ML070851356

From kanterella
Jump to navigation Jump to search
Information Request for NRC Biennial Baseline Component Design Bases Inspection 05000456-07-009 (Drs); 05000457-07-009 (DRS)
ML070851356
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 03/26/2007
From: Ann Marie Stone
NRC/RGN-III/DRS/EB2
To: Crane C
Exelon Generation Co, Exelon Nuclear
References
IR-07-009
Download: ML070851356 (9)


See also: IR 05000456/2007009

Text

March 26, 2007

Mr. Christopher M. Crane

President and Chief Nuclear Officer

Exelon Nuclear

Exelon Generation Company, LLC

4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2 - INFORMATION REQUEST FOR AN

NRC BIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION

05000456/2007009(DRS); 05000457/2007009(DRS)

Dear Mr. Crane:

On July 23, 2007, the NRC will begin a biennial baseline Component Design Bases Inspection

(CDBI) at the Braidwood Station, Units 1 and 2. This inspection will be performed in

accordance with revised NRC Baseline Inspection Procedure (IP) 71111.21 and replaces the

biennial Safety System Design and Performance Capability Inspection.

The CDBI inspection focuses on components which have high risk and low design margins.

The components to be reviewed during this baseline inspection will be identified during an

in-office preparation week prior to the first week of the on-site inspection. In addition, a number

of risk significant operator actions and operating experience issues, associated with the

component samples, will also be selected for review.

The inspection will include 3 weeks on-site, including the information gathering during the first

on-site week. The inspection team will consist of six NRC inspectors, of whom five will focus on

engineering and one on operations. The current inspection schedule is as follows:

July 23 through July 27, 2007;

August 6 through August 10, 2007; and

August 20 through August 24, 2007.

The team will be preparing for the inspection, mainly during the week of July 16, 2007, as

discussed in the attached enclosure. A Region III Senior Reactor Analyst may accompany the

inspection team during the week of July 23, 2007, to review probabilistic risk assessment data

and assist in identifying risk significant components, which will be reviewed during the

inspection.

Experience with previous baseline design inspections of similar depth and length has shown

that these type of inspections are extremely resource intensive, both for the NRC inspectors

and the licensee staff. In order to minimize the inspection impact on the site and to ensure a

productive inspection for both parties, we have enclosed a request for information needed for

the inspection.

C. Crane

-2-

It is important that all of these documents are up to date and complete in order to minimize the

number of additional documents requested during the preparation and/or the on-site portions of

the inspection. Insofar as possible, this information should be provided electronically to the

lead inspector. The information request has been divided into three groups:

The first group lists information necessary for our initial inspection scoping activities.

This information should be available to the lead inspector no later than June 25, 2007.

By July 5, 2007, the lead inspector will communicate the initial selected set of

approximately 30 high risk components.

The second group of documents requested are those items needed to support our

in-office preparation activities. This set of documents, including the calculations

associated with the initial selected components, should be available at the Regional

Office no later than July 11, 2007. During the in-office preparation activities, the team

may identify additional information needed to support the inspection.

The last group includes the additional information above as well as plant specific

reference material. This information should be available to the team on the first day of

the inspection. It is also requested that corrective action documents and questions

developed during the inspection be provided to the inspectors throughout the inspection.

The lead inspector for this inspection is Mr. John Jacobson. We understand that our licensing

contact for this inspection is Mr. M. Cichon of your organization. If there are any questions

about the inspection or the material requested in the enclosure, please contact the lead

inspector at (630) 829-9736 or via e-mail at JMJ3@nrc.gov.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-456; 50-457

License No. NPF-72; NPF-77

Enclosure:

Component Design Bases Inspection Document Request

See Attached Distribution

C. Crane

-3-

cc w/encl:

Site Vice President - Braidwood Station

Plant Manager - Braidwood Station

Regulatory Assurance Manager - Braidwood Station

Chief Operating Officer

Senior Vice President - Nuclear Services

Vice President - Operations Support

Director Licensing

Manager Licensing - Braidwood and Byron

Senior Counsel, Nuclear, Mid-West Regional

Operating Group

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

State Liaison Officer

Chairman, Illinois Commerce Commission

C. Crane

-2-

It is important that all of these documents are up to date and complete in order to minimize the

number of additional documents requested during the preparation and/or the on-site portions of

the inspection. Insofar as possible, this information should be provided electronically to the

lead inspector. The information request has been divided into three groups:

The first group lists information necessary for our initial inspection scoping activities.

This information should be available to the lead inspector no later than June 25, 2007.

By July 5, 2007, the lead inspector will communicate the initial selected set of

approximately 30 high risk components.

The second group of documents requested are those items needed to support our

in-office preparation activities. This set of documents, including the calculations

associated with the initial selected components, should be available at the Regional

Office no later than July 11, 2007. During the in-office preparation activities, the team

may identify additional information needed to support the inspection.

