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| author name = Dimitriadis A
| author name = Dimitriadis A
| author affiliation = NRC/RGN-I/DRP/PB5
| author affiliation = NRC/RGN-I/DRP/PB5
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000333
| docket = 05000333
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=Text=
=Text=
{{#Wiki_filter:(Addressee)
{{#Wiki_filter:February 11, 2019
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PA 19406-2713 February 11, 2019  


Mr. Bryan Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
==SUBJECT:==
 
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2018004
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2018004


==Dear Mr. Hanson:==
==Dear Mr. Hanson:==
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The NRC inspectors did not identify any findings or violations of more than minor significance.
The NRC inspectors did not identify any findings or violations of more than minor significance.


This letter, its enclosure, and your response (if any) will be made available for public inspection  
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and 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/


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."
Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects


Sincerely,
Docket Number: 50-333 License Number: DPR-59
/RA/ Anthony Dimitriadis, Chief Reactor Projects Branch 5


Division of Reactor Projects Docket Number: 50-333 License Number: DPR-59 Enclosure:
===Enclosure:===
Inspection Report 05000333/2018004  
Inspection Report 05000333/2018004  


cc w/encl: Distribution via ListServ
==Inspection Report==
Docket Number:
50-333


ML19043A899 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP RI/DRP NAME CHighley/CJH JSchussler/JES AZiedonis/AVZ ADimitriadis/AD DATE 2/11/19 2/11/19 2/8/19 2/11/19
License Number:
DPR-59


1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION
Report Number:
05000333/2018004


==Inspection Report==
Enterprise Identifier: I-2018-004-0067
 
Licensee:
Exelon Generation Company, LLC (Exelon)


Docket Number: 50-333
Facility:
James A. FitzPatrick Nuclear Power Plant


License Number: DPR-59
Location:
Scriba, NY


Report Number: 05000333/2018004
Inspection Dates:
October 1, 2018 to December 31, 2018


Enterprise Identifier: I-2018-004-0067
Inspectors:
C. Highley, Acting Senior Resident Inspector


Licensee: Exelon Generation Company, LLC (Exelon)
J. Schussler, Acting Senior Resident Inspector


Facility: James A. FitzPatrick Nuclear Power Plant
G. Stock, Resident Inspector


Location: Scriba, NY
J. Ambrosini, Senior Emergency Preparedness Inspector


Inspection Dates: October 1, 2018 to December 31, 2018
P. Boguszewski, Project Engineer


Inspectors: C. Highley, Acting Senior Resident Inspector J. Schussler, Acting Senior Resident Inspector G. Stock, Resident Inspector J. Ambrosini, Senior Emergency Preparedness Inspector P. Boguszewski, Project Engineer S. Pindale, Senior Reactor Inspector  
S. Pindale, Senior Reactor Inspector  


Approved By: Anthony Dimitriadis, Chief  
Approved By:
Anthony Dimitriadis, Chief  


Reactor Projects Branch 5 Division of Reactor Projects
Reactor Projects Branch 5  


2
Division of Reactor Projects


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelon's performance at FitzPatrick 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-revealing findings, violations, and additional items are summarized in the table below.
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at  
 
FitzPatrick by conducting the baseline inspections described in this report 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. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.


No findings or more-than-minor violations were identified.
No findings or more-than-minor violations were identified.


Additional Tracking Items Type Issue number Title Inspection Results Section Status LER 05000333/2017-004-00 Safety Relief Valves Out of Tolerance 71153 Discussed LER 05000333/2017-004-01 Safety Relief Valve Lift Out of Tolerance 71153 Discussed  
===Additional Tracking Items===
Type Issue number Title Inspection Results Section Status LER 05000333/2017-004-00 Safety Relief Valves Out of Tolerance 71153 Discussed  


3
LER 05000333/2017-004-01 Safety Relief Valve Lift Out of Tolerance 71153 Discussed


=PLANT STATUS=
=PLANT STATUS=


FitzPatrick began the inspection period shutdown for planned refueling outage 23. Upon completion of refueling outage 23, operators performed a reactor startup and the generator was placed on the grid on October 7, 2018. On October 9, after raising power to approximately 80 percent, the 'B' recirculation pump tripped during testing. This resulted in a decrease in power to 53 percent. Following repairs, power ascension commenced and 100 percent was achieved on October 12. On October 27, operators reduced power to approximately 60 percent for a post-outage control rod pattern adjustment. Operators then raised power to 100 percent on October 28. FitzPatrick remained at or near rated thermal power for the remainder of the inspection period.
FitzPatrick began the inspection period shutdown for planned refueling outage 23. Upon completion of refueling outage 23, operators performed a reactor startup and the generator was placed on the grid on October 7, 2018. On October 9, after raising power to approximately 80 percent, the B recirculation pump tripped during testing. This resulted in a decrease in power to 53 percent. Following repairs, power ascension commenced and 100 percent was achieved on October 12. On October 27, operators reduced power to approximately 60 percent for a post-outage control rod pattern adjustment. Operators then raised power to 100 percent on October 28. FitzPatrick remained at or near rated thermal power for the remainder of the inspection period.


==INSPECTION SCOPES==
==INSPECTION SCOPES==
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light-Water Reactor Inspection Program - Operations Phase.The inspectors performed 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.
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 Exelons performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


==REACTOR SAFETY==
==REACTOR SAFETY==
==71111.01 - Adverse Weather Protection==
==71111.01 - Adverse Weather Protection==
===Seasonal Extreme Weather (1 Sample)===
===Seasonal Extreme Weather (1 Sample)===
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 12, 2018.
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 12, 2018.


===External Flooding (1 Sample)===
===External Flooding (1 Sample)===
The inspectors evaluated readiness to cope with external flooding on October 19, 2018.
The inspectors evaluated readiness to cope with external flooding on October 19, 2018.


==71111.04 - Equipment Alignment==
==71111.04 - Equipment Alignment==
===Partial Walkdown (2 Samples)===
===Partial Walkdown (2 Samples)===
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) Reactor core isolation cooling system on October 12, 2018
: (1) Reactor core isolation cooling system on October 12, 2018
: (2) 'B' station battery on November 6, 2018
: (2) B station battery on November 6, 2018


==71111.05A/Q - Fire Protection Annual/Quarterly==
==71111.05A/Q - Fire Protection Annual/Quarterly==
===Quarterly Inspection (2 Samples)===
===Quarterly Inspection (2 Samples)===
 
The inspectors evaluated fire protection program implementation in the following selected areas:
The inspectors evaluated fire protection program implementation in the following selected  
: (1) A and C emergency diesel generator and switchgear rooms, fire area/zones V/EG-1, EG-2, and EG-5 on December 18, 2018
 
: (2) B and D emergency diesel generator and switchgear rooms, fire area/zones VI/ EG-3, EG-4, and EG-6 on December 18, 2018
areas:
: (1) 'A' and 'C' emergency diesel generator and sw itchgear rooms, fire area/zones V/EG-1, EG-2, and EG-5 on December 18, 2018
: (2) 'B' and 'D' emergency diesel generator and sw itchgear rooms, fire area/zones VI/ EG-3, EG-4, and EG-6 on December 18, 2018


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
===Operator Requalification (1 Sample)===
===Operator Requalification (1 Sample)===
The inspectors observed and evaluated a simulator scenario including the removal of offsite  
The inspectors observed and evaluated a simulator scenario including the removal of offsite line 1 from service; an unexpected closure of a turbine control valve; an unexpected opening of an automatic depressurization system safety relief valve (SRV); fuel failure and a failure of a steam line to isolate, requiring emergency depressurization; and event declaration on October 18, 2018.
 
line 1 from service; an unexpected closure of a turbine control valve; an unexpected opening of an automatic depressurization system safety relief valve (SRV); fuel failure and a failure of a steam line to isolate, requiring emergency depressurization; and event declaration on October 18, 2018.


===Operator Performance (1 Sample)===
===Operator Performance (1 Sample)===
The inspectors observed and evaluated operations personnel during startup activities following refueling outage 23 on October 6, 2018, as well as synchronizing the unit to the grid on October 7, 2018.
The inspectors observed and evaluated operations personnel during startup activities following refueling outage 23 on October 6, 2018, as well as synchronizing the unit to the grid on October 7, 2018.


