IR 05000333/2022010: Difference between revisions

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{{Adams
{{Adams
| number = ML22153A261
| number = ML22005A023
| issue date = 06/02/2022
| issue date = 01/05/2022
| title = Design Basis Assurance Inspection (Teams) Inspection Report 05000333/2022010
| title = Information Request for a Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000333/2022010
| author name = Gray M
| author name = Gray M
| author affiliation = NRC/RGN-I/DORS
| author affiliation = NRC/RGN-I/DORS
| addressee name = Rhoades D
| addressee name = Rhoades D
| addressee affiliation = Constellation Energy Generation, LLC, Constellation Nuclear
| addressee affiliation = Exelon Generation Co LLC, Exelon Nuclear
| docket = 05000333
| docket = 05000333
| license number = DPR-059
| license number = DPR-059
| contact person = Gray M
| contact person = Gray M
| document report number = IR 2022010
| document report number = IR 2022010
| document type = Inspection Report, Letter
| document type = Inspection Plan, Letter
| page count = 17
| page count = 7
}}
}}


Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:June 2, 2022
{{#Wiki_filter:January 5, 2022


==SUBJECT:==
Mr. David P. Rhoades Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000333/2022010


==Dear Mr. Rhoades:==
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INFORMATION REQUEST FOR A TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM); INSPECTION REPORT 0500033 3/2022 010
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, a nd other members o f 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.
==Dear Mr. Rhoades :==
The purpose of this letter is to notify you that the U.S. Nuclear Regul atory Commission (NRC)
Region I staff will conduct a Design Bases Assurance Inspection (DBAI) at FitzPatrick Nuclear Power Plan Joe Schoppy, a Senior Reactor Inspector from the NRCs Region I O ffice, will lead the inspection tea The inspection will b e conducted in accordance with Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team), dated December 8, 2016 (ADAMS Accession No. ML16340B000).


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:
The inspection will evaluate the capability of risk -significant/low-margin components to f unction as designed to support proper system operatio The inspection will also include a review of selected modifications, operating experience, and as applicable, operator action During a telephone conversation on January 3, 2022, with Mr. Ma rk Hawes, FitzPatrick Regulatory Assurance, we confirmed arrangements for an information-gathering site visit and the two-week onsite inspectio The schedule is as follows:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement ; and the NRC R esident Inspector at James A. FitzPatrick Nuclear Power Plant.
* Information-gathering visit: Week of March 7, 2022
* Onsite weeks: Weeks of May 2 and Ma y 16, 2022


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. This letter, its enclosure, and your response (if any) will be m ade available for public inspection and copying at http://www.nrc.gov/reading-rm /a dam s.h tm l 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.
The purpose of the information-gathering visit is to meet with members of your staff to identify risk-significant components, modifications, operator actions, and operating experience item Information and documentation needed to sup port the inspection will also be identifie Da v e Werkheiser, a Region I Senior Risk Analyst, will support Joe Schoppy during the inform ation-gathering visit to review probabilistic risk assessment data and identify components to be examined during the inspectio Experience with previous baseline design/modification inspections of similar depth and length has shown this type of inspection is resource intensive, both for the NRC inspectors and the licensee staf In order to minimize the inspection impac t on the site and to ensure a productive D. Rhoades 2


Sincerely, Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety
inspection for both parties, we have enclosed a request for information needed for the inspectio It is important that all of these documents are up-to-date and complete in order to minimize the num ber of additional documents requested during the preparation and/or the onsite portions of the inspectio Insofar as possible, this information should be provided electronically to the lead inspecto The information request has been divided into two groups:
* The first group lists information necessary for our initial inspection scoping activitie This information should be provided to the lead inspector by March 7, 202 By March 14, 2022, the lead inspector will communicate the initial selected set of components and m odification * The second group of documents requested is those items needed to support our in-office preparation activitie This set of documents, specific to the selected components and modifications, should be provided to the lead inspector at the Region I Office no later than April 25, 202 During the in-office preparation activities, the team may identify additional information needed to support the inspection, and those item s will be communicated directly to Mark Hawes.


