IR 05000220/2018004

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Integrated Inspection Report 05000220/2018004 and 05000410/2018004
ML19045A127
Person / Time
Site: Nine Mile Point Exelon icon.png
Issue date: 02/13/2019
From: Erin Carfang
Division Reactor Projects I
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
Download: ML19045A127 (31)


Text

February 13, 2019

SUBJECT:

NINE MILE POINT NUCLEAR STATION

- INTEGRATED INSPECTION REPORT 05000220/2018004 AND 05000410/2018004

Dear Mr. Hanson

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station (NMPNS), Units 1 and On January 23, 2019, the NRC inspectors discussed the results of this inspection with Mr. Peter Orphanos, Site Vice President, and other members of your staf The results of this inspection are documented in the enclosed repor NRC inspectors documented one finding of very low safety significance (Green) in this repor This finding involve d a violation of NRC requirement The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Polic If you contest the violation or significance of the NCV, 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 NMPN In addition, 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, DC 20555-0001; with copies to the Regional Administrator, Region I, and the NRC Resident Inspector at NMPN B. Hanson 2 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 the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,

/RA/ Erin Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Numbers: 50-220 and 50-410 License Numbers: DPR-63 and NPF-69

Enclosure:

Inspection Report 05000220/2018004 and 05000410/2018004

Inspection Report

Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2018004 and 05000410/2018004 Enterprise Identifier:

I-2018-004-0066 Licensee: Exelon Generation Company, LLC (Exelon)

Facility: Nine Mile Point Nuclear Station, LLC (NMPNS)

Units 1 and 2 Location: Oswego, New York Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors:

E. Miller, Senior Resident Inspector J. Dolecki, Resident Inspector B. Sienel, Resident Inspector B. Fuller, Senior Operations Engineer T. Hedigan, Operations Engineer J. Kulp, Senior Reactor Inspector M. Orr, Reactor Inspector A. Patel, Senior Reactor Inspector M. Patel, Operations Engineer R. Rolph, Health Physicist A. Rosebrook, Senior Project Engineer D. Werkheiser, Senior Reactor Inspector Approved By:

E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring

Exelon's performance at NMPNS Units 1 and 2 by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC

-identified and self-revealed findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Inadequate Risk Mitigation Actions re sulted in Loss of Decay Heat Removal and Partial Loss of Offsite Power Cornerstone Significance Cross-Cutting Aspect Inspection Results Section Mitigating Systems Green NCV 05000410/2018004

-02 Open/Closed H.5 - Human Performance, Work Management 71152 Annual Follow-up of Selected Issues A self-revealed Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," was identified when Exelon did not assess and manage the increase in risk for outage maintenance activities. Specifically, on May 10, 2018

, Exelon did not adequately provide risk mitigation actions for electrical protection relays in the Unit 2 switchyard that result ed in a partial loss of an offsite power and a loss of decay heat removal.

Additional Tracking Item s Type Issue number Title Inspection Results Section Status URI 05000220/2018004-01 Potential Failure to Classify a Scram with Complications 71151 Open LER 05000410/2018

-001-00 Auto Start of Division II Emergency Diesel Generator Due to Loss of Line 6 71153 Closed 3

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On December 8 , 2018, operators reduced reactor power to 70 percent to perform high pressure coolant injection surveillance testing, turbine valve surveillance testing, and a control rod pattern adjustment. Operators restored reactor power to rated thermal power on December 9, 2018, and remained at or near rated thermal power for the remainder of the inspection period.

===Unit 2 began the inspection period at rated thermal power. On December 21, 2018, operators reduced reactor power to 70 percent to perform planned control rod channel interference testing and a control rod pattern adjustment. Operators restored reactor power to rated thermal power on December 22, 2018, and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPE

S 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 plant status activities described in IMC 2515 , Appendix D, "Plant Status

," and conducted routine reviews using IP 71152, "Problem Identification and Resolution." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Exelon's performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on October 18, 2018.

71111.04 - Equipment Alignment

Partial Walkdown

The inspectors evaluated system configuration s during partial walkdowns of the following systems/trains

(1) Unit 1 emergency diesel generator 102 during emergency diesel generator 103 planned maintenance on October 9, 2018
(2) Unit 1 125 volts direct current battery 12 during emergency diesel generator 102 planned maintenance on October 23, 2018
(3) Unit 2 Division II emergency diesel generator during elevated risk for Division III emergency diesel generator planned maintenance on November 27, 2018
(4) Unit 2 Division I emergency diesel generator during elevated risk for Division III emergency diesel generator engine replacement on December 14, 2018 Complete Walkdown (2 Samples) The inspectors evaluated system configuration s during complete walkdown s of the following systems:
(1) Unit 1 core spray 111 on December 3, 2018
(2) Unit 1 12 high pressure coolant injection on December 18, 2018

71111.05A/Q - Fire Protection Annual/Quarterly

===Quarterly Inspection (5 Samples

) The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 turbine building 261' battery board 11, fire area 5, on October 2, 2018
(2) Unit 1 turbine building 261' battery board 12, fire area 5, on October 2, 2018
(3) Unit 2 reactor building 196' north, fire area 34, on October 3, 2018
(4) Unit 2 reactor building 215' north, fire area 34, on October 3, 2018
(5) Unit 1 reactor building 198' northeast, fire area 1 , on October 3, 2018

71111.06 - Flood Protection Measures

Internal Flooding===

The inspectors evaluated internal flooding mitigation protections at Unit 2 uninterruptible power supplies 2C and 2D on November 29, 2018.

71111.07 - Heat Sink Performance

Heat Sink

The inspectors evaluated Exelon's monitoring and maintenance of the Unit 2 high pressure core spray pump room unit cooler 2HVR*UC403A performance

.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (Quarterly)

(1) The inspectors observed and evaluated Unit 1 operator training that involved a transition to Nuclear Energy Institute 99

-01, "Methodology for Development of Emergency Action Levels," Revision 6 on October 26, 2018

(2) The inspectors observed and evaluated Unit 2 operator training that involved a transition to Nuclear Energy Institute 99

-01, "Methodology for Development of Emergency Action Levels," Revisi on 6 on October 26, 2018 Operator Performance (Quarterly)

(2 Samples)

(1) The inspectors observed Unit 1 operations personnel during planned reactor power manipulations down to approximately 70 percent for a control rod pattern adjustment and high pressure coolant injection surveillance testing on December 8 and 9, 2018
(2) The inspectors observed Unit 2 operations personnel during power restoration to 100 percent following a B train 6 th point heater normal level control failure on October 29, 2018 and during reactor core isolation cooling quarterly surveillance testing on November 8, 2018 Operator Requalification Exam Results (Annual)

(2 Sample s)

(1) The inspectors reviewed and evaluated requalification examination results for Unit 1 (written and operating test) on November 20, 2018.
(2) The inspectors reviewed and evaluated requalification examination results for Unit 2 (operating test only) on November 20, 2018.

Operator Requalification Program and Operator Performance (Biennial)

(1 Sample)===

The inspectors reviewed and evaluated operator performance, evaluator performance, and simulator performance during the Unit 1 requalification examinations completed on November 1, 2018.

