IR 05000333/2023004: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot change)
(StriderTol Bot change)
 
(2 intermediate revisions by the same user not shown)
Line 20: Line 20:
{{#Wiki_filter:February 7, 2024
{{#Wiki_filter:February 7, 2024


David Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer (CNO)
==SUBJECT:==
Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2023004 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200012/2023001
 
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2023004 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200012/2023001


==Dear David Rhoades:==
==Dear David Rhoades:==
Line 30: Line 28:
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.


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


If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading- rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely, Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety
Sincerely, Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety  


Docket No. 05000333 and 07200012 License No. DPR- 59
Docket No. 05000333 and 07200012 License No. DPR-59  


===Enclosure:===
===Enclosure:===
As stated
As stated  


==Inspection Report==
==Inspection Report==
Docket Number: 05000333 and 07200012
Docket Number:
05000333 and 07200012  
 
License Number:
DPR-59
 
Report Number:
05000333/2023004 and 07200012/2023001


License Number: DPR- 59
Enterprise Identifier: I-2023-004-0037 and I-2023-001-0070


Report Number: 05000333/2023004 and 07200012/2023001
Licensee:  


Enterprise Identifier: I-2023-004- 0037 and I- 2023- 001- 0070
Constellation Energy Generation, LLC


Licensee: Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant


Facility: James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY


Location: Oswego, NY
Inspection Dates:
October 1, 2023 to December 31, 2023


Inspection Dates: October 1, 2023 to December 31, 2023
Inspectors:
E. Miller, Senior Resident Inspector


Inspectors: E. Miller, Senior Resident Inspector B. Sienel, Resident Inspector H. Anagnostopoulos, Senior Health Physicist E. Eve, Senior Project Engineer C. Hargest, Health Physicist M. Henrion, Senior Health Physicist A. Kostick, Health Physicist J. Kulp, Senior Reactor Inspector J. Schoppy, Senior Reactor Inspector
B. Sienel, Resident Inspector  


Approved By: Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety
H. Anagnostopoulos, Senior Health Physicist


Enclosure
E. Eve, Senior Project Engineer
 
C. Hargest, Health Physicist
 
M. Henrion, Senior Health Physicist
 
A. Kostick, Health Physicist
 
J. Kulp, Senior Reactor Inspector
 
J. Schoppy, Senior Reactor Inspector
 
Approved By:
Erin E. Carfang, Chief
Projects Branch 1
Division of Operating Reactor Safety


=SUMMARY=
=SUMMARY=
Line 69: Line 93:


===List of Findings and Violations===
===List of Findings and Violations===
Failure to Maintain Adequate Dry Cask Storage Procedures Cornerstone Severity Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 60855 NCV 05000333/2023004-01 Open/Closed A self-revealed Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.150, "Instructions, Procedures, and Drawings," was identified when Constellation failed to maintain adequate procedures to prevent dry cask storage equipment from adversely impacting the spent fuel pool (SFP) and associated equipment.
Failure to Maintain Adequate Dry Cask Storage Procedures Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2023004-01 Open/Closed Not Applicable 60855 A self-revealed Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.150, "Instructions, Procedures, and Drawings," was identified when Constellation failed to maintain adequate procedures to prevent dry cask storage equipment from adversely impacting the spent fuel pool (SFP) and associated equipment.


===Additional Tracking Items===
===Additional Tracking Items===
Type Issue Number Title Report Section Status URI 05000333/2023004-02 Use of Holtec Multipurpose 60855 Open Canister Continuous Basket Shim Variant
Type Issue Number Title Report Section Status URI 05000333/2023004-02 Use of Holtec Multipurpose Canister Continuous Basket Shim Variant 60855 Open


=PLANT STATUS=
=PLANT STATUS=
Line 79: Line 103:


==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.
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, 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.
 
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, 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.


==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==
===Partial Walkdown (IP Section 03.01) (2 Samples)===
===Partial Walkdown (IP Section 03.01) (2 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:  
: (1) 'B' and 'D' emergency diesel generators (EDGs) following planned maintenance on the 'B' EDG on October 17, 2023
 
: (2) 'B' and 'D' EDGs during planned maintenance on the 'A' EDG on October 30, 2023
(1)  
'B' and 'D' emergency diesel generators (EDGs) following planned maintenance on the 'B' EDG on October 17, 2023 (2)  
'B' and 'D' EDGs during planned maintenance on the 'A' EDG on October 30, 2023


==71111.05 - Fire Protection==
==71111.05 - Fire Protection==
Line 112: Line 136:
: (1) West crescent reactor core isolation cooling room enclosure structural monitoring on October 31, 2023
: (1) West crescent reactor core isolation cooling room enclosure structural monitoring on October 31, 2023
: (2) Maintenance Rule Periodic a(3) maintenance effectiveness assessment for the period of April 1, 2021 to March 31, 2023
: (2) Maintenance Rule Periodic a(3) maintenance effectiveness assessment for the period of April 1, 2021 to March 31, 2023
: (3) Emergency diesel generators on December 14, 2023
: (3) Emergency diesel generators on December 14, 2023  


===Aging Management (IP Section 03.03) (1 Sample)===
===Aging Management (IP Section 03.03) (1 Sample)===
Line 119: Line 143:


==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
Risk Assessment and Management (IP Section 03.01) (5 Samples)
===Risk Assessment and Management (IP Section 03.01) (5 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) Elevated risk during 'A' residual heat removal system planned maintenance on October 3, 2023
: (1) Elevated risk during 'A' residual heat removal system planned maintenance on October 3, 2023
Line 134: Line 157:


==71111.24 - Testing and Maintenance of Equipment Important to Risk==
==71111.24 - Testing and Maintenance of Equipment Important to Risk==
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:  


===Post-Maintenance Testing (IP Section 03.01) (6 Samples)===
===Post-Maintenance Testing (IP Section 03.01) (6 Samples)===
: (1) 'A' residual heat removal system following planned system maintenance, on October 4, 2023
(1)  
: (2) 'A' residual heat removal service water pump following planned maintenance, on October 4, 2023
'A' residual heat removal system following planned system maintenance, on October 4, 2023 (2)  
: (3) 'B' emergency diesel generator following planned system maintenance, on October 11, 2023
'A' residual heat removal service water pump following planned maintenance, on October 4, 2023 (3)  
: (4) 'B' and 'D' emergency diesel generator tie breaker 71-10604 following 200 rpm speed relay 93-TBR-1EDGB12 replacement and breaker replacement, on October 12, 2023
'B' emergency diesel generator following planned system maintenance, on October 11, 2023 (4)  
: (5) Control room ventilation following planned damper preventive maintenance, on October 18, 2023
'B' and 'D' emergency diesel generator tie breaker 71-10604 following 200 rpm speed relay 93-TBR-1EDGB12 replacement and breaker replacement, on October 12, 2023
: (6) 'A' emergency diesel generator following right bank air start motor airline restoration from a configuration control event, on November 2, 2023
: (5) Control room ventilation following planned damper preventive maintenance, on October 18, 2023 (6)  
'A' emergency diesel generator following right bank air start motor airline restoration from a configuration control event, on November 2, 2023  