Docket No. 05000333 License No. DPR-59
If there are any questions about the inspection or the material requested in the enclosure, please contact Mr. Joe Schoppy at 610- 337-5286 or via e-mail at jgs@nrc.gov.


===Enclosure:===
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-001 The NRC may not conduct or 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 Office of Management and Budget Control Numbe This letter and its enclosure will be made available for publ ic 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, Part 2.390, Public Inspec tion s, Exemptions, Requests for Withholdin
As stated


==Inspection Report==
Sincerely, Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety
Docket Number: 05000333
 
License Number: DPR-59
 
Report Number: 05000333/2022010
 
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. E ve, Senior Reactor Inspector J. Schoppy, Senior Reactor Inspector
 
Approved By: Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety
 
Enclosure
 
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licens ees performance by conducting a design basis assurance inspection (teams) inspection at Jam e s 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 Report Aspect Section Mitigating Green [H.8] - 71111.21M Systems NCV 05000333/2022010-01 Procedure Open/Closed 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.
 
=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 websi te a t http://www.nrc.gov/reading -
rm /doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requireme nts 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)
 
===
{{IP sample|IP=IP 71111.21|count=4}}
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
* Mitiod itled configurion (, visual iption/wkd
* Nm,m, gencyperin
* Consistencymg digd liceing besnd her documes/
* iee r d crtivti histy
* Ay ofi (ccio and mofications)
* Surveillce tti and ttesults
* System aomptfmamotori
* Equipme tion fromirlo,atntrion, or
* a tem,ooling wat d ventilion
* Controgic
* C cyimumta
* Prection coornatild in-rfl ld crent)
* Rang accy, apoi of itled itrumention
* Oper actions
* Prseum avlality (w, air, trici)
* Enerourclalitytricity,tm,u, r)
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)
* Mitiod itled configurion (, visual iption/wkd
* Nm,m, gencyperin
* Consistencymg digd liceing besnd her documes/pr
* System health report, mntee, d crtive acti histy
* Surveillce tti and ttesults
* System aomptfmamotori
* Controgic
* Oper actions
* Prseum avlality (w, air, trici)
* Enerourclalitytricity,tm,u, r)
 
The te us* guie Valves, Pumps, Instrumentation, and As -
Built System.
: (3) Containment Venting (Loss of Function)
* Mi ctio itled configurion (,isualption/wkd
* Nm,m, gencyperin
* Consistencymg digd liceing besnd her documes/
* System health report, mntee, d crtive acti his ry
* Equipme/environme cors anificion
* Ay ofi (ccio and mofications)
* Surveillce tti and ttesults
* System aomptfmamotori
* Equipme tion fromirlo,tm,errio or s
* Heatem,ooling wat d ventilion
* Controgic
* Rang accy, apoi of itled itrumention
* Oper actions
* Prseum avlality (w, air, trici)
* Enerourclalitytricity,tm,u e)
 
The te us* guie Valves, Pumps, Instrumentation, and As -
Built System.
: (4) B 125 Vdc Battery (SB-2) and Battery B Control Board (BCB -2B)
* Mitiod itled configurion (, visual iption/wkd
* Nm,m, gencyperin
* Consistencymg digd liceing besnd her documes/
* Mee r d crtivti histy
* Equipme/environme cors anificion
* A y ofi (ccio and mofications)
* Surveillance testing and test results
* System and component level performance monitoring
* Equipme tion fromirlo,tm,errio
* Vtiliofempe ctrnor
* Circt bre d feings
* C cyimumta
* Prection coornatild in-r florent,ht -circt prtio
* Rang accy, apoi of itled itrumention
* Oper actions
* Ener sourclalitychger lability,ality,iality)
 