==71111.12 - Maintenance Effectiveness==
==71111.12 - Maintenance Effectiveness==
===Routine Maintenance Effectiveness (4 Samples)===
===Routine Maintenance Effectiveness (4 Samples)===
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
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The inspectors evaluated the risk assessments for the following planned and emergent work activities:
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) Drain down, operations with the potential to drain the reactor vessel, outage risk window 4, on October 1, 2018
: (1) Drain down, operations with the potential to drain the reactor vessel, outage risk window 4, on October 1, 2018
: (2) 'A' emergency service water inoperable and unavailable on October 31, 2018
: (2) A emergency service water inoperable and unavailable on October 31, 2018
: (3) Transition from Mode 4 to Modes 2 and 1 with inoperable residual heat removal pump, in accordance with Technical Specification 3.0.4.b, on November 28, 2018
: (3) Transition from Mode 4 to Modes 2 and 1 with inoperable residual heat removal pump, in accordance with Technical Specification 3.0.4.b, on November 28, 2018
: (4) 'B' residual heat removal system inoperable and unavailable on December 11, 2018
: (4) B residual heat removal system inoperable and unavailable on December 11, 2018


==71111.15 - Operability Determinations and Functionality Assessments==
==71111.15 - Operability Determinations and Functionality Assessments==
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The inspectors evaluated the following operability determinations and functionality assessments:
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) 'B' inboard main steam isolation valve, 29AOV-80B, main control board dual indication on October 18, 2018
: (1) B inboard main steam isolation valve, 29AOV-80B, main control board dual indication on October 18, 2018
: (2) Sodium pentaborate identified on reactor vessel instrumentation valve body on November 29, 2018
: (2) Sodium pentaborate identified on reactor vessel instrumentation valve body on November 29, 2018
: (3) Water hammer induced damage to reactor coolant pressure boundary snubber on December 19, 2018
: (3) Water hammer induced damage to reactor coolant pressure boundary snubber on December 19, 2018
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The inspectors evaluated post maintenance testing for the following maintenance/repair activities:
The inspectors evaluated post maintenance testing for the following maintenance/repair activities:
: (1) 'A' residual heat removal service water loop quarterly operability test following pump fastener replacement on October 4, 2018
: (1) A residual heat removal service water loop quarterly operability test following pump fastener replacement on October 4, 2018
: (2) SRV electric lift logic system functional and simulated automatic actuation test following planned valve replacement on October 24, 2018
: (2) SRV electric lift logic system functional and simulated automatic actuation test following planned valve replacement on October 24, 2018
: (3) Reactor containment isolation cooling 150 pound operability test after containment closure on October 30, 2018
: (3) Reactor containment isolation cooling 150 pound operability test after containment closure on October 30, 2018
: (4) 'A' emergency service water pump following planned packing replacement on November 1, 2018
: (4) A emergency service water pump following planned packing replacement on November 1, 2018


==71111.20 - Refueling and Other Outage Activities==
==71111.20 - Refueling and Other Outage Activities==
{{IP sample|IP=IP 71111.20|count=1}}
{{IP sample|IP=IP 71111.20|count=1}}


The inspectors evaluated planned refueling outage 23 activities from October 1, 2018 to  
The inspectors evaluated planned refueling outage 23 activities from October 1, 2018 to October 12, 2018.
 
October 12, 2018.


==71111.22 - Surveillance Testing==
==71111.22 - Surveillance Testing==
The inspectors evaluated the following surveillance tests:  
The inspectors evaluated the following surveillance tests:  


===Routine (2 Samples)===
===Routine===
{{IP sample|IP=IP 71111.22|count=2}}
: (1) ST-39H, Reactor pressure vessel system leakage test, on October 3, 2018
: (1) ST-39H, Reactor pressure vessel system leakage test, on October 3, 2018
: (2) ST-6M, Standby liquid control recirculation injection test, on October 25, 2018
: (2) ST-6M, Standby liquid control recirculation injection test, on October 25, 2018
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{{IP sample|IP=IP 71114.04|count=1}}
{{IP sample|IP=IP 71114.04|count=1}}


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.
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 did not require NRC approval.
 
This evaluation did not require NRC approval.


==OTHER ACTIVITIES - BASELINE==
==OTHER ACTIVITIES - BASELINE==
==71152 - Problem Identification and Resolution==
==71152 - Problem Identification and Resolution==
===Semiannual Trend Review (1 Sample)===
===Semiannual Trend Review (1 Sample)===
 
The inspectors reviewed Exelons corrective action program for trends that might be indicative of a more significant safety issue.
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 Issues (2 Samples)===
===Annual Follow-up of Selected Issues (2 Samples)===
The inspectors reviewed Exelon's implementation of its corrective action program related to the following issues:
The inspectors reviewed Exelons implementation of its corrective action program related to the following issues:
: (1) SRV As-Found Testing Failures (IRs 4077124 and 4082823)
: (1) SRV As-Found Testing Failures (IRs 4077124 and 4082823)
: (2) Failure of Condensate Storage Tank Level Switches for Reactor Core Isolation Cooling Suction Realignment (IR 04164618)  
: (2) Failure of Condensate Storage Tank Level Switches for Reactor Core Isolation Cooling Suction Realignment (IR 04164618)  


71153 - Follow-up of Events and Notices of Enforcement Discretion  
===71153 - Follow-up of Events and Notices of Enforcement Discretion Events===
{{IP sample|IP=IP 71153|count=1}}


===Events (1 Sample)===
The inspectors evaluated response to the following event:
The inspectors evaluated response to the following event:
: (1) Degraded instrument air header pressure caused by a trip of service air compressor 39AC-2A led to reactor building ventilation isolation. Consequently with reactor building ventilation isolated, secondary containment di fferential pressure exceeded the technical specification requirement of greater than or equal to 0.25 inches of vacuum water gauge.
: (1) Degraded instrument air header pressure caused by a trip of service air compressor 39AC-2A led to reactor building ventilation isolation. Consequently with reactor building ventilation isolated, secondary containment differential pressure exceeded the technical specification requirement of greater than or equal to 0.25 inches of vacuum water gauge.


The condition existed for 3 minutes on December 5, 2018, and is documented in event notification report EN 53778.
The condition existed for 3 minutes on December 5, 2018, and is documented in event notification report EN 53778.


===Licensee Event Reports (1 Sample)===
===Licensee Event Reports (1 Sample)===
The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx
The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
:
: (1) LER 05000333/2017-004-00, Safety Relief Valves Out of Tolerance (ADAMS Accession No. ML18089A040). The circumstances surrounding this LER were discussed and are documented in report section Inspection Results. This LER remains Open.
: (1) LER 05000333/2017-004-00, Safety Relief Valves Out of Tolerance (ADAMS Accession No. ML18089A040). The circumstances surrounding this LER were discussed and are documented in report section Inspection Results. This LER remains Open.
: (2) LER 05000333/2017-004-01, Safety Relief Valve Lift Out of Tolerance (ADAMS Accession No. ML18022A031). The circumstances surrounding this LER were discussed and are documented in report section Inspection Results. This LER remains  
: (2) LER 05000333/2017-004-01, Safety Relief Valve Lift Out of Tolerance (ADAMS Accession No. ML18022A031). The circumstances surrounding this LER were discussed and are documented in report section Inspection Results. This LER remains Open.


Open.
==INSPECTION RESULTS==
Observations 71152 Annual Follow-up of Selected issues Safety Relief Valve As-Found Testing Failures


==INSPECTION RESULTS==
The inspectors performed a review of Exelon's evaluation and corrective actions associated with FitzPatrick main steam SRV setpoint drift issues. Over the past several operating cycles, SRV testing has resulted in some SRVs exceeding the technical specification allowable as-found lift setpoint acceptance criterion of 1145 psig +/- 3 percent. The setpoint drift has been attributed to corrosion bonding, which involves bridging oxide buildup between the pilot disc surface and pilot valve body disc seating surface. This phenomenon typically affects the initial SRV actuation.
Observations 71152  Annual Follow-up of Selected issues Safety Relief Valve As-Found Testing Failures


The inspectors performed a review of Exelon's evaluation and corrective actions associated with FitzPatrick main steam SRV setpoint drift issues. Over the past several operating cycles, SRV testing has resulted in some SRVs exceeding the technical specification allowable as-found lift setpoint acceptance criterion of 1145 psig +/- 3 percent. The setpoint drift has been attributed to "corrosion bonding," which involves bridging oxide buildup between the pilot disc surface and pilot valve body disc seating surface. This phenomenon typically affects the initial SRV actuation.
The inspectors evaluated Exelons prioritization and timeliness of corrective actions to determine whether they were appropriately identifying, characterizing, and correcting problems associated with this issue, and whether the planned or completed corrective actions were commensurate with the safety significance of the issue. The inspectors determined Exelon staff implemented corrective actions intended to improve SRV performance which included installation of Stellite 21 discs in all 11 SRV pilot assemblies and installation of an SRV electric lift system (additional, redundant pressure actuation switches modification).


The inspectors evaluated Exelon's prioritization and timeliness of corrective actions to determine whether they were appropriately identifying, characterizing, and correcting problems associated with this issue, and whether the planned or completed corrective actions were commensurate with the safety significance of the issue. The inspectors determined Exelon staff implemented corrective actions intended to improve SRV performance which included installation of Stellite 21 discs in all 11 SRV pilot assemblies and installation of an SRV electric lift system (additional, redundant pressure actuation switches modification). Additionally, Exelon staff began to replace the 2-stage SRVs with 3-stage Target Rock SRVs, which were designed to address the corrosion bonding issue. Three SRVs were installed in 2010 of the 3-stage design. However, operating experience at another plant indicated an unrelated problem with the 3-stage SRV design (ADAMS Accession No. ML15134A017). Subsequently, the SRV vendor re-designed the 3-stage SRV to eliminate the problem. In the interim, Exelon staff removed two of their three 3-stage SRVs from service and replaced them with 2-stage SRVs.
Additionally, Exelon staff began to replace the 2-stage SRVs with 3-stage Target Rock SRVs, which were designed to address the corrosion bonding issue. Three SRVs were installed in 2010 of the 3-stage design. However, operating experience at another plant indicated an unrelated problem with the 3-stage SRV design (ADAMS Accession No. ML15134A017).


