ML22153A261
| ML22153A261 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/02/2022 |
| From: | Mel Gray Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Gray M | |
| References | |
| IR 2022010 | |
| Download: ML22153A261 (17) | |
See also: IR 05000333/2022010
Text
June 2, 2022
Mr. David P. Rhoades
Senior Vice President
Constellation Energy Generation
President and Chief Nuclear Officer (CNO)
Constellation Energy
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - DESIGN BASIS
ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT
Dear Mr. Rhoades:
On May 20, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
James A. FitzPatrick Nuclear Power Plant. On May 19, 2022, the NRC inspectors discussed
the results of this inspection with Mr. Timothy Peter, Site Vice President, and other members of
your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at
James A. FitzPatrick Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC
Resident Inspector at James A. FitzPatrick Nuclear Power Plant.
D. Rhoades
2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Mel Gray, Chief
Engineering Branch 1
Division of Operating Reactor Safety
Docket No. 05000333
License No. DPR-59
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Melvin K.
Gray
Digitally signed by Melvin
K. Gray
Date: 2022.06.02
14:22:32 -04'00'
x
SUNSI Review
x
Non-Sensitive
Sensitive
x
Publicly Available
Non-Publicly Available
OFFICE RI/DORS
RI/DORS
RI/DORS
RI/DORS
NAME
JSchoppy
DWerkheiser
ECarfang
MGray
DATE
6/2/22
6/2/22
6/2/22
6/2/22
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000333
License Number:
Report Number:
Enterprise Identifier: I-2022-010-0045
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Scriba, NY
Inspection Dates:
May 2, 2022 to May 20, 2022
Inspectors:
C. Bickett, Senior Reactor Inspector
J. Brand, Reactor Inspector
P. Cataldo, Senior Reactor Inspector
E. Dipaolo, Senior Reactor Inspector
E. Eve, Senior Reactor Inspector
J. Schoppy, Senior Reactor Inspector
Approved By:
Mel Gray, Chief
Engineering Branch 1
Division of Operating Reactor Safety
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting a design basis assurance inspection (teams) inspection at James A.
FitzPatrick Nuclear Power Plant, in accordance with the Reactor Oversight Process. The
Reactor Oversight Process is the NRCs program for overseeing the safe operation of
commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Test Control for Modified Performance Discharge Testing of 'B' Station Battery
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.8] -
Procedure
Adherence
The team identified a Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B,
Criterion XI, Test Control, because Constellation personnel did not perform battery testing in
accordance with written test procedures. Specifically, the test deficiencies included: 1) the
initial battery terminal voltage did not meet the test prerequisite; 2) technicians did not ensure
that an adequate and reliable power supply was available for test equipment as required in
the test prerequisites which resulted in a pause in testing; 3) the duration of the pause in
testing was inappropriately included in the total duration of the battery discharge; and 4)
records of individual cell voltages and battery terminal voltages required to be read and
recorded at various stages of the test were not included in the official test record.
Additional Tracking Items
None.
3
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 reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21M - Design Bases Assurance Inspection (Teams)
The inspectors evaluated the following components and listed applicable attributes, permanent
modifications, and operating experience:
Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02)
(4 Samples)
The team evaluated the following components, permanent modifications, and operating
experience during the weeks of May 2 and May 16, 2022.
For the components, the team reviewed the attributes listed in IP 71111.21M, Appendix A,
Component Review Attributes, such as those listed below. Specifically, the team evaluated
these attributes as per IP 71111.21M, Appendix B, Component Design Review
Considerations and 71111.21M, Appendix C, Component Walkdown
Considerations. Specific documents reviewed are listed in the Documents Reviewed
section.
