IR 05000333/2023001
| ML23123A168 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 05/03/2023 |
| From: | Erin Carfang NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023001 | |
| Download: ML23123A168 (1) | |
Text
May 3, 2023
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2023001
Dear David Rhoades:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On April 27, 2023, the NRC inspectors discussed the results of this inspection with Timothy Peter, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Three findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations 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, D.C. 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.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; 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 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Digitally signed by Erin E.
Erin E. Carfang Date: 2023.05.03 Carfang 13:55:41 -04'00'
Erin E. Carfang, Chief Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000333 License No. DPR-59
Enclosure:
As stated
Inspection Report
Docket Number: 05000333 License Number: DPR-59 Report Number: 05000333/2023001 Enterprise Identifier: I-2023-001-0035 Licensee: Constellation Energy Generation, LLC Facility: James A. FitzPatrick Nuclear Power Plant Location: Oswego, NY Inspection Dates: January 1, 2023 to March 31, 2023 Inspectors: E. Miller, Senior Resident Inspector J. England, Senior Construction Inspector H. Anagnostopoulos, Senior Health Physicist S. Haney, Senior Project Engineer D. Kern, Senior Reactor Inspector J. Lilliendahl, Senior Emergency Response Coordinator J. Rady, Senior Reactor Inspector J. Schussler, Senior Resident Inspector 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 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
'A' LPCI Battery Cell Performance Not Trended in Accordance with Procedures Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.15 Systems FIN 05000333/2023001-01 Identification Open/Closed The inspectors identified a Green finding because Constellation personnel did not adequately trend 'A' LPCI (low-pressure coolant injection) battery cell performance in accordance with ER-AA-2003, System Performance Monitoring and Analysis. Specifically, Constellation's failure to identify cell 171 voltage degradation resulted in the failure to meet Technical Specifications (TS) 3.8.6 voltage limits and its inoperability on December 3, 2022.
Missed Surveillance of the 'A' Low-Pressure Coolant Injection Battery Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.15 Systems NCV 05000333/2023001-02 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification Surveillance Requirement 3.8.4.4 DC, Sources - Operating.
Specifically, the licensee failed to perform battery capacity testing every 12 months following the November 2018 test indicating battery degradation.
Inadvertent Foam Initiation Causes Group 1 Containment Isolation Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.8] - 71111.15 NCV 05000333/2023001-03 Procedure Open/Closed Adherence A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specifications (TS) 5.4.1(a), Procedures were identified when the licensee failed to follow a procedure during a fire system test. Specifically, while performing firefighting foam system testing for the main condenser, an operator inadvertently depressed the initiation button causing a release of foam. The foam entered the reactor coolant system and caused a containment isolation signal.
Additional Tracking Items
None.
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On March 3, 2023, operators reduced reactor power to 70 percent to perform a control rod pattern adjustment and turbine valve testing. On March 4, 2023, operators restored reactor power to rated thermal power.
FitzPatrick remained at or near rated thermal power for the remainder of the quarter.