===Surveillance Testing (IP Section 03.01) (1 Sample)===
===Surveillance Testing (IP Section 03.01) (1 Sample)===
: (1) ISP-175B2, Reactor and Containment Cooling and anticipated transient without scram (ATWS) Instrument Functional Test/Calibration, on October 19, 2023
: (1) ISP-175B2, Reactor and Containment Cooling and anticipated transient without scram (ATWS) Instrument Functional Test/Calibration, on October 19, 2023  


===Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)===
===Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)===
Line 151: Line 175:


==71114.06 - Drill Evaluation==
==71114.06 - Drill Evaluation==
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
===Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)===
: (1) The inspectors observed and evaluated a simulator scenario that included the declaration of an Alert due to an anticipated transient with an inability to manually or automatically scram the reactor on October 24,
: (1) The inspectors observed and evaluated a simulator scenario that included the declaration of an Alert due to an anticipated transient with an inability to manually or automatically scram the reactor on October 24,


==RADIATION SAFETY==
==RADIATION SAFETY==
==71124.08 - Radioactive Solid Waste Processing and==
==71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,==
Radioactive Material Handling, Storage, and Transportation
and Transportation  
 
===Radioactive Material Storage (IP Section 03.01)===
{{IP sample|IP=IP 71124.08|count=2}}


===Radioactive Material Storage (IP Section 03.01) (2 Samples)===
The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
: (1) Waste and equipment stored in the interim waste storage facility
: (1) Waste and equipment stored in the interim waste storage facility
: (2) Waste stored in the outdoor sea land metals and dry active waste loading area
: (2) Waste stored in the outdoor sea land metals and dry active waste loading area  


===Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)===
===Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)===
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
: (1) The modular fluidized transfer demineralization and sluice system (the advanced liquid processing system skid)
: (1) The modular fluidized transfer demineralization and sluice system (the advanced liquid processing system skid)
: (2) The radwaste facility 250' elevation pump room and associated waste sludge tank and spent resin tank rooms
: (2) The radwaste facility 250' elevation pump room and associated waste sludge tank and spent resin tank rooms  


===Waste Characterization and Classification (IP Section 03.03) (2 Samples)===
===Waste Characterization and Classification (IP Section 03.03) (2 Samples)===
The inspectors evaluated the following characterization and classification of radioactive waste:
The inspectors evaluated the following characterization and classification of radioactive waste:
: (1) Title 10 CFR 61 waste profile analysis for dry active waste in 2023
: (1) Title 10 CFR 61 waste profile analysis for dry active waste in 2023
: (2) The characterization of bead resins in waste shipment JAF-2023-1894
: (2) The characterization of bead resins in waste shipment JAF-2023-1894  


===Shipping Records (IP Section 03.05) (4 Samples)===
===Shipping Records (IP Section 03.05) (4 Samples)===
The inspectors evaluated the following non- excepted radioactive material shipments through a record review:
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
: (1) Shipment JAF-2021-1872, UN3321 LSA-II, Type 2 quantity of radioactive material, ion exchange media for disposal
: (1) Shipment JAF-2021-1872, UN3321 LSA-II, Type 2 quantity of radioactive material, ion exchange media for disposal
: (2) Shipment JAF-2023-048, UN2915 Type A package, metal coupons for analysis
: (2) Shipment JAF-2023-048, UN2915 Type A package, metal coupons for analysis
Line 181: Line 207:


==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
===71151 - Performance Indicator Verification
===71151 - Performance Indicator Verification  


The inspectors verified licensee performance indicators submittals listed below:
The inspectors verified licensee performance indicators submittals listed below:  


OR01: Occupational Exposure Control Effectiveness (IP Section 02.15) (1 Sample)
OR01: Occupational Exposure Control Effectiveness (IP Section 02.15)===
: (1) For the period of July 1, 2022 through September 30, 2023
{{IP sample|IP=IP 71151|count=1}}
: (1) For the period of July 1, 2022 through September 30, 2023  


PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16)===
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)
{{IP sample|IP=IP 71151|count=1}}
: (1) For the period of July 1, 2022 through September 30, 2023  
: (1) For the period of July 1, 2022 through September 30, 2023


===71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)===
===71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)===
Line 205: Line 231:


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL  


===60855 - Operation of an ISFSI Operation of an ISFSI===
===60855 - Operation of an ISFSI Operation of an ISFSI===
Line 212: Line 238:
* Placement of empty transfer cask (HI-TRAC) and multipurpose canister (MPC) into SFP
* Placement of empty transfer cask (HI-TRAC) and multipurpose canister (MPC) into SFP
* Fuel loading and verification
* Fuel loading and verification
* Itlif the MPCid ontoMPC wle in t
* Installation of the MPC lid onto the loaded MPC while in the SFP
* Removal of the HI-TRAC/MPC out of the SFP and transfer to the HI-TRAC processing platform
* Removal of the HI-TRAC/MPC out of the SFP and transfer to the HI-TRAC processing platform
* Decontamination of loaded HI-TRAC/MPC
* Decontamination of loaded HI-TRAC/MPC
* Welding and non- destructive examination of MPC lid and shell
* Welding and non-destructive examination of MPC lid and shell
* Drying of MPC using canister processing system
* Drying of MPC using canister processing system
* Hydrostatic pressure testing, vacuum drying, and helium backfilling of the MPC
* Hydrostatic pressure testing, vacuum drying, and helium backfilling of the MPC
Line 221: Line 247:
* Stack-up and download of MPC into overpack (HI-STORM)
* Stack-up and download of MPC into overpack (HI-STORM)
* Transfer of the loaded HI-STORM out of the reactor building into the track bay
* Transfer of the loaded HI-STORM out of the reactor building into the track bay
* ansporti plement ofI -SRM onhe ISI
* Transportation and placement of HI-STORM on the ISFSI pad


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Failure to Maintain Adequate Dry Cask Storage Procedures Cornerstone Severity Cross- Cutting Report Aspect Section Not Severity Level IV Not 60855 Applicable NCV 05000333/2023004 - 01 Applicable Open/Closed A self - revealed Severity Level IV NCV of 10 CFR Part 72.150, "Instructions, Procedures, and Drawings," was identified when Constellation failed to maintain adequate procedures to prevent dry cask storage equipment from adversely impacting the SFP and associated equipment.
Failure to Maintain Adequate Dry Cask Storage Procedures Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2023004-01 Open/Closed  


Description : On October 16, 2023, during an ISFSI campaign, Constellation staff were lowering Cask #4 (reusable shielding HI - TRAC containing empty MPC ) into the SFP when tighter than normal clearances were noticed in the area between the HI - TRAC and SFP storage racks immediately adjacent to the cask pit.
Not Applicable 60855 A self-revealed Severity Level IV NCV of 10 CFR Part 72.150, "Instructions, Procedures, and Drawings," was identified when Constellation failed to maintain adequate procedures to prevent dry cask storage equipment from adversely impacting the SFP and associated equipment.