The te us* guie 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)
* Mitiod itled configurion (, visual iption/wkd
* Nm, am, angency operin
* Consistencymg digd liceing besnd her documes/
* System health report, mntee, d crtive acti histy
* Equipme/environme cors anificion
* Ay ofi (ccio an dificions)
* Surveillce tti and ttesults
* System aomptfmamotori
* Equipme tion fromirlo,tm,errio
* Heatem,ooling wat d ventilion
* Controgic
* Rang accy, and spoi tltrumention
* Oper actions
* Prseum avlality (w, air, trici)
* Enerourclalitytricity,tm,u, r)
 
The te us* guie 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
 
===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 Report Aspect Section Mitigating Green [H.8] - 71111.21M Systems NCV 05000333/2022010 - 01 Procedure Open/Closed 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 requir ed to be read and recorded at various stages of the test were not included in the official test record.


=====Description:=====
Docket No. 05000333 License N DP R-59
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.
Enclosure:
Document Request for Design Bases Assurance Inspection


First, the battery terminal voltage before starting the test did not meet the test prerequisite.
cc: Distribution via ListSe rv D. Rhoades 3


MST- 071.
SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INFORMATION REQUEST FOR A TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM); INSPECTION REPORT 05000333/2022010 DATED JANUARY 5, 2022


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 volta ge 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 hours following being on an equalizing charge prior to starting the discharge test.
DISTRIBUTION:
ECarfang, DORS JHawkins, DORS SHaney, DORS CDukehart, DORS EMiller, DORS, SRI CSwisher, DORS, RI ATrudell, DORS AA LHowell, RI OEDO RidsNrrPMFitzPatrick Resource RidsNrrDorlLpl1 Resource


Second, technicians did not ensure that adequate and reliable power was available for test equipment as stated in the tes t 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 equipm ent. 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.
DOCUMENT NAME: G:\\DRS\\Engineering Branch 1\\ schoppy\\DBAI Request for Information Letter FitzPatrick. docx ADAMS ACCESSION NUMBER: ML22005A023 x SUNSI Review x Non - Sensitive x Publicly Available


Constellation personnel did not adequately perform this step. As a result, at approximately 16 m inutes 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.
Sensite n -Publ Avaible


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.
OFFICE RI/DORS RI/DORS RI/DORS ME JSchoppy DWkheis MGr TE 1/4 2 OFFICIAL CORD CO


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 rec ord.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION


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.
Inspection Report: 05000333/2 022010


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.
Onsite Inspection Dates: May 2, 2022 through Ma y 6, 2022; and May 16, 2022 through May 20, 2022


Factoring in the pause in the testing and oth er 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).
Inspection P r oc e dur e: Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team)


Corrective Action References: IRs 4497226, 4497328, 4497663, and 4497832.
Lead Inspector: Joe Schoppy, Senior Reactor Inspector 610-337-5286 jgs@nrc.gov Information Requested for Selection of Components and Modifications


=====Performance Assessment:=====
The following information is requested by March 7, 2022, to facilitate inspection preparatio Feel free to contact the lead inspector as soon as possible if you have any questions regarding this information reques Please provide the information electronically in pdf files, Excel, or other searchable formats, preferably on some portable electronic media (e.g.,
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.
CD-ROM, DVD). The files should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use. Information in lists should contain enough information to be easily understood by someone who has knowledge of light water reactor technolog. The site probabilistic risk analysis (PRA) System Notebook and latest PRA Summary Docum en. Risk ranking of top 250 basic events sorted by Risk Achievement Worth (>/= 1.3).


Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At -Power. Though the perf ormance 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.
Include values f or Risk Reduction Worth, Birnbaum Importance, and Fussel l-Vesely (as applicable). Please provide in an excel spreadsheet or other sortable format, and include an understandable definition of the coded basic event. Risk-ranking of top 100 components from site specific PRA sorted by Large Early Release Frequenc. If you have an External Events PRA Model, provide the information requested in Item 2 for external event Provide narrative description of each coded event, including flood zone descriptio. List of time -critical and/or risk significant operator action. List of emergency and abnormal operating procedure. If available, any pre-existing evaluation or list of components and associated calculations with low design margins (e.g., pumps closest to the design limit for flow or pressure, diesel generator close to design required output, heat exchangers close to rated design heat removal).