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
71111.01 - Adverse Weather Protection
Impending Severe Weather (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated readiness for impending adverse weather for the emergency diesel generators and FLEX diesel generator on March 13, 2023
71111.04 - Equipment Alignment
Partial Walkdown (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Fuel pool cooling on January 5 and 10, 2023
- (2) 'A' standby gas treatment system during reactor building ventilation planned maintenance on February 14, 2023
- (3) High-pressure coolant injection (HPCI) system on March 15, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection (IP Section 03.01) (6 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) Independent spent fuel storage installation pad, fire area YARD, on January 3, 2023
- (2) Auxiliary boiler, hydrogen storage area, and oxygen storage area, fire area YARD, on January 11, 2023
- (3) Warehouse 1, elevation 272', fire area YARD, on January 24, 2023
- (4) Reactor building fire areas/zones X/RB-1B and VIII/RB-1C, on February 14 and 15, 2023
- (5) Crescent area west, elevations 227' and 242', fire area/zone XVII/RB-1W, on February 22, 2023
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) 'B' residual heat removal heat exchanger on February 1, 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 reactor downpower and turbine valve testing on March 3 and 4, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 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) Battery room ventilation on January 17, 2023
- (2) Safety-related breaker review following core spray failure to start on January 26, 2023
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management (IP Section 03.01) (4 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) Temporary battery room ventilation during 'B' battery room ventilation planned maintenance on January 17, 2023
- (2) 'A' core spray pump failure to start on January 18, 2023
- (3) Elevated risk during 115-kilovolt to 4-kilovolt transformer 71T-3 planned maintenance on March 6 and 7, 2023
- (4) Elevated risk and use of risk informed completion time during Line 4 out of service for planned maintenance on March 16 and 17, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) LPCI battery cell 171 individual cell voltage failure due to low individual cell voltage on January 3, 2023
- (2) Residual heat removal shutdown cooling through-wall leak upstream of 10RHR-796B on January 10, 2023
- (3) 'A' core spray pump failure to start during surveillance testing on January 18, 2023
- (4) 'A' LPCI 419 volts direct current battery on February 2, 2023
- (5) Reactor coolant system due to firefighting foam intrusion on February 19, 2023
- (6) 'E' safety relief valve following NRC identification of lockwire installation error on March 13, 2023
- (7) 71-T8 4-kilovolt to 600-volt transformer loose mechanical connection on March 24, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Permanent Modification: Engineering Change 638087, Drawing Updates for Incorrect Torque Values on Safety Relief Valve Pilot Bolts/Belleville Washer and Lock Wire Used on Safety Relief Valve (SRV) Pilots on March 2, 2023
- (2) Permanent Modification: Engineering Change 638106, Anticipated Transient Without Scram (ATWS) Overpressure Analysis Implementation on March 15, 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)
- (1) 'A' core spray following failure to start and breaker troubleshooting on January 18, 2023
- (2) 10MOV-39B, 'B' residual heat removal torus return valve following preventive maintenance and wiring modification on February 1, 2023
- (3) 'B' residual heat removal system following preventive maintenance on February 2, 2023
- (4) 23MOV-16, HPCI turbine steam supply outboard isolation valve following installation of shunt field circuit protection on March 6, 2023
- (5) 23MOV-19, HPCI inboard isolation valve following installation of shunt field circuit protection on March 6, 2023
Surveillance Testing (IP Section 03.01) (4 Samples)
- (2) MST-071.25, LPCI Battery Modified Performance Test for 71BAT-3A on February 8, 2023
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) ST-3PA, Core Spray Loop A Quarterly Operability Test (IST) on January 19,
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 the licensee 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 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Administration building 272' elevation "old access area" control point
- (2) Radiation protection area main access control point
Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) RWP JF-1-22-00506
- (2) RWP JF-1-22-00513
- (3) RWP JF-1-22-00901
- (4) RWP JF-1-22-00903 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Reactor building 272' elevation traversing incore probe room
- (2) Reactor building 272' elevation 'B' residual heat removal heat exchanger room
- (3) Reactor building 300' elevation reactor water cleanup sludge decant pump room 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 (IP Section 02.01) ===
- (1) January 1, 2022 through December 31, 2022
IE03: Unplanned Power Changes per 7000 Critical Hours (IP Section 02.02) (1 Sample)
- (1) January 1, 2022 through December 31, 2022
IE04: Unplanned Scrams with Complications (IP Section 02.03) (1 Sample)
- (1) January 1, 2022 through December 31, 2022
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03)
- (1) The inspectors evaluated a Group 1 primary containment isolation signal due to high radiation signal on the main steam line and condenser bay firefighting foam system actuation on February 19,
INSPECTION RESULTS
'A' LPCI Battery Cell Performance Not Trended in Accordance with Procedures Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71111.15 Systems FIN 05000333/2023001-01 Identification Open/Closed The inspectors identified a Green finding because Constellation personnel did not adequately trend 'A' low-pressure coolant injection battery cell performance in accordance with ER-AA-2003, "System Performance Monitoring and
Analysis.
Specifically, Constellation's failure to identify cell 171 voltage degradation resulted in the failure to meet TS 3.8.6 voltage limits and its inoperability on December 3, 2022.