Relative to the 10 of 11 SRVs that did not meet test acceptance criterion for the SRVs removed during the Fall 2017 refueling outage, Exelon staff determined that the safety significance was minimal due to the availability of the electric lift system. Nine of the 10 SRV test failures were 2-stage valves, and one was the remaining 3-stage valve. The nine 2-stage SRVs that failed were out of specification high, and the 3-stage SRV was out of specification low. Exelon staff attributed the nine 2-stage SRV test failures to corrosion bonding. The 3-stage SRV test failure was attributed to calibrating the pilot within the lower half of the acceptance range, for which Exelon subsequently implemented a new work practice to conduct additional spring testing during SRV refurbishment to reduce the likelihood of setpoint
Subsequently, the SRV vendor re-designed the 3-stage SRV to eliminate the problem. In the interim, Exelon staff removed two of their three 3-stage SRVs from service and replaced them with 2-stage SRVs.


drift.
Relative to the 10 of 11 SRVs that did not meet test acceptance criterion for the SRVs removed during the Fall 2017 refueling outage, Exelon staff determined that the safety significance was minimal due to the availability of the electric lift system. Nine of the 10 SRV test failures were 2-stage valves, and one was the remaining 3-stage valve. The nine 2-stage SRVs that failed were out of specification high, and the 3-stage SRV was out of specification low. Exelon staff attributed the nine 2-stage SRV test failures to corrosion bonding. The 3-stage SRV test failure was attributed to calibrating the pilot within the lower half of the acceptance range, for which Exelon subsequently implemented a new work practice to conduct additional spring testing during SRV refurbishment to reduce the likelihood of setpoint drift.


During the most recent refueling outage at FitzPatrick (Fall 2018), Exelon staff removed all 11 2-stage SRVs and sent them to an offsite testing facility. Those tests have not yet been completed. Exelon staff further replaced all SRVs with newly modified 3-stage design.
During the most recent refueling outage at FitzPatrick (Fall 2018), Exelon staff removed all 11 2-stage SRVs and sent them to an offsite testing facility. Those tests have not yet been completed. Exelon staff further replaced all SRVs with newly modified 3-stage design.
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The inspectors concluded Exelon staff implemented corrective actions consistent with industry and vendor initiatives to minimize the corrosion bonding issues. In addition, Exelon staff replaced all SRVs with the 3-stage modified design in September 2018 after an unrelated problem was addressed by the vendor. These corrective actions implemented industry and vendor recommendations and were commensurate with the safety significance of the issue.
The inspectors concluded Exelon staff implemented corrective actions consistent with industry and vendor initiatives to minimize the corrosion bonding issues. In addition, Exelon staff replaced all SRVs with the 3-stage modified design in September 2018 after an unrelated problem was addressed by the vendor. These corrective actions implemented industry and vendor recommendations and were commensurate with the safety significance of the issue.


Additional discussion on this issue is documented in Inspection Results, Section 71153, in this report. Observations 71152 Annual Follow-up of Selected issues Failure of Condensate Storage Tank Level Switches for Reactor Core Isolation Cooling Suction Realignment The inspectors performed an in-depth review of Exelon's analysis and corrective actions associated with multiple failures of the condensate storage tank level switches for reactor core isolation cooling suction realignment. The inspectors reviewed condition reports, engineering evaluations, and causal evaluations; and held discussions with plant personnel. The inspectors assessed Exelon's problem identification threshold, cause analysis, and the prioritization and timeliness of the corrective actions.
Additional discussion on this issue is documented in Inspection Results, Section 71153, in this report.


The reactor core isolation cooling system is normally aligned to take suction from the condensate storage tank. When the condensate storage tank experiences a low water level condition, level switches actuate resulting in a suction realignment to the Torus. There are four of these switches, two per division, 13LS-76A, 13LS-77A, 13LS-76B, and 13LS-77B. For suction realignment, one switch from both divisions must actuate. Technical Specification 3.3.5.3 requires all four switches be operable. If a switch is found to be inoperable, the channel must be put in trip, reactor core isolation cooling must be realigned to the Torus within 24 hours, or reactor core isolation cooling must be declared inoperable. On February 27, 2018, 13LS-76B failed its routine surveillance but was able to be recalibrated. This issue was documented in IR 04109193. As a result of this failure, the surveillance frequency was increased from 90 to 45 days. The inspectors determined this was an appropriate response to the failure.
Observations 71152 Annual Follow-up of Selected issues Failure of Condensate Storage Tank Level Switches for Reactor Core Isolation Cooling Suction Realignment


Both 13LS-76A and 13LS-76B performed successfully during the following two surveillances. On August 15, 2018, during the third performance of the surveillance, both 13LS-76A and 13LS-76B failed, and only 13LS-76A was able to be reset. 13LS-76B was found to have a broken internal component, called the shunt, which made it unable to be calibrated. Exelon's apparent cause evaluation on the issue, and discussions with the manufacturer, found that the shunt was undersized. The shunt for 13LS-76B was replaced with the appropriate component and was successfully post-maintenance tested. This issue was documented in IR 04164618.
The inspectors performed an in-depth review of Exelons analysis and corrective actions associated with multiple failures of the condensate storage tank level switches for reactor core isolation cooling suction realignment. The inspectors reviewed condition reports, engineering evaluations, and causal evaluations; and held discussions with plant personnel. The inspectors assessed Exelons problem identification threshold, cause analysis, and the prioritization and timeliness of the corrective actions.


It was also recognized at this time that both 13LS-76A and 13LS-77B were potentially susceptible to the same failure mode. Exelon's operability determination found there was confidence that the function was maintained based on surveillance history and that, after the repair, one switch from both divisions was not susceptible to the broken shunt failure mode, specifically 13LS-76B and 13LS-77A. Also, work orders were generated to open and inspect 13LS-76A and 13LS-77B in future work weeks to verify the undersized shunt was not present. The inspectors inquired about the justification for continued operations with the potentially degraded switches. Exelon's response included pursuit of switch replacement; ensuring that the installed switches either passed previous surveillances or post-maintenance tests; and verification that  the remaining susceptible switches were not in the same division, therefore, the safety function was maintained. The inspectors determined these actions were reasonable.
The reactor core isolation cooling system is normally aligned to take suction from the condensate storage tank. When the condensate storage tank experiences a low water level condition, level switches actuate resulting in a suction realignment to the Torus. There are four of these switches, two per division, 13LS-76A, 13LS-77A, 13LS-76B, and 13LS-77B. For suction realignment, one switch from both divisions must actuate. Technical Specification 3.3.5.3 requires all four switches be operable. If a switch is found to be inoperable, the channel must be put in trip, reactor core isolation cooling must be realigned to the Torus within 24 hours, or reactor core isolation cooling must be declared inoperable. On February 27, 2018, 13LS-76B failed its routine surveillance but was able to be recalibrated.


On November 8, 2018, both 13LS-76A and 13LS-76B failed the surveillance again. These failures were documented in IR 04193121 and 04193124. Given the history of these switches, Exelon swapped reactor core isolation cooling suction to the Torus and expedited the complete switch replacement of 13LS-76B. Once 13LS-76B was replaced, suction was returned to the condensate storage tank, however, the 'A' division was left in the trip state due to the suspect condition of 13LS-76A. 13LS-76A has since been replaced, on January 2, 2019, and the 'A' division was brought out of trip to the normal lineup. Following the 13LS-76B replacement after the November 8, 2018, failure, the removed switch was sent to Exelon PowerLabs for analysis. The analysis was inconclusive because the identified condition could not be repeated. Long term corrective actions include a design change to utilize a more robust style level switch.
This issue was documented in IR 04109193. As a result of this failure, the surveillance frequency was increased from 90 to 45 days. The inspectors determined this was an appropriate response to the failure.


The inspectors concluded that the issues had been appropriately identified in the corrective action program and that corrective actions were timely, based on information available at the time of each failure. The above items were evaluated using NRC IMC 0612, Appendix B, "Issue Screening," and NRC IMC 0612, Appendix E, "Examples of Minor Issues," and determined to be of minor significance because the safety function was always maintained.
Both 13LS-76A and 13LS-76B performed successfully during the following two surveillances.


Observations 71152 Semi-Annual Trend Review The inspectors evaluated a sample of condition reports generated over the course of the second and third 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.
On August 15, 2018, during the third performance of the surveillance, both 13LS-76A and 13LS-76B failed, and only 13LS-76A was able to be reset. 13LS-76B was found to have a broken internal component, called the shunt, which made it unable to be calibrated. Exelons apparent cause evaluation on the issue, and discussions with the manufacturer, found that the shunt was undersized. The shunt for 13LS-76B was replaced with the appropriate component and was successfully post-maintenance tested. This issue was documented in IR 04164618.
 
It was also recognized at this time that both 13LS-76A and 13LS-77B were potentially susceptible to the same failure mode. Exelons operability determination found there was confidence that the function was maintained based on surveillance history and that, after the repair, one switch from both divisions was not susceptible to the broken shunt failure mode, specifically 13LS-76B and 13LS-77A. Also, work orders were generated to open and inspect 13LS-76A and 13LS-77B in future work weeks to verify the undersized shunt was not present.
 
The inspectors inquired about the justification for continued operations with the potentially degraded switches. Exelons response included pursuit of switch replacement; ensuring that the installed switches either passed previous surveillances or post-maintenance tests; and verification that the remaining susceptible switches were not in the same division, therefore, the safety function was maintained. The inspectors determined these actions were reasonable.
 