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).
Enclosure DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION If applicable, copy of any self -assessments and/or Quality Assurance assessments of low margin structures, systems and components (SSC s) completed since August 1, 201. List of available design margins in both the open and closed direction for valves in the m otor-operated valve and air -operated valve programs (related to GL 96 -05, looking for resultant output - matrix of risk vs margin for MOVs and AOVs, as applicable).


Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions.
1 The age and capacity of the safety -related DC batterie. The In-Service Testing (IST) Program Basis document identifying the in-scope valves and pumps, and the associated IST Program requirements for each component (e.g.,
IST valve table identifying category, active/passive function).


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.
1 Access to IST trend data for the follow ing pum ps: HPCI, RCIC, RHR, and ES [Note:
needed for each discrete component (e.g. for each RHR pump)]


=====Enforcement:=====
1 Listing of MR (a)(1) systems, date entered into (a)(1) status, and brief description of why (a)(1).
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.
1 List of MRFFs evaluations completed since August 1, 20 19 (include those determined not to be a MRFF).


(NCV 05000333/20220010-01, Inadequate Test Control for Modified Performance Discharge Testing of B Station Battery)
1 A copy of the most recent System Health and/or trending reports for the following systems (as applicable): SR 4KV, SR 600 Vac, HPCI, RCIC, RHR, ESW, SR 125 Vdc, SR 419 Vdc, SLC, EDGs, and RHRS. A copy of the most recent Program Health and/or trending reports for the following programs, as applicable: GL 89-10 (MOVs), GL 89-13, IST, AOVs, breakers, relay. List of open operability evaluation. List of current operator work arounds/burden. List of permanent plant modifications to SSCs that are field work complete since August 1, 20 1 For the purpose of this inspection, permanent plant modifications include permanent: plant changes, design changes, set point changes, equivalency evaluations, suitability analyses, and commercial grade dedication The list should contain the number of each document, title (sufficient to understand the purpose of the modification), revision/date, and the affected syste. List of calculation changes (including new calculations) that have been issued for use since August 1, 2019.
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==
2 Corrective Action Program procedur. Procedures addressing the following: modifications, design changes, set point changes, equivalency evaluations or suitability analyses, c ommercial grade dedications, and post-m odification testin DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
The inspectors verified no proprietary information was retained or documented in this report.
* On May 19, 2022, the inspector s presented the design basis assurance inspection (teams) inspection results to Mr. Timothy Peter, Site Vice President, and other m em bers of the licensee staff.


=DOCUMENTS REVIEWED=
2 List of corrective action documents (open and closed) since August 1, 2019, that address permanent plant modifications issues, concerns, or processe. Any internal/external self -assessments and associated corrective action documents generated in preparation for this inspectio. Updated Final Safety Analysis Report, Technical Specifications, Technical Specifications Bases, and Technical Requirements Manua. Electrical simple one-line drawings for 4KV, 600V, 345KV, & 115KV (11 X 17 preferred).