===71111.12 - Maintenance Effectiveness

===

Routine Maintenance Effectiveness===

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Unit 1 emergency diesel generator system
(2) Unit 2 emergency diesel generator system Quality Control (1 Sample) The inspectors evaluated maintenance and quality control activities associated with the commercial grade dedication of ball valves subsequently installed in the Unit 1 reactor building closed loop cooling system piping supporting the 11 instrument air compressor on August 21, 2018 and 12 instrument air compressors on March 13, 2018

.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

===

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1 emergency diesel generator 103 planned maintenance on October 9, 2018
(2) Elevated risk for Unit 2 Division II emergency diesel generator during planned maintenance on October 30, 2018
(3) Elevated risk for Unit 2 Division III emergency diesel generator during engine replacement on December 10, 2018

71111.15 - Operability Determinations and Functionality Assessments

(2 Sample s) The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 1 emergency diesel generator 103 fuel oil storage tank level due to refueling of an unintended fuel oil storage tank on October 9, 2018
(2) Unit 2 Division III emergency diesel generator hot restart surveillance test results on December 17, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Permanent Modification:

Engineering Change Package 15

-000005, Unit 1 Fire Panel Replacement for Local Fire Control Panel PNL

-LFP5

(2) Temporary Modification:

Engineering Change Package 18

-000388, New Computer Points and Alarm for Unit 2 Recirculation Pump Subcooling Differential Temperature

(3) Permanent Modification:

Engineering Change Package 18

-000699, Replace 2EGS*EG2 Division III High Pressure Core Spray Diesel Generator

71111.19 - Post Maintenance Testing (6 Samples

) The inspectors evaluated post maintenance testing for the following maintenance/repair activities

(1) Unit 1 emergency diesel generator 103 following preventive maintenance on October 10, 2018
(2) Unit 2 Division II emergency diesel generator following preventive maintenance on October 30, 2018
(3) Unit 2 high pressure core spray pump room unit cooler 2HVR*UC403A following cleaning due to zebra mussel fouling on November 13, 2018
(4) Unit 2 Division III emergency diesel generator following preventive maintenance on November 27, 2018
(5) Unit 2 Division III emergency diesel generator slow start testing following engine replacement on December 15, 2018
(6) Unit 2 Division III emergency diesel generator loss of offsite power and loss of coolant accident testing following engine replacement on December 17, 2018

71111.22 - Surveillance

Testing The inspectors evaluated the following surveillance tests

Routine===
(1) Unit 2 Division I emergency diesel generator during review of Technical Specification 3.5.1 emergency license amendment submittal on December 6, 2018
(2) Unit 2 Division II emergency diesel generator during review of Technical Specification 3.5.1 emergency license amendment submittal on December 6, 2018 In service (2 Samples)===
(1) Unit 2 reactor core isolation cooling system during review of Technical Specification 3.5.1 emergency license amendment submittal on December 6, 2018
(2) Unit 2 low pressure core spray system during review of Technical Specification 3.5.1 emergency license amendment submittal on December 6, 2018

71114.04 - Emergency Action Level and Emergency Plan Changes

===

The inspectors verified that the changes made to the emergency plan were done in accordance with 10 CFR 50.54(q)(3), and any change made to the Emergency Action Levels, Emergency Plan, and its lower

-tier implementing procedures, had not resulted in any reduction in effectiveness of the Plan.

This evaluation does not constitute NRC approval.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Contamination and Radioactive Material Control===

The inspectors observed personnel and material exiting the radiologically controlled areas from the control points of Unit 1 and Unit 2. The inspectors observed personnel monitor alarm responses. The inspectors ensured Nationally Tracked Sources were accounted for and reported as required.

Instructions to Workers (1 Sample) The inspectors evaluated instructions provided to workers

. Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample) The inspectors evaluated radiation worker and radiation protection technician radiological performance

==OTHER ACTIVITIES

- BASELINE==

===71151 - Performance Indicator Verification (7 Samples) The inspectors verified Exelon's performance indicator submittals listed below, for the period from January 1, 2017 , through December 31, 201 7: (6 Samples)

(1) IE01, Unit 1, Unplanned Scrams
(2) IE01, Unit 2, Unplanned Scrams
(3) IE03, Unit 1, Unplanned Power Change
(4) IE03, Unit 2, Unplanned Power Change
(5) IE04, Unit 1, Unplanned Scrams With Complications
(6) IE04, Unit 2, Unplanned Scrams With Complications The inspectors verified Exelon's performance indicator submittals listed below, for the period from October 1, 2017

, through September 3 0 , 2018: ===

(7) OR01, Occupational Exposure Control Effectiveness

71152 - Problem Identification and Resolution

Semiannual Trend Review

The inspectors reviewed Exelon's corrective action program for trends that might be indicative of a more significant safety issue

. Annual Follow

-up of Selected Issue s (5 Sample s) The inspectors reviewed Exelon's implementation of its corrective action program related to the following issues:

(1) Issue Report 04137255, Unit 2 loss of condensate flow during plant start up on May 12, 2018
(2) Issue Report 04082686, Unit 2 implementation of T echnical Specification Limiting Condition for Operation 3.0.9
(3) Issue Report 04155651, Unit 2 snubber functional test failures and maintenance planning
(4) Issue Report 04136339, Unit 2 partial loss of offsite power and loss of shutdown cooling on May 10, 2018
(5) Issue Report 04163117 , Unit 1 and Unit 2 degraded gaseous radiation monitoring equipment 71153 - Follow-up of Events and Notices of Enforcement Discretion Events (3 Sample s) The inspectors evaluated response to the following events
(1) Unit 2 loss of feedwater heating due to the 'B' 5 th point feedwater heater normal level control valve failure on November 21, 2018
(2) Unit 2 Alert Emergency Action Level event declaration due to failure of the Division III emergency diesel generator on December 2, 2018
(3) Unit 2 post event follow

-up for failure of the Division III emergency diesel generator on December 3, 2018 Licensee Event Reports (1 Sample) The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000410/2018 00, Auto Start of Division II Emergency Diesel Generator Due to Loss of Line 6 (Adams Accession No. ML18192B988). The circumstances surrounding this LER are documented in Inspection Results Section 71152, Problem Identification and Resolution.

INSPECTION RESULTS

Inadequate Risk Mitigation Actions Result ed in Loss of Decay Heat Removal and Partial Loss of Offsite Power Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000410/2018004

-02 Open/Closed H.5 - Human Performance, Work Management 71152 Annual Follow-up of Selected Issues A self-revealed Green finding and associated non

-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," was identified when Exelon did not assess and manage the increase in risk for outage maintenance activities. Specifically, on May 10, 2018

, Exelon did not adequately provide risk mitigation actions for electrical protection relays in the Unit 2 switchyard that result ed in a partial loss of an offsite power and a loss of decay heat removal.

Description:

During the Unit 2 refueling and maintenance outage, Exelon staff performed planned testing of offsite protective relays in the station switchyard. The scope of the testing involved bypassing the protective relays to allow functional testing of the Unit 2 output breakers, R230 and R925. Each protective relay contains an engineered connecting plug to allow a technician to bypass it for testing. On May 10, 2018, at 2:48 a.m., while an Exelon technician attempted to remove the engineered connecting plug for a protective relay associated with R925, a partial actuation of the relay occurred. The actuation of the protective relay caused the 'B' 345 KV bus to trip. As a result, power to 115 KV offsite power source Line 6 (Division II) was lost.

At the time of the loss of Line 6, Unit 2 was in Mode 4, Cold Shutdown, with the reactor vessel head on and fully tensioned, and reactor vessel water level at the flange. Line 6 was supplying power to the Division II 4KV emergency switchgear, and decay heat removal for the reactor coolant system was being performed by Division II residual heat removal pump and heat exchanger. Concurrent with the loss of Line 6, power was immediately lost to the Division II 4KV emergency switchgear and all equipment being supplied power by it. The Division II emergency diesel generator started immediately upon the loss of Line 6. Operators took immediate action and restored the Division II decay heat removal system within 6 minutes after the loss of power occurred.