(1)
Loss of AC Bus 10500 Initiating Event
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
Maintenance records and corrective action history
Adequacy of design (calculations and modifications)
Surveillance testing and test results
System and component level performance monitoring
Equipment protection from fire, flood, water intrusion, or spray
Heat removal, cooling water and ventilation
Control logic
Component adequacy for minimum voltage
Protection coordination (load in-rush and full load current)
Range, accuracy, and setpoint of installed instrumentation
Operator actions
Process medium availability (water, air, electrical signal)
Energy source availability (electricity, steam, fuel, air)
4
The team used Appendix B guidance for Instrumentation, Circuit Breakers and Fuses,
Cables, Electrical Loads, and Motor Control Centers (MCCs).
(2)
High Pressure Coolant Injection System (Failure to Run)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance records, and corrective action history
Surveillance testing and test results
System and component level performance monitoring
Control logic
Operator actions
Process medium availability (water, air, electrical signal)
Energy source availability (electricity, steam, fuel, air)
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-
Built System.
(3)
Containment Venting (Loss of Function)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance records, and corrective action history
Equipment/environmental controls and qualification
Adequacy of design (calculations and modifications)
Surveillance testing and test results
System and component level performance monitoring
Equipment protection from fire, flood, steam, water intrusion, or spray
Heat removal, cooling water and ventilation
Control logic
Range, accuracy, and setpoint of installed instrumentation
Operator actions
Process medium availability (water, air, electrical signal)
Energy source availability (electricity, steam, fuel, air)
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-
Built System.
(4)
B 125 Vdc Battery (SB-2) and Battery B Control Board (BCB-2B)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
Maintenance records and corrective action history
Equipment/environmental controls and qualification
Adequacy of design (calculations and modifications)
5
Surveillance testing and test results
System and component level performance monitoring
Equipment protection from fire, flood, steam, water intrusion, or spray
Ventilation for temperature control and hydrogen removal
Circuit breaker and fuse ratings
Component adequacy for minimum voltage
Protection coordination (load in-rush, full load current, and short-circuit protection)
Range, accuracy, and setpoint of installed instrumentation
Operator actions
Energy source availability (charger availability, capability, and reliability)
The team used Appendix B guidance for Instrumentation, Circuit Breakers and Fuses,
Cables, Electric Loads, and Motor Control Centers (MCCs).
Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02) (1 Sample)
(1)
B Loop Suppression Pool Cooling and Containment Spray (Loss of Function)
Material condition and installed configuration (e.g., visual inspection/walkdown)
Normal, abnormal, and emergency operating procedures
Consistency among design and licensing bases and other documents/procedures
System health report, maintenance records, and corrective action history
Equipment/environmental controls and qualification
Adequacy of design (calculations and modifications)
Surveillance testing and test results
System and component level performance monitoring
Equipment protection from fire, flood, steam, water intrusion, or spray
Heat removal, cooling water and ventilation
Control logic
Range, accuracy, and setpoint of installed instrumentation
Operator actions
Process medium availability (water, air, electrical signal)
Energy source availability (electricity, steam, fuel, air)
The team used Appendix B guidance for Valves, Pumps, Instrumentation, and As-
Built System.
Modification Review - Permanent Mods (IP Section 02.03) (5 Samples)
(1)
EC 626665, Replace 10MOV-26B Double Lead Screw Form Stem with Single Lead
Screw Form Stem
(2)
EC 627111, Torus Wide Range Pressure Transmitter 27PT-101A Replacement
(3)
EC 628065, 72MOD-101B(OP) Replacement with New Model Operator
(4)
EC 629418, Evaluate Use of 3 Basket Hold Down Bolts in ESW Strainer
(5)
EC 632618, Evaluate Replacement of 23HPI-149 from Vogt Ball Check to a Velan
Piston Check
6
Review of Operating Experience Issues (IP Section 02.06) (2 Samples)
(1)
NRC Information Notice 2019-01: Inadequate Evaluation of Temporary Alterations
(2)
NRC Information Notice 2020-02: FLEX Diesel Generator Operational Challenges;
Operating Experience Smart Sample (OpESS) 2020/01 was used to inform the
inspection sample
INSPECTION RESULTS
Inadequate Test Control for Modified Performance Discharge Testing of 'B' Station Battery
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
Open/Closed
[H.8] -
Procedure
Adherence
The team identified a Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B,
Criterion XI, Test Control, because Constellation personnel did not perform battery testing in
accordance with written test procedures. Specifically, the test deficiencies included: 1) the
initial battery terminal voltage did not meet the test prerequisite; 2) technicians did not ensure
that an adequate and reliable power supply was available for test equipment as required in
the test prerequisites which resulted in a pause in testing; 3) the duration of the pause in
testing was inappropriately included in the total duration of the battery discharge; and 4)
records of individual cell voltages and battery terminal voltages required to be read and
recorded at various stages of the test were not included in the official test record.
