdown Cooling Water Seal Check Va lve Operability Test, on March 1, 2022
: (4) N2-OSP-MSS-CS001, Main Steam Isolation Valve Operability Test, on March 7, 2022
: (4) N2-OSP-MSS-CS001, Main Steam Isolation Valve Operability Test, on March 7, 2022
: (5) N2-OSP-RHS-R001, Division II ECCS [emergency core cooling system] Functional Test, on March 9, 2022
: (5) N2-OSP-RHS-R001, Division II ECCS [emergency core cooling system] Functional Test, on March 9, 2022
: (6) N2-OSP-SLS-R001, Standby Liquid Control Manual Initiate Actuation and ASME XI Pressure Test, on March 16, 2022
: (6) N2-OSP-SLS-R001, Standby Liquid Control Manual Initiate Actuation and ASME XI Pressure Test, on March 16, 2022
: (7) N2-OSP-ADS-R002, ADS [automatic depressurization system] Functional Test and Remote Shutdown System Test, on March 19, 2022
: (7) N2-OSP-ADS-R002, ADS [automatic depressurization system] Functional Test and Remote Shutdown System Test, on March 19, 2022
: (8) N2-OSP-EGS-R001, Diesel Generator ECCS Start and Load Reject Division II, on
: (8) N2-OSP-EGS-R001, Diesel Generator ECCS Start and Load Reject Division II, on March 20, 2022


===March 20, 2022 Inservice Testing (IP Section 03.01) (2 Samples)===
Inservice Testing (IP Section 03.01) (2 Sam ples)
: (1) N2-OSP-ICS-Q@002, Reactor Core Isolation Cooling Pump and Valve Operability Test and System Integrity Test and ASME XI Functional Test and Analysis, on February 10, 2022
: (1) N2-OSP-I CS-Q@002, Reactor Core Isolation Cooling Pump and Valve Operability Test and System Integrity Test and ASME XI Functional Test and Analysis, on February 10, 2022
: (2) N2-ISP-RRC-R001, ARI [alternate rod insertion] Function of RRCS [redundant reactivity control system], on March 7, 2022
: (2) N2-ISP-RRC-R001, ARI [alternate rod insertion] Function of RRCS [redundant reactivity control system], on March 7, 2022


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==RADIATION SAFETY==
==RADIATION SAFETY==
==71124.01 - Radiological Hazard Assessment and Exposure Controls==
==71124.01 - Radiological Hazard Assessment and Exposure Controls==
===Radiological Hazard Assessment (IP Section 03.01) (1 Sample)===
===Radiological Hazard Assessment (IP Section 03.01) (1 Sample)===
: (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how Constellation assesses radiological hazards.
: (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how Constellation assesses radiological hazards.
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: (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
: (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.


===Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)===
Contamination and Radioactive Material Control (IP Section 03.03) (2 Sam p les)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
 
The inspectors observed/evaluated the following licensee process es for monitoring and controlling contamination and radioactive material:
: (1) Workers exiting the Unit 2 radiologically controlled area during refueling outage N2R18
: (1) Workers exiting the Unit 2 radiologically controlled area during refueling outage N2R18
: (2) Licensee surveys of contaminated equipment on the refuel floor during refueling outage N2R18
: (2) Licensee surveys of contaminated equipment on the refuel floor during refueling outage N2R18
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: (3) Unit 2 refuel floor equipment decontamination activities
: (3) Unit 2 refuel floor equipment decontamination activities
: (4) Unit 2 drywell feedwater nozzle inspection activities
: (4) Unit 2 drywell feedwater nozzle inspection activities
: (5) Unit 2 safety relief valve maintenance in the drywell High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
: (5) Unit 2 safety relief valve maintenance in the drywell
 
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)
 
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
: (1) High Radiation Area in the Unit 2 reactor building valve pit, 196' elevation
: (1) High Radiation Area in the Unit 2 reactor building valve pit, 196' elevation
: (2) Locked High Radiation Areas in the Unit 2 drywell Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
: (2) Locked Hig h Radiation Areas in the Unit 2 drywell
 
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
: (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
: (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.


==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:


===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Sam ples)
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===
{{IP sample|IP=IP 71151|count=2}}
: (1) Unit 1 (January 1, 2021 through December 31, 2021)
: (1) Unit 1 (January 1, 2021 through December 31, 2021)
: (2) Unit 2 (January 1, 2021 through December 31, 2021)
: (2) Unit 2 (January 1, 2021 through December 31, 2021)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)
(2 Samples)
 
===
{{IP sample|IP=IP 71151|count=2}}
: (1) Unit 1 (January 1, 2021 through December 31, 2021)
: (1) Unit 1 (January 1, 2021 through December 31, 2021)
: (2) Unit 2 (January 1, 2021 through December 31, 2021)
: (2) Unit 2 (January 1, 2021 through December 31, 2021)


===IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)===
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
: (1) Unit 1 (January 1, 2021 through December 31, 2021)
: (1) Unit 1 (January 1, 2021 through December 31, 2021)
: (2) Unit 2 (January 1, 2021 through December 31, 2021)
: (2) Unit 2 (January 1, 2021 through December 31, 2021)


===71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03) ===
===71152A - Annual Follow -up Problem Identification and Resolution Annual Follow -up of Selected Issues (Section 03.03)===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
Line 266: Line 299:


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Observation: Nine Mile Point Control Rod Blade Technical Evaluation                     71152A On November 23, 2020, General Electric Hitachi (GEH) released Safety Communication 20-06 (SC 20-06) Revision 0, describing the discovery that Boron 10 (B-10) depletion had been underpredicted in the top 6-inch node of the neutron absorber section of control rod blades currently in use in boiling water reactors in the United States. Nine Mile Point Nuclear Station was on the list of plants affected by this issue. In Revision 0 of the Safety Communication, the population of control rod blades affected was restricted to Original Equipment Manufacturer (OEM) series D-100 control rod blades, still in operation from the 1970s and 1980s. On February 26, 2021, GEH issued Revision 1 to SC 20-06, in which it was determined that the population of control rod blades affected by the underprediction of B-10 in the tip segment included all control rod blades that did not contain Hafnium (Hf) in the tips, not just OEM D-100 control rod blades. This greatly increased the population of control rod blades affected by this issue.
Observation: Nine Mile Point Control Rod Blade Techni cal Evaluation 71152A On November 23, 2020, General Electric Hitachi (GEH) released Safety Communication 20 -
06 (SC 20- 06) Revision 0, describing the discovery that Boron 10 (B -10) depletion had been underpredicted in the top 6-inch node of the neutron absorber section of control rod blades currently in use in boiling water reactors in the United States. Nine Mile Point Nuclear Station was on the list of plants affected by this issue.
 
In Revision 0 of the Safety Communication, the population of control rod blades affected was restricted to Original Equipment Manufacturer (OEM) series D-100 control rod blades, still in operation from the 1970s and 1980s. On February 26, 2021, GEH issued Revision 1 to SC 20- 06, in which it was determined that the population of control rod blades affected by the underprediction of B -10 in the tip segm ent included all control rod blades that did not contain Hafnium (Hf) in the tips, not just OEM D-100 control rod blades. This greatly increased the population of control rod blades affected by this issue.