Inspection Type Designation Description or Title Revision or
2 Copy of Exelons internal response to the following NRC Information Notices: 2019 -01, 2019- 02, 2020- 02, and 2020-0. Copy of FitzPatricks internal response to MPR Ass ociates Part 21 - Basler Electric SBSR AVR Card Solder Joints (dated 9/21/07).
Procedure Date
71111.21M Calculations JAF-CALC-15-FLEX Strategy - Portable Generator System Sizing Revision 0
00031
JAF-CALC-CAD-Design Basis Calculations for the Torus Inner and Outer Revision 0
04481 Exhaust AOVs 27AOV-117 & 27AOV-118 at FitzPatrick NPP
JAF-CALC-125V DC System Short-Circuit Calculation and Coordination Revision 1
ELEC-02016 Evaluation
JAF-CALC-Determination of Float and Equalize Voltage for Station Revision 1
ELEC-02551 Batteries 71SB-1 & 71SB2
JAF-CALC-SWS-Local Wall Thinning Evaluation for ESW Strainers 46STR-Revision 2C
04170 5 A/B
Corrective Action 04036374
Docum ents 04176609
221269
246355
252619
252625
266619
290349
04319445
04323766
04335008
04339876
04347868
04348143
04369686
04371604
04371715
04372411
04372680
04373277
04374549
04377286
Inspection Type Designation Description or Title Revision or
Procedure 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 04497169
Docum ents 04497226
Resulting from 04497328
Inspection 04497349
04497394
04497395
04497409
04497663
04497664
04497672
04497680
04497832
04497910


Inspection Type Designation Description or Title Revision or
2 A list of NRC Part 21 Reports, determined to be applicable to FitzPatrick, since August 1, 20 1. An electronic copy of the following DBDs (if applicable & available): SR 4KV, SR 600 Vac, HPCI, RCIC, RHR, ESW, SR 125 Vdc, SR 419 Vdc, SLC, EDGs, and RHRS I Information Requested to Be Available by April 25, 2022
Procedure 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
FM-20A Residual Heat Removal System Flow Diagram Revision 73
FM-25A High Pressure Coolant Injection Flow Diagram Revision 75
Miscellaneous DBD-023 Design Basis Document for the High Pressure Coolant Revision 12
Injection System
E406-0001 200 KW FLEX Diesel Generator Revision 1
G185-0029 Instruction Manuals for 60 Cells NCN-33 or NCN-35 (GNB dated
Industrial Power) 9/11/11
JAF-SPEC-MISC-James A. FitzPatrick Nuclear Power Plant Piping Revision 15


Inspection Type Designation Description or Title Revision or
This information should be separated for each selected component and modification, especially if provided electronically (e.g., a folder for each component and modification named after the component or modification that includes the information requested below).
Procedure Date
00334 Specification
NRC Information Battery and Battery Charger Short-Circuit Current dated
Notice 2017- 06 Contributions to a Fault on the Direct Current Distribution 9/26/17
System
OP-AA-102-106, Operator Response Time Validation Sheet performed
Att. 1 11/12/20
P319-0047 Three-Phase Magnetic Amplifier Controlled CP Battery Revision 8
Charger
RHR 2B 10E-2B Preliminary Report of Eddy Current Inspections dated
11/20/13
SDLP-23 High Pressure Coolant Injection System Revision 28
ST-1CA Outside Primary Containment Isolation Valve Exercise Test performed
(IST) 3/16/22
ST-2AK RHR Loop B Containment Spray Headers and Nozzles Air performed
Test (ISI) 9/23/12
ST-2AM RHR Loop B Quarterly Operability Test (IST) performed
3/10/21 &
3/8/22
Procedures AOP-18 Loss of 10500 Bus Revision 18
AOP-19 Loss of 10600 Bus Revision 18
CC-JF-118 Site Implementation of Diverse and Flexible Coping Revision 5
Strategies (FLEX) and Spent Fuel Instrumentation Program
EP-6 Po st Accident Containment Venting and Gas Control Revision 13
OP-13 Residual Heat Removal System Revision 100
OP-15 High Pressure Coolant Injection Revision 69
Work Orders 00205886
00340684
04655870
04806288
04806289
04915450
04938333
04938334
04938915