Description: Constellation completed a battery modified performance discharge test on the
B 125V DC station service battery (71SB-2) on September 18, 2020, to satisfy Technical
Specification (TS) Surveillance Requirement (SR) 3.8.4.3, to verify adequate battery capacity
to support emergency loads, and TS SR 3.8.4.4, to verify battery capacity was > 80 percent
of the manufacturers rating. Per the TS SR 3.8.4.4 Bases, the acceptance criteria for battery
testing are consistent with Institute of Electrical and Electronics Engineers Standard 450,
IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-
Acid Batteries for Stationary Applications, 1995 (IEEE 450).
The team reviewed the documentation for the battery modified performance discharge test
performed in accordance with Constellation procedure MST-071.24, Station Battery B
Modified Performance Test, Revision 19. The team identified several instances where the
test procedure was not followed and/or the problem was not entered into the corrective action
program.
First, the battery terminal voltage before starting the test did not meet the test prerequisite.
MST-071.24, Prerequisite Step 8.13 required that the battery be on a float charge with battery
terminal voltage between 131 - 133V DC. Actual voltage was 136V DC due to the battery
being charged by the swing charger and technicians believed the swing charger voltage could
not be adjusted to the required range. This was discussed with the on-shift senior reactor
operator and the decision made to continue with the test. The actual voltage of 136V DC was
within the equalizing charge range. IEEE 450 specifies that the battery be on a float charge
for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following being on an equalizing charge prior to starting the
discharge test.
7
Second, technicians did not ensure that adequate and reliable power was available for test
equipment as stated in the test prerequisites. MST-071.24, Prerequisite Step 8.11 required
technicians to Ensure an AC outlet (nominal 120 VAC, 20 Amp) is available for test
equipment and other outlets on circuit are not used during test except to power test
equipment. Tag other outlets as necessary. The purpose of this step was to ensure a reliable
control power source to the battery test equipment during the performance of the test.
Constellation personnel did not adequately perform this step. As a result, at approximately 16
minutes into the test, the power supply was lost to the test equipment. This resulted in an
11.53 minute pause in testing. IEEE 450 only provides for one short duration pause in testing
(10 percent of the test duration or 6 minutes, whichever is shorter) for the specific purpose of
disconnecting a battery cell that is approaching reversal of polarity early in the test. Test data
showed that battery terminal voltage was higher when the load was reapplied than prior to the
pause in testing. This demonstrated that the battery recovered during the pause and that the
battery test would indicate a higher battery capacity than if no pause occurred. The team
noted that technicians did not initiate a corrective action issue report (IR) for this problem
encountered during the testing.
Third, the 11.53 minute duration of the pause in testing was inappropriately included in the
total duration of the battery discharge. This resulted in a higher and non-conservative
calculated battery capacity versus actual capacity.
Fourth, records of individual cell voltages and battery terminal voltages required to be read
and recorded at the beginning of the test, at specified intervals, and at the completion of the
test per the guidance contained in IEEE 450 were not included in the official test record.
Specifically, personnel did not comply with Step 10.7 which stated to Obtain a printout of the
individual cell voltages from the Alber BCT 2000 test equipment and include in work
package.