Description:
The LPCI battery provides the primary power supply for the three motor operated valves (MOVs) in each of the two redundant LPCI (low-pressure coolant injection) loops and for the operation of two MOVs in the recirculation loops. Constellation Plant Engineering establishes a system performance monitoring program which gathers, evaluates, and analyzes data pertinent to system performance so that system health can be assessed.
Monitoring system parameters is performed to identify degradation mechanisms or degrading system or equipment performance. Procedure ER-AA-2003, System Performance Monitoring and Analysis, requires the establishment of a Performance Monitoring Plan. This plan identifies parameters to be monitored, failure modes, alert and action levels. Monitoring bands and frequency should be sufficient to identify degrading trends before alarms are actuated and before design, operating, or license requirements are challenged. The System 71-DC Station DC Distribution System Performance Monitoring Plan approved July 2020 requires the battery individual cell voltages (ICV) be monitored with an alert set for any ICV more than 0.04 volts direct current (VDC) below the average ICV. ER-AA-2003, Section 4.1.5.E requires that when a parameter exceeds the alert level, an issue report (IR) must be generated. The ICVs for the A LPCI battery are monitored quarterly using surveillance test, MST-071.11, LPCI Battery Quarterly Surveillance Test.
Contrary to ER-AA-2003, Section 4.1.5.E, the station failed to generate an IR on four occasions. The inspector identified that the August 3, 2021 test had five battery cells including cell #171 in the alert level, the September 27, 2021 test had eleven battery cells including cell #171 in the alert level, the March 3, 2022 test had eight cells including cell #171 in the alert level, and the May 19, 2022 seven cells including cell #171 in the alert level. In each of these cases an IR was not generated and additional action such as performing an equalize charge was not performed.
On December 2, 2022, the ICV for cell #171 was 2.08 VDC. The surveillance test, MST-071.11 Section 11.1.3 and TS 3.8.6, Battery Cell Parameters, require individual cell voltage to exceed 2.13 VDC. TS Limiting Condition of Operation (LCO) 3.8.6 required the ICV to be verified greater than 2.07 VDC and restore the battery cell parameters within 31 days. On December 3, 2022, the ICV for cell #171 was measured at 2.06 VDC. Technical Specification LCO 3.8.6 requires the 'A' LPCI battery to be declared inoperable. Technical Specification 3.5.1, ECCS -Operating, requires restoration of low pressure ECCS injection to operable within 7 days.
Corrective Actions: Battery cell #171 was replaced on December 4, 2022.
Corrective Action References: IR 04540528
Performance Assessment:
Performance Deficiency: The licensee failed to generate IRs on August 3, 2021, September 27, 2021, March 3, 2022, and May 19, 2022 when cell #171 was in the alert range as required by ER-AA-2003, "System Performance Monitoring and Analysis," Section 4.1.5.E and the Station DC Distribution System Performance Monitoring Plan.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Constellation's failure to identify cell #171 voltage degradation resulted in the failure to meet TS 3.8.6 voltage limits and its inoperability on December 3, 2022.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined this finding to be of very low safety significance (Green) in accordance with Exhibit 2, because it
- (1) did not involve a deficiency affecting the design or qualification of a mitigating SSC that affected its operability or Probabilistic Risk Assessment (PRA)functionality;
- (2) was not a degraded condition that represented a loss of the PRA function of a single train TS system for greater than its TS allowed outage time;
- (3) did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time;
- (4) did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;
- (5) did not represent a loss of a PRA system and/or function as defined in the Plant Risk Information Book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and
- (6) did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, Constellation staff had several opportunities to identify the degraded condition and did not follow procedural trending requirements to identify a degraded condition.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
Missed Surveillance of the 'A' Low-Pressure Coolant Injection Battery Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.15 Systems NCV 05000333/2023001-02 Open/Closed The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification Surveillance Requirement 3.8.4.4 DC Sources - Operating.
Specifically, the licensee failed to perform battery capacity testing every 12 months following the November 2018 test indicating battery degradation.
