ML22153A261

Design Basis Assurance Inspection (Teams) Inspection Report 05000333/2022010

ML22153A261
Person / Time
Site:	FitzPatrick
Issue date:	06/02/2022
From:	Mel Gray NRC/RGN-I/DORS
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

05000333/2022010

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,

Digitally signed by Melvin

Melvin K. K. Gray

Date: 2022.06.02

Gray 14:22:32 -04'00'

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

ML22153A261

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive 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

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000333

License Number: DPR-59

Report Number: 05000333/2022010

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

Enclosure

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 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.

2

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)

3

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)

4

• 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

5

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 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.

6

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.

7

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)

8

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.

9

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

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 5A/B

Corrective Action 04036374

Documents 04176609

04221269

04246355

04252619

04252625

04266619

04290349

04319445

04323766

04335008

04339876

04347868

04348143

04369686

04371604

04371715

04372411

04372680

04373277

04374549

04377286

10

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

Documents 04497226

Resulting from 04497328

Inspection 04497349

04497394

04497395

04497409

04497663

04497664

04497672

04497680

04497832

04497910

11

Inspection Type Designation Description or Title Revision or

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

12

Inspection Type Designation Description or Title Revision or

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 Post 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

13

Inspection Type Designation Description or Title Revision or

Procedure Date

04943427

04964506

05043091

05047158

05131958

05131959

05150464

05150801

82606584

82705256

82740044

99-01814-00

14