Corrective Actions: Constellations short-term corrective actions included performing a
technical evaluation (EC 636754) to assess battery operability and capacity of the B 125V
DC station service battery and entering the issues into their corrective action program.
Factoring in the pause in the testing and other considerations, Constellation staff determined
that the worst-case battery capacity was 101.08 percent (as compared to the battery capacity
of 106.8 percent recorded following the test in September 2020). This demonstrated that the
battery had margin to the TS required > 80 percent capacity and that the battery did not show
signs of degradation (i.e., capacity was not greater than 10 percent lower than the previous
modified performance discharge test).
Corrective Action References: IRs 4497226, 4497328, 4497663, and 4497832.
Performance Assessment:
Performance Deficiency: The licensee failed to conduct modified performance discharge
testing on the B 125V DC station service battery (71SB-2) on September 18, 2020, in
accordance with written test procedures consistent with the recommendations and
acceptance criteria contained in IEEE 450. Specifically, the test was started with battery
terminal voltage in the equalize range, technicians did not ensure that an adequate and
reliable power supply was available for test equipment as required in the test prerequisites
which resulted in a pause in testing, the duration of the pause in testing was inappropriately
included in the total duration of the battery discharge, and records of individual cell voltages
and battery terminal voltages were not included in the official test record.
8
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. Though the performance
deficiency occurred while the plant was shut down, the assessment of risk was best
represented by using Appendix A, The Significance Determination Process (SDP) for
Findings At-Power, using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609,
Appendix A. The team determined that this finding was a deficiency affecting the design or
qualification of mitigating structures, systems, or components, where the structures, systems,
or components maintained their operability or functionality. Although not performed
consistent with the acceptance criteria of IEEE 450, the test did demonstrate with reasonable
confidence that there was sufficient margin to the TS required battery capacity of > 80
percent. Therefore, the team determined the finding to be of very low safety significance
(Green).
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures,
and work instructions. Specifically, Constellation personnel did not follow the modified
performance discharge test procedure when performing the test on the B 125V DC station
service battery on September 18, 2020.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test
program shall be established to assure that all testing required to demonstrate that structures,
systems, and components will perform satisfactorily in service is identified and performed in
accordance with written test procedures which incorporate the requirements and acceptance
limits contained in applicable design documents. Constellation was committed to perform
battery modified performance discharge testing consistent with the recommendations and
acceptance criteria of IEEE 450 and required to perform battery modified performance
discharge testing of the B 125V DC station service battery in accordance with MST-071.24,
Station Battery B Modified Performance Test, Revision 19.
Contrary to the above, on September 18, 2020, Constellation personnel did not perform
battery modified performance discharge testing on the B 125V DC station service battery
(71SB-2) in accordance with written test procedures consistent with the recommendations
and acceptance criteria contained in IEEE 450. Specifically, the test deficiencies included: 1)
the initial battery terminal voltage did not meet the test prerequisite (required range 131-133V
DC versus actual 136V DC and was in the equalizing charge range which was not consistent
with IEEE 450); 2) technicians did not ensure that adequate and reliable power was available
for test equipment as stated in the test prerequisites (the loss of power to test equipment
during the test resulted in an 11.53-minute test interruption which was not consistent with
IEEE 450); 3) including the 11.53 minute duration of the pause in testing from the total
duration of the battery discharge resulted in a higher and non-conservative calculated battery
capacity versus actual capacity; and 4) records of individual cell voltages and battery terminal
voltages required to be read and recorded at the beginning of the test, at specified intervals,
and at the completion of the test per IEEE 450 guidance were not included in the official test
record. Because this violation was of very low safety significance (Green) and has been
entered into Constellations corrective action program, the NRC is treating this violation as a
Non-Cited Violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy.
(NCV 05000333/20220010-01, Inadequate Test Control for Modified Performance Discharge
Testing of B Station Battery)
9
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 19, 2022, the inspectors presented the design basis assurance inspection
(teams) inspection results to Mr. Timothy Peter, Site Vice President, and other members
of the licensee staff.