Exelon performed a root cause investigation and determined the risk mitigation strategy of bypassing protective relays solely by removing the engineered connecting plug during the performance of protective relay testing was not recognized as a failure mechanism that could cause an actuation. The inspectors performed a review of the root cause investigation and identified that Line 6 was considered to be protected in accordance with OU

-NM-103-101, "Shutdown Safety Management Program," Revision 00200

, at the time of the protective relay testing, however no risk mitigation barrier was in place at the location of the work being performed. 10 CFR 50.65(a)(4) states, in part: "-the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities." OP

-AA-108-117, "Protected Equipment Program," Revision 5

, provides guidance for protecting equipment and developing risk mitigation actions in order to minimize plant risk and to meet 10 CFR 50.65(a)(4). OP

-AA-108-117, Section 4.2.7 provides the following guidance for determining when to protect equipment during an outage:

"EXTEND the protected equipment train concept to work within the station switchyard and associated relays, switchgear and transformers. This includes activities by station, supplemental, and transmission personnel."

Although risk was reviewed for the testing of the protective relay, it was understood by Exelon staff that the risk mitigation strategy of removing the engineered connecting plug was suitable to prevent a relay actuation. The inspectors determined that had the relay in the switchyard been protected in accordance with OP

-AA-108-117 and OU

-NM-103-101 for Line 6 using a sign or barrier, then an additional review by Exelon would have been required before proceeding with the work, allowing an additional opportunity to prevent a loss of decay heat removal and the loss of an offsite power source.

OP-AA-108-117, Section 4.4.3 states in part, "if work on protected equipment is required, then comply with the following:

"-work groups are required to obtain Shift Manager approval every shift for work on protected equipment-

-During outage conditions, the work group will receive outage control center approval from the Shift Outage Manager or Shift Outage Director prior to obtaining Shift Manager or designee authorization."

Additionally, the inspectors identified three non

-compliances with site shutdown safety management and integrated risk management procedures which contributed to the partial loss of offsite power and loss of decay heat removal. See the 71152 Observation below for more details about these non

-compliances.

Exelon assess ed the need to add risk mitigation barriers to the applicable relays and update the protected equipment implementing procedure. Exelon attributed the need for additional barriers to the potential for mechanical induced vibration of relays that could cause a loss of offsite power. Although Exelon did not identify the failure to meet OP

-AA-108-117, the corrective action to establish the barrier for the applicable relays addresses the concern identified by the inspectors.

Corrective Action: Exelon entered this issue into the corrective action program and modified the scheduling plant impact when protective relay testing will occur. Maintenance and work scheduling programs have also been updated to ensure appropriate codes are applied to ensure the risk of losing an offsite power source and decay heat removal is recognized. The applicable relays that could cause a loss of offsite power have also been added to the Unit 2 protected equipment implementing procedure.

Corrective Action Reference: IR 04136339 Performance Assessment

Performance Deficiency: The inspectors determined that the failure to assess and manage the increase in risk for outage maintenance activities was contrary to 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and was a performance deficiency.

Screening: This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon did not provide an adequate risk mitigation barrier to ensure proper reviews were conducted before allowing work on a system that could cause the loss of a key safety function, decay heat removal. The inspectors reviewed IMC 0612, "Power Reactor Inspection Reports," Appendix E, "Examples of Minor Issues," dated August 11, 2009

, and determined this issue is also similar to Example 7.g, because the failure to manage risk as required by 10 CFR 50.65(a)(4) resulted in the loss of a key safety function, decay heat removal.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process," dated May 9, 2014. The plant was in operating state one (POS 1), which is a condition with the reactor vessel head on and tensioned and shutdown cooling in service.

The event occurred late in the outage which resulted in a lower decay heat loading.

The inspectors reviewed the guidance in IMC 0609, Appendix G, Attachment 3, for boiling water reactors (BWRs) and determined that for this condition, the simplified models provided did not adequately represent Unit 2, which is a BWR type 5 with a Mark 2 containment.

A shutdown SPAR model has not been developed for Unit 2, however a shutdown SPAR model for Columbia Generating Station, also a BWR type 5 with a Mark 2 containment, was judged to be a suitable substitute. The condition was modeled as a loss of shutdown cooling with a failure of offsite power to Division II AC buses.

The change in core damage frequency was approximately 8E

- 7, Green.

The dominant sequence included a loss of shutdown cooling with a failure to restore before a high pressure isolation occurred, failure to depressurize, failure to establish alternate decay heat removal paths, failure to vent containment and failure to restore long term shutdown cooling.

The potential for a large early release was evaluated in accordance with IMC 0609, Appendix H and screened out as Green in Section 5.2, Approach for Assessing Type A Findings During Shutdown, step 2.2 since the finding did not occur while the plant was in the early phase of POS 1, and the finding occurred after the first eight days of the outage.

Cross-Cutting Aspect: The inspectors determined that the finding had a cross

-cutting aspect of Work Management within the cross

-cutting area of Human Performance because Exelon did not adequately plan, control, and execute the work associated with a protective relay that caused a partial loss of offsite power and a loss of decay heat removal. Specifically, Exelon did not ensure adequate risk mitigation barriers were in place to ensure proper reviews were conducted prior to work execution, resulting in a relay actuation during testing, a partial loss of offsite power and loss of decay heat removal.

[H.5]

Enforcement

Violation: Title 10 CFR 50.65(a)(4) requires, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Exelon procedure OP

-AA-108-117, "Protected Equipment Program," implements this requirement. OP

-AA-108-117, Section 4.2.7 provides the following guidance for determining when to protect equipment during an outage:

"EXTEND the protected equipment train concept to work within the station switchyard and associated relays, switchgear and transformers. This includes activities by station, supplemental, and transmission personnel."

Contrary to the above, on May 10, 2018, Exelon did not provide an adequate risk mitigation barrier in accordance with OP

-AA-108-117. This resulted in a partial loss of offsite power and a loss of decay heat removal when workers attempted to remove an engineered connecting plug of a switchyard relay in preparation for testing. The inspectors determined that had the relay in the switchyard been protected in accordance with OP

-AA-108-117 and OU-NM-103-101 for Line 6 using a sign or barrier, an additional review by Exelon would have been required before proceeding with the work, allowing an additional opportunity to prevent a loss of decay heat removal and an offsite power source.

Disposition: Exelon entered this issue into the corrective action program as IR 04136339 and this violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy. The disposition of this NCV closes LER 05000410/2018 00. Observations 71152 Annual Follow

-up of Selected Issues Unit 2 Partial Loss of Offsite Power and Loss of Shutdown Cooling on May 10, 2018 On May 10, 2018, Unit 2 experienced a partial loss of offsite power and loss of shutdown cooling during a planned refueling and maintenance outage. Exelon staff were preparing to conduct testing of protective relays in the switchyard associated with Unit 2 main generator output breakers. When Exelon staff attempted to remove an engineered connecting plug in the bottom of the relay as a risk mitigation action to prevent spurious trips, a partial actuation occurred due to vibration. A loss of offsite power to Line 6 resulted in the loss of safety-related power to all Division 2 systems and components. At the time

, the Division 2 residual heat removal system was providing decay heat removal. Upon loss of power to the Division 2 safety electrical bus, the Division 2 emergency diesel generator immediately started and restored power to the bus. Operators restored decay heat removal 6 minutes following the event.

The inspectors performed a review of Exelon's root cause evaluation, reviewed associated procedures and operator logs, conducted interviews with Exelon staff, and performed plant walkdowns of related equipment. The inspectors focused on cause identification, extent of cause, and extent of condition to determine if Exelon staff adequately addressed the event and developed appropriate corrective actions to prevent recurrence.