Control rod blades deplete the B-10 isotope as they absorb neutrons when they are inserted into an operating reactor core. Control rod blades are typically fully withdrawn from the core when the reactor is at full power. However, the tips of the control rod blades still experience some thermal neutron flux. The B-10 depletion in the top node of the control rod blade is accounted for in engineering analysis by adding a "tip adder" factor in the B-10 depletion calculation for each control rod blade. Safety Communication SC 20-06 stated that the tip adder factor was much larger than previously calculated, for control rod blades without Hf in the tips. General Electric manufactured control rod blades with Hf tips for a period of time in the 1980s and 1990s that are excluded from the tip adder issue described in SC 20-06. All other control rod blade models, including the OEM blades, are affected by the tip adder issue described in SC 20-06. The higher depletion values in the control rod blade tips for multiple control rod blade types may cause the control rod blade to exceed its effective neutron absorbing capability before the end of the operating fuel cycle. This has the potential to decrease the overall shutdown margin (SDM), which is the ability of all the control rods, except for the most reactive control rod, to shut down the reactor core in all anticipated normal and accident scenarios.
Control rod blades deplete the B -10 isotope as they absorb neutrons when they are inserted into an operating reactor core. Control rod blades are typically fully withdrawn from the core when the reactor is at full power. However, the tips of the control rod blades still experience some thermal neutron flux. The B -10 depletion in the top node of the control rod blade is accounted for in engineering analysis by adding a "tip adder" factor in the B -10 depletion calculation for each control rod blade. Safety Communication SC 20- 06 stated that the tip adder factor was much larger than previously calculated, for control rod blades without Hf in the tips. General Electric manufactured control rod blades with Hf tips for a period of time in the 1980s and 1990s that are excluded from the tip adder issue described in SC 20 -06. All other control rod blade models, including the OEM blades, are affected by the tip adder issue described in SC 20- 06. The higher depletion values in the control rod blade tips for multiple control rod blade types may cause the control rod blade to exceed its effective neutron absorbing capability before the end of the operating fuel cycle. This has the potential to decrease the overall shutdown margin (SDM), which is the ability of all the control rods, except for the most reactive control r od, to shut down the reactor core in all anticipated normal and accident scenarios.


In Revision 1 to SC 20-06, GEH recommended all customers ensure that adequate SDM was available in the current operating fuel cycle until the end of the fuel cycle, once the amount of B-10 depletion was determined in all control rod blade tips. GEH recommended this be done for all General Electric control rod blades that did not contain Hf tips, as well as alternate vendor control rod blades. GEH also recommended all customers assess the impact of control rod blades exceeding their nuclear end of life (NEOL) criteria - the ability of the control rod blade to effectively absorb neutrons - for future fuel cycles beyond the current operating fuel cycle.
In Revision 1 to SC 20- 06, GEH recommended all customers ensure that adequate SDM was available in the current operating fuel cycle until the end of the fuel cycle, once the am ount of B-10 depletion was determined in all control rod blade tips. GEH recommended this be done for all General Electric control rod blades that did not contain Hf tips, as well as alternate vendor control rod blades. GEH also recommended all customers assess the impact of control rod blades exceeding their nuclear end of life (NEOL) criteria - the ability of the control rod blade to effectively absorb neutrons - fo r future fuel cycles beyond the current operating fuel cycle.


Following issuance of GEH SC 20-06, Revision 1, Nine Mile Point Unit 1 entered a refueling outage in March 2021. A control rod blade depletion engineering evaluation was performed, taking into account the new tip adder calculation in SC 20-06. It was determined that two control rod blades that had been located in higher power locations in the previous fuel cycle would be shuffled to two lower power locations in the core for the current Unit 1 operating fuel cycle. No control rod blades in the previous or current fuel cycle have exceeded their NEOL criteria, thus requiring replacement.
Following issuance of GEH SC 20-06, Revision 1, Nine Mile Point Unit 1 entered a refueling outage in March 2021. A control rod blade depletion engineering evaluation was performed, taking into account the new tip adder calculation in SC 20- 06. It was determined that two control rod blades that had been located in higher power locations in the previous fuel cycle would be shuffled to two lower power locations in the core for the current Unit 1 operating fuel cycle. No control rod blades in the previous or current fuel cycle have exceeded their NEOL criteria, thus requiring replacement.


In July 2021, Exelon Nuclear Fuels validated that adequate SDM existed for the remainder of the current fuel cycle for Nine Mile Point Unit 2, and that thermal limit margins were not impacted. One control rod blade on the core periphery was predicted to exceed its NEOL criteria due to the tip adder issue described in SC 20-06, before the end of the Unit 2 fuel cycle in March 2022. This blade, along with six other control rod blades, are scheduled for replacement in the upcoming refueling outage. In September 2021, General Electric Global Nuclear Fuels completed an analysis to confirm that SDM would be maintained above the technical specification limit for the remainder of the Unit 2 fuel cycle. Exelon procedure NF-AB-135-1410, "BWR Control Blade Lifetime Management," contains guidance for calculating B-10 depletion in all models of control rod blades currently in operation in the nuclear fleet.
In July 2021, Exelon Nuclear Fuels validated that adequate SDM existed for the remainder of the current fuel cycle for Nine Mile Point Unit 2, and that thermal limit margins were not im pa cted. One control rod blade on the core periphery was predicted to exceed its NEOL criteria due to the tip adder issue described in SC 20- 06, before the end of the Unit 2 fuel cycle in March 2022. This blade, along with six other control rod blades, are scheduled for replacement in the upcoming refueling outage. In September 2021, General Electric Global Nuclear Fuels completed an analysis to confirm that SDM would be maintained above the technical specification limit for the remainder of the Unit 2 fuel cycle. Exelon procedure NF -
AB-135-1410, "BWR Control Blade Lifetime Management," contains guidance for calculating B-10 depletion in all models of control rod blades currently in operation in the nuclear fleet.


This procedure will require an update to incorporate the new guidance from SC 20-06, for estimating the tip adder factor for non-Hf tipped control rod blades. Issue Report 04242262 is tracking completion of this procedural update.
This procedure will require an update to incorpora te the new guidance from SC 20- 06, for estimating the tip adder factor for non-Hf tipped control rod blades. Issue Report 04242262 is tracking completion of this procedural update.


The inspectors interviewed engineering staff from Exelon Nuclear Fuels and Nine Mile Point Reactor Engineering to discuss corrective actions taken in response to GEH SC 20-06, and reviewed shutdown margin and control rod blade depletion engineering evaluations. The inspectors also reviewed the corrective actions taken and planned for responding to GEH SC 20-06 entered into the corrective action system. No performance deficiencies were identified.
The inspectors interviewed engineering staff from Exelon Nuclear F uels and Nine Mile Point Reactor Engineering to discuss corrective actions taken in response to GEH SC 20-06, and reviewed shutdown margin and control rod blade depletion engineering evaluations. The inspectors also reviewed the corrective actions taken and planned for responding to GEH SC 20- 06 entered into the corrective action system. No performance deficiencies were identified.