On November 8, 2018, both 13LS-76A and 13LS-76B failed the surveillance again. These failures were documented in IR 04193121 and 04193124. Given the history of these switches, Exelon swapped reactor core isolation cooling suction to the Torus and expedited the complete switch replacement of 13LS-76B. Once 13LS-76B was replaced, suction was returned to the condensate storage tank, however, the A division was left in the trip state due to the suspect condition of 13LS-76A. 13LS-76A has since been replaced, on January 2, 2019, and the A division was brought out of trip to the normal lineup. Following the 13LS-76B replacement after the November 8, 2018, failure, the removed switch was sent to Exelon PowerLabs for analysis. The analysis was inconclusive because the identified condition could not be repeated. Long term corrective actions include a design change to utilize a more robust style level switch.
 
The inspectors concluded that the issues had been appropriately identified in the corrective action program and that corrective actions were timely, based on information available at the time of each failure. The above items were evaluated using NRC IMC 0612, Appendix B, Issue Screening, and NRC IMC 0612, Appendix E, Examples of Minor Issues, and determined to be of minor significance because the safety function was always maintained.
 
Observations 71152 Semi-Annual Trend Review The inspectors evaluated a sample of condition reports generated over the course of the second and third 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 significance safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Exelon staff for potential trends at a low threshold, and resolved within the scope of the corrective action program. The inspectors noted minor adverse trends identified by Exelon staff in the area of vendor quality parts, foreign material exclusion, source range monitors, and boron related issue reports.
The evaluation did not reveal any new trends that could indicate a more significance safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Exelon staff for potential trends at a low threshold, and resolved within the scope of the corrective action program. The inspectors noted minor adverse trends identified by Exelon staff in the area of vendor quality parts, foreign material exclusion, source range monitors, and boron related issue reports.


There were no 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 had properly identified adverse trends at FitzPatrick 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 that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRC's Enforcement Policy.
There were no 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 had properly identified adverse trends at FitzPatrick 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 that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.


LER (Discussed/
LER (Discussed/
Open) LER 05000333/2017-004-00, Safety Relief Valves Out of Tolerance and Supplemental  
Open)
 
LER 05000333/2017-004-00, Safety Relief Valves Out of Tolerance and Supplemental LER 05000333/2017-004-01, Safety Relief Valve Lift Out of Tolerance 71153 Follow-up of Events and Notices of Enforcement Discretion  
LER 05000333/2017-004-01, Safety Relief Valve Lift Out of Tolerance 71153 Follow-up of Events and Notices of Enforcement Discretion


=====Description:=====
=====Description:=====
On November 21, 2017, Exelon staff received results that the as-found setpoint tests for the main steam SRV pilot stage assemblies had exceeded the lift setting tolerance prescribed in technical specifications. Specifically, 10 of the 11 pilot stage assemblies tested experienced drift beyond the +/- 3 percent tolerance permitted by Technical Specification 3.4.3. Exelon staff concluded that the cause of the setpoint drift was attributed to corrosion bonding between the pilot disc and seating surfaces for 9 of the 10 test failures (these were 2-stage SRVs which all failed high); and calibrating the pilot within the lower half of the acceptance range was the cause for the other test failure (which was a 3-stage SRV that failed low). This condition was reportable under 10 CFR 50.73(a)(2)(i)(B) and (a)(2)(v)(D) as any operation or condition which was prohibited by the plant's technical specifications, and any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident, respectively.
On November 21, 2017, Exelon staff received results that the as-found setpoint tests for the main steam SRV pilot stage assemblies had exceeded the lift setting tolerance prescribed in technical specifications. Specifically, 10 of the 11 pilot stage assemblies tested experienced drift beyond the +/- 3 percent tolerance permitted by Technical Specification 3.4.3. Exelon staff concluded that the cause of the setpoint drift was attributed to corrosion bonding between the pilot disc and seating surfaces for 9 of the 10 test failures (these were 2-stage SRVs which all failed high); and calibrating the pilot within the lower half of the acceptance range was the cause for the other test failure (which was a 3-stage SRV that failed low). This condition was reportable under 10 CFR 50.73(a)(2)(i)(B) and (a)(2)(v)(D)as any operation or condition which was prohibited by the plants technical specifications, and any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident, respectively.


The SRV corrosion bonding issue has been reported to the NRC by a number of plant operators. Currently, NRC staff in the Office of Nuclear Reactor Regulation are meeting with the Boiling Water Reactor Owners Group and other stakeholders to gain a better understanding of the industry initiatives to address this issue (reference ADAMS Accession No. ML18267A016). It is expected that further guidance on dispositioning these issues will be provided to regional inspectors in the near term.
The SRV corrosion bonding issue has been reported to the NRC by a number of plant operators. Currently, NRC staff in the Office of Nuclear Reactor Regulation are meeting with the Boiling Water Reactor Owners Group and other stakeholders to gain a better understanding of the industry initiatives to address this issue (reference ADAMS Accession No. ML18267A016). It is expected that further guidance on dispositioning these issues will be provided to regional inspectors in the near term.


While the inspectors did not identify a performance deficiency associated with Exelon's corrective actions, this LER, including characterization of this issue, will remain open pending the completion of NRC interaction with the industry and subsequent guidance on the dispositioning of these issues.
While the inspectors did not identify a performance deficiency associated with Exelons corrective actions, this LER, including characterization of this issue, will remain open pending the completion of NRC interaction with the industry and subsequent guidance on the dispositioning of these issues.


Corrective Action References: IRs 4077124 and 4082823  
Corrective Action References: IRs 4077124 and 4082823  


LER 05000333/2017-004-00 and Supplemental LER 05000333/2017-004-01 are Open.
LER 05000333/2017-004-00 and Supplemental LER 05000333/2017-004-01 are Open.
Line 281: Line 282:
=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


71111.01 Procedures AOP-13, Severe Weather, Revision 33
71111.01
Procedures
AOP-13, Severe Weather, Revision 33
AOP-13, Severe Weather, Revision 34
AOP-13, Severe Weather, Revision 34
WC-AA-107, Seasonal Readiness, Revision 21
WC-AA-107, Seasonal Readiness, Revision 21
Line 287: Line 290:
04724778
04724778
Miscellaneous
Miscellaneous
UFSAR 71111.04 Procedures AOP-46, Loss of DC Power System B, Revision 16 FM-22A, Flow Diagram Reactor Core Isolation Cooling, Revision 57 OP-43A, 125 VDC Power System, Revision 30
UFSAR
71111.05 Procedures PFP-PWR31, Emergency Diesel Generator Spaces-South / Elevation 272-foot Fire Area/Zone V/EG-1, EG-2, EG-5, Revision 4 PFP-PWR32, Emergency Diesel Generator Spaces-North / Elevation 272-foot Fire Area/Zone
71111.04
Procedures
AOP-46, Loss of DC Power System B, Revision 16
FM-22A, Flow Diagram Reactor Core Isolation Cooling, Revision 57
OP-43A, 125 VDC Power System, Revision 30
71111.05
Procedures
PFP-PWR31, Emergency Diesel Generator Spaces-South / Elevation 272-foot Fire Area/Zone
V/EG-1, EG-2, EG-5, Revision 4
PFP-PWR32, Emergency Diesel Generator Spaces-North / Elevation 272-foot Fire Area/Zone
VI/EG-3, EG-4, EG-6, Revision 5
VI/EG-3, EG-4, EG-6, Revision 5
71111.11
71111.11
Procedure OP-65, Start-up and Shutdown Procedure, Revision 124A
Procedure
71111.12 Procedures Design Equivalent Change Packet 625754, Justification for Alternate Screws for RHRSW
OP-65, Start-up and Shutdown Procedure, Revision 124A
Pumps 10P-1A and 10P-1C, Revision 0 ER-AA-310-1003, Maintenance Rule Performance Criteria Selection, Revision 5
71111.12
JAF-RPT-MULTI-02294, Maintenance Rule Basis
Procedures
Document for Service Water Systems, Revision 12 Vendor Manual A180-0052, Installation and Maintenance Instructions for Vertical Turbine Pumps, Revision 2
Design Equivalent Change Packet 625754, Justification for Alternate Screws for RHRSW
Issue Reports 03992524 03992574 03997323 04003347
Pumps 10P-1A and 10P-1C, Revision 0
04005476 04026429 04034868 04047111
ER-AA-310-1003, Maintenance Rule Performance Criteria Selection, Revision 5
04084185 04109193 04133925 04117191
JAF-RPT-MULTI-02294, Maintenance Rule Basis Document for Service Water Systems,
04118802 04118803 04122120 04122622
Revision 12
04122627 04122774 04122776 04122777 04123048 04134050 04154237 04160342
Vendor Manual A180-0052, Installation and Maintenance Instructions for Vertical Turbine
04160344 04160345 04160346 04163480 04164618 04164660 04173069 04173442 04175529 04175532 04175533 04175762
Pumps, Revision 2
04178640 04180688 04188092 04190096
Issue Reports
03992524
03992574
03997323
04003347
04005476
04026429
04034868
04047111
04084185
04109193
04133925
04117191
04118802
04118803
04122120
04122622  
 
04122627
04122774
04122776
04122777
04123048
04134050
04154237
04160342
04160344
04160345
04160346
04163480
04164618
04164660
04173069
04173442
04175529
04175532
04175533
04175762
04178640
04180688
04188092
04190096
04194525
04194525
Drawing 2.28-5, Sectional Allis Chalmers (RHRSW Drawing), Revision 2  
Drawing
 