Inspection Type Designation Description or Title Revision or
Items 1 through 11 are associated with the selected components and Item 12 is for the selected modification. List of corrective action documents associated with each selected component since August 1, 20 1. Maintenance history (e.g., corrective, preventive, and elective) associated with each selected component for the last five year Identify frequency of preventive maintenance activitie. Aging Management Program docum ents and/or License Renewal committed inspection results applicable to each selected com ponen. List of calculations associated with each selected component, excluding data file Pipe stress calculations are excluded from this reques. System Health Report (last completed) and Design Basis Document associated with each selected component, as applicabl. Access to or copy of vendor manual (s) for each selected componen DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION List of open temporary modifications associated with each selected component, if applicabl. Trend data/graphs on the selected components performance since August 1, 2019 (e.g., pump performance including IST, other vibration monitoring, oil sample results). List of normal operating and alarm response procedures associated with each selected componen. Last completed tests and surveillances for each selected component performed since August 1, 20 1 For those tests and surveillances performed at a periodicity of greater than three years, provide the latest test performe. Schedule of surveillance testing of selected components that occur during the onsite inspection week. For each selected modification, copies of associated documents such as modification package, engineering changes, 50.59 screening or evaluation, relevant calculation s, post-modification test packages, associated corrective action documents, design drawings, and new/revised preventive maintenance requirements.
Procedure Date
04943427
04964506
05043091
05047158
05131958
05131959
05150464
05150801
2606584
2705256
2740044
99-01814-00


14
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Revision as of 00:21, 19 November 2024

Information Request for a Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000333/2022010
ML22005A023
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 01/05/2022
From: Mel Gray
Division of Operating Reactors
To: Rhoades D
Exelon Generation Co LLC, Exelon Nuclear
Gray M
References
IR 2022010
Download: ML22005A023 (7)
v • d • e


Text

January 5, 2022

Mr. David P. Rhoades 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 - INFORMATION REQUEST FOR A TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM); INSPECTION REPORT 0500033 3/2022 010

Dear Mr. Rhoades :

The purpose of this letter is to notify you that the U.S. Nuclear Regul atory Commission (NRC)

Region I staff will conduct a Design Bases Assurance Inspection (DBAI) at FitzPatrick Nuclear Power Plan Joe Schoppy, a Senior Reactor Inspector from the NRCs Region I O ffice, will lead the inspection tea The inspection will b e conducted in accordance with Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team), dated December 8, 2016 (ADAMS Accession No. ML16340B000).

The inspection will evaluate the capability of risk -significant/low-margin components to f unction as designed to support proper system operatio The inspection will also include a review of selected modifications, operating experience, and as applicable, operator action During a telephone conversation on January 3, 2022, with Mr. Ma rk Hawes, FitzPatrick Regulatory Assurance, we confirmed arrangements for an information-gathering site visit and the two-week onsite inspectio The schedule is as follows:

  • Information-gathering visit: Week of March 7, 2022
  • Onsite weeks: Weeks of May 2 and Ma y 16, 2022

The purpose of the information-gathering visit is to meet with members of your staff to identify risk-significant components, modifications, operator actions, and operating experience item Information and documentation needed to sup port the inspection will also be identifie Da v e Werkheiser, a Region I Senior Risk Analyst, will support Joe Schoppy during the inform ation-gathering visit to review probabilistic risk assessment data and identify components to be examined during the inspectio Experience with previous baseline design/modification inspections of similar depth and length has shown this type of inspection is resource intensive, both for the NRC inspectors and the licensee staf In order to minimize the inspection impac t on the site and to ensure a productive D. Rhoades 2

inspection for both parties, we have enclosed a request for information needed for the inspectio It is important that all of these documents are up-to-date and complete in order to minimize the num ber of additional documents requested during the preparation and/or the onsite portions of the inspectio Insofar as possible, this information should be provided electronically to the lead inspecto The information request has been divided into two groups:

  • The first group lists information necessary for our initial inspection scoping activitie This information should be provided to the lead inspector by March 7, 202 By March 14, 2022, the lead inspector will communicate the initial selected set of components and m odification * The second group of documents requested is those items needed to support our in-office preparation activitie This set of documents, specific to the selected components and modifications, should be provided to the lead inspector at the Region I Office no later than April 25, 202 During the in-office preparation activities, the team may identify additional information needed to support the inspection, and those item s will be communicated directly to Mark Hawes.