The licensee finished fuel loading of Cask
=====Description:=====
#4 and removed it from the SFP for further processing. On October 18, 2023, the inspectors were notified that there was a shifted SFP rack that needed to be resolved before continuing the ISFSI campaign with Cask #5.
On October 16, 2023, during an ISFSI campaign, Constellation staff were lowering Cask #4 (reusable shielding HI-TRAC containing empty MPC) into the SFP when tighter than normal clearances were noticed in the area between the HI-TRAC and SFP storage racks immediately adjacent to the cask pit. The licensee finished fuel loading of Cask  
 
#4 and removed it from the SFP for further processing. On October 18, 2023, the inspectors were notified that there was a shifted SFP rack that needed to be resolved before continuing the ISFSI campaign with Cask #5. The shifted rack was identified as Rack 26, which held double blade guides but did not contain spent fuel assemblies. Constellation determined that Rack 26 had been lifted and shifted out of its normal position on October 11, 2023, when the refuel floor overhead crane was lifting the fully loaded Cask #3 out of the SFP, and the bottom flange of the HI-TRAC unintentionally hooked onto the bottom of Rack 26.
The shifted rack was identified as Rack 26, which held double blade guides but did not contain spent fuel asse mblies.


Constellation determined that Rack 26 had been lifted and shifted out of its normal position on October 11, 2023, when the refuel floor overhead crane was lifting the fully loaded Cask #3 out of the SFP, and the bottom flange of the HI - TRAC unintentionally hooked onto the bottom of Rack 26.
Procedure MP-019.06, MPC Loading and Sealing, Revision 35, was not adequate to ensure that the HI-TRAC bottom flange was clear of adjacent spent fuel storage racks because this revision of the procedure did not require the use of underwater camera shots so spotters could see the HI-TRAC bottom flange when the cask was being lifted in or out of the SFP and traveling past SFP storage racks in the areas immediately adjacent to the movement activities.


P rocedure MP - 019.06, MPC Loading and Sealing, Revision 35, was not adequate to ensure that the HI - TRAC bottom flange was clear of adjacent spent fuel storage racks because this revision of the procedure did not require the use of underwater camera shots so spotters could see the HI - TRAC bottom flange when the cask was being lifted in or out of the SFP and traveling past SFP storage racks in the areas immediately adjacent to the movement activities.
Corrective Actions: Constellation revised procedure MP-019.06, "MPC Loading and Sealing,"
to include the use of underwater cameras for viewing the bottom of the HI-TRAC while lifting it into and out of the SFP.


Corrective Actions: Constellation revised procedure MP - 019.06, "MPC Loading and Sealing,"
Corrective Action References: IR 04709988  
to include the use of underwater cameras for viewing the bottom of the HI- TRAC while lifting it into and out of the SFP.
 
Corrective Action References: IR 04709988


=====Performance Assessment:=====
=====Performance Assessment:=====
Line 254: Line 277:
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.


Unresolved Item Use of Holtec Multipurpose Canister Continuous Basket 60855 (Open) Shim Variant URI 05000333/2023004-02
Unresolved Item (Open)
Use of Holtec Multipurpose Canister Continuous Basket Shim Variant URI 05000333/2023004-02 60855


=====Description:=====
=====Description:=====
The inspectors identified an unresolved item (URI) related to design changes on the dry storage system MPCs utilized by Constellation.
The inspectors identified an unresolved item (URI) related to design changes on the dry storage system MPCs utilized by Constellation. On February 17th, 2021, Holtec International, the supplier of the HI-STORM 100 dry storage system for FitzPatrick, performed engineering change order (ECO) 5014-320, Revision 0 and 10 CFR 72.48 evaluation 1502, Revision 0. These evaluations performed a design change to introduce a new MPC basket design to the HI-STORM 100 dry storage system, designated as the continuous basket shim (CBS) variant.
 
On February 17th, 2021, Holtec International, the supplier of the HI-STORM 100 dry storage system for FitzPatrick, performed engineering change order (ECO) 5014- 320, Revision 0 and 10 CFR 72.48 evaluation 1502, Revision 0. These evaluations performed a design change to introduce a new MPC basket design to the HI-STORM 100 dry storage system, designated as the continuous basket shim (CBS) variant.


On September 12, 2023, the NRC issued Inspection Report 07201014/2022- 201 (ADAMS Accession No. ML23145A175) to Holtec International, identifying three apparent violations associated with design change. The apparent violations, related to 10 CFR 72.48 and 10 CFR 72.146 requirements, are for Holtec Internationals apparent failures to provide adequate bases that the CBS variant did not require a license amendment, failure to ensure the change did not result in a departure from the method of evaluations described in the Final Safety Analysis Report, and failure to establish design control measures commensurate with those applied to the original design. At this time, the NRC has determined there is no immediate safety concern associated with the use of the modified basket design.
On September 12, 2023, the NRC issued Inspection Report 07201014/2022-201 (ADAMS Accession No. ML23145A175) to Holtec International, identifying three apparent violations associated with design change. The apparent violations, related to 10 CFR 72.48 and 10 CFR 72.146 requirements, are for Holtec Internationals apparent failures to provide adequate bases that the CBS variant did not require a license amendment, failure to ensure the change did not result in a departure from the method of evaluations described in the Final Safety Analysis Report, and failure to establish design control measures commensurate with those applied to the original design. At this time, the NRC has determined there is no immediate safety concern associated with the use of the modified basket design.


On August 14, 2023, FitzPatrick adopted Holtec Internationals CBS ECO/72.48 through Constellation's 72.48 program, #JAF-72SCN-23- 001; evaluated Holtec Internationals 72.48 in accordance with 72.212(b)(7); and subsequently loaded the MPC-68M-CBS canisters from September 24 to November 6, 2023.
On August 14, 2023, FitzPatrick adopted Holtec Internationals CBS ECO/72.48 through Constellation's 72.48 program, #JAF-72SCN-23-001; evaluated Holtec Internationals 72.48 in accordance with 72.212(b)(7); and subsequently loaded the MPC-68M-CBS canisters from September 24 to November 6, 2023.