2.28-5, Sectional Allis Chalmers (RHRSW Drawing), Revision 2
Engineering Change Package 625811, Residual Heat Removal Service Water Cap Screw Corrosion, Revision 0
Engineering Change Package
Miscellaneous Maintenance Rule (a)(1) Action Plan System 10 RHRSW 'B' Train, Revision 4 Maintenance Rule Basis Document, Reactor Core Isolation Cooling, dated November 12, 2018
25811, Residual Heat Removal Service Water Cap Screw Corrosion, Revision 0
Miscellaneous
Maintenance Rule (a)(1) Action Plan System 10 RHRSW B Train, Revision 4
Maintenance Rule Basis Document, Reactor Core Isolation Cooling, dated November 12, 2018
Maintenance Rule Basis Document, Standby Liquid Control, dated December 10, 2018
Maintenance Rule Basis Document, Standby Liquid Control, dated December 10, 2018
Maintenance Rule Performance Criteria Selection Template Used for Maintenance Rule
Maintenance Rule Performance Criteria Selection Template Used for Maintenance Rule
ID 11- 1 Revision, Dated March 5, 2018 Maintenance Rule Systems Basis Document, Emergency Service Water, dated December 12, 2018
ID 11-1 Revision, Dated March 5, 2018
71111.13 Procedures
Maintenance Rule Systems Basis Document, Emergency Service Water, dated
ER-AA-600-1042, On-Line Risk Management, Revision 11 OU-AA-103, Shutdown Safety Management Program, Revision 20
December 12, 2018
71111.13
Procedures
ER-AA-600-1042, On-Line Risk Management, Revision 11
OU-AA-103, Shutdown Safety Management Program, Revision 20
WC-AA-101, On-Line Work Control Process, Revision 28
WC-AA-101, On-Line Work Control Process, Revision 28
Issue Reports
Issue Reports
04179738 04198300
04179738
Engineering Change 17239, Low Pressure Coolant Injection Inverter Replacement, Revision 1
04198300
Engineering Change
239, Low Pressure Coolant Injection Inverter Replacement, Revision 1
Miscellaneous
Miscellaneous
Risk Management Document No. JF-Mode-001, Transition from Mode 4 to Modes 2 and 1 with Inoperable RHR Pump, Revision 0
Risk Management Document No. JF-Mode-001, Transition from Mode 4 to Modes 2 and 1 with
Inoperable RHR Pump, Revision 0
71111.15
71111.15
Procedures ER-AA-335-016, VT-3 Visual Examination of Component Supports, Attachments and Interiors of
Procedures
Reactor Vessels, Revision 11 MA-AA-716-004, Conduct of Troubleshooting, Revision 015
ER-AA-335-016, VT-3 Visual Examination of Component Supports, Attachments and Interiors of
Reactor Vessels, Revision 11
MA-AA-716-004, Conduct of Troubleshooting, Revision 015
Work Order
Work Order
24885  
24885  


Issue Reports 03992605 04029823 04172631 04172786 04173609 04173773 04175339 04182254
Issue Reports
Drawings FM-24A, Flow Diagram Reactor Water Cleanup System 12, Revision 12
03992605
04029823
04172631
04172786
04173609
04173773
04175339
04182254
Drawings
FM-24A, Flow Diagram Reactor Water Cleanup System 12, Revision 12
FP-1B, Reactor Water Cleanup Piping, Revision 38
FP-1B, Reactor Water Cleanup Piping, Revision 38
MSK-101A1, Reactor Water Cleanup Piping Pump Suction, Revision 15
MSK-101A1, Reactor Water Cleanup Piping Pump Suction, Revision 15
Engineering Change Package 625791, Reactor Water Cleanup Snubber Past Operability, Revision 1
Engineering Change Package
Miscellaneous JAF-SPEC-MISC-00334, James  
25791, Reactor Water Cleanup Snubber Past Operability, Revision 1
: [[contact::A. FitzPatrick Nuclear Power Plant Piping Specification]], Revision 14
Miscellaneous
JAF-SPEC-MISC-00334, James  
: [[contact::A. FitzPatrick Nuclear Power Plant Piping Specification]],
Revision 14
Operability Evaluation 18-005
Operability Evaluation 18-005
Troubleshooting Plan for AR 04175339, Attachment 1 of MA-AA-716-004, Revision 15
Troubleshooting Plan for AR 04175339, Attachment 1 of MA-AA-716-004, Revision 15
Troubleshooting Plan for Valve 02-3NBI-26 and 32, Attachments 2 and 3 of MA-AA-716-004, Revision 15
Troubleshooting Plan for Valve 02-3NBI-26 and 32, Attachments 2 and 3 of MA-AA-716-004,
71111.18 Procedure AOP-13, Severe Weather, Revision 34
Revision 15
71111.18
Procedure
AOP-13, Severe Weather, Revision 34
Issue Reports
Issue Reports
03992524 04144501
03992524
04144501
04144602
04144602
Condition Report CR-2017-00812
Condition Report
CR-2017-00812
Work Orders
Work Orders
466553
466553
466554 Engineering Changes 17239, Low Pressure Coolant Injection Inverter Replacement, Revision 1
466554
Engineering Changes
239, Low Pressure Coolant Injection Inverter Replacement, Revision 1
69507, Residual Heat Removal Strainer Temporary Modification, Revision 0
69507, Residual Heat Removal Strainer Temporary Modification, Revision 0
20371, Tornado Missile Assessment for FitzPatrick, Revision 0 622608, Tornado Missile Protection Non-Conformance Relay Room and Control Room AC System, Revision 0 624475, Reinforced Concrete Wall Barrier Non-Conformance for Tornado Missile Protection, Revision 1 624477, Tornado Missile Protection Non-Conformance Relay Room and Control Room AC System, Revision 0
20371, Tornado Missile Assessment for FitzPatrick, Revision 0
Drawings 6.60-85, Sure Flow Suction Strainer Module RHR1 Module Assembly and Design Information, Revision A
2608, Tornado Missile Protection Non-Conformance Relay Room and Control Room AC
6.60-103, Sure Flow Suction Strainer RHR and CS Modules Subassembly Sections and Details, Revision A
System, Revision 0
Miscellaneous DBD-010, FitzPatrick Nuclear Power Plant Design Basis Document for the Residual Heat Removal System, Revision 13
24475, Reinforced Concrete Wall Barrier Non-Conformance for Tornado Missile Protection,
71111.19 Procedures ST-2XA, RHR Service Water Loop A Quarterly Operability Test, Revision 13 ST-8Q, Testing of the Emergency Service Water System (IST), Revision 51
Revision 1
24477, Tornado Missile Protection Non-Conformance Relay Room and Control Room AC
System, Revision 0
Drawings
6.60-85, Sure Flow Suction Strainer Module RHR1 Module Assembly and Design Information,
Revision A  
 
6.60-103, Sure Flow Suction Strainer RHR and CS Modules Subassembly Sections and Details,
Revision A
Miscellaneous
DBD-010, FitzPatrick Nuclear Power Plant Design Basis Document for the Residual Heat
Removal System, Revision 13
71111.19
Procedures
ST-2XA, RHR Service Water Loop A Quarterly Operability Test, Revision 13
ST-8Q, Testing of the Emergency Service Water System (IST), Revision 51
ST-22A, Automatic Depressurization System Simulated Automatic Actuation Test, Revision 24
ST-22A, Automatic Depressurization System Simulated Automatic Actuation Test, Revision 24
ST-22J, ST-22J, Safety Relief Valve Electric Lift Logic System Functional and Simulated
ST-22J, ST-22J, Safety Relief Valve Electric Lift Logic System Functional and Simulated
Automatic Actuation Test, Revision 7 ST-24J, RCIC Flow Rate and Inservice Test (IST), Revision 50  
Automatic Actuation Test, Revision 7
 
ST-24J, RCIC Flow Rate and Inservice Test (IST), Revision 50
Issue Reports
Issue Reports
04175529 04190317 71111.20 Procedures OP-65, Startup and Shutdown Procedure, Revision 123
04175529
04190317
71111.20
Procedures
OP-65, Startup and Shutdown Procedure, Revision 123
OP-AA-108-108, Unit Restart Review, Revision 20
OP-AA-108-108, Unit Restart Review, Revision 20
71111.22 Procedures ST-39H, RPV System Leakage Test, Revision 35
71111.22
Procedures
ST-39H, RPV System Leakage Test, Revision 35
ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI) Revision 10
ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI) Revision 10
ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI) Revision 11  
ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI) Revision 11
 
Issue Reports
Issue Reports
04179739 04179951
04179739
04179951
Work Order
Work Order
4646277
4646277
71114.04
71114.04
Procedures EP-AA-122-100, Drill and Exercise Planning and Scheduling, Revision 008
Procedures
EP-AA-122-100, Drill and Exercise Planning and Scheduling, Revision 008
EP-AA-122-100-F-08, Pre-Exercise and NRC Exercise Checklist, Revision F
EP-AA-122-100-F-08, Pre-Exercise and NRC Exercise Checklist, Revision F
EP-AA-122-100-F-09, Off-Year Exercise Checklist, Revision D EP-AA-122-100-F-10, Focus Area or Station Only Drill Checklist, Revision E EP-AA-122-100-F-12, Hostile Action Based Exercise Checklist, Revision D EP-AA-122-100-F-13, Call in Drill (CID) Checklist, Revision F
EP-AA-122-100-F-09, Off-Year Exercise Checklist, Revision D
EP-AA-122-100-F-14, Drive in Drill (DID) Checklist, Revision F
EP-AA-122-100-F-10, Focus Area or Station Only Drill Checklist, Revision E
EP-AA-122-300-F-01, Drill and Exercise Evaluation Criteria, Revision J EP-AA-122-300-F-02, Drill and Exercise Objective Evaluation Summary, Revision F
EP-AA-122-100-F-12, Hostile Action Based Exercise Checklist, Revision D
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-122-100-F-13, Call in Drill (CID) Checklist, Revision F
EP-AA-122-100-F-14, Drive in Drill (DID) Checklist, Revision F  
 