Description:
FitzPatrick has two trains of LPCI. Each train consists of two pumps, piping, motor operated valves, and valve power supplies. The valves are powered by a 600volts alternating current (VAC) power supply system which is composed of two separate and independent power supplies that includes a 419 VDC battery, 600 VAC emergency bus power supply, an inverter, a rectifier/charger, a transformer, and associated circuit breakers.
The normal valve power supply is the 419 VDC LPCI battery.
Battery health is monitored by the performance of capacity tests. Capacity tests are a controlled discharge of the battery and the test results are compared with the needed battery capacity. At FitzPatrick, a modified performance discharge test is performed every 5 years to meet Technical Specifications Surveillance Requirement 3.8.4.4 using surveillance test procedure MST-071.25, LPCI Battery Modified Performance Test.
During a review of the November 29, 2018 capacity test completed as work order 82678888, the inspectors identified that FitzPatrick engineering staff failed to complete Step 12.8 of MST-071.25. Step 12.8 states, Engineer review procedure and collected data as follows:
12.8.1 Compare capacity rating with capacity as determined by last performance of this procedure.
12.8.2 Accelerated performance testing (or modified performance test) shall be conducted on any battery meeting the following criteria.
A. SR 3.8.4.4 (Bases) (Reference Definitions Section)1. Annually if battery capacity drops more than 10% from its previous performance test (or modified performance test).
2. Annually if battery capacity is below 90% of manufacturers rating.
3. Annually if battery has reached 85% of its service life with capacity LESS THAN 100% of manufacturers rating.
12.8.3 If any criteria of Step 12.8.2 has been met AND not previously addressed THEN initiate an IR in addition to a test frequency change as applicable in accordance with (12.8.2).
12.8.4 Trend performance test results and post test quarterly data."
The inspectors observed a degradation in battery performance between 2018 and 2013.
Section 4.4.1 of MST-071.25 defines degradation as "according to IEEE-450 when the battery capacity drops more than 10% relative to its capacity on the previous performance test."
The November 29, 2018 test measured the capacity of the A LPCI 419 VDC battery bank (71BAT-3A) at 130.6 percent. The previous test was performed February 15, 2013 and measured the capacity at 147.3 percent. The difference between these tests was greater than 10 percent. Technical Specification Surveillance Requirement 3.8.4.4 further requires battery capacity to be verified every 12 months when the battery shows degradation. The inspector informed licensee staff of the missed surveillance on February 2, 2023.
Corrective Actions: The licensee entered SR 3.0.3 due to the missed surveillance. The licensee performed a risk evaluation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and performed the missed surveillance on February 10, 2023. The battery capacity was found acceptable when tested.
Corrective Action References: IRs 04552150 and 04552202
Performance Assessment:
Performance Deficiency: Constellation failed to perform battery capacity tests at the required frequency as required by TS SR 3.8.4.4.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This issue is also similar to Inspection Manual Chapter 0612, Appendix E, Example 2.a because the battery performance degradation was such that the licensee had to initiate actions as required by the procedure and surveillance requirement and the time period specified had been exceeded. Specifically, the battery degradation between the capacity tests conducted in February 2013 and November 2018 resulted in increased testing frequency to yearly, but the issue was identified by NRC inspectors over 4 years later.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined this finding to be of very low safety significance (Green) in accordance with Exhibit 2, because
- (1) it did not involve a deficiency affecting the design or qualification of a mitigating SSC that affected its operability or PRA functionality;
- (2) it was not a degraded condition that represented a loss of the PRA function of a single train TS system for greater than its TS allowed outage time;
- (3) it did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time;
- (4) it did not represent a loss of the PRA function of two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;
- (5) it did not represent a loss of a PRA system and/or function as defined in the Plant Risk Information Book or the licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and
- (6) it did not represent a loss of the PRA function of one or more non-TS trains of equipment designated as risk-significant in accordance with Constellation's maintenance rule program for greater than 3 days.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Technical Specification Surveillance Requirement 3.8.4.4 requires verification that battery capacity is greater than or equal to 80 percent of the manufacturers rating when subjected to a performance discharge test every 12 months when the battery shows degradation.