10
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21M Calculations
JAF-CALC-15-
00031
FLEX Strategy - Portable Generator System Sizing
Revision 0
JAF-CALC-CAD-
04481
Design Basis Calculations for the Torus Inner and Outer
Exhaust AOVs 27AOV-117 & 27AOV-118 at FitzPatrick NPP
Revision 0
JAF-CALC-
ELEC-02016
125V DC System Short-Circuit Calculation and Coordination
Evaluation
Revision 1
JAF-CALC-
ELEC-02551
Determination of Float and Equalize Voltage for Station
Batteries 71SB-1 & 71SB2
Revision 1
JAF-CALC-SWS-
04170
Local Wall Thinning Evaluation for ESW Strainers 46STR-
5A/B
Revision 2C
Corrective Action
Documents
04036374
04176609
04221269
04246355
04252619
04252625
04266619
04290349
04319445
04323766
04335008
04339876
04347868
04348143
04369686
04371604
04371715
04372411
04372680
04373277
04374549
04377286
11
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04381156
04384096
04384807
04385340
04389930
04394054
04401931
04407061
04425606
04425805
04428931
04455782
04467798
04483344
04483639
04483997
04496433
04496616
04497610
CR-JAF-2007-
03363
Corrective Action
Documents
Resulting from
Inspection
04497169
04497226
04497328
04497349
04497394
04497395
04497409
04497663
04497664
04497672
04497680
04497832
04497910
12
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04497962
04497964
04497965
04497967
04497969
04497970
04497997
04498019
04498006
04498022
04498129
04498210
04499080
04500102
04500121
04500293
04500320
04500330
04500418
04500553
04500554
04500555
04500563
04500635
04500821
Drawings
FE-1H Sh. 4
4160V One Line Diagram Emergency Bus 10500
Revision 14
Residual Heat Removal System Flow Diagram
Revision 73
High Pressure Coolant Injection Flow Diagram
Revision 75
Miscellaneous
Design Basis Document for the High Pressure Coolant
Injection System
Revision 12
E406-0001
200 KW FLEX Diesel Generator
Revision 1
G185-0029
Instruction Manuals for 60 Cells NCN-33 or NCN-35 (GNB
Industrial Power)
dated
9/11/11
JAF-SPEC-MISC-
James A. FitzPatrick Nuclear Power Plant Piping
Revision 15
13
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
00334
Specification
NRC Information
Notice 2017-06
Battery and Battery Charger Short-Circuit Current
Contributions to a Fault on the Direct Current Distribution
System
dated
9/26/17
Att. 1
Operator Response Time Validation Sheet
performed
11/12/20
P319-0047
Three-Phase Magnetic Amplifier Controlled CP Battery
Charger
Revision 8
Preliminary Report of Eddy Current Inspections
dated
11/20/13
SDLP-23
High Pressure Coolant Injection System
Revision 28
Outside Primary Containment Isolation Valve Exercise Test
(IST)
performed
3/16/22
RHR Loop B Containment Spray Headers and Nozzles Air
Test (ISI)
performed
9/23/12
RHR Loop B Quarterly Operability Test (IST)
performed
3/10/21 &
3/8/22
Procedures
Loss of 10500 Bus
Revision 18
Loss of 10600 Bus
Revision 18
CC-JF-118
Site Implementation of Diverse and Flexible Coping
Strategies (FLEX) and Spent Fuel Instrumentation Program
Revision 5
Post Accident Containment Venting and Gas Control
Revision 13
Residual Heat Removal System
Revision 100
High Pressure Coolant Injection
Revision 69
Work Orders
00205886
00340684
04655870
04806288
04806289
04915450
04938333
04938334
04938915
14
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04943427
04964506
05043091
05047158
05131958
05131959
05150464
05150801
82606584
82705256
82740044
99-01814-00