Exelon identified the root cause to be the risk mitigation strategy. Specifically, bypassing protective relays solely by removing the engineered connecting plug during the performance of testing was not recognized as a failure mechanism that could cause an actuation. Exelon also identified a contributing cause associated with the type of relay having engineered connecting plugs that are difficult to remove from their housing; and the difficulty removing it , increasing the probability of that type of relay actuating while being bypassed. Corrective actions established by Exelon include modifying the plant impact section of the protective relay testing procedure, adding work scheduling codes to identify the trip risk during testing of the relays, adding the affected switchyard relays to the risk mitigation protected equipment scheme, evaluating the need to replace the switchyard relays with a different type, and training on risk recognition to Exelon staff.

The inspectors determined that Exelon's root cause assessment and corrective actions appear to be adequate. In addition, the inspectors identified one Green NCV which is documented in this inspection report. As mentioned in NCV 05000410/2018004

-01 , the inspectors identified several non-compliances with station shutdown safety management and integrated work management programs

. Specifically:

OU-NM-103-101, "Shutdown Safety Management Program," Revision 00200, Section 5.9.I, provides direction to update protective controls for protected systems in the Shift Outage Safety Assessment. Contrary to this, inspectors identified during interviews that although Line 5 was protected, the Shift Outage Safety Assessment was not updated to appropriately reflect plant conditions.

Exelon documented this issue in the corrective action program as IR 04217839.

OU-AA-103, "Shutdown Safety Management Program," Revision 20, Section 4.10.2, states in part, to evaluate schedule changes to determine their effects on the shutdown safety plan.

Specifically, in subsection 1.B it states to perform a High Risk activity review. Section 4.4.3, states in part to review work that affects equipment with a key safety function, work that could cause an undesirable equipment actuation, and switchyard work affected shutdown safety.

This would have provided an additional opportunity to identify the risk of performing relay testing on equipment that could cause a loss of offsite power and loss of shutdown cooling.

Exelon documented this issue in the corrective action program as IR 04217839.

The inspectors review of the work order (C93470730) associated with testing of the breaker protection relays identified that a switchyard risk review was not completed during the work planning process. WC

-AA-104, "Integrated Risk Management," Revision 25, Section 5.2.6 states, if the work is in the switchyard, evaluate the work using Attachment 5; contrary to this requirement Attachment 5 was not completed.

Exelon documented this issue in the corrective action program as IR 04217671.

The above items were considered to be separate performance deficiencies, which contributed to the performance deficiency discussed in NCV 05000410/2018004

-01 not being identified prior to the loss of Line 6 and shutdown cooling.

Unresolved Item (05000220/2018004

-01) (Open) Potential Failure to Classify an Unplanned Scram with Complications 71151 Performance Indicator Verification

Description:

On September 6, 2017, NMPNS Unit 1 experienced a reactor scram due to low reactor water level when a feedwater flow/steam flow proportional amplifier failed. The low reactor water level caused main steam isolation valves to automatically close, the start of all core spray pumps, and an automatic initiation of the high pressure coolant injection system. In addition

, operators manually place d the emergency condenser (i.e. isolation condenser) in service for reactor pressure control until the main steam isolation valves could be re

-op ened. Exelon reported this scram to the NRC as a scram in their Unplanned Scrams performance indicator. Exelon determined that this scram did not meet the criteria for an Unplanned Scram with Complications. Nuclear Energy Institute 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, establishes a series of questions to assist in determining if a scram should be classified as a Scram with Complications.

Nuclear Regulatory Commission Position:

The inspectors reviewed Nuclear Energy Institute 99

-02; N1-EOP-2, "RPV [reactor pressure vessel] Control," Revision 01600; the post transient review for the scram on September 6, 2017; and IR 04049445 and its associated root cause report

, and determined that it appeared that a Scram with Complications should have been classified.

Question 6 of Nuclear Energy Institute 99

-02 states:

"Following the initial transient, did stabilization of reactor pressure/level and drywell pressure meet the entry conditions for EOP's?"

The pressure control leg of N1

-EOP-2 states: "-stabilize RPV pressure below 1080 psig using the main turbine bypass valves. Use alternate pressure control systems if needed."

Operators did not have turbine bypass valves available for use because the main steam isolation valves were closed. Instead, operators utilized an "alternate pressure control system" listed in N1

-EOP-2, the emergency condenser. Pressure was controlled using the emergency condenser for approximately 8 minutes before the main steam isolation valves were opened and reactor pressure control was re-establish ed using the turbine bypass valves. The inspectors also reviewed Reactor Oversight Process Task Force FAQ

[frequently asked questions] Log March 1, 2018 regarding the definition of "initial transient," as it is not described in Nuclear Energy Institute 99

-02.

The Frequently Asked Questions Log states

"Initial Transient is intended to envelope the immediate and expected changes to BWR parameters as a result of a scram (e.g., pressure, level, etc.) because of the collapsing of voids in the core and the routine response of the main feedwater and turbine control systems.

For example, at some BWRs the reflected pressure wave resulting from the rapid closure of turbine valves during a turbine trip may result in a pressure spike in the reactor vessel that causes one or more safety

-relief valves (SRVs) to briefly lift. The intent is to allow a licensee to exclude the momentary operation of SRVs when answering "Was pressure control unable to be established?" The sustained or repeated operation of SRVs in response to turbine control bypass valve failures or Main Steam Isolation Valve (Group I) isolations are not a part of routine BWR scram responses and are therefore not considered to occur within the initial transient.

" Based on the inspectors

' review it appeared that Question 6 should have been answered "Y es," because the ultimate heat sink was lost with main steam isolation valves closed following the initial transient requiring additional time for the use of the alternate pressure control system, emergency condensers, as defined in N1

-EOP-2.

Exelon Generation Position:

Exelon staff also provided that part of their determination of the scram not being complicated was due to their review of Question 2 of Nuclear Energy Institute 99

-02, which states:

"Was pressure control unable to be established following the initial transient?

- reactor pressure must be controlled following the initial transient without the use of Safety Relief Valves (SRVs)." Exelon answered "No" to Question 2 because Safety Relief Valves were not required to be used. Exelon noted Question 2 provides background information regarding normal pressure control systems, and that "isolation condenser" was included. Exelon agreed that this conflicts with Question 6 and with N1

-EOP-2, which lists the emergency condenser as an alternate pressure control system. Planned Closure Action: The inspectors are opening an unresolved item (URI) to determine if a performance deficiency exists.

Licensee Actions:

Exelon entered the concern into their corrective action program, and created an action to enter the question into the NRC performance indicator FAQ [frequently asked questions

] process for resolution

. Corrective Action Reference: IR 04209092 NRC Tracking Number:

05000220/2018004-02 Observations 71152 Annual Follow

-up of Selected Issues Review of Unit 2 Loss of Condensate Flow During Plant Start-up on May 12, 2018 On May 12, 2018, with reactor power at approximately 5 percent, plant operators inadvertently isolated condensate flow while swapping steam jet air ejectors

, causing both condensate booster pumps to trip on low suction pressure. The plant operators immediately recognized their error, promptly entered N2

-SOP-6, "Feedwater Failures," restored condensate flow

, and restarted a condensate booster pump. During the transient, reactor vessel water level dropped approximately 7 inches. Exelon entered the issue into its corrective action program as IR 04137255, conducted a human performance review board and a corrective action program evaluation, and remediated the operators involved.