Contrary to this, from November 19, 2019, and February 10, 2023, the licensee did not verify that battery capacity was greater than or equal to 80 percent of the manufacturers rating when subjected to a performance discharge test every 12 months for a battery that showed degradation. Specifically, the A LPCI 419 VDC battery bank (71BAT-3A) showed degradation when tested on November 29, 2018, but the licensee did not again test the battery until February 10, 2023, a period greater than 12 months.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
Inadvertent Foam Initiation Causes Group 1 Containment Isolation Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.8] - 71111.15 NCV 05000333/2023001-03 Procedure Open/Closed Adherence A self-revealed Green finding and associated non-cited violation (NCV) of Technical Specifications (TS) 5.4.1(a), Procedures was identified when the licensee failed to follow a procedure during a fire system test. Specifically, while performing firefighting foam system testing for the main condenser, an operator inadvertently depressed the initiation button causing a release of foam. The foam entered the reactor coolant system and caused a containment isolation signal.
Description:
The firefighting foam (foam) system is a protein-based substance used to extinguish and limit fires from oil slicks. At FitzPatrick, one of the areas it is used is the main condenser pit, due to the potential for oil from various lubricating systems to be in the area.
Thermostats in the area trigger the system.
On February 19, 2023, FitzPatrick operations personnel were performing a test of the foam system for the main condenser pit as part of FPP-3.25, "Fire Protection Manifold #5 Sprinkler System Main Drain and Water Flow Alarm Test," Revision 7. At 1:05 AM, an operator caused an inadvertent actuation of the foam system by depressing the wrong button. The accumulation of the foam in the condenser bay reached a level that allowed intrusion into the low conductivity sump and into the main condenser.
Procedure HU-AA-101, "Human Performance Tools and Verification Practices," Section 4.1 requires performing a self-check prior to proceeding with performance of a procedure step.
Procedure FPP-3.25, Step 8.1.13 states, Press Acknowledge button on FPP (fire protection panel) and verify the following: 1. Alarm Bell is off and 2. Red Condenser Pit Foam System light is on. Contrary to HU-AA-101, the operator performing Step 8.1.13 failed to perform a self-check and depressed the foam initiation push button.
Foam is high in organic content and resulted in a spike in reactor water conductivity. Elevated conductivity reflects an increase in water contaminants. The organic contaminants become radioactive as they are circulated through the reactor coolant system and can be seen by radiation monitors in the steam line. As a result, operators received high radiation alarms for the main steam line and off-gas radiation monitors. The high main steam line radiation signal caused a partial Group 1 isolation signal for the reactor water recirculation system sample line primary containment isolation valves. In addition, the other Group 1 isolation valves for main condenser vacuum system main steam line drains were already met because they are closed during normal operation.
Technical Requirements Manual 3.4, Reactor Coolant System (RCS) Chemistry, requires the chemistry of the RCS to be maintained within the limits specified in SP-05.02, Chemistry Surveillance and Scheduling System, Revision 14. Technical Requirements Manual 3.4 B requires reactor water sulfates to be less than 3 parts per billion (ppb). Reactor water sulfates peaked during the event at 4.15 ppb.
In addition, the station's Water Chemistry Control - BWR Program relies on monitoring and control of RCS chemistry to control the aging effects caused by corrosion and cracking mechanisms. The program is based on EPRI (Electric Power Research Institute) 1016579 BWRVIP (Boiling Water Reactor Vessel Internals Program) -190. To meet the EPRI requirements, the station implements CY-AB-120-100, Reactor Water Chemistry, Revision 21. The organic content resulted in reactor water conductivity exceeding EPRI Action Level 1, which requires conductivity to be less than 0.3 mircosiemens/centimeter.
Reactor water conductivity peaked at 0.69 microsiemens/centimeter.
Operations staff entered AOP-3, High Activity in Reactor Coolant or Off-gas, Revision 18 to address the main steam line high-high radiation monitor alarm, AOP-15, Isolation Verification and Recovery, Revision 32 to verify and address the Group 1 containment isolation signal, and AOP-76, High Conductivity in Condensate System, Revision 9 to address the elevated conductivity and sulfate levels in the reactor coolant system. Operators verified the alarms, and initiated actions for chemistry to perform reactor water sampling.
