ML21244A500
| ML21244A500 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/03/2021 |
| From: | David Lew NRC Region 1 |
| To: | Exelon Generation Co |
| References | |
| EA-20-138 IR 2021090 | |
| Download: ML21244A500 (2) | |
See also: IR 05000333/2021090
Text
ENCLOSURE 3
NOTICE OF VIOLATION
Exelon Generation Company, LLC Docket No. 50-333
James A. FitzPatrick Nuclear Power Plant License No. DPR-59 EA-20-138
During an NRC review in response to a contested violation conducted from June 3, 2021,
through September 3, 2021, violations of NRC requirements were identified. In accordance with
the NRC Enforcement Policy, the violations are listed below:
Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states,
in part, that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished
in accordance with these instructions, procedures, or drawings.
Title 10 CFR Part 50, Appendix B, Criterion XV, Nonconforming Materials, Parts, or
Components, states, in part, that measures shall be established to control materials, parts, or
components which do not conform to requirements in order to prevent their inadvertent use or
installation. These measures shall include, as appropriate, procedures for identification,
documentation, segregation, disposition, and notification to affected organizations.
Exelon Procedure SM-AA-102, Warehouse Operations, Revision 23, prescribes activities
affecting quality and measures to control nonconforming components. Procedure SM-AA-102,
Attachment 1, step 1.10.6, states Items that are on hold at one site can be released to another
site while on hold only if an action item is created at the receiving site to track resolution of the
item before the transfer occurs, and the item is added to the receiving sites hold tag log. A hold
tag shall be attached to the item upon receipt of the transfer at the receiving site.
FitzPatrick Technical Specification (TS 3.5.1) requires, in part, that the HPCI system be
operable in Modes 1, 2 and 3 with reactor steam dome pressure >150 psig. If the HPCI system
is determined to be inoperable, it shall be returned to an operable status within 14 days. If not
restored to an operable status, the unit shall be shut down and in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, from December 16, 2017, to April 10, 2020, activities affecting quality
were not accomplished in accordance with procedures for controlling a nonconforming
component and a nonconforming component was not controlled in accordance with documented
procedures. Specifically, Exelon failed to initiate an action item at FitzPatrick to track resolution
of a nonconforming Pressure Control Valve (PCV) before its transfer occurred, did not add it to
the receiving sites hold tag log, and did not attach a hold tag upon receipt. As a result, on
December 16, 2017, Exelon did not identify that the PCVs diaphragm required replacement and
installed the nonconforming PCV in the High Pressure Coolant Injection (HPCI) system.
Consequently, the HPCI system was rendered inoperable prior to April 10, 2020, for a period
longer than its TS allowed outage time, and the unit was not shut down and placed in Mode 3
within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in accordance with requirements.
These violations are categorized collectively as a problem and are associated with a White
Significance Determination Process finding.
Notice of Violation 2
No response to this Notice of Violation is required since the NRC previously received adequate
responses as documented in a letter dated February 26, 2021 (ML21057A190). If you wish to
provide additional information for the NRC to consider, you should notify the Region I Regional
Administrator verbally within 10 days of receipt of this Notice of Violation, followed by a written
response submitted within 30 days of the date of the notification to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is
the subject of this Notice. This reply should be clearly marked as a "Reply to a Notice of
Violation; EA-20-138". If you do not notify the Region I Regional Administrator within 10 days of
receipt, this Notice of Violation will be considered final.
Your response, if made, will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, the licensee may be required to post this Notice within two
working days of receipt.
Dated this 3rd day of September 2021.