The inspectors reviewed Exelon's issue reports, corrective action program evaluation and human performance review board, interviewed personnel familiar with the event, and conducted walkdowns. Exelon determined that the apparent cause was inadequate engagement of operations leadership with a contributing cause of the quality of procedure N2-OP-9, "Condenser Air Removal," Revision 02000. The inspectors concurred with Exelon's apparent and contributing cause, but determined that communications were also a contributing cause. The plant operators were directed to "swap steam jet air ejectors," which would imply using N2

-OP-2 Section F 2.0, "Swapping SJAE Trains," which explicitly directs operators to manipulate condensate valves in the proper sequence to maintain condensate flow and is written for swapping from train B to train A. Instead, the recently qualified plant operators were provided a copy of N2

-OP-2 , Section E 2.0, "Placing the Steam Jet Air Ejectors in Service," which does not have specific guidance for operating condensate valves, as this section is written with the assumption that the condensate system is already lined up and in service and operators only have to verify valve position. If this had been discussed during the pre

-job brief, if there had been a caution statement in N2

-OP-2 , Section E 2.0, or if the crew had been more experienced the error could still have been prevented. Therefore, the inspectors considered this a contributing cause. The corrective action s for the apparent cause were determined to be adequate to correct this contributing cause as well, therefore no violation of NRC requirements was identified.

This item was evaluated using IMC 0612, Appendix B, "Issue Screening," and IMC 0612, Appendix E, "Examples of Minor Issues," and determined to be of minor significance. Exelon has entered the issue into their corrective action program as IR 04137255 and documented corrective actions to be taken.

Observations 71152 Annual Follow

-up of Selected Issues Implementation of Technical Specification Limiting Condition for Operation 3.0.9 One of the causes identified for NCV 05000410/2017004

-03 , "Inadequate Operability Determination for Impaired Internal Flood Barrier," was a knowledge gap with respect to the application and implementation of Technical Specification Limiting Condition for Operation (LCO) 3.0.9. Exelon wrote IR 04082686 to evaluate and address this knowledge gap. The inspectors reviewed the issue report and associated corrective action program evaluation, Exelon procedures related to barrier impairment and work control

, control room log s, and applicable NRC and industry guidance documents in order to assess the effectiveness of the corrective actions. Exelon revised procedure CC

-NM-201-1001, "Plant Barrier Control Program Implementation," and conducted training with plant staff on LCO 3.0.9. The inspectors determined that the corrective actions were generally effective. However, the inspectors did identify one evolution where LCO 3.0.9 should have been applied and was not. On January 22, 2018, May 17, 2018, and May 29, 2018, floor plugs in barriers credited to support Unit 2 service water system operability were removed for replacement of service water pump motors.

Since each service water cubicle contains three service water pumps, either the entire service water subsystem should have been declared inoperable and the 72-hour Technical Specification Action Statement 3.7.1.C entered or LCO 3.0.9 entered for an inoperable barrier which would allow deferral from entry into 3.7.1.C for 30 days. Instead , Exelon applied the guidance of NRC Regulatory Issue Summary (RIS)2001-0 9 , "Control of Hazard Barriers ," and declared the supported equipment operable based upon contingencies put in place to restore the barrier and monitor weather conditions. Only the pump which was out of service for the motor replacement was declared inoperable. A single pump out of service does not require entry in to Technical Specification LCO 3.7.1.

The basis for LCO 3.0.9 state s: "Barriers are door s, walls, floor plugs, curbs, hatches, mechanical devices, or other devices, not explicitly described in Technical Specifications that support the performance of the function of the systems described in the Technical Specifications." The floor plugs provide protection for the service water pumps in each cubicle against missile hazards. Therefore, Technical Specification 3.0.9 should have been entered. However, the inspectors determined the plant barrier impairments were appropriately logged and tracked, risk management actions and contingencies were put in place, and the barriers were restored within

72 hours
8.333333e-4 days
0.02 hours
1.190476e-4 weeks
2.7396e-5 months

. Thus, no violation o f Technical Specification 3.7.1 or LCO 3.0.9 occurred This item w as evaluated using IMC 0612, Appendix B, "Issue Screening," and IMC 0612, Appendix E, "Examples of Minor Issues," and determined to be of minor significance. Exelon has entered the issue into their corrective action program as IR 04082313 and documented corrective actions to be taken.

Observations 71152 Annual Follow

-up of Selected Issues Unit 2 Snubber Functional Failures and Maintenance Planning During the NMP NS Unit 2 refueling outage in the Spring of 2018

, seismically

-qualified snubbers were removed and tested for functionality in accordance with applicable industry standards and Exelon procedures. Inspectors reviewed Exelon's procedures associated with snubber removal , testing, results, cause evaluations

, and the associated corrective actions. Exelon tested a representative sample of randomly selected small mechanical, large mechanical, and hydraulic snubbers. Following failure of as

-found testing of both a small and a large mechanical snubber in the initial sample test population, Exelon expanded both testing sample plans. At the completion of the snubber functional testing, a total of 1 out of 11 small mechanical and 6 out of 68 large mechanical snubbers failed the as

-found testing. The piping associated with each failed snubber was evaluated by Exelon in the corrective action program. Exelon developed corrective actions for the failed snubbers which included replacement with pre-tested snubbers that met the functional testing acceptance criteria. In addition, each snubber that failed functional testing is scheduled to be tested during the next refueling outage.

During review

, the inspectors identified that OU-NM-103-101, "Shutdown Safety Management Program ," Section 4.16.D, provides direction to evaluate activities on systems which penetrate the RPV below the Top of Active Fuel against Technical Specification 3.5.2 and to use Drain Time to determine whether an elevated risk level is reached. However, due to L CO 3.0.8 being implemented when one or more required snubbers are removed from service and unable to perform their support function(s), a Drain Time does not have to be performed, which could result in a failure to evaluate a change in risk in accordance with OU-NM-103-101. By not evaluating station risk for work activities affecting Reactor Vessel Water Level inventory control in accordance with OU

-NM-103-101, Unit 2 has the potential to not meet 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants

." The inspectors reviewed a sample of cases involving snubber removal and did not identify any cases involving a failure to adequately identify an increase in risk. Exelon has entered this issue into the corrective action program as IR 04207466 and 04218549. The inspectors determined Exelon's cause evaluation and corrective actions for each of the failed snubbers appeared adequate. The above item w as evaluated using I MC 0612, Appendix B, "Issue Screening," and IMC 0612, Appendix E, "Examples of Minor Issues," and determined to be of minor significance.

Observations 71152 Annual Follow

-up of Selected Issues Degraded Gaseous Radiation Monitoring Equipment The inspectors performed an in

-depth review of Exelon's analysis and corrective actions associated with gaseous radiation monitoring equipment. The inspectors' review focused on the stack radiation monitoring and associated support equipment in both the Unit 1 stack and the Unit 2 stack. The inspectors reviewed condition reports, self

-assessments, and held discussions with plant personnel. The inspectors assessed Exelon's problem identification threshold, cause analysis, and the prioritization and timeliness of corrective actions to determine whether Exelon was taking timely corrective actions.