Corrective Action References: 04242262, 04386300,
Corrective Action References: 04242262, 04386300,
Line 284: Line 321:
==EXIT MEETINGS AND DEBRIEFS==
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.
The inspectors verified no proprietary information was retained or documented in this report.
* On April 21, 2022, the inspectors presented the integrated inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the licensee staff.
* On April 21, 2022, the inspector s presented the integrated inspection results to Mr. Peter Orphanos, Site Vice Preside n t, and other members of the licensee staff.
* On February 8, 2022, the inspectors presented the control rod blade technical evaluation problem identification and resolution inspection results to Philip Nichols, Manager Reactor Engineering, and other members of the licensee staff.
* On February 8, 2022, the inspectors presented the control rod blade technical evaluation problem identification and resolution inspection results to Philip Nichols, Manager Reactor Engineering, and other members of the licensee staff.
* On March 17, 2022, the inspectors presented the Unit 2 inservice inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the licensee staff.
* On March 17, 2022, the inspector s presented the Unit 2 i nservice inspection results to Mr. Pe ter Orphanos, Site Vice President, and other members of the licensee staff.
* On March 17, 2022, the inspectors presented the radiological hazard assessment and exposure controls inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the licensee staff.
* On March 17, 2022, the inspector s presented the radiological hazard assessment and exposure controls inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the licensee staff.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type             Designation     Description or Title                                         Revision or
Inspection Type Designation Description or Title Revision or
Procedure                                                                                                 Date
Procedure Date
71111.01   Procedures       N1-OP-64       Meteorological Monitoring                                     02100
71111.01 Procedures N1-OP-64 Meteorological Monitoring 02100
N2-OP-102       Meteorological Monitoring                                     02800
N2-OP-102 Meteorological Monitoring 02800
OP-AA-108-111- Severe Weather and Natural Disaster Guidelines               24
OP-AA-108-111-Severe Weather and Natural Disaster Guidelines 24
1001
1001
71111.04   Drawings         C-18022-C       Piping & Instrumentation Diagram, Reactor Building Closed     55
71111.04 Drawings C-18022-C Piping & Instrumentation Diagram, Reactor Building Closed 55
Loop Cooling System
Loop Cooling System
PID-031A, B, E Piping & Instrumentation Diagram Residual Heat Removal       27
PID-031A, B, E Piping & Instrumentation Diagram Residual Heat Removal 27
System
System
PID-31G         Piping & Instrumentation Diagram Residual Heat Removal       15
PID-31G Piping & Instrumentation Diagram Residual Heat Removal 15
PID-35A         Piping & Instrumentation Diagram Reactor Core Isolation       17
PID-35A Piping & Instrumentation Diagram Reactor Core Isolation 17
Cooling
Cooling
PID-35B         Piping & Instrumentation Diagram Reactor Core Isolation       13
PID-35B Piping & Instrumentation Diagram Reactor Core Isolation 13
Cooling
Cooling
PID-38B         Piping & Instrumentation Diagram Fuel Pool Cooling &         15
PID-38B Piping & Instrumentation Diagram Fuel Pool Cooling & 15
Cleanup
Cleanup
PID-38C         Piping & Instrumentation Diagram Fuel Pool Cooling &         17
PID-38C Piping & Instrumentation Diagram Fuel Pool Cooling & 17
Cleanup
Cleanup
Procedures       N1-OP-11       Reactor Building Closed Loop Cooling System                   03400
Procedures N1-OP-11 Reactor Building Closed Loop Cooling System 03400
N2-OP-100A     Standby Diesel Generators                                     03200
N2-OP-100A Standby Diesel Generators 03200
N2-OP-100A-     Standby Diesel Generators - LINEUPS                           00500
N2-OP-100A-Standby Diesel Generators - LINEUPS 00500
LINEUPS
LINEUPS
N2-OP-31       Residual Heat Removal System                                 03700
N2-OP-31 Residual Heat Removal System 03700
N2-OP-31-       Residual Heat Removal System                                 003
N2-OP-31-Residual Heat Removal System 003
LINEUPS
LINEUPS
N2-OP-38       Spent Fuel Cooling and Cleanup System                         2700
N2-OP-38 Spent Fuel Cooling and Cleanup System 2700
71111.05   Corrective Action 04477281
71111.05 Corrective Action 04477281
Documents
Docum ents
Drawings         B-40143-C       Fire Zones Reactor Building - Fl. El. 261' Turbine Building - 10
Drawings B-40143-C Fire Zones Reactor Building - Fl. El. 261' Turbine Building - 10
Fl. El. 261' Fire Rated Walls and Slabs
Fl. El. 261' Fire Rated Walls and Slabs
Fire Plans       N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans                                         06
Fire Plans N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans 06
71111.06   Corrective Action 04416206
71111.06 Corrective Action 04416206
Documents        04477927
Docum ents 04477927
Inspection Type             Designation   Description or Title                                   Revision or
Inspection Type Designation Description or Title Revision or
Procedure                                                                                           Date
Procedure Date
04661043
04661043
71111.07A Corrective Action 04484882
71111.07A Corrective Action 04484882
Documents        04486864
Docum ents 04486864
Procedures       ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide           11
Procedures ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide 11
S-TDP-REL-0102 Service Water Heat Exchanger and Component Inspection   03
S-TDP-REL-0102 Service Water Heat Exchanger and Component Inspection 03
Guide
Guide
Work Orders       C93738267
Work Orders C93738267
71111.08G Corrective Action 04327298
71111.08G Corrective Action 04327298
Documents
Docum ents
Corrective Action 04484400
Corrective Action 04484400
Documents
Docum ents
Resulting from
Resulting from
Inspection
Inspection
Engineering       ECP-20-000224 Recirculation Inlet Nozzle DMW No. 2RPV-KB11 (N2J) Flaw 03/25/2020
Engineering ECP-20-000224 Recirculation Inlet Nozzle DMW No. 2RPV-KB11 (N2J) Flaw 03/25/2020
Evaluations                     Evaluation
Evaluations Evaluation
Miscellaneous     ER-NM-330-2001 ISI Program Plan Fourth Ten-Year Inspection Interval   Revision 3
Miscellaneous ER-NM-330-2001 ISI Program Plan Fourth Ten-Year Inspection Interval Revision 3
ER-NM-330-2004 Risk Informed Inservice Inspection Program Fourth Ten- Revision 0
ER-NM-330-2004 Risk Informed Inservice Inspection Program Fourth Ten-Revision 0
Year Inspection Interval
Year Inspection Interval
Procedures       ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic   Revision 15
Procedures ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic Revision 15
Liners of Class CC Components
Liners of Class CC Components
ER-AA-335-030 Ultrasonic Examination of Ferritic Piping Welds         Revision 5
ER-AA-335-030 Ultrasonic Examination of Ferritic Piping Welds Revision 5
ER-AA-335-1000 Nondestructive Examination (NDE)                       Revision 16
ER-AA-335-1000 Nondestructive Examination (NDE) Revision 16
GEH-UT-254     Automated Phased Array Ultrasonic Examination of       Version 1
GEH-UT-254 Automated Phased Array Ultrasonic Examination of Version 1
Dissimilar Metal Welds with the TOPAZ
Dissimilar Metal Welds with the TOPAZ
WPS 8-8-GTSM   Welding Procedure Specification Record for Manual GTAW Revision 7
WPS 8-8-GTSM Welding Procedure Specification Record for Manual GTAW Revision 7
and SMAW of P-Number 8 to P-Number 8 Base Metal
and SMAW of P-Number 8 to P-Number 8 Base Metal
71111.11Q Procedures         N1-ST-W1       Control Rod Exercising Operability Test                 02300
71111.11Q Procedures N1-ST-W1 Control Rod Exercising Operability Test 02300
N2-OP-101C     Plant Shutdown                                         04100
N2-OP-101C Plant Shutdown 04100
N2-OP-29       Reactor Recirculation System                           03400
N2-OP-29 Reactor Recirculation System 03400
N2-OP-31       Residual Heat Removal System                            03700
N2-OP-31 Residual Heat Remova l S yst em 03700
71111.12   Procedures       N2-MSP-EGS-   Diesel Generator Inspection Division 1 and 2           025
71111.12 Procedures N2-MSP-EGS-Diesel Generator Inspection Division 1 and 2 025
R001
R001
Work Orders       C938144677
Work Orders C938144677
71111.13   Corrective Action 04481795
71111.13 Corrective Action 04481795
Inspection Type             Designation     Description or Title                                         Revision or
 