Corrective Actions: Constellation performed a briefing with all station personnel to discuss the event and reinforce the requirements of HU-AA-101. In addition, the operator involved was disqualified. The station conducted cleanup of the reactor coolant system using additional charcoal filtration to restore chemistry parameters to acceptable levels.
Corrective Action References: IRs 04555544, 04555907 and 04555914
Performance Assessment:
Performance Deficiency: Failure to follow a procedure during a fire system test.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, while performing fire foam system testing for the main condenser, an operator inadvertently depressed the initiation button causing a release of the fire foam into the condenser bay. The foam entered the reactor coolant system and resulted in exceeding the primary water chemistry EPRI Action Level 1 conductivity requirement.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that this finding was of very low safety significance (Green) by answering No to the question in Exhibit 3 associated with Reactor Coolant System Boundary, because this issue did not involve potential non-compliance with regulatory requirements for protection of the reactor pressure vessel against fracture.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, while performing fire foam system testing for the main condenser, an operator failed to use human error reduction techniques such as self-check as described in HU-AA-101. As a result, the operator inadvertently depressed the initiation button causing a release of foam. The foam entered the reactor coolant system and caused a containment isolation signal.
Enforcement:
Violation: Technical Specification 5.4.1(a), Procedures, requires in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in Regulator Guide 1.33, Appendix A, November 1972. Regulatory Guide 1.33, Appendix A, Section H.2 states, in part, that specific procedures for surveillance tests, inspections, and calibrations should be written (implementing procedures are required for each surveillance test, inspection, or calibration listed in technical specification), which includes b(32) Fire Protection System Functional Tests.
Procedure FPP-3.25, "Fire Protection Manifold #5 Sprinkler System Main Drain and Water Flow Alarm Test," Revision 7, Step 8.1.13 states, Press Acknowledge button on FPP (fire protection panel) and verify the following: 1. Alarm Bell is off and 2. Red Condenser Pit Foam System light is on.
Contrary to the requirements of FPP-3.25, on February 19, 2023, the operator performing Step 8.1.13 failed to perform a self-check, and depressed the foam initiation push button.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 9, 2023, the inspectors presented the radiological hazards assessment and exposure controls inspection results to Timothy Peter, Site Vice President, and other members of the licensee staff.
- On April 27, 2023, the inspectors presented the integrated inspection results to Timothy Peter, 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 AOP-13 Severe Weather 40
ESP-99.001 FLEX Equipment Inventory and Inspection 3
OP-AA-108-111- Severe Weather and Natural Disaster Guidelines 25
1001
ST-40K Periodic Tests and Inspections 56
71111.04 Corrective Action 04547604
Documents
Resulting from
Inspection
04547610
71111.04 Drawings FM-19A Flow Diagram Fuel Pool Cooling and Cleanup System 19
FM-25A Flow Diagram High-Pressure Coolant Injection System 23 75
71111.04 Procedures OP-15 High-Pressure Coolant Injection 69
OP-20 Standby Gas Treatment System 43
OP-30 Fuel Pool Cooling and Cleanup System 47
71111.05 Corrective Action 04519347-35
Documents
Resulting from
Inspection
04519347-36
04546705
71111.05 Fire Plans PFP-OUT02 Building #2 Security 4