The stack radiation monitors at both Unit 1 and Unit 2 were declared non

-functional numerous times over the past 2 years. Water intrusion into the Unit 1 and Unit 2 stack monitor sample lines caused the monitors to be taken out of service until the lines could be "blown down" to remove the water. On one occasion, the water froze in the line and sample flow went to zero. In accordance with the requirements of the Unit 1 and Unit 2 Off Site Dose Calculation Manual, Chemistry performed alternate sampling every shift until the monitor flow rate was restored. A review of the issue reports indicate that the low flow was handled timely and the sample flow restored. However, it was not apparent that the plant recognized the cause of the water intrusion. Several conditions were recognized

, but repairs were not implemented due to industrial safety concerns and other station priorities. A bent sample line was discovered in the Unit 1 stack sample line, but could not be repaired due to industrial safety concerns until the winter weather was over. Condensation forming in the Unit 2 stack was identified in 2015 due to degraded heat trace. This condition was not addressed due to successive mild winters in 2016 and 2017 that did not impact the sample flow. In 2018 the winter weather conditions resulted in a repeat of condensation from the degraded heat trace.

Exelon entered the issue into the corrective action plan under IR 04184941. In another instance, an area heater was found inoperable and a hatch left open in the Unit 2 stack monitor building in January 2018

, which caused the temperature in the monitor building to drop and condensation to accumulate in the sample lines and restrict flow. The heater was repaired and the hatch was closed to resolve the issue. To prevent recurrence, the operator rounds procedure was updated to include operator actions when room temperature drops below a pre

-determined value when the heat trace is out of service. The inspectors concluded that the issues have been identified in the corrective action program and timely actions are being taken to bring the monitors back to service.

The inspectors determined that in a number of cases, Exelon's corrective action program did not correct the equipment problems resulting in repetitive unavailability. Exelon subsequently performed a Self-Assessment which confirmed the inspector s' observations, and corrective actions are either completed or planned for the degraded equipment. While these corrective actions are considered to be timely

, commensurate with the safety significance of the equipment and thus not a violation of NRC requirements, they do represent an operator burden and could impact plant assessment capabilities during a postulated accident.

Equipment issues included: Unit 1 total stack flow oscillations Unit 2 external heat trace failure of the stack wide range gaseous radiation monitoring system Unit 2 water intrusion into the stack wide range gaseous radiation monitoring system Unit 2 missing insulation on the stack wide range gaseous radiation monitoring system Unit 2 source check failures on the stack wide range gaseous radiation monitoring system These observations were entered into the corrective action program as IR 04184941. The inspectors determined that these issues are minor in accordance with IMC 0612

, Appendix B; and that Exelon's plans for corrective actions appear commensurate with the risk associated with the components and adequate to address the concerns.

Observations 71152 Semi-Annual Trend Review The inspectors evaluated a sample of issues and events that occurred over the course of the third and fourth quarters of 2018 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified that these issues were addressed within the scope of the corrective action program or through department review.

The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors assessed that Exelon personnel were identifying trend issues at a low threshold and entering them into the corrective action program for resolution and were appropriately prioritizing investigation reviews. The inspectors noted minor adverse trends, also identified by Exelon staff, in the areas of FLEX equipment performance (IRs 04168525 and 04183223) and transient combustible control (IR 04194745). In addition, the inspectors noted a continuation of the adverse trend associated with procedure quality and adherence issues identified in the previous NRC semi

-annual trend review (NRC Inspection Report 05000220/20 18002 and 05000410/2018002). Following the inspectors identifying the trend during the second quarter of 2018, Exelon created IR 04157970. Exelon performed a work group evaluation

and determined the cause to be Exelon Operations staff not displaying department and site leadership necessary to ac hieve operational excellence in the quality of site procedures and had not set the proper site procedural standards for others to follow. More specifically, weaknesses in procedural guidance were attributed to gaps in operator questioning

-attitude in regard to procedural direction and precise control of plant evolutions including procedure quality. The inspectors determined that Exelon has addressed many of the specific concerns with procedural adequacy, however with regard to the identified cause, corrective actions remain in progress

. The inspectors will continue to assess the effectiveness of Exelon's corrective actions.

Specific examples of the continued trend include inspectors' observations of the following:

Unit 2, as discussed in Observation Table for 71152 Annual Follow

-Up, Review of Unit 2 Loss of Condensate Flow During Plant Start

-up on May 12, 2018, the inspectors identified that procedure N2

-OP-2, "Moisture Separator Reheater System," Revision 01200, appeared inadequate, and tha t a caution statement in N2

-OP-2 , Section E 2.0, would have provided operators an opportunity to identify the proper sequencing needed to conduct activity for the plant conditions they were in and ensure condensate flow was not isolated

. Unit 2 operators did not ensure that thermal power was controlled less than or equal to the licensed power limit on multiple occasions between May 22, 2018

, and October 19, 2018, for extended periods of time on each occasion. This issue was documented as NCV 05000410/201 8003-01.

Fix-It-Now Maintenance staff manipulated a non

-safety-related system without using proper configuration control on November 13, 2018. Unit 2 operators did not recognize that high pressure core spray emergency diesel generator frequency was outside of the Technical Specification surveillance acceptance criteria during post maintenance testing on December 19, 2018. Exelon then performed an evaluation to determine if the manual governor adjustment (followed by steady

-state operation) made by an operator later in the emergency diesel generator run was acceptable to meet the surveillance requirement. It was subsequently determined that it was not a violation of the Technical Specification surveillance requirement.

Exelon generated IR 04217844 to address the inspector's observation of the continued trend. There were no adverse safety consequences as a result of these low

-level trend issues. Based on the overall results of the semi

-annual trend review, the inspectors determined that Exelon was properly identifying adverse trends at NMP NS before they became 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." The inspectors determined these conditions were deficiencies of minor significance and, therefore, are not subject to enforcement action in accordance with the NRC's Enforcement Policy.

EXIT MEETING S AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On October 18, 2018, the inspectors presented the inspection results for IP 71124.01 to Mr. Rob Kreider , Plant General Manager, and other members of the Exelon staff.

On November 1, 2018

, the inspectors presented the inspector results for IP 71111.11B to Mr. James Tsardakas, Director Site Training, and other members of the Exelon staff On January 23, 2019, the inspector s presented the quarterly resident inspection results to Mr. Peter Orphanos, Site Vice President

, and other members of the Exelon staff.

DOCUMENTS REVIEWED

71111.01 Procedures

N1-OP-64, Meteorological Monitoring, Revision 01800

N2-OP-102, Meteorological Monitoring, Revision 02

400 WC-AA-107, Seasonal Readiness, Revision 20

Issue Reports

04087967 04093734 04096186 04141388 04150731 04179685 Work Orders

C93632392 C93634010 71111.04 Procedures

C-18026-C, Sheet 1, Emergency Diesel Generator 102 Starting Air, Cooling Water, Lube O il & Fuel P&ID, Revision 27

N1-ESP-SB-275, 125 VDC Battery Cell Surveillance, Revision 01300

N1-OP-2, Core Spray System, Revision 03600

N1-OP-15A, Condensate System, Revision 03300

N1-OP-16, Feedwater System Booster Pumps to Reactor, Revision 06600

N 1-OP-45, Emergency Diesel Generators, Revision 04600

N1-OP-47A, 125 VDC Power System, Revision 03200

N1-ST-Q1A, Pump, Valve and SDC Water Seal Check Valve Operability Test, Revision 01800

N1-ST-Q3, High Pressure Coolant Injection Pump and Check Valve Operability Test, completed 4/5/17, 1/24/18, 4/5/18, 6/25/18, 9/8/18 and 12/9/18

N2-OP-100A, Standby Diesel Generators, Revision 02600

Issue Reports

(*initiated in response to inspection)

2630634 03989927 03995248 04050119 04056151 04066901 04069095 04204590* 04204897 Work Orders

C04362756 C93241726 C93351625 C93642422 C93642988 C93643601 Drawings C-18003-C, Sheet 1, Condensate Flow P&I Diagram, Revision 61

