ML24018A001

Notification of Commercial Grade Dedication Inspection (05000333/2024010) and Request for Information

ML24018A001
Person / Time
Site:	FitzPatrick
Issue date:	01/18/2024
From:	Glenn Dentel NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 05000333
Download: ML24018A001 (1)

See also: IR 05000333/2024010

Text

January 18, 2024

David P. Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT- NOTIFICATION OF

COMMERCIAL GRADE DEDICATION INSPECTION (05000333/2024010) AND

REQUEST FOR INFORMATION

Dear David Rhoades:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff

will conduct the commercial grade dedication baseline inspection at James A. Fitzpatrick

Nuclear Power Plant (FitzPatrick), beginning on June 10, 2024. The inspection team will be

composed of three personnel from the NRC Region I office. The inspection will be conducted in

accordance with NRC Inspection Procedure 71111.21N.03, Commercial Grade Dedication,

dated June 28, 2022.

The inspection will evaluate the implementation of FitzPatricks process for dedicating

commercial-grade items, as required in applicable portions of Appendix B to Title 10 of the Code

of Federal Regulations (10 CFR) Part 50, Appendix B, to ensure reasonable assurance is

provided that these items will perform their intended safety function. Additionally, this inspection

will evaluate implementation of FitzPatricks procurement process for safety-related components

as required in Appendix B.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

• Onsite Information Gathering Visit: April 29 May 3, 2024

• Offsite Preparation Week: June 3 7, 2024

• Onsite Inspection Weeks: June 10 14, 2024, and June 24 28, 2024

The purpose of the onsite information gathering visit is to meet with staff expected to support

this inspection, and to become familiar with the process for dedicating commercial-grade items

and the process for procuring safety-related components at FitzPatrick. We are aware that

portions of the commercial grade dedication and safety-related procurement process may be

handled at locations other than your site, and we will coordinate the best dates, times, and

location(s) for the onsite information gathering visit with your staff. This visit may include a tour

D. Rhoades 2

of onsite commercial-grade item dedication facilities, receipt inspection facilities, storage

facilities, and installed plant components associated with potential inspection samples. The

team lead will also review your plans for onsite inspection logistics including resources that will

be provided to the team while onsite (e.g., conference rooms, network access, printers,

monitors, etc.) and how information requests will be tracked and processed.

To minimize the impact on your staff and to ensure a productive inspection, we have enclosed

two separate requests for information needed prior to the onsite information gathering visit and

offsite inspection preparation week. The first request (Enclosure 1) is generally for information

that will be used to choose the inspection samples or information that will be applicable to all

inspection samples throughout the inspection. This information should be made available to the

team lead before April 8, 2024. The team lead will use this information to support preparation for

the onsite information gathering visit and selection of a list of potential inspection samples. The

second request (Enclosure 2) is for information that is more specific to the selected inspection

samples and should be made available before May 27, 2024.

Additional information requests, interviews with your staff, and/or walkdowns of facilities or

installed plant components will be made by the team throughout the inspection to complete their

review of the selected inspection samples. It is important that all documentation provided to the

team is complete and up-to-date to minimize the number of additional documents requested

during the preparation and/or the onsite portions of the inspection. Additionally, to facilitate an

efficient inspection, we request that a contact individual be assigned to each inspector to ensure

information requests, questions, and concerns are addressed in a timely manner.

We understand that Chelsea Troutman from your Regulatory Assurance organization is our

contact for this inspection. If there are any questions about the inspection or the information

requested, please contact the team lead, Manan Patel, by telephone at 610-337-5304 or by

email at Manan.Patel@nrc.gov. Enclosure 3 contains additional contact information for the

inspection team.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001, or by email to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of

Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct nor sponsor, and a person is not required to respond to, a request

for information or an information collection requirement unless the requesting document

displays a currently valid OMB control number.

D. Rhoades 3

This letter, its enclosures, 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

Digitally signed by Glenn

Glenn T. T. Dentel

Date: 2024.01.18

Dentel 10:11:07 -05'00'

Glenn T. Dentel, Chief

Engineering Branch 2

Division of Operating Reactor Safety

Docket Nos. 05000333

License Nos. DPR-59

Enclosures:

1. Documents Requested Prior to Information

Gathering Visit

2. Documents Requested Prior to Inspection

Preparation Week

3. Inspection Team Contact Information

cc w/ encls: Distribution via LISTSERV

ML24018A001

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DORS RI/DORS

NAME MPatel GDentel

DATE 1/17/2024 1/17/2024

Enclosure 1: Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both onsite and offsite during the information gathering visit.

Electronic format is the preferred media. If electronic media is made available via an internet

based remote document management system, then the remote document access must allow

inspectors to download, save, and print the documents in the NRC's regional office. Electronic

media on compact disc or paper records (hard copy) are acceptable. At the end of the

inspection, the documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents requested by April 8, 2024 (Prior to the Information Gathering Visit):

1. Licensing basis documents such as the updated final safety analysis report and

technical specifications.