General licensees are responsible to ensure that each cask they use conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 72.214 and regulatory requirements in 10 CFR Part 72.
General licensees are responsible to ensure that each cask they use conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 72.214 and regulatory requirements in 10 CFR Part 72.
Line 273: Line 295:
Licensee Actions: Constellation's loading of the CBS fuel basket MPC-68M-CBS assumes the risk of potentially being in violation of regulatory requirements pending the outcome of the NRC enforcement action involving Holtec International.
Licensee Actions: Constellation's loading of the CBS fuel basket MPC-68M-CBS assumes the risk of potentially being in violation of regulatory requirements pending the outcome of the NRC enforcement action involving Holtec International.


Corrective Action References: IR 04697142 Engineering Change 639367
Corrective Action References: IR 04697142 Engineering Change 639367  


Minor Performance Deficiency 71152S Minor Performance Deficiency: The inspectors evaluated a sample of issues and events that occurred over the third and fourth quarters of 2023. The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Constellation staff for potential trends at a low threshold and resolved within the scope of the corrective action program.
Minor Performance Deficiency 71152S Minor Performance Deficiency: The inspectors evaluated a sample of issues and events that occurred over the third and fourth quarters of 2023. The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Constellation staff for potential trends at a low threshold and resolved within the scope of the corrective action program.


The inspectors identified a trend associated with ground water intrusion into secondary containment through degraded penetration seals in an outdoor manhole, manhole- 1 (MH-1).
The inspectors identified a trend associated with ground water intrusion into secondary containment through degraded penetration seals in an outdoor manhole, manhole-1 (MH-1).


Specifically, the combination of degraded seals, abandoned conduits, and sump pump failures have contributed to repeat occurrences of ground water intrusion. This ground water intrusion has affected the west crescent area radiation monitor, which is used to determine actions associated with a radioactive release during an accident in secondary containment. In addition, the degrading seals and conduits represent a reduction in available margin associated with the maximum allowable opening size permissible to support the standby gas treatment systems function to drawdown the secondary containment, treat the air, and monitor it before being released to the atmosphere.
Specifically, the combination of degraded seals, abandoned conduits, and sump pump failures have contributed to repeat occurrences of ground water intrusion. This ground water intrusion has affected the west crescent area radiation monitor, which is used to determine actions associated with a radioactive release during an accident in secondary containment. In addition, the degrading seals and conduits represent a reduction in available margin associated with the maximum allowable opening size permissible to support the standby gas treatment systems function to drawdown the secondary containment, treat the air, and monitor it before being released to the atmosphere.


Following heavy rains, equipment operators discovered the sump pump for manhole MH-1 was not operating on October 9, 2023. Elevated water levels in the sump, combined with degraded seal penetrations, resulted in leakage into the secondary containment. The water damaged an area radiation monitor in the west crescent, causing it to be non- functional and require compensatory measures. This radiation monitor is credited in EOP-SC, "Emergency Operating Procedure for Secondary Containment," for determining when to insert a reactor scram or perform an emergency depressurization. On October 10, 2023, the inspectors accompanied maintenance staff to observe conditions and maintenance repairs to the sump.
Following heavy rains, equipment operators discovered the sump pump for manhole MH-1 was not operating on October 9, 2023. Elevated water levels in the sump, combined with degraded seal penetrations, resulted in leakage into the secondary containment. The water damaged an area radiation monitor in the west crescent, causing it to be non-functional and require compensatory measures. This radiation monitor is credited in EOP-SC, "Emergency Operating Procedure for Secondary Containment," for determining when to insert a reactor scram or perform an emergency depressurization. On October 10, 2023, the inspectors accompanied maintenance staff to observe conditions and maintenance repairs to the sump.


The inspectors found a significant amount of water leaking through the manhole wall. In addition, penetration seals were degraded along with severe corrosion of several cables metal conduit shielding.
The inspectors found a significant amount of water leaking through the manhole wall. In addition, penetration seals were degraded along with severe corrosion of several cables metal conduit shielding.


Title 10 CFR 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non- conformances are promptly identified and corrected.
Title 10 CFR 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.


Contrary to this, between January 16, 2012, and October 10, 2023, Constellations corrective action program did not ensure that a condition adverse to quality associated with a secondary containment penetration seal leak was promptly identified and corrected. Specifically, CR-JAF-2012- 00321, CR-JAF-2014- 03826, CR-JAF-2016- 00054, IR 04289195 on October 19, 2019, IR 04375824 on October 10, 2020, and IR 04708330 on October 9, 2023, and IR 4708354 on October 10, 2023, were entered into the corrective action program between 2012 and 2023 regarding water leakage into secondary containment through the reactor building west crescent penetration from MH-1. Constellation entered the issue into the corrective action program as IR 4708565 to document observation of the penetrations and cracks in the wall on October 10, 2023, and immediately assessed the condition for impact on secondary containment operability with satisfactory results.
Contrary to this, between January 16, 2012, and October 10, 2023, Constellations corrective action program did not ensure that a condition adverse to quality associated with a secondary containment penetration seal leak was promptly identified and corrected. Specifically, CR-JAF-2012-00321, CR-JAF-2014-03826, CR-JAF-2016-00054, IR 04289195 on October 19, 2019, IR 04375824 on October 10, 2020, and IR 04708330 on October 9, 2023, and IR 4708354 on October 10, 2023, were entered into the corrective action program between 2012 and 2023 regarding water leakage into secondary containment through the reactor building west crescent penetration from MH-1. Constellation entered the issue into the corrective action program as IR 4708565 to document observation of the penetrations and cracks in the wall on October 10, 2023, and immediately assessed the condition for impact on secondary containment operability with satisfactory results.


Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that Constellations failure to address this condition adverse to quality is minor because, similar to NRC Inspection Manual Chapter 0612 Appendix E, Examples of Minor Issues, Example 3.g, the degradation of the secondary containment penetration seals did not result in a loss of margin that exceeded the acceptance criteria, there were no changes to any assumptions used in the drawdown calculation to obtain favorable results, there were no revisions to calculations to establish operability, and there was no change to use a different calculation/approach from the original approach that would have resulted in unfavorable margin.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that Constellations failure to address this condition adverse to quality is minor because, similar to NRC Inspection Manual Chapter 0612 Appendix E, Examples of Minor Issues, Example 3.g, the degradation of the secondary containment penetration seals did not result in a loss of margin that exceeded the acceptance criteria, there were no changes to any assumptions used in the drawdown calculation to obtain favorable results, there were no revisions to calculations to establish operability, and there was no change to use a different calculation/approach from the original approach that would have resulted in unfavorable margin.
Line 301: Line 323:
=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