C-18003-C, Sheet 4, Condensate Flow P&I Diagram, Revision 4

C-18004-C, Feed Water Flow

Low Pressure, P&I Diagram, Revision 23

C-18005-C, Sheet 1, Feed Water Flow High Pressure P&I Diagram, Revision 51

C-18005-C, Sheet 2, Feed Water Flow High Pressure P&I Diagram, Revision 39

C-18007-C-001, Reactor Core Spray P & I Diagram, Revision 62

Miscellaneous

ER-AA-600-1047, Mitigating Systems Performance Index Basis Document, Revision 11

Maintenance Rule Basis Document for Unit 1 High Pressure Coolant Injection, viewed December 13, 20

71111.05 Procedures

N1-FPM-FPE-A001, Annual Inspection of Portable Fire Extinguishers, Revision 01900

N1-PFP-0101, Unit 1 Pre

-Fire Plans, Revision 00500

N2-FPI-PFP-0201, Unit 2 Pre

-Fire Plans, Revision 05

Issue Report 04180615 Miscellaneous

DCD-805, Nine Mile Point Unit 1 NFPA 805 Design Criteria, Revision 1

71111.06 Drawing 12177-EB-406C-7, Sheet 3, Air & Water Tightness Design Requirements Plan El 237'

-0" and 240'- 0", Revision 7

Procedures

N2-EPM-GEN-635, Operational Checks, Cleaning, and Inspecting Unit 2 UPSs, Revision 00800

N2-OP-71D, Uninterruptible Power Supplies (UPS), Revision 01900

N2-PM-S014, Building Rounds, Revision 02700

Miscellaneous

A10.1-AA-7, Max Leakage Rates for Moderate Energy Systems in Control Building and Diesel Generator Building, Revision 1

A10.1-AA-8, Maximum Flood Level inside the Control Building, Revision 2

71111.07 Procedures

GAP-HSC-02, System Aging Inspection and Cleanness Controls, Revision 02000

N2-MMP-GEN-320, Unit Cooler Chemical Cleaning, Revision 00100

N2-OP-52, Reactor Building Ventilation, Revision 02000

N2-TTP-HVR-@403, Performance Evaluation Test for Unit Cooler 2HVR*UC403A and B, Revision 00401

S-TDP-REL-0102, Service Water Heat Exchanger and Component Inspection Guide, Revision 03 S-TDP-REL-0103, GL 89

-13 Service Water System Problems

Affecting Safety

-Related Equipment Program Plan, Revision 00

Issue Reports

04065978 0 4153112 04153434 04153647 04155610 04198987*

Work Orders

C92862777 C93634000 C93643355 Miscellaneous

Commitment Response Letter NMP2L 1265, dated December 10, 1990

Commitment Response Letter NMP2L 1348, dated July 17, 1992 NRC Generic Letter 89-13, Service Water System Problems Affecting Safety

-Related Equipment, dated July 18, 1989

NRC Information Notice 89

-76, Biofouling Agent: Zebra Mussel, dated November 21, 198 9 71111.11 Procedures

N1-OP-43B, Normal Power Operations, Revision 02500

N1-ST-Q3, High Pressure Coolant Injection Pump and Check Valve Operability Test, Revision 01800 N2-OSP-ICS-Q@002, RCIC Pump and Valve Operability Test and System Integrity Test and

ASME XI Functional Test and Analysis, Revision 01500

N2-SOP-08, Unplanned Power Changes, Revision 01300

Miscellaneous

Reactivity Maneuver Plan NM1C23

-EM, Revision 0

71111.12 Issue Reports

03965400 03980934 04045341 04083406 04166733 04197761 Work Orders C93659311 C93659320 Miscellaneous

Procurement Requirements Evaluation Form 5972

Purchase Order 7717181

Supply Chain Test and Inspection Report 10-0064 TDI 740 - ESI-EMD Owners Group Guidance Document Post Maintenance Testing of On

-Line Governor Replacements

71111.13 Procedures

N2-OP-100A, Standby Diesel Generators, Revision 02600

OP-AA-108-117, Protected Equipment Program, Revision 005

OP-NM-108-117, Protected Equipment Program at Nine Mile Point, Revision 00500

OP-NM-201-012-1001, Operations O

n-Line Fire Risk Management at NMP, Revision 00100

71111.15 Procedures

N1-MPM-EGF-10Y001, Diesel Generator Fuel Oil Storage Tank Cleaning, Revision 00201.01

N1-OP-45, Emergency Diesel Generators, Revision 04600

N1-PM-V19, Filling Diesel Fuel Oil Storage Tanks, Revision 00800

N1-ST-Q1A, CS 111 Pump, Valve and SDC Water Seal Check Valve Operability Test, Revision 01600 N1-ST-Q1A, CS 111 Pump, Valve and SDC Water Seal Check Valve Operability Test, Revision 01800 N1-ST-Q1B, CS 121 Pump, Valve and SDC Water Seal Check Valve Operability Test, Revision 02000 N2-OSP-EGS-M@002, Diesel Generator and Diesel Air Start Valve Operability Test, Division III, Revision 02200

N2-OSP-EGS-R006, Operating Cycle Diesel Generator 24 Hour Run and Load Rejection Test, Division III, Revision 01200

OP-NM-102-1001, Operations On

-Line Work Management, Revision 00000

SDBD-804, Emergency Diesel Generator System, Revision 11

WC-AA-101, On-Line Work Control Process, Revision 28

WC-AA-111, Surveillance Program Requirements, Revision

Issue Reports

04177972 04182341 04182449 04183194* 04203952 Work Orders

C93432297 C93441998 C93548634 C93548675 C93589384 C93625381 C93625384 C93689087 Miscellaneous

PCR-18-05278 71111.18 Procedures

N1-MFT-129, Modification Functional Test

for Panel PNL

-LFP5, Revision 00100

N2-ARP-602200, 2CEC*PNL602 Series 200 Alarm Response Procedures, Revision 00800

N2-SOP-29, Sudden Reduction

in Core Flow, Revision 01700

Issue Report

s 04103482 04148579 Work Orders

C93598477 C93649516

Miscellaneous

50.59-2018-01, Bypass Reactor Recirculation Cavitation Protection Interlock, Revision 0

50.59-2018-348, Bypass Reactor Recirculation Cavitation Protection Interlock, Revision 0

ECP-15-000005, Unit 1 Fire Panel Replacement for Local Fire Control Panel PNL

-LFP5, Revision 0

ECP-18-000388, New Computer Points and Alarm for Unit 2 Recirc Pump Subcooling Differential Temperature, Revision 0

ECP-18-000699, ESR

-18-00310 NMP-ESR (0000)

- Replace 2EGS*EG2 (Div. III HPCS Diesel Generator), Revision 0

Unit 2, UFSAR, Revision 22 71111.19 Procedures

GAP-HSC-02, System Aging Inspection and Cleanness Controls, Revision 02000

N1-ST-M4B, Emergency Diesel Generator 103 and PB 103 Operability Test, Revision 02100

N2-EPM-EGS-R655, 4400 KW Standby Diesel Generator and Auxiliary

Equipment Refuel PM, Revision 01200

N2-MMP-GEN-320, Unit Cooler Chemical Cleaning, Revision 00100

N2-MSP-EGS-R002, Diesel Generator Inspection Division III (2EGS*EG2), Revision 01900

N2-OP-52, Reactor Building Ventilation, Revision 02000

N2-OP-100A, Standby Diesel Generators, Revision 02500

N2-OP-100B, HPCS Diesel Generator, Revision 02400

N2-OSP-EGS-M@002, Diesel Generator and Diesel Air Start Valve Operability Test, Division III, Revision 02100