Procedure                                                                                                 Date
Inspection Type Designation Description or Title Revision or
Documents
Procedure Date
Procedures       N2-OP-19-       Instrument and Service Air Systems                           8
Docum ents
Procedures N2-OP-19-Instrument and Service Air Systems 8
Lineups
Lineups
N2-OP-70       Station Electrical Feed and 115KV Switchyard                 02800
N2-OP-70 Station Electrical Feed and 115KV Switchyard 02800
N2-PM-082       RPV [reactor pressure vessel] Flood-Up/Draindown             01900
N2-PM-082 RPV [reactor pressure vessel] Flood-Up/Draindown 01900
OP-NM-108-117   Protected Equipment Program at Nine Mile Point               5
OP-NM-108-117 Protected Equipm ent Program at Nine Mile Point 5
OP-NM-108-117   Protected Equipment Program at Nine Mile Point               00500
OP-NM-108-117 Protected Equipm ent Program at Nine Mile Point 00500
OU-NM-103-101   Shutdown Safety Management Program                           0700
OU-NM-103-101 Shutdown Safety Management Program 0700
71111.15   Calculations     002N3714       Nine Mile Point Nuclear Station Unit 1 TRACG-LOCA             0
71111.15 Calculations 002N3714 Nine Mile Point Nuclear Station Unit 1 TRACG-LOCA 0
Analysis for GNF2 Fuel
Analysis for GNF2 Fuel
Corrective Action 04061889
Corrective Action 04061889
Documents        04470659
Docum ents 04470659
04475343
04475343
04476776
04476776
Line 381: Line 419:
04483059
04483059
04488015
04488015
Drawings         0001040209048   Control Diagram Shutdown System                               13.00
Drawings 0001040209048 Control Diagram Shutdown System 13.00
Engineering       ECP-22-000147   Technical Evaluation for MSIV Failed Stroke Time Extent of   0000
Engineering ECP-22-000147 Technical Evaluation for MSIV Failed Stroke Time Extent of 0000
Changes                           Condition
Changes Condition
Miscellaneous     NEI 06-09-A     Risk-Informed Technical Specifications Initiative 4b: Risk-   0
Miscellaneous NEI 06-09-A Risk-Informed Technical Specifications Initiative 4b: Risk-0
Managed Technical Specifications (RMTS) Guidelines
Managed Technical Specifications (RMTS) Guidelines
Purchase Order Service, Repair, Refurbishment of MSIV Actuator Air Pack     2
Purchase Order Service, Repair, Refurbishment of MSIV Actuator Air Pack 2
00802656
00802656
RICT Record for Failed MSIV 7D RPS Testing                                   04/06/2022
RICT Record fo r Failed MSIV 7D RPS Testing 04/06/2022
March 28, 2022
March 28, 2022
Procedures       N1-OP-1         Nuclear Steam Supply System                                   07700
Procedures N1-OP-1 Nuclear Steam Supply System 07700
N2-OP-100A     Standby Diesel Generators                                     03100
N2-OP-100A Standby Diesel Generators 03100
N2-OSP-EGS-     Diesel Generator and Diesel Air Start Valve Operability Test- 024T1
N2-OSP-EGS-Diesel Generator and Diesel Air Start Valve Operability Test-024T1
M@001           Division I and II
M@001 Division I and II
OP-AA-108-118   Risk Informed Completion Time                                 2
OP-AA-108-118 Risk Informed Completion Time 2
71111.18   Corrective Action 02547530
71111.18 Corrective Action 02547530
Inspection Type             Designation   Description or Title                                         Revision or
 
Procedure                                                                                               Date
Inspection Type Designation Description or Title Revision or
Documents        02689624
Procedure Date
Docum ents 02689624
04359704
04359704
04365824
04365824
04428910
04428910
04482114
04482114
Engineering       ECP-21-000088 PCIV Supply Nitrogen Line Primary Containment Inboard       0000
Engineering ECP-21-000088 PCIV Supply Nitrogen Line Primary Containment Inboard 0000
Changes                         Isolation Re-Design
Changes Isolation Re-Design
ECP-21-000437 EDG Governor Booster                                         0000
ECP-21-000437 EDG Governor Booster 0000
ECP-21-000454 Digital Electro-Hydraulic Control (DEHC) Low Pass Filter     0
ECP-21-000454 Digital Electro-Hydraulic Control (DEHC) Low Pass Filter 0
Modification
Modification
Miscellaneous                   FAT/SAT Testing for DEHC Low Pass Filter Mod                 0000
Miscellaneous FAT/SAT Testing for DEHC Low Pass Filter Mod 0000
Procedures       N2-OSP-EGS-   Diesel Generator and Diesel Air Start Valve Operability Test 024T1
Procedures N2-OSP-EGS-Diesel Generator and Diesel Air Start Valve Operability Test 024T1
M@0001       - Division I and II
M@0001 - Division I and II
Work Orders       C93782709
Work Orders C93782709
C93809087
C93809087
C93813137
C93813137
71111.19   Corrective Action 04480094
71111.19 Corrective Action 04480094
Documents        04481795
Docum ents 04481795
04484882
04484882
04486059
04486059
Corrective Action 04486063
Corrective Action 04486063
Documents
Docum ents
Resulting from
Resulting from
Inspection
Inspection
Procedures       GAP-HSC-09   System Aging Inspection and Cleanliness Controls             02000
Procedures GAP-HSC-09 System Aging Inspection and Cleanliness Controls 02000
N2-MSP-EGS-   Diesel Generator Inspection Division I and II               02400
N2-MSP-EGS-Diesel Generator Inspection Division I and II 02400
R001
R001
N2-OSP-EGS-   Diesel Generator and Diesel Air Start Valve Operability Test 02400.01
N2-OSP-EGS-Diesel Generator and Diesel Air Start Valve Operability Test 02400.01
M@0001       - Division I and II
M@0001 - Division I and II
N2-OSP-RHS-   RHR System Loop B Pump and Valve Operability Test,           01500
N2-OSP-RHS-RHR System Loop B Pump and Valve Operability Test, 01500
Q@005         System Integrity Test and ASME XI Pressure Test
Q@005 System Integrity Test and ASME XI Pressure Test
N2-OSP-RHS-   Division II ECCS Functional Test                             00900
N2-OSP-RHS-Division II ECCS Functional Test 00900
R001
R001
Inspection Type             Designation   Description or Title                                 Revision or
 
Procedure                                                                                         Date
Inspection Type Designation Description or Title Revision or
S-EPM-GEN-004 Insulation of Power, Control, and Instrument Cable   00700
Procedure Date
S-EPM-GEN-004 Insulation of Power, Control, and Instrument Cable 00700
Connections
Connections
Work Orders       C93738267
Work Orders C93738267
C93782709
C93782709
C93814677
C93814677
C93825512
C93825512
71111.20   Corrective Action 04482986
71111.20 Corrective Action 04482986
Documents        04482995
Docum ents 04482995
04483785
04483785
04484026
04484026
Line 446: Line 486:
04485270
04485270
Corrective Action 04484400
Corrective Action 04484400
Documents        04486063
Docum ents 04486063
Resulting from
Resulting from
Inspection
Inspection
Miscellaneous     NM2C19-SU     Reactivity Maneuver Plan                             0
Miscellaneous NM2C19-SU Reactivity Maneuver Plan 0
Procedures       LS-AA-119     Fatigue Management and Work Hour Limits              15
Procedures LS-AA-119 Fatigue Management and Work Hour L im it s 15
N2-FHP-13.3   Core Shuffle                                         01200
N2-FHP-13.3 Core Shuffle 01200
N2-OP-101A     Plant Start-up                                       05400
N2-OP-101A Plant Start-up 05400
N2-OP-38       Spent Fuel Cooling and Cleanup System                 02700
N2-OP-38 Spent Fuel Cooling and Cleanup System 02700
N2-OSP-NMS-   Source Range Monitor Check During Core Offload/Reload 00201
N2-OSP-NMS-Source Range Monitor Check During Core Offload/Reload 00201
                            @002
@002
OP-AA-109-101 Personnel and Equipment Tagout Process               16
OP-AA-109-101 Personnel and Equipment Tagout Process 16
OP-AA-300     Reactivity Management                                 14
OP-AA-300 Reactivity Management 14
OP-AA-300-1520 Reactivity Management - Fuel Handling, Storage and   7
OP-AA-300-1520 Reactivity Management - Fuel Handling, Storage and 7
Refueling
Refueling
OU-NM-103-101 Shutdown Safety Management Program                   00700
OU-NM-103-101 Shutdown Safety Management Program 00700
OU-NM-4001     Refueling Operations                                 00800
OU-NM-4001 Refueling Operations 00800
71111.22   Corrective Action 04481649
71111.22 Corrective Action 04481649
Documents        04482027
Docum ents 04482027
04483059
04483059
04483200
04483200
Inspection Type             Designation     Description or Title                                       Revision or
 