Inspection Type Designation Description or Title Revision or
Inspection
Procedure Date
Procedure
71111.04 Procedures OP-21 Emergency Service Water (ESW) 42
Type
OP-22 Diesel Generator Emergency Power 72
Designation
OP-60 Diesel Generator Room Ventilation 10
Description or Title
71111.05 Fire Plans PFP-PWR29 Switchgear Room East/Elevation 272'/ Fire Area/Zone II/SW-4
Revision or
PFP-PWR30 Switchgear Room West/Elevation 272'/ Fire Area/Zone 2
Date
71111.04
Procedures
OP-21
Emergency Service Water (ESW)
OP-22
Diesel Generator Emergency Power
OP-60
Diesel Generator Room Ventilation
71111.05
Fire Plans
PFP-PWR29
Switchgear Room East/Elevation 272'/ Fire Area/Zone II/SW-
PFP-PWR30
Switchgear Room West/Elevation 272'/ Fire Area/Zone
IC/SW-1
IC/SW-1
Miscellaneous JAF-RPT-04- JAF Fire Hazards Analysis 3
Miscellaneous
JAF-RPT-04-
00478
00478
Procedures FPP-3.56 Portable Fire Extinguisher Inspection 10
JAF Fire Hazards Analysis
71111.06 Corrective Action 04708330
Procedures
Documents 04708354
FPP-3.56
71111.11Q Procedures OP-27 Reactor Water Recirculation
Portable Fire Extinguisher Inspection
OSP-25.007 Control Rod Drive Stall Flow Test 3
71111.06
RAP-7.3.16 Plant Power Changes 62
Corrective Action
RAP-7.4.01 Control Rod Scram Time Evaluation 33
Documents
71111.12 Corrective Action 04550060
04708330  
Documents 04669409
 
04672634
04708354  
04685201
 
04708932
71111.11Q Procedures
04714627
OP-27
04714656
Reactor Water Recirculation
Miscellaneous Maintenance Rule (a)(3) Periodic Maintenance Effectiveness 06/16/2023
OSP-25.007
Control Rod Drive Stall Flow Test
RAP-7.3.16
Plant Power Changes
RAP-7.4.01
Control Rod Scram Time Evaluation
71111.12
Corrective Action
Documents
04550060  
 
04669409  
 
04672634  
 
04685201  
 
04708932  
 
04714627  
 
04714656  
 
Miscellaneous
Maintenance Rule (a)(3) Periodic Maintenance Effectiveness
Assessment for the period April 1, 2021 to March 31, 2023
Assessment for the period April 1, 2021 to March 31, 2023
DBD-09 Design Basis Document for Emergency Diesel Generator 14
06/16/2023
DBD-09
Design Basis Document for Emergency Diesel Generator
Systems
Systems
Procedures 22-MH-271-016- Condensate Storage Tank North Manhole, Elevation 271' 04/29/2022
Procedures
ER-JF-450 James A. FitzPatrick Structures Monitoring Program 1
2-MH-271-016-
71111.13 Procedures OP-AA-108-117 Protected Equipment Program 7
 
Work Orders 05297943-47
Condensate Storage Tank North Manhole, Elevation 271'
Inspection Type Designation Description or Title Revision or
04/29/2022
Procedure Date
ER-JF-450
71111.15 Corrective Action 04691010
James A. FitzPatrick Structures Monitoring Program
71111.13
Procedures
OP-AA-108-117
Protected Equipment Program
Work Orders
297943-47  
 
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.15
Corrective Action
Documents
Documents
Engineering 639679
04691010
Changes 639700
 
639783
Engineering
NDE Reports B23UT007 5 Extent of Condition Locations on 15-6-WES-151-103 09/19/2023
Changes
B23UT011 Extent of Condition UT Exams on B ESW Line 15-3-WES- 09/19/2023
639679  
 
639700  
 
639783  
 
NDE Reports
B23UT007
Extent of Condition Locations on 15-6-WES-151-103
09/19/2023
B23UT011
Extent of Condition UT Exams on B ESW Line 15-3-WES-
151-136
151-136
B23UT012 Extent of Condition UT Exams on B ESW Line 15-3-WES- 09/19/2023
09/19/2023
B23UT012
Extent of Condition UT Exams on B ESW Line 15-3-WES-
151-136
151-136
71111.24 Corrective Action 04708932
09/19/2023
Documents 04714656
71111.24
Procedures ISP-16 Drywell Floor Drain Sump Flow Loop Functional 46
Corrective Action
Documents
04708932  
 
04714656  
 
Procedures
ISP-16
Drywell Floor Drain Sump Flow Loop Functional
Test/Calibration
Test/Calibration
ISP-175B2 Reactor and Containment Cooling and ATWS Instrument 21
ISP-175B2
Reactor and Containment Cooling and ATWS Instrument
Functional Test/Calibration
Functional Test/Calibration
ST-18BB CREVAS B Operability Test 10
ST-18BB
ST-2AL RHR Loop A Quarterly Operability Test 46
CREVAS B Operability Test
ST-9BB EDG B and D Full Load Test and ESW Pump Operability 26
ST-2AL
RHR Loop A Quarterly Operability Test
ST-9BB
EDG B and D Full Load Test and ESW Pump Operability
Test
Test
Work Orders 05121000
Work Orders
05123104
05121000  
05123426
 
05131119
05123104  
259935
 
05407704
05123426  
71153 Corrective Action 04709988
 
Documents 04710830
05131119  
04721172
 
04721229
259935  
Procedures AOP-31 Loss of Condenser Vacuum 28
 
MA-AA-716-015 Control of Diving 16
05407704  
OP-4 Circulating Water System 96
 
13
71153
Corrective Action
Documents
04709988  
 
04710830  
 
04721172  
 
04721229  
 
Procedures
AOP-31
Loss of Condenser Vacuum
MA-AA-716-015
Control of Diving
OP-4
Circulating Water System
96
}}
}}

Latest revision as of 16:31, 2 January 2025

Integrated Inspection Report 05000333/2023004 and Independent Spent Fuel Storage Installation Inspection Report 07200012/2023001
ML24036A076
Person / Time
Site: FitzPatrick  Constellation icon.png
Issue date: 02/07/2024
From: Erin Carfang
NRC/RGN-I/DORS
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
References
IR 2023004
Download: ML24036A076 (1)


Text

February 7, 2024

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2023004 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200012/2023001

Dear David Rhoades:

On December 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On February 1, 2024, the NRC inspectors discussed the results of this inspection with Garrick Olson, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One Severity Level IV violation without an associated finding is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

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

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety

Docket No. 05000333 and 07200012 License No. DPR-59

Enclosure:

As stated

Inspection Report

Docket Number:

05000333 and 07200012

License Number:

DPR-59

Report Number:

05000333/2023004 and 07200012/2023001

Enterprise Identifier: I-2023-004-0037 and I-2023-001-0070

Licensee:

Constellation Energy Generation, LLC

Facility:

James A. FitzPatrick Nuclear Power Plant

Location:

Oswego, NY

Inspection Dates:

October 1, 2023 to December 31, 2023

Inspectors:

E. Miller, Senior Resident Inspector

B. Sienel, Resident Inspector

H. Anagnostopoulos, Senior Health Physicist

E. Eve, Senior Project Engineer

C. Hargest, Health Physicist

M. Henrion, Senior Health Physicist

A. Kostick, Health Physicist

J. Kulp, Senior Reactor Inspector

J. Schoppy, Senior Reactor Inspector

Approved By:

Erin E. Carfang, Chief

Projects Branch 1

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at James A. FitzPatrick Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to Maintain Adequate Dry Cask Storage Procedures Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2023004-01 Open/Closed Not Applicable 60855 A self-revealed Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.150, "Instructions, Procedures, and Drawings," was identified when Constellation failed to maintain adequate procedures to prevent dry cask storage equipment from adversely impacting the spent fuel pool (SFP) and associated equipment.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000333/2023004-02 Use of Holtec Multipurpose Canister Continuous Basket Shim Variant 60855 Open

PLANT STATUS

FitzPatrick began the inspection period at rated thermal power. On December 3, 2023, the main condenser experienced an increase in differential temperature due to debris. Operators reduced reactor power to 84 percent, flushed the debris and restored power to rated thermal power the same day. On December 9, 2023, the main condenser experienced an increase in differential temperature due to debris. Operators reduced reactor power to 80 percent, flushed the debris and restored power to rated thermal power the same day. On December 17, 2023, the main condenser experienced an increase in differential temperature due to debris. Operators reduced reactor power to 75 percent, flushed the debris and restored power to rated thermal power the same day. On December 29, 2023, operators reduced reactor power to 84 percent to flush any remaining main condenser debris following intake cleaning. Operators restored reactor power to rated thermal power on December 30, 2023. The unit 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, 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.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown (IP Section 03.01) (2 Samples)

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

(1)

'B' and 'D' emergency diesel generators (EDGs) following planned maintenance on the 'B' EDG on October 17, 2023 (2)

'B' and 'D' EDGs during planned maintenance on the 'A' EDG on October 30, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection (IP Section 03.01) (2 Samples)

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) East switchgear room, fire area/zone II/SW-2, on November 7, 2023
(2) West switchgear room, fire area/zone IC/SW-1, on November 7, 2023

71111.06 - Flood Protection Measures

Flooding (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the Manhole-1 (MH-1) following water intrusion into the secondary containment (west crescent) on October 10, 2023.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed operations personnel during a downpower to 74 percent that included unlocking of the 'B' reactor water recirculation motor generator set scoop tube, and control rod scram time testing on October 6 and 7, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed a simulator evaluation that included a nuclear instrument failure, the loss of both electrohydraulic control pumps, and a failure of the reactor to scram on October 24, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

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

(1) West crescent reactor core isolation cooling room enclosure structural monitoring on October 31, 2023
(2) Maintenance Rule Periodic a(3) maintenance effectiveness assessment for the period of April 1, 2021 to March 31, 2023
(3) Emergency diesel generators on December 14, 2023

Aging Management (IP Section 03.03) (1 Sample)

The inspectors evaluated the effectiveness of the aging management program for the following SSCs that did not meet their inspection or test acceptance criteria:

(1) Condensate storage tank north valve pit on November 16, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management (IP Section 03.01) (5 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:

(1) Elevated risk during 'A' residual heat removal system planned maintenance on October 3, 2023
(2) Elevated risk during 'B' emergency diesel generator planned maintenance on October 10, 2023
(3) Elevated risk during 'B' station battery charger planned maintenance on October 17, 2023
(4) Elevated risk during restoration of spent fuel pool rack 26 to its original location following an unintentional move during independent spent fuel storage campaign on October 26, 2023
(5) Elevated risk during 'A' emergency diesel generator planned maintenance on October 30, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)

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

(1) Emergency service water through-wall leaks on 'B' train in three locations upstream of the supply lines to the east crescent coolers on August 27, 2023, and August 30, 2023.

71111.24 - Testing and Maintenance of Equipment Important to Risk

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

Post-Maintenance Testing (IP Section 03.01) (6 Samples)

(1)

'A' residual heat removal system following planned system maintenance, on October 4, 2023 (2)

'A' residual heat removal service water pump following planned maintenance, on October 4, 2023 (3)

'B' emergency diesel generator following planned system maintenance, on October 11, 2023 (4)

'B' and 'D' emergency diesel generator tie breaker 71-10604 following 200 rpm speed relay 93-TBR-1EDGB12 replacement and breaker replacement, on October 12, 2023

(5) Control room ventilation following planned damper preventive maintenance, on October 18, 2023 (6)

'A' emergency diesel generator following right bank air start motor airline restoration from a configuration control event, on November 2, 2023

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) ISP-175B2, Reactor and Containment Cooling and anticipated transient without scram (ATWS) Instrument Functional Test/Calibration, on October 19, 2023

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) ISP-16, Drywell Floor Drain Sump Flow Loop Functional Test/Calibration, on October 30, 2023

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a simulator scenario that included the declaration of an Alert due to an anticipated transient with an inability to manually or automatically scram the reactor on October 24,

RADIATION SAFETY

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:

(1) Waste and equipment stored in the interim waste storage facility
(2) Waste stored in the outdoor sea land metals and dry active waste loading area

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) The modular fluidized transfer demineralization and sluice system (the advanced liquid processing system skid)
(2) The radwaste facility 250' elevation pump room and associated waste sludge tank and spent resin tank rooms

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) Title 10 CFR 61 waste profile analysis for dry active waste in 2023
(2) The characterization of bead resins in waste shipment [[::JAF-2023-1894|JAF-2023-1894]]

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) Shipment [[::JAF-2021-1872|JAF-2021-1872]], UN3321 LSA-II, Type 2 quantity of radioactive material, ion exchange media for disposal
(2) Shipment [[::JAF-2023-048|JAF-2023-048]], UN2915 Type A package, metal coupons for analysis
(3) Shipment [[::JAF-2023-1894|JAF-2023-1894]], UN3321 LSA-II, bead resins for disposal
(4) Shipment [[::JAF-2023-1909|JAF-2023-1909]], UN2915 Type A package, radioactive check sources for disposal

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

OR01: Occupational Exposure Control Effectiveness (IP Section 02.15)===

(1) For the period of July 1, 2022 through September 30, 2023

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences (IP Section 02.16) (1 Sample)

(1) For the period of July 1, 2022 through September 30, 2023

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors reviewed the FitzPatrick corrective action program for potential adverse trends in that might be indicative of a more significant safety issue.