If there are any questions about the inspection or the material requested in the enclosure, please contact Mr. Joe Schoppy at 610- 337-5286 or via e-mail at jgs@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-001 The NRC may not conduct or 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 Office of Management and Budget Control Numbe This letter and its enclosure will be made available for publ ic 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, Part 2.390, Public Inspec tion s, Exemptions, Requests for Withholdin

Sincerely, Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety

Docket No. 05000333 License N DP R-59

Enclosure:

Document Request for Design Bases Assurance Inspection

cc: Distribution via ListSe rv D. Rhoades 3

SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INFORMATION REQUEST FOR A TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM); INSPECTION REPORT 05000333/2022010 DATED JANUARY 5, 2022

DISTRIBUTION:

ECarfang, DORS JHawkins, DORS SHaney, DORS CDukehart, DORS EMiller, DORS, SRI CSwisher, DORS, RI ATrudell, DORS AA LHowell, RI OEDO RidsNrrPMFitzPatrick Resource RidsNrrDorlLpl1 Resource

DOCUMENT NAME: G:\\DRS\\Engineering Branch 1\\ schoppy\\DBAI Request for Information Letter FitzPatrick. docx ADAMS ACCESSION NUMBER: ML22005A023 x SUNSI Review x Non - Sensitive x Publicly Available

Sensite n -Publ Avaible

OFFICE RI/DORS RI/DORS RI/DORS ME JSchoppy DWkheis MGr TE 1/4 2 OFFICIAL CORD CO

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

Inspection Report: 05000333/2 022010

Onsite Inspection Dates: May 2, 2022 through Ma y 6, 2022; and May 16, 2022 through May 20, 2022

Inspection P r oc e dur e: Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector: Joe Schoppy, Senior Reactor Inspector 610-337-5286 jgs@nrc.gov Information Requested for Selection of Components and Modifications

The following information is requested by March 7, 2022, to facilitate inspection preparatio Feel free to contact the lead inspector as soon as possible if you have any questions regarding this information reques Please provide the information electronically in pdf files, Excel, or other searchable formats, preferably on some portable electronic media (e.g.,

CD-ROM, DVD). The files should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use. Information in lists should contain enough information to be easily understood by someone who has knowledge of light water reactor technolog. The site probabilistic risk analysis (PRA) System Notebook and latest PRA Summary Docum en. Risk ranking of top 250 basic events sorted by Risk Achievement Worth (>/= 1.3).

Include values f or Risk Reduction Worth, Birnbaum Importance, and Fussel l-Vesely (as applicable). Please provide in an excel spreadsheet or other sortable format, and include an understandable definition of the coded basic event. Risk-ranking of top 100 components from site specific PRA sorted by Large Early Release Frequenc. If you have an External Events PRA Model, provide the information requested in Item 2 for external event Provide narrative description of each coded event, including flood zone descriptio. List of time -critical and/or risk significant operator action. List of emergency and abnormal operating procedure. If available, any pre-existing evaluation or list of components and associated calculations with low design margins (e.g., pumps closest to the design limit for flow or pressure, diesel generator close to design required output, heat exchangers close to rated design heat removal).

Enclosure DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION If applicable, copy of any self -assessments and/or Quality Assurance assessments of low margin structures, systems and components (SSC s) completed since August 1, 201. List of available design margins in both the open and closed direction for valves in the m otor-operated valve and air -operated valve programs (related to GL 96 -05, looking for resultant output - matrix of risk vs margin for MOVs and AOVs, as applicable).

1 The age and capacity of the safety -related DC batterie. The In-Service Testing (IST) Program Basis document identifying the in-scope valves and pumps, and the associated IST Program requirements for each component (e.g.,

IST valve table identifying category, active/passive function).