Procedure                                                                                                 Date
Inspection Type Designation Description or Title Revision or
Procedure Date
04483399
04483399
04485322
04485322
Miscellaneous     Technical       MSIV Leak Rate Tests                                       Approved
Miscellaneous Technical MSIV Leak Rate Tests Approved
Evaluation N2R18                                                             03/17/2022
Evaluation N2R18 03/17/2022
Procedures       N1-ST-M4A       Emergency Diesel Generator 102 and PB 102 Operability       03000
Procedures N1-ST-M4A Emergency Diesel Generator 102 and PB 102 Operability 03000
Test
Test
N1-ST-Q1A       CS 111 Pump, Valve and SDC Water Seal Check Valve           02200
N1-ST-Q1A CS 111 Pump, Valve and SDC Water Seal Check Valve 02200
Operability Test
Operability Test
N2-ISP-RRC-     ARI [alternate rod insertion] function of RRCS [redundant   00700
N2-ISP-RRC-ARI [alternate rod insertion] function of RRCS [redundant 00700
R001             reactivity control system]
R001 reactivity control system]
N2-OSP-ADS-     ADS System Functional Test and Remote Shutdown System       009
N2-OSP-ADS-ADS System Functional Test and Remote Shutdown System 009
R002             Test
R002 Test
N2-OSP-CSL-     LPCS Pump and Valve Operability and System Integrity       01500
N2-OSP-CSL-LPCS Pump and Valve Operability and System Integrity 01500
Q@002           Test
Q@002 Test
N2-OSP-EGS-     Diesel Generator ECCS Start and Load Reject Division II     9
N2-OSP-EGS-Diesel Generator ECCS Start and Load Reject Division II 9
R001
R001
N2-OSP-ICS-     RCIC Pump and Valve Operability Test and System Integrity   01600
N2-OSP-I CS-RCIC Pump and Valve Operability Test and System Integrity 01600
Q@002           Test and ASME XI Functional Test and Analysis
Q@002 Test and ASME XI Functional Test and Analysis
N2-OSP-MSS-     Main Steam Isolation Valve Leak Rate Test                   00300
N2-OSP-MSS-Main Steam Isolation Valve Leak Rate Test 00300
003
003
N2-OSP-MSS-     Main Steam Isolation Valve Leak Rate Test (Reactor Vessel   00200
N2-OSP-MSS-Main Steam Isolation Valve Leak Rate Test (Reactor Vessel 00200
004             Head Removed)
004 Head Rem oved)
N2-OSP-MSS-     Main Steam Isolation Valve Operability Test                 01000 and
N2-OSP-MSS-Main Steam Isolation Valve Operability Test 01000 and
CS001                                                                       01100
CS001 01100
N2-OSP-SLS-     Standby Liquid Control Manual Initiate Actuation and ASME   01100
N2-OSP-SLS-Standby Liquid Control Manual Initiate Actuation and ASME 01100
R001             XI Pressure Test
R001 XI Pressure Test
71151     Procedures       NEI 99-02       Regulatory Assessment Performance Indicator Guideline       7
71151 Procedures NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7
71152A     Corrective Action 04242262
71152A Corrective Action 04242262
Documents        04386300
Docum ents 04386300
04436618
04436618
Engineering       ECP-20-000291   Control Blade Replacement Strategy for Nine Mile Point Unit 0
Engineering ECP-20-000291 Control Blade Replacement Strategy for Nine Mile Point Unit 0
Evaluations                       1 Cycle 25 (Reload 26)
Evaluations 1 Cycle 25 (Reload 26)
ECP-21-000248   Control Blade Replacement Strategy for Nine Mile Point Unit 0
ECP-21-000248 Control Blade Replacement Strategy for Nine Mile Point Unit 0
  (Reload 18)
  (Reload 18)
Inspection Type         Designation     Description or Title                                 Revision or
 
Procedure                                                                                       Date
Inspection Type Designation Description or Title Revision or
ECP-21-000380   SC 20-06: Nine Mile Point Unit 2 Cycle 18 SDM and     0
Procedure Date
ECP-21-000380 SC 20-06: Nine Mile Point Unit 2 Cycle 18 SDM and 0
MSBWP Evaluation
MSBWP Evaluation
Miscellaneous General Electric Impact of Ex-core Flux on Control Rod Lifetime Limits 02/26/2021
Miscellaneous General Electric Impact of Ex-core Flux on Control Rod Lifetime L im it s 02/26/2021
Hitachi Safety
Hitachi Safety
Communication
Communication
20-06, Rev. 1
20-06, Rev. 1
Procedures   NF-AB-130-3690   Maximum Subcritical Banked Withdrawal Position       10
Procedures NF-AB-130-3690 Maximum Subcritical Banked Withdrawal Position 10
NF-AB-135-1410   BWR Control Blade Lifetime Management                 16
NF-AB-135-1410 BWR Control Blade Lifetime Management 16
 
19
19
}}
}}

Latest revision as of 02:35, 18 November 2024

Integrated Inspection Report 05000220/2022001 and 05000410/2022001
ML22119A018
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 04/29/2022
From: Erin Carfang
NRC/RGN-I/DORS
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
Carfang E
References
IR 2022001
Download: ML22119A018 (21)


Text

April 29, 2022

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000220/2022001 AND 05000410/2022001

Dear Mr. Rhoades:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, Units 1 and 2. On April 21, 2022, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, a nd other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

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

Sincerely, Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reac to r Safety

Docket Nos. 05000220 and 05000410 License Nos. DPR-63 and NPF-69

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000220 and 05000410

License Numbers: DPR-63 and NPF -69

Report Num bers: 05000220/2022001 and 05000410/2022001

Enterprise Identifier: I-2022- 001-0049

Licensee: Constellation Energy Generation, LLC

Facility: Nine Mile Point Nuclear Station, Units 1 and 2

Location: Oswego, NY

Inspection Dates: January 1, 2022 to March 31, 2022

Inspectors: G. Stock, Senior Resident Inspector C. Kline, Resident Inspector B. Sienel, Resident Inspector N. Floyd, Senior Reactor Inspector S. Haney, Senior Project Engineer C. Hobbs, Reactor Inspector S. Wilson, Senior Health Physicist

Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees performance by conducting an integrated inspection at Nine Mile Point Nuclear Station, Units 1 and 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to h ttps://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Ite ms

None.

PLANT STATUS

Unit 1 operated at or near rated thermal power for the entire inspection period.

Unit 2 began the inspection period at rated thermal power.

On January 7, 2022, the unit was downpowered to 78 percent to perform planned control r od channel interference testing and a control rod pattern adjustment, and returned to rated thermal power on January 8, 2022.

On January 28, 2022, the unit began end-of-cycle coastdown.

On February 11, 2022, the unit was downpowered to 85 percent to avoid a known oscillation region during end-of-cycle coastdown. On March 7, 2022, the unit was shut down for a planned refueling outage.

Startup was commenced on March 25, 2022, and rated thermal power was reached on March 29, 2022.

Later that day, the unit was downpowered to 80 percent for a planned rod pattern adjustment. During the downpower, a main turbine control valve malfunction required an additional downpower to 60 percent.

The unit returned to rated thermal power on March 31, 2022, and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading -

rm /doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light -Water Reactor Inspection Program - Operations Phase.

The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk -significant activities, and completed on-site portions of IPs.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

On February 1, 2022, the operating license for Nine Mile Point Nuclear Station, held by Exelon Generation Company, LLC, was transferred to Constellation Energy Generation, LLC (Constellation). While some or all of the inspections documented in this report w ere performed while the license was held by Exelon Generation Company, LLC, this report will refer to the licensee as Constellation throughout.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk -

significant systems due to a winter storm warning on March 11, 2022.