PFP-OUT03 Building #3 Building & Grounds 5
PFP-OUT20 Warehouse 1/Elev. 272' Fire Area/Yard 05
PFP-OUT35 Auxiliary Boiler Yard/South 1
PFP-OUT36 Oxygen Storage Facility 2
PFP-OUT37 Hydrogen Storage Facility 2
PFP-OUT39 ISFSI Pad Location 4
PFP-PWR01 East Cable Tunnel/Elev. 258' Fire Area/Zone II/CT-2 3
PFP-PWR02 West Cable Tunnel/Elev. 258' Fire Area/Zone IC/CT-1 5
PFP-PWR15 Crescent Area - West/ Elev. 227' 242' Fire Area/Zone 5
Inspection Type Designation Description or Title Revision or
Procedure Date
XVIII/RB-1W
PFP-PWR21 Reactor Building - West/Elev. 272' Fire Area/Zone X/RB-1B 5
PFP-PWR25 Reactor Building - West/Elev. 300' Fire Area/Zone X/RB-1B, 3
VIII/RB-1C
71111.07A Corrective Action 04551812
Documents
Drawings 4.95-6, 10E-2B RHR Heat Exchanger 'B' Tube Plugging Map 2
Procedures ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide 11
Work Orders 05271324
71111.11Q Procedures ST-1E Main Turbine Stop Valves Limit Switch Instrument Functional 27
Test
ST-1L Main Turbine Control Valve Instrument Channel and Valve 41
Operability Check
ST-1LA Main Turbine Control Valve Instrument Channel Check, 3
Operability Check, and Fast Closure Response Time Test
71111.12 Corrective Action 04320828
Documents
04351383
04401041
04418483
04421463
04423190
04432510
04495410
04551565
71111.12 Miscellaneous JAF-RPT-ELEC- Maintenance Rule Basis Document for System 71AC 10
2300 Electrical Distribution System
JAF-RPT-RHR- Maintenance Rule Basis Document System 10 Residual 12
281 Heat Removal
71111.12 Work Orders 05330736
71111.13 Procedures OP-59A Battery Room Ventilation 20
OP-AA-108-117 Protected Equipment Program 7
OP-AA-108-118 Risk Informed Completion Time 2
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.15 Corrective Action 04227187
Documents
04528916
04540527
04540528
04540676
04549167
04549381
04552202
04560422
71111.15 Corrective Action 045521507
Documents
Resulting from
Inspection
04552202
04559736
Engineering 637745
Changes
638629 SRV Pilot Valve Hardware Installation 0
Procedures ER-AA-2003 System Performance Monitoring and Analysis 17
- D.C. Elementary Diagram, 4160 Ckt Core Spray Pump 14P- 25
1A
SP-05.02 Chemistry Surveillance and Scheduling System 14
Work Orders 05261303-01
291468-01
05316301-03
05329545
267888-04
71111.18 Corrective Action 04509819
Documents
04510560
Corrective Action 04551229
Documents
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
04552504
04552506
Engineering 638087 Drawing Updates for Incorrect Torque Values on SRV Pilot 0
Changes Bolts/Belleville Washer and Lock Wire Used on SRV Pilots
638106 TRACG ATWS Overpressure Analysis Implementation at 0
FitzPatrick NPP
Procedures JE-00-037 Alternate Locking Device on SRV Pilots 0
MP-002.12 3 Stage Safety Relief Valve (SRV) Installation, Removal and 10
Maintenance (ISI)
MST 071.11 LPCI Quarterly Surveillance Test 23
MST-071.25 LPCI Battery Modified Performance Test 20
ST-2AM RHR Loop B Quarterly Operability Test (IST) 45
ST-4N High-Pressure Coolant Injection (HPCI) Quick-Start, 81
Inservice, and Transient Monitoring Test (IST)
ST-9BB EDG B and D Full Load Test and ESW Pump Operability 22
Test
Work Orders 05113541
05160367-07
236186
05325174
05326679
71111.24 Corrective Action 04549167
Documents
Corrective Action 04551229
Documents
Resulting from
Inspection
Procedures ST-3PA Core Spray Loop A Quarterly Operability Test (IST) 33
ST-9BB EDG B and D Full Load Test and ESW Pump Operability 22
Test
Work Orders 05156949
214562-01
Inspection Type Designation Description or Title Revision or
Procedure Date
214566-01
05305961-01
05325174
05326679
05329545-08
71153 Corrective Action 04555630
Documents
Procedures AOP-15 Isolation Verification and Recovery 29
AOP-3 High Activity in Reactor Coolant or Off-Gas 18
AOP-76 High Conductivity in Condensate System 9
Work Orders 05182427
19