EP-AA-122-300-F-01, Drill and Exercise Evaluation Criteria, Revision J
EP-AA-122-300-F-02, Drill and Exercise Objective Evaluation Summary, Revision F
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, 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-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-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 18-02, EP-AA-111/EP-CE-111, Emergency Classification and Protective Action Recommendations, Revision 21-04 Evaluation 18-09, Drill and Exercise Procedure Changes
EP-AA-110-201-F-14, NMP Unit 2 Rapid Release Path Board, Revision B
Evaluation 18-02, EP-AA-111/EP-CE-111, Emergency Classification and Protective Action
Recommendations, Revision 21-04
Evaluation 18-09, Drill and Exercise Procedure Changes
Evaluation 18-19, URI Procedures and Supporting Forms
Evaluation 18-19, URI Procedures and Supporting Forms
Evaluation 18-75, TQ-AA-113, ERO Training and Qualification, Revision 34
Evaluation 18-75, TQ-AA-113, ERO Training and Qualification, Revision 34
71152 Procedures AP-19.01, Surveillance Testing Program, Revision 22 ER-AA-2003, System Performance Monitoring and Analysis, Revision 14 ISP-75.1, RCIC CST Low Water Level Switch Functional Test/Calibration, Revision 24
71152
Procedures
AP-19.01, Surveillance Testing Program, Revision 22
ER-AA-2003, System Performance Monitoring and Analysis, Revision 14
ISP-75.1, RCIC CST Low Water Level Switch Functional Test/Calibration, Revision 24
PI-AA-101-1001, Performance Monitoring and Analysis Manual, Revision 1
PI-AA-101-1001, Performance Monitoring and Analysis Manual, Revision 1
PI-AA-101, Conduct of Performance Improvement, Revision 1
PI-AA-101, Conduct of Performance Improvement, Revision 1
PI-AA-120, Issue Identification and Screening Process, Revision 8
PI-AA-120, Issue Identification and Screening Process, Revision 8
PI-AA-125, Corrective Action Program Procedure, Revision 6 WC-AA-120, Preventative Maintenance Modification Request, Revision 001
PI-AA-125, Corrective Action Program Procedure, Revision 6
Issue Reports 04164660 04164618 04174397 04176327
WC-AA-120, Preventative Maintenance Modification Request, Revision 001
04182832 04109193 04165105 04165110 04193121 04193124 04202844
Issue Reports
Drawing 791E464, Elementary Diagram RCIC System, Revision 9  
04164660
 
04164618
Miscellaneous DBD-013, Reactor Core Isolation Cooling System, Revision 6
04174397
04176327
04182832
04109193
04165105
04165110
04193121
04193124
202844
Drawing
791E464, Elementary Diagram RCIC System, Revision 9
Miscellaneous
DBD-013, Reactor Core Isolation Cooling System, Revision 6
Jaguar Instruments Vendor Manual, Level Ac SL-100, SL-300, SL-400, & SL-500 Series
Jaguar Instruments Vendor Manual, Level Ac SL-100, SL-300, SL-400, & SL-500 Series
Switches Robert Shaw Vendor Manual, External Float Chamber Level Switch SL-300, SL-700
Switches
Robert Shaw Vendor Manual, External Float Chamber Level Switch SL-300, SL-700
}}
}}

Latest revision as of 05:04, 5 January 2025

Integrated Inspection Report 05000333/2018004
ML19043A899
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 02/11/2019
From: Anthony Dimitriadis
NRC/RGN-I/DRP/PB5
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Dimitriadis A
References
IR 2018004
Download: ML19043A899 (17)


Text

February 11, 2019

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2018004

Dear Mr. Hanson:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). On January 22, 2019, the NRC inspectors discussed the results of this inspection with Mr. Joseph Pacher, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any findings or violations of more than minor significance.

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/

Anthony Dimitriadis, Chief Reactor Projects Branch 5 Division of Reactor Projects

Docket Number: 50-333 License Number: DPR-59

Enclosure:

Inspection Report 05000333/2018004

Inspection Report

Docket Number:

50-333

License Number:

DPR-59

Report Number:

05000333/2018004

Enterprise Identifier: I-2018-004-0067

Licensee:

Exelon Generation Company, LLC (Exelon)

Facility:

James A. FitzPatrick Nuclear Power Plant

Location:

Scriba, NY

Inspection Dates:

October 1, 2018 to December 31, 2018

Inspectors:

C. Highley, Acting Senior Resident Inspector

J. Schussler, Acting Senior Resident Inspector

G. Stock, Resident Inspector

J. Ambrosini, Senior Emergency Preparedness Inspector

P. Boguszewski, Project Engineer

S. Pindale, Senior Reactor Inspector

Approved By:

Anthony Dimitriadis, Chief

Reactor Projects Branch 5

Division of Reactor Projects

SUMMARY

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

FitzPatrick by conducting the baseline inspections described in this report 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. NRC-identified and self-revealing findings, violations, and additional items are summarized in the table below.

No findings or more-than-minor violations were identified.

Additional Tracking Items

Type Issue number Title Inspection Results Section Status LER 05000333/2017-004-00 Safety Relief Valves Out of Tolerance 71153 Discussed

LER 05000333/2017-004-01 Safety Relief Valve Lift Out of Tolerance 71153 Discussed

PLANT STATUS

FitzPatrick began the inspection period shutdown for planned refueling outage 23. Upon completion of refueling outage 23, operators performed a reactor startup and the generator was placed on the grid on October 7, 2018. On October 9, after raising power to approximately 80 percent, the B recirculation pump tripped during testing. This resulted in a decrease in power to 53 percent. Following repairs, power ascension commenced and 100 percent was achieved on October 12. On October 27, operators reduced power to approximately 60 percent for a post-outage control rod pattern adjustment. Operators then raised power to 100 percent on October 28. FitzPatrick remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed 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 Exelons performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 12, 2018.

External Flooding (1 Sample)

The inspectors evaluated readiness to cope with external flooding on October 19, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (2 Samples)

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

(1) Reactor core isolation cooling system on October 12, 2018
(2) B station battery on November 6, 2018

71111.05A/Q - Fire Protection Annual/Quarterly

Quarterly Inspection (2 Samples)

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

(1) A and C emergency diesel generator and switchgear rooms, fire area/zones V/EG-1, EG-2, and EG-5 on December 18, 2018
(2) B and D emergency diesel generator and switchgear rooms, fire area/zones VI/ EG-3, EG-4, and EG-6 on December 18, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated a simulator scenario including the removal of offsite line 1 from service; an unexpected closure of a turbine control valve; an unexpected opening of an automatic depressurization system safety relief valve (SRV); fuel failure and a failure of a steam line to isolate, requiring emergency depressurization; and event declaration on October 18, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operations personnel during startup activities following refueling outage 23 on October 6, 2018, as well as synchronizing the unit to the grid on October 7, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (4 Samples)

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

(1) Residual heat removal service water system October 29, 2018
(2) Reactor core isolation cooling system on November 20, 2018
(3) Standby liquid control system on December 10, 2018
(4) Emergency service water system on December 14, 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) Drain down, operations with the potential to drain the reactor vessel, outage risk window 4, on October 1, 2018
(2) A emergency service water inoperable and unavailable on October 31, 2018
(3) Transition from Mode 4 to Modes 2 and 1 with inoperable residual heat removal pump, in accordance with Technical Specification 3.0.4.b, on November 28, 2018
(4) B residual heat removal system inoperable and unavailable on December 11, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) B inboard main steam isolation valve, 29AOV-80B, main control board dual indication on October 18, 2018
(2) Sodium pentaborate identified on reactor vessel instrumentation valve body on November 29, 2018
(3) Water hammer induced damage to reactor coolant pressure boundary snubber on December 19, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change 17239 - Low pressure coolant injection inverter replacement on October 24, 2018
(2) Engineering Change 622608 - Remove temporary emergency core cooling system strainer clamshells and install permanent replacements on November 1, 2018
(3) Engineering Change 624477 - Tornado missile protection non-conformance contingency actions for relay room and control room air conditioning system on December 7, 2018

71111.19 - Post Maintenance Testing

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

(1) A residual heat removal service water loop quarterly operability test following pump fastener replacement on October 4, 2018
(2) SRV electric lift logic system functional and simulated automatic actuation test following planned valve replacement on October 24, 2018
(3) Reactor containment isolation cooling 150 pound operability test after containment closure on October 30, 2018
(4) A emergency service water pump following planned packing replacement on November 1, 2018

71111.20 - Refueling and Other Outage Activities

The inspectors evaluated planned refueling outage 23 activities from October 1, 2018 to October 12, 2018.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine

(1) ST-39H, Reactor pressure vessel system leakage test, on October 3, 2018
(2) ST-6M, Standby liquid control recirculation injection test, on October 25, 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 did not require NRC approval.

