JAMES A. FITZPATRICK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT

by Bob Meyer

Three Severity Level IV violations were discovered during this inpsection.

One interesting finding actually stemmed from a 2010 refueling outage. On September 15, 2010, FitzPatrick personnel commenced reactor refueling operations. At the time, one of the four installed SRMs was inoperable (SRM ‘A’). During core alterations (movement of fuel or control rods within the reactor vessel), TS SR 3.3.1.2.2 requires that an operable SRM be located in the core quadrant where core alterations are being performed. The inspectors questioned how fuel movements were being controlled such that no movements would be performed in the core quadrant that contained SRM ‘A’. The control room operators responded that, in accordance with procedure OSP-66.001, “Management of Refueling Activities,” Revision 1, refueling operations could proceed in any core location with any single SRM out of service.

Entergy personnel had developed a definition of “core quadrant” with placement of the axes that was based on the SRM locations. This orientation results in quadrant axes that are rotated approximately 18 degrees clockwise from the arrangement that was described above. This results in quadrant boundaries that bisect individual fuel assemblies; Entergy personnel considered that such fuel assemblies could be considered to reside in either of the adjacent quadrants. Entergy personnel used this concept to establish two quadrant boundaries, one rotated clockwise by 16° and the other rotated clockwise by 20°, such that the SRM would partially reside in both quadrants using either boundary. This created a set of fuel assemblies along a quadrant boundary that could be considered to be a part of either of the adjacent quadrants. Entergy personnel determined that, by selecting the appropriate boundary in the case that a single SRM is inoperable, this quadrant arrangement supports the requirement of TS 3.3.1.2.2, while allowing movement of fuel anywhere in the core.

Summary of Plant Status

James A. FitzPatrick Nuclear Power Plant (FitzPatrick) began the inspection period at 100 percent power. On January 30, 2013, operators reduced power to 63 percent to conduct a control rod sequence exchange, perform control blade interference testing, and perform main turbine valve testing. Operators restored power to 100 percent later that day.

On February 1, 2013, operators reduced power to 50 percent to address main condenser tube leakage. Following identification and repair, operators restored power to 100 percent the following day. On February 3, 2013, operators reduced power to 85 percent to conduct a control rod pattern adjustment and restored power to 100 percent later that day.

On February 23, 2013, operators reduced power to 50 percent to address main condenser tube leakage. Following identification and repair, operators restored power to 100 percent the following day. On February 25, 2013, operators reduced power to 80 percent to conduct a control rod pattern adjustment and restored power to 100 percent later that day.

On March 2, 2013, operators commenced a shutdown for repair of tube leaks in the 6A feedwater heater. Following completion of repairs, operators commenced a reactor startup on March 7, 2013. Operators returned the unit to 100 percent power on March 9, 2013.

On March 18, 2013, operators reduced power to 50 percent to address main condenser tube leakage. Following identification and repair, operators restored power to 100 percent on March 21, 2013. On March 22, 2013, operators reduced power to 50 percent to address main condenser tube leakage. Following identification and repair, operators restored power to 100 percent on March 23, 2013.

On March 24, 2013, operators reduced power to 85 percent to conduct a control rod pattern adjustment and restored power to 100 percent later that day. The plant remained at or near 100 percent power for the remainder of the inspection period.

Severity Level IV. The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.73, “Licensee Event Report [LER] System,” because failure of an isolation valve in the high-pressure coolant injection (HPCI) system torus suction line to fully open on demand caused the automatic suction swap function to be inoperable, but this condition was not reported to the NRC as a condition that could have prevented fulfillment of a safety function per 10 CFR 50.73(a)(v) within 60 days of when it should reasonably have been discovered. Specifically, while this condition existed, an automatic suction swap from the condensate storage tanks (CSTs) to the torus would not have gone to completion, but rather would have stopped with both suction paths open. Depending on whether or not HPCI was running at the time, this would either result in air entrainment in the HPCI pump suction, causing a loss of HPCI, or an increase in suppression pool level due to drainage from the CSTs. However, this condition was not reported to the NRC as a condition that could have prevented fulfillment of a safety function per 10 CFR 50.73(a)(v) within 60 days of when it should reasonably have been discovered.

The inspectors determined that the failure to submit an LER within 60 days in accordance with 10 CFR 50.73 was a performance deficiency that was reasonably within Entergy’s ability to foresee and correct. Because the issue impacted the regulatory process, in that a safety system functional failure was not reported to the NRC within the required timeframe, thereby delaying the NRC’s opportunity to review the matter, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process.

Severity Level IV. The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.73, “Licensee Event Report [LER] System,” because a violation of technical specification (TS) 3.0.4 for a reactor mode change being made from Mode 4 to Mode 2 without satisfying the TS required conditions for alignment of the containment air dilution and standby gas treatment (SGT) systems in Mode 2 was not reported to the NRC within 60 days of when it should reasonably have been discovered. Specifically, in Modes 1, 2, and 3, TS surveillance requirement (SR) 3.6.1.3.1 allows the 20-inch and 24-inch primary containment vent and purge valves to be open for inerting, deinerting, pressure control, or other reasons provided that valve 27MOV-120 in the full flow line to the SGT system is closed. This is to ensure that there would be no damage to the SGT filters if a loss-of-coolant accident (LOCA) were to occur with the vent and purge valves open. However, on November 24, 2012, operators transitioned the reactor from Mode 4 to Mode 2 while the 20-inch and 24-inch containment vent and purge valves, and valve 27MOV-120, were open. This condition was not reported to the NRC within 60 days of when it should reasonably have been discovered.

Severity Level IV. The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, “Changes, Tests, and Experiments,” because Entergy personnel implemented a change to the technical specification (TS) definition of core quadrant without prior review and approval by the NRC staff in accordance with 10 CFR 50.59(c)(1)(i). Specifically, Entergy staff changed the definition of core quadrant in Revision 5 of Reactor Analyst procedure RAP-7.1.04C, “Neutron Instrumentation Monitoring During In-Core Fuel Handling,” which allowed operators to interpret what constitute core quadrant boundaries, such that core alterations could be performed anywhere in the core provided any three source range [neutron] monitors (SRMs) were operable.

The inspectors determined that Entergy staff’s implementation of a redefinition of core quadrant prior to its review and approval by the NRC staff as specified in 10 CFR 50.59(c)(1)(i) was a performance deficiency that was reasonably within Entergy staff’s ability to foresee and correct. Because this was a violation of 10 CFR 50.59, it was considered to be a violation that potentially impedes or impacts the regulatory process.

 

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