71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)

(1) The inspectors evaluated the spent fuel pool rack 26 movement due to an independent spent fuel storage installation (ISFSI) rigging event on October 25, 2023.
(2) The inspectors evaluated the main condenser cleaning and downpower to 84 percent following debris intrusion on December 2, 2023.
(3) The inspectors evaluated the main condenser cleaning and downpower to 80 percent following debris intrusion on December 9, 2023.
(4) The inspectors evaluated the main condenser cleaning and downpower to 75 percent following debris intrusion on December 17, 2023.
(5) The inspectors evaluated the intake cleaning and traveling water screen inspection on December 20,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855 - Operation of an ISFSI Operation of an ISFSI

(1) The inspectors evaluated Constellation's ISFSI activities October 30 through November 2, 2023. Specifically, the inspectors observed the following activities:
  • Placement of empty transfer cask (HI-TRAC) and multipurpose canister (MPC) into SFP
  • Fuel loading and verification
  • Installation of the MPC lid onto the loaded MPC while in the SFP
  • Removal of the HI-TRAC/MPC out of the SFP and transfer to the HI-TRAC processing platform
  • Decontamination of loaded HI-TRAC/MPC
  • Drying of MPC using canister processing system
  • Transfer of the MPC/HI-TRAC down the equipment hatch and installation of the HI-TRAC onto the mating device
  • Stack-up and download of MPC into overpack (HI-STORM)
  • Transfer of the loaded HI-STORM out of the reactor building into the track bay
  • Transportation and placement of HI-STORM on the ISFSI pad

INSPECTION RESULTS

Failure to Maintain Adequate Dry Cask Storage Procedures Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000333/2023004-01 Open/Closed

Not Applicable 60855 A self-revealed Severity Level IV NCV of 10 CFR Part 72.150, "Instructions, Procedures, and Drawings," was identified when Constellation failed to maintain adequate procedures to prevent dry cask storage equipment from adversely impacting the SFP and associated equipment.

Description:

On October 16, 2023, during an ISFSI campaign, Constellation staff were lowering Cask #4 (reusable shielding HI-TRAC containing empty MPC) into the SFP when tighter than normal clearances were noticed in the area between the HI-TRAC and SFP storage racks immediately adjacent to the cask pit. The licensee finished fuel loading of Cask

  1. 4 and removed it from the SFP for further processing. On October 18, 2023, the inspectors were notified that there was a shifted SFP rack that needed to be resolved before continuing the ISFSI campaign with Cask #5. The shifted rack was identified as Rack 26, which held double blade guides but did not contain spent fuel assemblies. Constellation determined that Rack 26 had been lifted and shifted out of its normal position on October 11, 2023, when the refuel floor overhead crane was lifting the fully loaded Cask #3 out of the SFP, and the bottom flange of the HI-TRAC unintentionally hooked onto the bottom of Rack 26.

Procedure MP-019.06, MPC Loading and Sealing, Revision 35, was not adequate to ensure that the HI-TRAC bottom flange was clear of adjacent spent fuel storage racks because this revision of the procedure did not require the use of underwater camera shots so spotters could see the HI-TRAC bottom flange when the cask was being lifted in or out of the SFP and traveling past SFP storage racks in the areas immediately adjacent to the movement activities.

Corrective Actions: Constellation revised procedure MP-019.06, "MPC Loading and Sealing,"

to include the use of underwater cameras for viewing the bottom of the HI-TRAC while lifting it into and out of the SFP.

Corrective Action References: IR 04709988

Performance Assessment:

None. Independent spent fuel storage installations and nuclear materials facilities are only subject to traditional enforcement and therefore not subject to the Significance Determination Process outlined in NRC Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment Program."

Enforcement:

Severity: Consistent with the guidance in Section 1.2.6.D of the NRC Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level:

(1) commensurate with its safety significance; and
(2) informed by similar violations addressed in the violation examples. The violation screened as having very low safety significance (Severity Level IV).

Violation: Title 10 CFR 72.150, "Instructions, Procedures, and Drawings," states, The licensee, applicant for a license, certificate holder, and applicant for a Certificate of Compliance (CoC) shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall require that these instructions, procedures, and drawings be followed. The instructions, procedures, and drawings must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, prior to October 16, 2023, procedure MP-019.06, MPC Loading and Sealing, Revision 35, did not contain appropriate guidance (instructions, procedures or drawings) that ensured that the lifting of the HI-TRAC could not adversely impact the SFP and associated equipment. Specifically, Revision 35 of the procedure did not require the use of underwater cameras to ensure that the HI-TRAC was clear of adjacent SFP racks when being lifted into or out of the SFP.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Unresolved Item (Open)

Use of Holtec Multipurpose Canister Continuous Basket Shim Variant URI 05000333/2023004-02 60855

Description:

The inspectors identified an unresolved item (URI) related to design changes on the dry storage system MPCs utilized by Constellation. On February 17th, 2021, Holtec International, the supplier of the HI-STORM 100 dry storage system for FitzPatrick, performed engineering change order (ECO) 5014-320, Revision 0 and 10 CFR 72.48 evaluation 1502, Revision 0. These evaluations performed a design change to introduce a new MPC basket design to the HI-STORM 100 dry storage system, designated as the continuous basket shim (CBS) variant.

On September 12, 2023, the NRC issued Inspection Report 07201014/2022-201 (ADAMS Accession No. ML23145A175) to Holtec International, identifying three apparent violations associated with design change. The apparent violations, related to 10 CFR 72.48 and 10 CFR 72.146 requirements, are for Holtec Internationals apparent failures to provide adequate bases that the CBS variant did not require a license amendment, failure to ensure the change did not result in a departure from the method of evaluations described in the Final Safety Analysis Report, and failure to establish design control measures commensurate with those applied to the original design. At this time, the NRC has determined there is no immediate safety concern associated with the use of the modified basket design.

On August 14, 2023, FitzPatrick adopted Holtec Internationals CBS ECO/72.48 through Constellation's 72.48 program, #JAF-72SCN-23-001; evaluated Holtec Internationals 72.48 in accordance with 72.212(b)(7); and subsequently loaded the MPC-68M-CBS canisters from September 24 to November 6, 2023.

General licensees are responsible to ensure that each cask they use conforms to the terms, conditions, and specifications of a CoC or an amended CoC listed in 72.214 and regulatory requirements in 10 CFR Part 72.

Accordingly, this issue is being treated as a URI pending further inspection by the NRC staff to determine if FitzPatrick's loading of the dry storage systems constituted a noncompliance with regulatory requirements associated with the final enforcement action to Holtec International related to the design change.