2. Procedures for dedicating commercial-grade items and for procurement of safety-

related components. This should include procedure for controlling counterfeit,

fraudulent, and suspect items and, if applicable, procedures that address

requirements associated with the parts quality initiative (PQI).

3. List of commercial-grade items, with a brief description of application, that have been

dedicated for safety-related applications. These items may be dedicated by James A.

Fitzpatrick Nuclear Power Plant, or dedicated by a vendor (or other licensee) and

procured by James A. Fitzpatrick Nuclear Power Plant. Please note whether the item

has been installed in the plant. The list should encompass the past six years of

dedication activities. The list should identify the systems/components where the

items were installed or were intended to be installed for use. It should also identify

whether the item has been installed.

4. List of components procured as safety-related, with descriptions, if not included

above. Please note whether the item has been installed in the plant. The list should

encompass the past six years of procurement activities. The list should identify the

systems/components where the items were installed or were intended to be installed

for use. It should also identify whether the item has been installed.

5. List of corrective action program documents, with descriptions, associated with

commercial-grade items, safety-related procurement, receipt, or storage. The list

should include any items that failed while in service after completing the dedication

or safety-related procurement process. It should encompass the past six years of

these activities and should identify the systems/components where the items were

installed. The list should also identify the vendor who supplied the associated item.

Enclosure 1

6. List components procured as safety-related or commercial-grade items intended to

be dedicated for safety-related applications that are on hold because of concerns

identified during receipt, dedication, or from operating experience/corrective action

program as applicable. The list should identify the systems/components where the

items were intended to be installed for use.

7. List of components procured as safety-related or commercial-grade items dedicated

for safety-related applications, in the past six years, where the

procurement/dedication process was expedited to support rapid turnaround (less

than seven days). If possible, the list should identify the systems in which these

items were intended for use.

8. List of systems, system numbers/designators, corresponding names, and risk-

ranking.

9. Copies of any self-assessments/audits of the safety-related procurement or the

commercial grade dedication and procurement processes that were completed within

the two-years prior to the start date of this inspection.

10. List of site contacts that will be associated with the inspection and a copy of

qualifications, as applicable, of personnel who performed commercial grade

dedication, safety-related component procurement, and/or receipt inspection/testing

activities within the past six years.

2

Enclosure 2: Documents Requested Prior to Inspection Preparation Week

For the samples selected by the team lead and provided to your point of contact following the

information gathering visit, the documents and information requested below should generally be

made available to the inspection team for the team's use both onsite and offsite during the

inspection. Electronic format is the preferred media. If electronic media is made available via an

internet based remote document management system, then the remote document access must

allow inspectors to download, save, and print the documents in the NRC's regional office. Paper

records (hard copy) are acceptable when necessary. At the end of the inspection, the

documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents requested by May 27, 2024 (Prior to Preparation Week):

1. Purchase requisition and purchase orders.

2. Other pertinent vendor/licensee correspondence.

3. Original and updated design specifications.

4. Catalog specifications.

5. Procurement basis evaluation such as like-for-like, equivalency, plant design change

packages, drawing and specification updates.

6. 10 CFR 50.59 documentation, if required.

7. Material receiving reports, packing lists/invoices, and other shipping documents.

8. Receipt inspection reports and any related test reports.

9. Other documents to trace the item from the time it was dedicated to the time it was

installed, tested, and accepted.

10. Certificates of conformance/compliance/quality.

11. Vendor test and inspection reports.

12. Third-party or sub vendor test and inspection reports.

13. Shelf-life information.

14. Vendor dedication/partial dedication information.

15. Design/material/process change history information.

Enclosure 2

16. Completed commercial grade dedication document including safety classification,

identification of safety functions/application requirements, identification of critical

characteristics, identification of verification methods and acceptance criteria for the

critical characteristics, evaluation of credible failure modes, if applicable, and

identification of the suppliers quality assurance program that meets 10 CFR Part 50,

Appendix B.

17. Any deviation from design, material, and performance characteristics relevant to the

safety function (nonconformance dispositions).

18. Documents showing objective evidence such as special test and inspection

procedures and results, commercial-grade survey reports-item, design, material, and

specific performance characteristic (relevant to safety function), and source

inspection reports.

19. Completed post-installation test procedure and results.

20. Completed stock or material issue forms and installation work orders or reports.

21. Historical performance information.

2

Enclosure 3: Inspection Team Contact Information

Manan Patel (Lead) Andrey Turilin Eric Miller

Senior Reactor Inspector Reactor Inspector Reactor Inspector

610-337-5304 610-337-5177 610-337-5116

Manan.Patel@nrc.gov Andrey.Turilin@nrc.gov Eric.Miller2@nrc.gov

Mailing Address:

U.S. NRC, Region I

Attn: Manan Patel

475 Allendale Road

STE 102

King of Prussia, PA 19406-1415

Enclosure 3