71111.04 - Equipm ent Alignment

Partial Walkdown Sample (IP Section 03.01) (7 Samples)

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

(1) Unit 2 reactor core isolation cooling system on January 26, 2022
(2) Unit 1 reactor building closed loop cooling system on February 7, 2022
(3) Unit 2 'C' residual heat removal system on February 7, 2022
(4) Unit 2 Division II emergency diesel generator on February 22, 2022
(5) Unit 2 'B' residual heat removal system in shutdown cooling on March 8, 2022
(6) Unit 2 Division I emergency diesel generator on March 10, 2022
(7) Unit 2 'A' spent fuel pool cooling system on March 15, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (9 Sam ples)

The inspectors evaluated the implementation of the fire protection program by con ducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Unit 2 radwaste building 261/265, condensate storage building, fire area 55, on February 1, 2022
(2) Unit 2 reactor building 289, fire areas 34 and 35, on February 10, 2022
(3) Unit 2 reactor building 240 north, fire area 1, on February 14, 2022
(4) Unit 1 turbine building 261' west, fire area 5, on February 17, 2022
(5) Unit 2 reactor building 175' north, fire area 1, on February 28, 2022
(6) Unit 2 reactor building, primary containment steam tunnel, fire area 50, on March 7, 2022
(7) Unit 2 turbine building, condenser, fire area 50, on March 7, 2022
(8) Unit 2 turbine building, feedwater heater bays, fire area 50, on March 9, 2022
(9) Unit 2 reactor building, drywell, fire area 5, on March 16, 2022

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the Unit 1 cable spreading room on February 28, 2022.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Unit 2 'B' residual heat removal heat exchanger

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01)

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation, and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from March 7 to March 17, 2022:

==2R18 - ISI-UT-002 / -003).

  • ==

Visual examinations of the containment, including accessible portions of the drywell and suppression chamber metal liner (Work Order [WO] C93672957)

  • Welding activities associated with t he modification of the instrument air check valve, 2IAS*V450, under engineering change ECP -21- 000088 (Work Order

[WO] 93782709). This included liquid penetrant testing of two pipe-to-valve welds, FW-03 and FW-04 (NDE Report BOP-PT-22-004).

  • Flaw evaluation of the embedded reflector identified during the spring 2020 refueling outage using automated phased array UT on the N2J reactor recirculation nozzle to safe-end dissimilar metal weld (NDE Report N2R17-APR-06). The flaw was determined to be acceptabl e for continued service.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)

(1) The inspectors observed Unit 1 operations personnel during control rod exercising operability testing on March 5, 2022.
(2) The inspectors observed Unit 2 operations personnel during the plant shutdown for refueling outage N2R18 on March 6, 2022.

Licensed Operator Requalification Training /Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed a Unit 2 simulator evaluation that included an instrument air compressor failure, reactor core isolation cooling system inoperability, and a small loss of coolant accident with additional failures that required the depressurization of the reactor on January 25, 2022.
(2) The inspectors observed a Unit 1 simulator evaluation that included the inadvertent opening of an electromatic relief valve, a loss of offsite power, an emergency di esel generator failure to start, and a steam leak in the drywell on February 2, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the f ollowing structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Unit 2 Division I emergency diesel generator jacket water pump

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (9 Sam ples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unit 2 elevated risk during planned 'B' residual heat removal pump maintenance on January 4, 2022
(2) Unit 2 elevated risk during emergent work on the Division I emergency diesel generator starting air system on January 20, 2022
(3) Unit 1 elevated risk during emergent work on the 'C' instrument air compressor on February 16, 2022
(4) Unit 2 elevated risk during planned Division I emergency diesel generator maintenance on February 22, 2022
(5) Unit 2 elevated risk during emergent work on the 'B' service water pump on March 2, 2022
(6) Unit 2 elevated risk during a planned 115 -kilovolt Line 5 outage on March 6, 2022
(7) Unit 2 elevated risk during a planned reactor cavity flood-up on March 8, 2022
(8) Unit 2 elevated risk during planned maintenance on SWP*MOV66B, cooling water to Division II emergency diesel generator, on March 10- 12, 2022
(9) Unit 2 elevated risk during a planned reactor cavity draindown on March 22, 2022

71111.15 - Operability Determinations and Functionality Assessme nts

Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Unit 2 Division I emergency diesel generator slow start on January 3, 2022
(2) Unit 2 Division I emergency diesel generator starting air compressor 'B' failure on January 18, 2022
(3) Unit 2 Division I emergency diesel generator emergency start solenoid valve air leaks on January 20, 2022
(4) Unit 1 safety relief valve elevated discharge temperature indications on February 1, 2022
(5) Unit 1 emergency diesel generator 103 starting flywheel chipped tooth on February 15, 2022
(6) Unit 1 containment spray raw water 122 rate set valve unable to operate on February 24, 2022
(7) Unit 1 core spray topping pump 111 pump -bearing oil leak on March 2, 2022
(8) Unit 2 Division III diesel under voltage relay failure to reset after testing on March 4, 2022
(9) Unit 2 main steam isolation valve slow fast closure times on March 7, 2022

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Perm anent Modification: ECP-21-000437, Unit 2 Division II Emergency Diesel Generator Governor Booster
(2) Permanent Modification: ECP-21-000454, Unit 2 Digital Electro-Hydraulic Control (DEHC) Low Pass Filter Modification
(3) Perm anent Modification: ECP-21-000088, Unit 2 PCIV [primary containment isolation valve] Supply Nitrogen Line Primary Containment Inboard Isolation Re-Design

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Sam ples)

The inspectors evaluated the following post -maintenance testing activities to verify system operability and/or functionality:

(1) Unit 2 Division I emergency diesel generator jacket water pump following replacement on February 23, 2022
(2) Unit 2 'B' service water pump following a failure to start on March 2, 2022
(3) Unit 2 Division II emergency diesel generator following governor oil bo oster installation on March 21, 2022
(4) Unit 2 'B' residual heat removal system following heat exchanger inspectio n on March 25, 2022
(5) Unit 2 drywell nitrogen supply system following solenoid operated valve replacement on March 28, 2022

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated Unit 2 refueling outage N2R18 from March 6 to March 27, 2022.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (8 Samples)

(1) N1-ST-M4A, Emergency Diesel Generator 102 and PB 102 Operability Test, on January 24, 2022
(2) N2-OSP-CSL-Q@00 2, LPCS [low pressure core spray] Pump and Valve Operability and System Integrity Test, on February 28, 2022
(3) N1-ST-Q1A, Core Spray 111 Pump, Valve and Shutdown Cooling Water Seal Check Va lve Operability Test, on March 1, 2022
(4) N2-OSP-MSS-CS001, Main Steam Isolation Valve Operability Test, on March 7, 2022
(5) N2-OSP-RHS-R001, Division II ECCS [emergency core cooling system] Functional Test, on March 9, 2022
(6) N2-OSP-SLS-R001, Standby Liquid Control Manual Initiate Actuation and ASME XI Pressure Test, on March 16, 2022
(7) N2-OSP-ADS-R002, ADS [automatic depressurization system] Functional Test and Remote Shutdown System Test, on March 19, 2022
(8) N2-OSP-EGS-R001, Diesel Generator ECCS Start and Load Reject Division II, on March 20, 2022

Inservice Testing (IP Section 03.01) (2 Sam ples)

(1) N2-OSP-I CS-Q@002, Reactor Core Isolation Cooling Pump and Valve Operability Test and System Integrity Test and ASME XI Functional Test and Analysis, on February 10, 2022
(2) N2-ISP-RRC-R001, ARI [alternate rod insertion] Function of RRCS [redundant reactivity control system], on March 7, 2022

Containment Isolation Valve Testing (IP Section 03.01) (2 Samples)

(1) N2-OSP-MSS-003, Unit 2 Main Steam Isolation Valve Leak Rate Test, on March 7, 2022
(2) N2-OSP-MSS-004, Unit 2 Main Steam Isolation Valve Leak Rate Test (Reactor Vessel Head Removed), on March 25,

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how Constellation assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Sam p les)

The inspectors observed/evaluated the following licensee process es for monitoring and controlling contamination and radioactive material:

(1) Workers exiting the Unit 2 radiologically controlled area during refueling outage N2R18
(2) Licensee surveys of contaminated equipment on the refuel floor during refueling outage N2R18

Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)

The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:

(1) Unit 2 outage refuel floor activities, low power range monitor exchange, and supporting activities
(2) Unit 2 in-vessel inspection and supporting activities
(3) Unit 2 refuel floor equipment decontamination activities
(4) Unit 2 drywell feedwater nozzle inspection activities
(5) Unit 2 safety relief valve maintenance in the drywell

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (2 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) High Radiation Area in the Unit 2 reactor building valve pit, 196' elevation
(2) Locked Hig h Radiation Areas in the Unit 2 drywell

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Sam ples)

(1) Unit 1 (January 1, 2021 through December 31, 2021)
(2) Unit 2 (January 1, 2021 through December 31, 2021)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02)

=

(1) Unit 1 (January 1, 2021 through December 31, 2021)
(2) Unit 2 (January 1, 2021 through December 31, 2021)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 (January 1, 2021 through December 31, 2021)
(2) Unit 2 (January 1, 2021 through December 31, 2021)

71152A - Annual Follow -up Problem Identification and Resolution Annual Follow -up of Selected Issues (Section 03.03)

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

(1) IR 04436618 - Nine Mile Point Control Rod Blade Technical Evaluation

INSPECTION RESULTS

Observation: Nine Mile Point Control Rod Blade Techni cal Evaluation 71152A On November 23, 2020, General Electric Hitachi (GEH) released Safety Communication 20 -

06 (SC 20- 06) Revision 0, describing the discovery that Boron 10 (B -10) depletion had been underpredicted in the top 6-inch node of the neutron absorber section of control rod blades currently in use in boiling water reactors in the United States. Nine Mile Point Nuclear Station was on the list of plants affected by this issue.