Planned Closure Actions: Constellation's performance related to the adoption and use of the MPC-68M-CBS canister is unresolved at this time as the NRC has not made a final determination for the apparent violations documented in Inspection Report 07201014/2022-201. The inspectors can evaluate Constellation's compliance with regulatory requirements associated with loading of MPC baskets with the CBS variant once a final determination is made.

Licensee Actions: Constellation's loading of the CBS fuel basket MPC-68M-CBS assumes the risk of potentially being in violation of regulatory requirements pending the outcome of the NRC enforcement action involving Holtec International.

Corrective Action References: IR 04697142 Engineering Change 639367

Minor Performance Deficiency 71152S Minor Performance Deficiency: The inspectors evaluated a sample of issues and events that occurred over the third and fourth quarters of 2023. The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Constellation staff for potential trends at a low threshold and resolved within the scope of the corrective action program.

The inspectors identified a trend associated with ground water intrusion into secondary containment through degraded penetration seals in an outdoor manhole, manhole-1 (MH-1).

Specifically, the combination of degraded seals, abandoned conduits, and sump pump failures have contributed to repeat occurrences of ground water intrusion. This ground water intrusion has affected the west crescent area radiation monitor, which is used to determine actions associated with a radioactive release during an accident in secondary containment. In addition, the degrading seals and conduits represent a reduction in available margin associated with the maximum allowable opening size permissible to support the standby gas treatment systems function to drawdown the secondary containment, treat the air, and monitor it before being released to the atmosphere.

Following heavy rains, equipment operators discovered the sump pump for manhole MH-1 was not operating on October 9, 2023. Elevated water levels in the sump, combined with degraded seal penetrations, resulted in leakage into the secondary containment. The water damaged an area radiation monitor in the west crescent, causing it to be non-functional and require compensatory measures. This radiation monitor is credited in EOP-SC, "Emergency Operating Procedure for Secondary Containment," for determining when to insert a reactor scram or perform an emergency depressurization. On October 10, 2023, the inspectors accompanied maintenance staff to observe conditions and maintenance repairs to the sump.

The inspectors found a significant amount of water leaking through the manhole wall. In addition, penetration seals were degraded along with severe corrosion of several cables metal conduit shielding.

Title 10 CFR 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.

Contrary to this, between January 16, 2012, and October 10, 2023, Constellations corrective action program did not ensure that a condition adverse to quality associated with a secondary containment penetration seal leak was promptly identified and corrected. Specifically, CR-JAF-2012-00321, CR-JAF-2014-03826, CR-JAF-2016-00054, IR 04289195 on October 19, 2019, IR 04375824 on October 10, 2020, and IR 04708330 on October 9, 2023, and IR 4708354 on October 10, 2023, were entered into the corrective action program between 2012 and 2023 regarding water leakage into secondary containment through the reactor building west crescent penetration from MH-1. Constellation entered the issue into the corrective action program as IR 4708565 to document observation of the penetrations and cracks in the wall on October 10, 2023, and immediately assessed the condition for impact on secondary containment operability with satisfactory results.

Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that Constellations failure to address this condition adverse to quality is minor because, similar to NRC Inspection Manual Chapter 0612 Appendix E, Examples of Minor Issues, Example 3.g, the degradation of the secondary containment penetration seals did not result in a loss of margin that exceeded the acceptance criteria, there were no changes to any assumptions used in the drawdown calculation to obtain favorable results, there were no revisions to calculations to establish operability, and there was no change to use a different calculation/approach from the original approach that would have resulted in unfavorable margin.

Based on the overall results of the semiannual trend review, the inspectors determined that Constellation had generally identified adverse trends before they could become more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, and determined them to be minor.

EXIT MEETINGS AND DEBRIEFS

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

  • On October 12, 2023, the inspectors presented the 71124.08 inspection results to Timothy Sollenberger, Senior Radiation Protection Manager, and other members of the licensee staff.
  • On November 2, 2023, the inspectors presented the ISFSI inspection results to Garrick Olson, Plant Manager, and other members of the licensee staff.
  • On February 1, 2024, the inspectors presented the integrated inspection results to Garrick Olson, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.04

Procedures

OP-21

Emergency Service Water (ESW)

OP-22

Diesel Generator Emergency Power

OP-60

Diesel Generator Room Ventilation

71111.05

Fire Plans

PFP-PWR29

Switchgear Room East/Elevation 272'/ Fire Area/Zone II/SW-

PFP-PWR30

Switchgear Room West/Elevation 272'/ Fire Area/Zone

IC/SW-1

Miscellaneous

JAF-RPT-04-

00478

JAF Fire Hazards Analysis

Procedures

FPP-3.56

Portable Fire Extinguisher Inspection

71111.06

Corrective Action

Documents

04708330

04708354

71111.11Q Procedures

OP-27

Reactor Water Recirculation

OSP-25.007

Control Rod Drive Stall Flow Test

RAP-7.3.16

Plant Power Changes

RAP-7.4.01

Control Rod Scram Time Evaluation

71111.12

Corrective Action

Documents

04550060

04669409

04672634

04685201

04708932

04714627

04714656

Miscellaneous

Maintenance Rule (a)(3) Periodic Maintenance Effectiveness

Assessment for the period April 1, 2021 to March 31, 2023

06/16/2023

DBD-09

Design Basis Document for Emergency Diesel Generator

Systems

Procedures

2-MH-271-016-

Condensate Storage Tank North Manhole, Elevation 271'

04/29/2022

ER-JF-450

James A. FitzPatrick Structures Monitoring Program

71111.13

Procedures

OP-AA-108-117

Protected Equipment Program

Work Orders

297943-47

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.15

Corrective Action

Documents

04691010

Engineering

Changes

639679

639700

639783

NDE Reports

B23UT007

Extent of Condition Locations on 15-6-WES-151-103

09/19/2023

B23UT011

Extent of Condition UT Exams on B ESW Line 15-3-WES-

151-136

09/19/2023

B23UT012

Extent of Condition UT Exams on B ESW Line 15-3-WES-

151-136

09/19/2023

71111.24

Corrective Action

Documents

04708932

04714656

Procedures

ISP-16

Drywell Floor Drain Sump Flow Loop Functional

Test/Calibration

ISP-175B2

Reactor and Containment Cooling and ATWS Instrument

Functional Test/Calibration

ST-18BB

CREVAS B Operability Test

ST-2AL

RHR Loop A Quarterly Operability Test

ST-9BB

EDG B and D Full Load Test and ESW Pump Operability

Test

Work Orders

05121000

05123104

05123426

05131119

259935

05407704

71153

Corrective Action

Documents

04709988

04710830

04721172

04721229

Procedures

AOP-31

Loss of Condenser Vacuum

MA-AA-716-015

Control of Diving

OP-4

Circulating Water System

96