1 Access to IST trend data for the follow ing pum ps: HPCI, RCIC, RHR, and ES [Note:

needed for each discrete component (e.g. for each RHR pump)]

1 Listing of MR (a)(1) systems, date entered into (a)(1) status, and brief description of why (a)(1).

1 List of MRFFs evaluations completed since August 1, 20 19 (include those determined not to be a MRFF).

1 A copy of the most recent System Health and/or trending reports for the following systems (as applicable): SR 4KV, SR 600 Vac, HPCI, RCIC, RHR, ESW, SR 125 Vdc, SR 419 Vdc, SLC, EDGs, and RHRS. A copy of the most recent Program Health and/or trending reports for the following programs, as applicable: GL 89-10 (MOVs), GL 89-13, IST, AOVs, breakers, relay. List of open operability evaluation. List of current operator work arounds/burden. List of permanent plant modifications to SSCs that are field work complete since August 1, 20 1 For the purpose of this inspection, permanent plant modifications include permanent: plant changes, design changes, set point changes, equivalency evaluations, suitability analyses, and commercial grade dedication The list should contain the number of each document, title (sufficient to understand the purpose of the modification), revision/date, and the affected syste. List of calculation changes (including new calculations) that have been issued for use since August 1, 2019.

2 Corrective Action Program procedur. Procedures addressing the following: modifications, design changes, set point changes, equivalency evaluations or suitability analyses, c ommercial grade dedications, and post-m odification testin DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

2 List of corrective action documents (open and closed) since August 1, 2019, that address permanent plant modifications issues, concerns, or processe. Any internal/external self -assessments and associated corrective action documents generated in preparation for this inspectio. Updated Final Safety Analysis Report, Technical Specifications, Technical Specifications Bases, and Technical Requirements Manua. Electrical simple one-line drawings for 4KV, 600V, 345KV, & 115KV (11 X 17 preferred).

2 Copy of Exelons internal response to the following NRC Information Notices: 2019 -01, 2019- 02, 2020- 02, and 2020-0. Copy of FitzPatricks internal response to MPR Ass ociates Part 21 - Basler Electric SBSR AVR Card Solder Joints (dated 9/21/07).

2 A list of NRC Part 21 Reports, determined to be applicable to FitzPatrick, since August 1, 20 1. An electronic copy of the following DBDs (if applicable & available): SR 4KV, SR 600 Vac, HPCI, RCIC, RHR, ESW, SR 125 Vdc, SR 419 Vdc, SLC, EDGs, and RHRS I Information Requested to Be Available by April 25, 2022

This information should be separated for each selected component and modification, especially if provided electronically (e.g., a folder for each component and modification named after the component or modification that includes the information requested below).

Items 1 through 11 are associated with the selected components and Item 12 is for the selected modification. List of corrective action documents associated with each selected component since August 1, 20 1. Maintenance history (e.g., corrective, preventive, and elective) associated with each selected component for the last five year Identify frequency of preventive maintenance activitie. Aging Management Program docum ents and/or License Renewal committed inspection results applicable to each selected com ponen. List of calculations associated with each selected component, excluding data file Pipe stress calculations are excluded from this reques. System Health Report (last completed) and Design Basis Document associated with each selected component, as applicabl. Access to or copy of vendor manual (s) for each selected componen DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION List of open temporary modifications associated with each selected component, if applicabl. Trend data/graphs on the selected components performance since August 1, 2019 (e.g., pump performance including IST, other vibration monitoring, oil sample results). List of normal operating and alarm response procedures associated with each selected componen. Last completed tests and surveillances for each selected component performed since August 1, 20 1 For those tests and surveillances performed at a periodicity of greater than three years, provide the latest test performe. Schedule of surveillance testing of selected components that occur during the onsite inspection week. For each selected modification, copies of associated documents such as modification package, engineering changes, 50.59 screening or evaluation, relevant calculation s, post-modification test packages, associated corrective action documents, design drawings, and new/revised preventive maintenance requirements.

4

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