In Revision 0 of the Safety Communication, the population of control rod blades affected was restricted to Original Equipment Manufacturer (OEM) series D-100 control rod blades, still in operation from the 1970s and 1980s. On February 26, 2021, GEH issued Revision 1 to SC 20- 06, in which it was determined that the population of control rod blades affected by the underprediction of B -10 in the tip segm ent included all control rod blades that did not contain Hafnium (Hf) in the tips, not just OEM D-100 control rod blades. This greatly increased the population of control rod blades affected by this issue.

Control rod blades deplete the B -10 isotope as they absorb neutrons when they are inserted into an operating reactor core. Control rod blades are typically fully withdrawn from the core when the reactor is at full power. However, the tips of the control rod blades still experience some thermal neutron flux. The B -10 depletion in the top node of the control rod blade is accounted for in engineering analysis by adding a "tip adder" factor in the B -10 depletion calculation for each control rod blade. Safety Communication SC 20- 06 stated that the tip adder factor was much larger than previously calculated, for control rod blades without Hf in the tips. General Electric manufactured control rod blades with Hf tips for a period of time in the 1980s and 1990s that are excluded from the tip adder issue described in SC 20 -06. All other control rod blade models, including the OEM blades, are affected by the tip adder issue described in SC 20- 06. The higher depletion values in the control rod blade tips for multiple control rod blade types may cause the control rod blade to exceed its effective neutron absorbing capability before the end of the operating fuel cycle. This has the potential to decrease the overall shutdown margin (SDM), which is the ability of all the control rods, except for the most reactive control r od, to shut down the reactor core in all anticipated normal and accident scenarios.

In Revision 1 to SC 20- 06, GEH recommended all customers ensure that adequate SDM was available in the current operating fuel cycle until the end of the fuel cycle, once the am ount of B-10 depletion was determined in all control rod blade tips. GEH recommended this be done for all General Electric control rod blades that did not contain Hf tips, as well as alternate vendor control rod blades. GEH also recommended all customers assess the impact of control rod blades exceeding their nuclear end of life (NEOL) criteria - the ability of the control rod blade to effectively absorb neutrons - fo r future fuel cycles beyond the current operating fuel cycle.

Following issuance of GEH SC 20-06, Revision 1, Nine Mile Point Unit 1 entered a refueling outage in March 2021. A control rod blade depletion engineering evaluation was performed, taking into account the new tip adder calculation in SC 20- 06. It was determined that two control rod blades that had been located in higher power locations in the previous fuel cycle would be shuffled to two lower power locations in the core for the current Unit 1 operating fuel cycle. No control rod blades in the previous or current fuel cycle have exceeded their NEOL criteria, thus requiring replacement.

In July 2021, Exelon Nuclear Fuels validated that adequate SDM existed for the remainder of the current fuel cycle for Nine Mile Point Unit 2, and that thermal limit margins were not im pa cted. One control rod blade on the core periphery was predicted to exceed its NEOL criteria due to the tip adder issue described in SC 20- 06, before the end of the Unit 2 fuel cycle in March 2022. This blade, along with six other control rod blades, are scheduled for replacement in the upcoming refueling outage. In September 2021, General Electric Global Nuclear Fuels completed an analysis to confirm that SDM would be maintained above the technical specification limit for the remainder of the Unit 2 fuel cycle. Exelon procedure NF -

AB-135-1410, "BWR Control Blade Lifetime Management," contains guidance for calculating B-10 depletion in all models of control rod blades currently in operation in the nuclear fleet.

This procedure will require an update to incorpora te the new guidance from SC 20- 06, for estimating the tip adder factor for non-Hf tipped control rod blades. Issue Report 04242262 is tracking completion of this procedural update.

The inspectors interviewed engineering staff from Exelon Nuclear F uels and Nine Mile Point Reactor Engineering to discuss corrective actions taken in response to GEH SC 20-06, and reviewed shutdown margin and control rod blade depletion engineering evaluations. The inspectors also reviewed the corrective actions taken and planned for responding to GEH SC 20- 06 entered into the corrective action system. No performance deficiencies were identified.

Corrective Action References: 04242262, 04386300,

EXIT MEETINGS AND DEBRIEFS

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

  • On April 21, 2022, the inspector s presented the integrated inspection results to Mr. Peter Orphanos, Site Vice Preside n t, and other members of the licensee staff.
  • On February 8, 2022, the inspectors presented the control rod blade technical evaluation problem identification and resolution inspection results to Philip Nichols, Manager Reactor Engineering, and other members of the licensee staff.
  • On March 17, 2022, the inspector s presented the Unit 2 i nservice inspection results to Mr. Pe ter Orphanos, Site Vice President, and other members of the licensee staff.
  • On March 17, 2022, the inspector s presented the radiological hazard assessment and exposure controls inspection results to Mr. Peter Orphanos, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures N1-OP-64 Meteorological Monitoring 02100

N2-OP-102 Meteorological Monitoring 02800

OP-AA-108-111-Severe Weather and Natural Disaster Guidelines 24

1001

71111.04 Drawings C-18022-C Piping & Instrumentation Diagram, Reactor Building Closed 55

Loop Cooling System

PID-031A, B, E Piping & Instrumentation Diagram Residual Heat Removal 27

System

PID-31G Piping & Instrumentation Diagram Residual Heat Removal 15

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

Cooling

PID-35B Piping & Instrumentation Diagram Reactor Core Isolation 13

Cooling

PID-38B Piping & Instrumentation Diagram Fuel Pool Cooling & 15

Cleanup

PID-38C Piping & Instrumentation Diagram Fuel Pool Cooling & 17

Cleanup

Procedures N1-OP-11 Reactor Building Closed Loop Cooling System 03400

N2-OP-100A Standby Diesel Generators 03200

N2-OP-100A-Standby Diesel Generators - LINEUPS 00500

LINEUPS

N2-OP-31 Residual Heat Removal System 03700

N2-OP-31-Residual Heat Removal System 003

LINEUPS

N2-OP-38 Spent Fuel Cooling and Cleanup System 2700

71111.05 Corrective Action 04477281

Docum ents

Drawings B-40143-C Fire Zones Reactor Building - Fl. El. 261' Turbine Building - 10

Fl. El. 261' Fire Rated Walls and Slabs

Fire Plans N2-FPI-PFP-0201 Unit 2 Pre-Fire Plans 06

71111.06 Corrective Action 04416206

Docum ents 04477927

Inspection Type Designation Description or Title Revision or

Procedure Date

04661043

71111.07A Corrective Action 04484882

Docum ents 04486864

Procedures ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide 11

S-TDP-REL-0102 Service Water Heat Exchanger and Component Inspection 03

Guide

Work Orders C93738267

71111.08G Corrective Action 04327298

Docum ents

Corrective Action 04484400

Docum ents

Resulting from

Inspection

Engineering ECP-20-000224 Recirculation Inlet Nozzle DMW No. 2RPV-KB11 (N2J) Flaw 03/25/2020