OTHER ACTIVITIES - BASELINE

71152 - Problem Identification and Resolution

Semiannual Trend Review (1 Sample)

The inspectors reviewed Exelons corrective action program for trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues (2 Samples)

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

(1) SRV As-Found Testing Failures (IRs 4077124 and 4082823)
(2) Failure of Condensate Storage Tank Level Switches for Reactor Core Isolation Cooling Suction Realignment (IR 04164618)

71153 - Follow-up of Events and Notices of Enforcement Discretion Events

The inspectors evaluated response to the following event:

(1) Degraded instrument air header pressure caused by a trip of service air compressor 39AC-2A led to reactor building ventilation isolation. Consequently with reactor building ventilation isolated, secondary containment differential pressure exceeded the technical specification requirement of greater than or equal to 0.25 inches of vacuum water gauge.

The condition existed for 3 minutes on December 5, 2018, and is documented in event notification report EN 53778.

Licensee Event Reports (1 Sample)

The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) LER 05000333/2017-004-00, Safety Relief Valves Out of Tolerance (ADAMS Accession No. ML18089A040). The circumstances surrounding this LER were discussed and are documented in report section Inspection Results. This LER remains Open.
(2) LER 05000333/2017-004-01, Safety Relief Valve Lift Out of Tolerance (ADAMS Accession No. ML18022A031). The circumstances surrounding this LER were discussed and are documented in report section Inspection Results. This LER remains Open.

INSPECTION RESULTS

Observations 71152 Annual Follow-up of Selected issues Safety Relief Valve As-Found Testing Failures

The inspectors performed a review of Exelon's evaluation and corrective actions associated with FitzPatrick main steam SRV setpoint drift issues. Over the past several operating cycles, SRV testing has resulted in some SRVs exceeding the technical specification allowable as-found lift setpoint acceptance criterion of 1145 psig +/- 3 percent. The setpoint drift has been attributed to corrosion bonding, which involves bridging oxide buildup between the pilot disc surface and pilot valve body disc seating surface. This phenomenon typically affects the initial SRV actuation.

The inspectors evaluated Exelons prioritization and timeliness of corrective actions to determine whether they were appropriately identifying, characterizing, and correcting problems associated with this issue, and whether the planned or completed corrective actions were commensurate with the safety significance of the issue. The inspectors determined Exelon staff implemented corrective actions intended to improve SRV performance which included installation of Stellite 21 discs in all 11 SRV pilot assemblies and installation of an SRV electric lift system (additional, redundant pressure actuation switches modification).

Additionally, Exelon staff began to replace the 2-stage SRVs with 3-stage Target Rock SRVs, which were designed to address the corrosion bonding issue. Three SRVs were installed in 2010 of the 3-stage design. However, operating experience at another plant indicated an unrelated problem with the 3-stage SRV design (ADAMS Accession No. ML15134A017).

Subsequently, the SRV vendor re-designed the 3-stage SRV to eliminate the problem. In the interim, Exelon staff removed two of their three 3-stage SRVs from service and replaced them with 2-stage SRVs.

Relative to the 10 of 11 SRVs that did not meet test acceptance criterion for the SRVs removed during the Fall 2017 refueling outage, Exelon staff determined that the safety significance was minimal due to the availability of the electric lift system. Nine of the 10 SRV test failures were 2-stage valves, and one was the remaining 3-stage valve. The nine 2-stage SRVs that failed were out of specification high, and the 3-stage SRV was out of specification low. Exelon staff attributed the nine 2-stage SRV test failures to corrosion bonding. The 3-stage SRV test failure was attributed to calibrating the pilot within the lower half of the acceptance range, for which Exelon subsequently implemented a new work practice to conduct additional spring testing during SRV refurbishment to reduce the likelihood of setpoint drift.

During the most recent refueling outage at FitzPatrick (Fall 2018), Exelon staff removed all 11 2-stage SRVs and sent them to an offsite testing facility. Those tests have not yet been completed. Exelon staff further replaced all SRVs with newly modified 3-stage design.

The inspectors concluded Exelon staff implemented corrective actions consistent with industry and vendor initiatives to minimize the corrosion bonding issues. In addition, Exelon staff replaced all SRVs with the 3-stage modified design in September 2018 after an unrelated problem was addressed by the vendor. These corrective actions implemented industry and vendor recommendations and were commensurate with the safety significance of the issue.

Additional discussion on this issue is documented in Inspection Results, Section 71153, in this report.

Observations 71152 Annual Follow-up of Selected issues Failure of Condensate Storage Tank Level Switches for Reactor Core Isolation Cooling Suction Realignment

The inspectors performed an in-depth review of Exelons analysis and corrective actions associated with multiple failures of the condensate storage tank level switches for reactor core isolation cooling suction realignment. The inspectors reviewed condition reports, engineering evaluations, and causal evaluations; and held discussions with plant personnel. The inspectors assessed Exelons problem identification threshold, cause analysis, and the prioritization and timeliness of the corrective actions.

The reactor core isolation cooling system is normally aligned to take suction from the condensate storage tank. When the condensate storage tank experiences a low water level condition, level switches actuate resulting in a suction realignment to the Torus. There are four of these switches, two per division, 13LS-76A, 13LS-77A, 13LS-76B, and 13LS-77B. For suction realignment, one switch from both divisions must actuate. Technical Specification 3.3.5.3 requires all four switches be operable. If a switch is found to be inoperable, the channel must be put in trip, reactor core isolation cooling must be realigned to the Torus within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or reactor core isolation cooling must be declared inoperable. On February 27, 2018, 13LS-76B failed its routine surveillance but was able to be recalibrated.

This issue was documented in IR 04109193. As a result of this failure, the surveillance frequency was increased from 90 to 45 days. The inspectors determined this was an appropriate response to the failure.

Both 13LS-76A and 13LS-76B performed successfully during the following two surveillances.

On August 15, 2018, during the third performance of the surveillance, both 13LS-76A and 13LS-76B failed, and only 13LS-76A was able to be reset. 13LS-76B was found to have a broken internal component, called the shunt, which made it unable to be calibrated. Exelons apparent cause evaluation on the issue, and discussions with the manufacturer, found that the shunt was undersized. The shunt for 13LS-76B was replaced with the appropriate component and was successfully post-maintenance tested. This issue was documented in IR 04164618.

It was also recognized at this time that both 13LS-76A and 13LS-77B were potentially susceptible to the same failure mode. Exelons operability determination found there was confidence that the function was maintained based on surveillance history and that, after the repair, one switch from both divisions was not susceptible to the broken shunt failure mode, specifically 13LS-76B and 13LS-77A. Also, work orders were generated to open and inspect 13LS-76A and 13LS-77B in future work weeks to verify the undersized shunt was not present.

The inspectors inquired about the justification for continued operations with the potentially degraded switches. Exelons response included pursuit of switch replacement; ensuring that the installed switches either passed previous surveillances or post-maintenance tests; and verification that the remaining susceptible switches were not in the same division, therefore, the safety function was maintained. The inspectors determined these actions were reasonable.

On November 8, 2018, both 13LS-76A and 13LS-76B failed the surveillance again. These failures were documented in IR 04193121 and 04193124. Given the history of these switches, Exelon swapped reactor core isolation cooling suction to the Torus and expedited the complete switch replacement of 13LS-76B. Once 13LS-76B was replaced, suction was returned to the condensate storage tank, however, the A division was left in the trip state due to the suspect condition of 13LS-76A. 13LS-76A has since been replaced, on January 2, 2019, and the A division was brought out of trip to the normal lineup. Following the 13LS-76B replacement after the November 8, 2018, failure, the removed switch was sent to Exelon PowerLabs for analysis. The analysis was inconclusive because the identified condition could not be repeated. Long term corrective actions include a design change to utilize a more robust style level switch.

The inspectors concluded that the issues had been appropriately identified in the corrective action program and that corrective actions were timely, based on information available at the time of each failure. The above items were evaluated using NRC IMC 0612, Appendix B, Issue Screening, and NRC IMC 0612, Appendix E, Examples of Minor Issues, and determined to be of minor significance because the safety function was always maintained.

Observations 71152 Semi-Annual Trend Review The inspectors evaluated a sample of condition reports generated over the course of the second and third 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 significance safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Exelon staff for potential trends at a low threshold, and resolved within the scope of the corrective action program. The inspectors noted minor adverse trends identified by Exelon staff in the area of vendor quality parts, foreign material exclusion, source range monitors, and boron related issue reports.

There were no 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 had properly identified adverse trends at FitzPatrick 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 that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

LER (Discussed/

Open)

LER 05000333/2017-004-00, Safety Relief Valves Out of Tolerance and Supplemental LER 05000333/2017-004-01, Safety Relief Valve Lift Out of Tolerance 71153 Follow-up of Events and Notices of Enforcement Discretion

Description:

On November 21, 2017, Exelon staff received results that the as-found setpoint tests for the main steam SRV pilot stage assemblies had exceeded the lift setting tolerance prescribed in technical specifications. Specifically, 10 of the 11 pilot stage assemblies tested experienced drift beyond the +/- 3 percent tolerance permitted by Technical Specification 3.4.3. Exelon staff concluded that the cause of the setpoint drift was attributed to corrosion bonding between the pilot disc and seating surfaces for 9 of the 10 test failures (these were 2-stage SRVs which all failed high); and calibrating the pilot within the lower half of the acceptance range was the cause for the other test failure (which was a 3-stage SRV that failed low). This condition was reportable under 10 CFR 50.73(a)(2)(i)(B) and (a)(2)(v)(D)as any operation or condition which was prohibited by the plants technical specifications, and any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident, respectively.