N2-OSP-EGS-R008, Operating Cycle Diesel Generator Simulated Loss of Offsite Power with an ECCS Division III Initiation, Revision 01200

N2-TTP-HVR-@403, Performance Evaluation Test for Unit Cooler 2HVR*UC403A and B, Revision 00401

Issue Report

s 04065978 04153112 04153434 04153647 04155610 04160951 0418898 0 04189727 Work Orders

C92862777 C93586443 C93616957 C93620607 C93635550 C93637791 C93643355 C93634000 Miscellaneous

PCR-18-06062, Operating Cycle Diesel Generator Simulated Loss of Offsite Power with an ECCS Division III Initiation, Revision

200 71111.22 Work Orders

C93181010 C93255856 C93277491 C93303671 C93340053 C93345578 C93345584 C93345590 C93359272 C93362167 C93367512 C93372157 C93387729 C93391825 C93418313 C93427723 C93522477 C93455099 C93459496 C93467604 C93469655 C93505517 C93535823 C93553779

C93558181 C93563972 C93573084 C93573449 C93582983 C93583204 C93588944 C93589119 C93589562 C93591830 C93590567 C93592457 C93593061 C93595345 C93595929 C93596127 C93596456 C93598968 C93599783 C93601170 C93603711 C93603714 C93607075 C93607984 C93609201 C93609450 C93610278 C93611344 C93613052 C93614226 C93614507 C93614785 C93615606 C93616228 C93616417 C93618215 C93618453 C93618882 C93619324 C93619476 C93620539 C93622159 C93622207 C93628992 C93632258 C93623081 C93623949 C93624402 C93624968 C93625447 C93628769 C93629108 C93627748 C93629608 C93630548 C93631499 C93632666 C93633274 C93633110 C 93633689 C93634751 C93634913 C93634929 C93634944 C93634945 C93635872 C93636879 C93637527 C93638620 C93638751 C93640410 C93640867 C93640953 C93641980 C93642057 C93644950 71114.04 Evaluation 17

-68, EP-AA-1000, Exelon Nuclear Standardized Radiological Emergency Plan , Revision 29

Evaluation 18

-19, URI Procedures and Supporting Forms

EP-AA-110-200, Dose Assessment, Revision 10

EP-AA-110-200-F-04, JAF/NMP Evaluation of Possible Lake Breeze

Events, Revision B

EP-AA-110-200-F-21, JAF/NMP Meteorological Data Acquisition, Revision B

EP-AA-110-201, On-Shift Dose Assessment, Revision 5

EP-AA-110-201-F-17, Manual Summing of Dose Assessment Results, Revision A

EP-AA-110-201-F-13, NMP Unit 1 Rapid Release Path Board, Revision B

EP-AA-110-201-F-14, NMP Unit 2 Rapid Release Path Board, Revision B

Evaluation 18

-19 , EPIP-EPP-13 , Emergency Response Facilities Activation and Operation

71124.01 Procedures

RP-AA-401-1003, Contamination Control Best Practice Application, Revision 5

RP-AA-460, Controls for High and Locked High Radiation Areas, Revision 34

RP-AA-503, Unconditional Release Survey Method, Revision 14

RP-AA-503-1002, Radiological Release of Used Oil and Associated Components, Revision 0

Radiation Work Permits/ ALARA Plan

NM-2-18-00304 / 2018

-2-099 Surveys 2018-025742, Reactor Water Clean Up Pump Room

71151 Procedure LS-AA-2001, Collecting and Reporting of NRC Performance Indicator Data, Revision 15

N1-EOP-2, RPV Control, Revision 01600

Issue Reports

03987066 04031685 04039435 04049445 71152 Procedures

CC-NM-201-1001, Plant Barrier Control Program Implementation, Revisions 000 and 001

EP-CE-121-1004, Nine Mile Point Equipment Matrix, Revision 3

HU-AA-101-1002, Human Performance Review Board, Revision 000

N2-FHP-003, Refueling Manual, Revisio

n 01900 N2-MSP-GEN-V351, Snubber Functional Test Procedure, Revision 00800

N2-OP-9 Condenser Air Removal, Revision 02000 N2-OSP-LOG-S@ALL, Comprehensive Shift Checks, Revision 03300

N2-OSP-LOG-S004/5, Shift Checks

-Mode 4 and Mode 5, Revision 01000

N2-RCPM-GEN-201, Line 23/R230/R925 345KV Protective Relay Calibration and Testing, Revision 00300

NMPNS-ISTD-001, Snubber Inservice Testing Program, Revision 04

OU-AA-101-1001, Outage Risk Management, Revision 0

OU-AA-103, Shutdown Safety Management Program, Revision 20

OU-NM-103-101, Shutdown Safety Management Program, Revision

s 00200 and 00300 PI-AA-120, Issue Identification and Screening Process, Revision 008

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 006

PI-AA-125-1001, Root Cause Analysis Manual, Revision 003

PI-AA-125-1003, Corrective Action Program Evaluation Report, Revision 4

WC-AA-104, Integrated Risk Management, Revision 25

Issue Reports

01700562 02393154 024341190 02466796 0 2552099 02552139 02637636 02644235 03954220 03991908 04082313 04082686 04088525 04096186 04099835 04136339 04137255 04140093 04142082 04155651 04131826 04132043 04133314 04134668 04135044 04135723 04135725 04156797 04160054* 04161414 04162477 04163117 04168525 04183223 04187330* 04188100 04189009 04194745 04194758* 0 4198228* 04204705* 04207466* 04184941* Work Orders

C90640029 C92141684 C92592531 C93470730 C93478886 C93479238 C93482078 C93590912 C93591645 C93591666 C93591667 C93591669 C93591673 C93594212 C93676748

Calculations

N2-CRM-008, Technical Specification 3.0.9 Evaluation of Residual Heat Removal Division I and Division II Pump Room Barrier Penetrations to Support Maintenance, Revision 0

Engineering Change

s ECP-17-000635, NMP2 Recirc Motor R&R

- Early Snubber Removal

- Tech Eval Required, Revision 0000

ECP-18-000086, TSTF

-542: Reactor Pressure Vessel Water Inventory Control (RPV WIC) Implementation at Nine Mile Point Unit 2, Revision 0000

ECP-18-000256, Temporary Removal of Snubber 2WCS

-PSSP583A1

for Recirc Motor Replacement, Revision 0000

Operating Experience

439055 Configuration Event

-Momentary Interruption of Condensate Flow During Plant Startup

Miscellaneous

7590-01-P, Notice of Availability of Model Application Concerning Technical Specification Improvement to Modify Requirements Regarding the Addition of LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process

ASME Code for Operation and Maintenance of Nuclear Power Plants, Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants, 2004 Edition

EGM 11-003, Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specifications Containment Requirements During Operations with the Potential for Draining the Reactor Vessel, Revision 3

Event Notification #53395 on May 10, 2018

Nine Mile Point Barrier Impairment Logbook

NRC Regulatory Issue Summary 2001

-09, Control of Hazard Barriers

NRC Regulatory Issue Summary 2013-05, NRC Position on the Relationship between General Design Criteria and Technical Specification Operability, May 9, 2013

Technical Specification Task Force 427, Revision 2

71153 Procedures

EPIP-EPP-02-EAL, Emergency Action Level Matrix Unit 2, Revision 24 N2-SOP-08, Unplanned Power Changes, Revision 01300

Issue Report

04199584 Drawing PID-8Q, Piping & Instrumentation Diagram Feedwater Heaters and Extraction Steam Systems, Revision 13