Evaluations Evaluation

Miscellaneous ER-NM-330-2001 ISI Program Plan Fourth Ten-Year Inspection Interval Revision 3

ER-NM-330-2004 Risk Informed Inservice Inspection Program Fourth Ten-Revision 0

Year Inspection Interval

Procedures ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic Revision 15

Liners of Class CC Components

ER-AA-335-030 Ultrasonic Examination of Ferritic Piping Welds Revision 5

ER-AA-335-1000 Nondestructive Examination (NDE) Revision 16

GEH-UT-254 Automated Phased Array Ultrasonic Examination of Version 1

Dissimilar Metal Welds with the TOPAZ

WPS 8-8-GTSM Welding Procedure Specification Record for Manual GTAW Revision 7

and SMAW of P-Number 8 to P-Number 8 Base Metal

71111.11Q Procedures N1-ST-W1 Control Rod Exercising Operability Test 02300

N2-OP-101C Plant Shutdown 04100

N2-OP-29 Reactor Recirculation System 03400

N2-OP-31 Residual Heat Remova l S yst em 03700

71111.12 Procedures N2-MSP-EGS-Diesel Generator Inspection Division 1 and 2 025

R001

Work Orders C938144677

71111.13 Corrective Action 04481795

Inspection Type Designation Description or Title Revision or

Procedure Date

Docum ents

Procedures N2-OP-19-Instrument and Service Air Systems 8

Lineups

N2-OP-70 Station Electrical Feed and 115KV Switchyard 02800

N2-PM-082 RPV [reactor pressure vessel] Flood-Up/Draindown 01900

OP-NM-108-117 Protected Equipm ent Program at Nine Mile Point 5

OP-NM-108-117 Protected Equipm ent Program at Nine Mile Point 00500

OU-NM-103-101 Shutdown Safety Management Program 0700

71111.15 Calculations 002N3714 Nine Mile Point Nuclear Station Unit 1 TRACG-LOCA 0

Analysis for GNF2 Fuel

Corrective Action 04061889

Docum ents 04470659

04475343

04476776

04481649

04482642

04483059

04488015

Drawings 0001040209048 Control Diagram Shutdown System 13.00

Engineering ECP-22-000147 Technical Evaluation for MSIV Failed Stroke Time Extent of 0000

Changes Condition

Miscellaneous NEI 06-09-A Risk-Informed Technical Specifications Initiative 4b: Risk-0

Managed Technical Specifications (RMTS) Guidelines

Purchase Order Service, Repair, Refurbishment of MSIV Actuator Air Pack 2

00802656

RICT Record fo r Failed MSIV 7D RPS Testing 04/06/2022

March 28, 2022

Procedures N1-OP-1 Nuclear Steam Supply System 07700

N2-OP-100A Standby Diesel Generators 03100

N2-OSP-EGS-Diesel Generator and Diesel Air Start Valve Operability Test-024T1

M@001 Division I and II

OP-AA-108-118 Risk Informed Completion Time 2

71111.18 Corrective Action 02547530

Inspection Type Designation Description or Title Revision or

Procedure Date

Docum ents 02689624

04359704

04365824

04428910

04482114

Engineering ECP-21-000088 PCIV Supply Nitrogen Line Primary Containment Inboard 0000

Changes Isolation Re-Design

ECP-21-000437 EDG Governor Booster 0000

ECP-21-000454 Digital Electro-Hydraulic Control (DEHC) Low Pass Filter 0

Modification

Miscellaneous FAT/SAT Testing for DEHC Low Pass Filter Mod 0000

Procedures N2-OSP-EGS-Diesel Generator and Diesel Air Start Valve Operability Test 024T1

M@0001 - Division I and II

Work Orders C93782709

C93809087

C93813137

71111.19 Corrective Action 04480094

Docum ents 04481795

04484882

04486059

Corrective Action 04486063

Docum ents

Resulting from

Inspection

Procedures GAP-HSC-09 System Aging Inspection and Cleanliness Controls 02000

N2-MSP-EGS-Diesel Generator Inspection Division I and II 02400

R001

N2-OSP-EGS-Diesel Generator and Diesel Air Start Valve Operability Test 02400.01

M@0001 - Division I and II

N2-OSP-RHS-RHR System Loop B Pump and Valve Operability Test, 01500

Q@005 System Integrity Test and ASME XI Pressure Test

N2-OSP-RHS-Division II ECCS Functional Test 00900

R001

Inspection Type Designation Description or Title Revision or

Procedure Date

S-EPM-GEN-004 Insulation of Power, Control, and Instrument Cable 00700

Connections

Work Orders C93738267

C93782709

C93814677

C93825512

71111.20 Corrective Action 04482986

Docum ents 04482995

04483785

04484026

04484553

04485270

Corrective Action 04484400

Docum ents 04486063

Resulting from

Inspection

Miscellaneous NM2C19-SU Reactivity Maneuver Plan 0

Procedures LS-AA-119 Fatigue Management and Work Hour L im it s 15

N2-FHP-13.3 Core Shuffle 01200

N2-OP-101A Plant Start-up 05400

N2-OP-38 Spent Fuel Cooling and Cleanup System 02700

N2-OSP-NMS-Source Range Monitor Check During Core Offload/Reload 00201

@002

OP-AA-109-101 Personnel and Equipment Tagout Process 16

OP-AA-300 Reactivity Management 14

OP-AA-300-1520 Reactivity Management - Fuel Handling, Storage and 7

Refueling

OU-NM-103-101 Shutdown Safety Management Program 00700

OU-NM-4001 Refueling Operations 00800

71111.22 Corrective Action 04481649

Docum ents 04482027

04483059

04483200

Inspection Type Designation Description or Title Revision or

Procedure Date

04483399

04485322

Miscellaneous Technical MSIV Leak Rate Tests Approved

Evaluation N2R18 03/17/2022

Procedures N1-ST-M4A Emergency Diesel Generator 102 and PB 102 Operability 03000

Test

N1-ST-Q1A CS 111 Pump, Valve and SDC Water Seal Check Valve 02200

Operability Test

N2-ISP-RRC-ARI [alternate rod insertion] function of RRCS [redundant 00700

R001 reactivity control system]

N2-OSP-ADS-ADS System Functional Test and Remote Shutdown System 009

R002 Test

N2-OSP-CSL-LPCS Pump and Valve Operability and System Integrity 01500

Q@002 Test

N2-OSP-EGS-Diesel Generator ECCS Start and Load Reject Division II 9

R001

N2-OSP-I CS-RCIC Pump and Valve Operability Test and System Integrity 01600

Q@002 Test and ASME XI Functional Test and Analysis

N2-OSP-MSS-Main Steam Isolation Valve Leak Rate Test 00300

003

N2-OSP-MSS-Main Steam Isolation Valve Leak Rate Test (Reactor Vessel 00200

004 Head Rem oved)

N2-OSP-MSS-Main Steam Isolation Valve Operability Test 01000 and

CS001 01100

N2-OSP-SLS-Standby Liquid Control Manual Initiate Actuation and ASME 01100

R001 XI Pressure Test

71151 Procedures NEI 99-02 Regulatory Assessment Performance Indicator Guideline 7

71152A Corrective Action 04242262

Docum ents 04386300

04436618

Engineering ECP-20-000291 Control Blade Replacement Strategy for Nine Mile Point Unit 0

Evaluations 1 Cycle 25 (Reload 26)

ECP-21-000248 Control Blade Replacement Strategy for Nine Mile Point Unit 0

(Reload 18)

Inspection Type Designation Description or Title Revision or

Procedure Date

ECP-21-000380 SC 20-06: Nine Mile Point Unit 2 Cycle 18 SDM and 0

MSBWP Evaluation

Miscellaneous General Electric Impact of Ex-core Flux on Control Rod Lifetime L im it s 02/26/2021

Hitachi Safety

Communication

20-06, Rev. 1

Procedures NF-AB-130-3690 Maximum Subcritical Banked Withdrawal Position 10

NF-AB-135-1410 BWR Control Blade Lifetime Management 16

19