The SRV corrosion bonding issue has been reported to the NRC by a number of plant operators. Currently, NRC staff in the Office of Nuclear Reactor Regulation are meeting with the Boiling Water Reactor Owners Group and other stakeholders to gain a better understanding of the industry initiatives to address this issue (reference ADAMS Accession No. ML18267A016). It is expected that further guidance on dispositioning these issues will be provided to regional inspectors in the near term.

While the inspectors did not identify a performance deficiency associated with Exelons corrective actions, this LER, including characterization of this issue, will remain open pending the completion of NRC interaction with the industry and subsequent guidance on the dispositioning of these issues.

Corrective Action References: IRs 4077124 and 4082823

LER 05000333/2017-004-00 and Supplemental LER 05000333/2017-004-01 are Open.

EXIT MEETINGS AND DEBRIEFS

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

On November 28, 2018, the inspector presented the Problem Identification and Resolution inspection results for Safety Relief Valves As-Found Testing Failures, to Mr. Keith Schoales, Senior Staff Engineer, and other members of the Exelon staff.

On January 22, 2019, the inspectors presented the quarterly resident inspection results to Mr. Joseph Pacher, Site Vice President, and other members of the Exelon staff.

DOCUMENTS REVIEWED

71111.01

Procedures

AOP-13, Severe Weather, Revision 33

AOP-13, Severe Weather, Revision 34

WC-AA-107, Seasonal Readiness, Revision 21

Work Order 04724778

Miscellaneous

UFSAR

71111.04

Procedures

AOP-46, Loss of DC Power System B, Revision 16

FM-22A, Flow Diagram Reactor Core Isolation Cooling, Revision 57

OP-43A, 125 VDC Power System, Revision 30

71111.05

Procedures

PFP-PWR31, Emergency Diesel Generator Spaces-South / Elevation 272-foot Fire Area/Zone

V/EG-1, EG-2, EG-5, Revision 4

PFP-PWR32, Emergency Diesel Generator Spaces-North / Elevation 272-foot Fire Area/Zone

VI/EG-3, EG-4, EG-6, Revision 5

71111.11

Procedure

OP-65, Start-up and Shutdown Procedure, Revision 124A

71111.12

Procedures

Design Equivalent Change Packet 625754, Justification for Alternate Screws for RHRSW

Pumps 10P-1A and 10P-1C, Revision 0

ER-AA-310-1003, Maintenance Rule Performance Criteria Selection, Revision 5

JAF-RPT-MULTI-02294, Maintenance Rule Basis Document for Service Water Systems,

Revision 12

Vendor Manual A180-0052, Installation and Maintenance Instructions for Vertical Turbine

Pumps, Revision 2

Issue Reports

03992524

03992574

03997323

04003347

04005476

04026429

04034868

04047111

04084185

04109193

04133925

04117191

04118802

04118803

04122120

04122622

04122627

04122774

04122776

04122777

04123048

04134050

04154237

04160342

04160344

04160345

04160346

04163480

04164618

04164660

04173069

04173442

04175529

04175532

04175533

04175762

04178640

04180688

04188092

04190096

04194525

Drawing 2.28-5, Sectional Allis Chalmers (RHRSW Drawing), Revision 2

Engineering Change Package

25811, Residual Heat Removal Service Water Cap Screw Corrosion, Revision 0

Miscellaneous

Maintenance Rule (a)(1) Action Plan System 10 RHRSW B Train, Revision 4

Maintenance Rule Basis Document, Reactor Core Isolation Cooling, dated November 12, 2018

Maintenance Rule Basis Document, Standby Liquid Control, dated December 10, 2018

Maintenance Rule Performance Criteria Selection Template Used for Maintenance Rule

ID 11-1 Revision, Dated March 5, 2018

Maintenance Rule Systems Basis Document, Emergency Service Water, dated

December 12, 2018

71111.13

Procedures

ER-AA-600-1042, On-Line Risk Management, Revision 11

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

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

Issue Reports

04179738

04198300

Engineering Change 239, Low Pressure Coolant Injection Inverter Replacement, Revision 1

Miscellaneous

Risk Management Document No. JF-Mode-001, Transition from Mode 4 to Modes 2 and 1 with

Inoperable RHR Pump, Revision 0

71111.15

Procedures

ER-AA-335-016, VT-3 Visual Examination of Component Supports, Attachments and Interiors of

Reactor Vessels, Revision 11

MA-AA-716-004, Conduct of Troubleshooting, Revision 015

Work Order 24885

Issue Reports

03992605

04029823

04172631

04172786

04173609

04173773

04175339

04182254

Drawings

FM-24A, Flow Diagram Reactor Water Cleanup System 12, Revision 12

FP-1B, Reactor Water Cleanup Piping, Revision 38

MSK-101A1, Reactor Water Cleanup Piping Pump Suction, Revision 15

Engineering Change Package

25791, Reactor Water Cleanup Snubber Past Operability, Revision 1

Miscellaneous

JAF-SPEC-MISC-00334, James

A. FitzPatrick Nuclear Power Plant Piping Specification,

Revision 14

Operability Evaluation 18-005

Troubleshooting Plan for AR 04175339, Attachment 1 of MA-AA-716-004, Revision 15

Troubleshooting Plan for Valve 02-3NBI-26 and 32, Attachments 2 and 3 of MA-AA-716-004,

Revision 15

71111.18

Procedure

AOP-13, Severe Weather, Revision 34

Issue Reports

03992524

04144501

04144602

Condition Report

CR-2017-00812

Work Orders

466553

466554

Engineering Changes 239, Low Pressure Coolant Injection Inverter Replacement, Revision 1

69507, Residual Heat Removal Strainer Temporary Modification, Revision 0

20371, Tornado Missile Assessment for FitzPatrick, Revision 0

2608, Tornado Missile Protection Non-Conformance Relay Room and Control Room AC

System, Revision 0

24475, Reinforced Concrete Wall Barrier Non-Conformance for Tornado Missile Protection,

Revision 1

24477, Tornado Missile Protection Non-Conformance Relay Room and Control Room AC

System, Revision 0

Drawings 6.60-85, Sure Flow Suction Strainer Module RHR1 Module Assembly and Design Information,

Revision A

6.60-103, Sure Flow Suction Strainer RHR and CS Modules Subassembly Sections and Details,

Revision A

Miscellaneous

DBD-010, FitzPatrick Nuclear Power Plant Design Basis Document for the Residual Heat

Removal System, Revision 13

71111.19

Procedures

ST-2XA, RHR Service Water Loop A Quarterly Operability Test, Revision 13

ST-8Q, Testing of the Emergency Service Water System (IST), Revision 51

ST-22A, Automatic Depressurization System Simulated Automatic Actuation Test, Revision 24

ST-22J, ST-22J, Safety Relief Valve Electric Lift Logic System Functional and Simulated

Automatic Actuation Test, Revision 7

ST-24J, RCIC Flow Rate and Inservice Test (IST), Revision 50

Issue Reports

04175529

04190317

71111.20

Procedures

OP-65, Startup and Shutdown Procedure, Revision 123

OP-AA-108-108, Unit Restart Review, Revision 20

71111.22

Procedures

ST-39H, RPV System Leakage Test, Revision 35

ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI) Revision 10

ST-6M, Standby Liquid Control Recirculation, Injection Test (IST, ISI) Revision 11

Issue Reports

04179739

04179951

Work Order 4646277

71114.04

Procedures

EP-AA-122-100, Drill and Exercise Planning and Scheduling, Revision 008

EP-AA-122-100-F-08, Pre-Exercise and NRC Exercise Checklist, Revision F

EP-AA-122-100-F-09, Off-Year Exercise Checklist, Revision D

EP-AA-122-100-F-10, Focus Area or Station Only Drill Checklist, Revision E

EP-AA-122-100-F-12, Hostile Action Based Exercise Checklist, Revision D

EP-AA-122-100-F-13, Call in Drill (CID) Checklist, Revision F

EP-AA-122-100-F-14, Drive in Drill (DID) Checklist, Revision F

EP-AA-122-300-F-01, Drill and Exercise Evaluation Criteria, Revision J

EP-AA-122-300-F-02, Drill and Exercise Objective Evaluation Summary, Revision F

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 18-02, EP-AA-111/EP-CE-111, Emergency Classification and Protective Action

Recommendations, Revision 21-04

Evaluation 18-09, Drill and Exercise Procedure Changes

Evaluation 18-19, URI Procedures and Supporting Forms

Evaluation 18-75, TQ-AA-113, ERO Training and Qualification, Revision 34

71152

Procedures

AP-19.01, Surveillance Testing Program, Revision 22

ER-AA-2003, System Performance Monitoring and Analysis, Revision 14

ISP-75.1, RCIC CST Low Water Level Switch Functional Test/Calibration, Revision 24

PI-AA-101-1001, Performance Monitoring and Analysis Manual, Revision 1

PI-AA-101, Conduct of Performance Improvement, Revision 1

PI-AA-120, Issue Identification and Screening Process, Revision 8

PI-AA-125, Corrective Action Program Procedure, Revision 6

WC-AA-120, Preventative Maintenance Modification Request, Revision 001

Issue Reports

04164660

04164618

04174397

04176327

04182832

04109193

04165105

04165110

04193121

04193124

202844

Drawing

791E464, Elementary Diagram RCIC System, Revision 9

Miscellaneous

DBD-013, Reactor Core Isolation Cooling System, Revision 6

Jaguar Instruments Vendor Manual, Level Ac SL-100, SL-300, SL-400, & SL-500 Series

Switches

Robert Shaw Vendor Manual, External Float Chamber Level Switch SL-300, SL-700