The last group includes the additional information above as well as plant specific

reference material. This information should be available to the team on the first day of

the inspection. It is also requested that corrective action documents and questions

developed during the inspection be provided to the inspectors throughout the inspection.

The lead inspector for this inspection is Mr. John Jacobson. We understand that our licensing

contact for this inspection is Mr. M. Cichon of your organization. If there are any questions

about the inspection or the material requested in the enclosure, please contact the lead

inspector at (630) 829-9736 or via e-mail at JMJ3@nrc.gov.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the

Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-456; 50-457

License No. NPF-72; NPF-77

Enclosure:

Component Design Bases Inspection Document Request

See Attached Distribution

DOCUMENT NAME:C:\\FileNet\\ML070851356.wpd

G Publicly Available

G Non-Publicly Available

G Sensitive

G Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N = No copy

OFFICE RIII

RIII

RIII

RIII

NAME

JJacobson: ls

LKozak

AMStone

DATE

03/22/07

03/23/07

03/26/07

OFFICIAL RECORD COPY

C. Crane

-3-

cc w/encl:

Site Vice President - Braidwood Station

Plant Manager - Braidwood Station

Regulatory Assurance Manager - Braidwood Station

Chief Operating Officer

Senior Vice President - Nuclear Services

Vice President - Operations Support

Director Licensing

Manager Licensing - Braidwood and Byron

Senior Counsel, Nuclear, Mid-West Regional

Operating Group

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

State Liaison Officer

Chairman, Illinois Commerce Commission

ADAMS DISTRIBUTION:

DXC1

TEB

RFK

RidsNrrDirsIrib

GEG

KGO

GLS

SPR

CAA1

DRPIII

DRSIII

PLB1

TXN

COMPONENT DESIGN BASES INSPECTION

INFORMATION REQUEST

Enclosure

1

Site:

Braidwood Station, Units 1 and 2

Inspection Report: 05000456/2007009(DRS); 05000457/2007009(DRS)

Inspection Dates:

July 23 through July 27, August 6 through August 10; and

August 20 through August 24, 2007

Inspection Procedure:

IP 71111.21, Component Design Bases Inspection

Lead Inspector:

John Jacobson, (630) 829-9736, (JMJ3@nrc.gov)

I.

Information Requested Prior to the On-site Information Gathering/Inspection

Week

The following information is requested by June 25, 2007, or sooner, to facilitate

inspection preparation. If you have any questions regarding this information, please call

the lead inspector as soon as possible. (Please provide the information electronically in

pdf files, Excel, or other searchable formats, preferably either through electronic mail

or on CDROM. The CDROM 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 a knowledge of light water

reactor technology).

1.

Provide a risk ranking of top 150 components from your site specific probabilistic

safety analysis (PSA) sorted by Risk Achievement Worth (RAW). Include values

for Birnbaum Importance, Risk Reduction Worth (RRW), and Fussell-Veseley

(FV) (as applicable). If possible, list the system, train, and PSA failure mode for

each component.

2.

Provide a list of the top 200 cut-sets from your PSA.

3.

If you have an External Events or Fire PSA Model, provide the information

requested in Items 1 and 2 for external events and fire. Provide narrative

description of each coded event (including fire, flood zone description).

4.

Provide a risk ranking of operator actions from your site specific PSA sorted by

RAW. Provide copies of your human reliability worksheets for these items.

5

Provide a list of PSA assumptions regarding operator actions.

6.

Provide any pre-existing evaluation or list of components and associated

calculations with low design margins, (i.e., 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 etc.).

COMPONENT DESIGN BASES INSPECTION

INFORMATION REQUEST

Enclosure

2

7.

Provide a list of available design (setup) margins for valves in the motor-

operated valve (MOV) and air-operated valve (AOV) programs.

8.

Provide a list of high risk Maintenance Rule systems/components based on

engineering or expert panel judgement.

9.

Provide a list of structures, systems, or components (SSCs) in the Maintenance

Rule (a)(1) category.

10.

Provide the site top ten issues list (if applicable).

11.

Provide information on any common cause failure of components experienced in

the last five years at your facility.

12.

Provide a list of Root Cause Evaluations associated with component failures or

design issues initiated or completed in the last five years.

II.

Information requested (for the approximately 30 selected components) to be

available by July 11, 2007. This information should be separated for each

selected component, especially if provided electronically (e.g., folder with

component name that includes calculations, condition reports, maintenance

history, etc). Please provide separate disks for electrical and mechanical

components.

1.

Provide a list and copies of condition reports (corrective action documents)

associated with each of the selected components for the last four years.

2.

Provide the completed corrective maintenance history associated with each of

the selected components for the last four years. Please ensure this list only

includes completed activities and does not include routine surveillances.

3.

Provide copies of calculations associated with each of the selected components

(if not previously provided), excluding data files. Please review the calculations

and provide copies of referenced material (such as drawings, engineering

requests, or vendor letters).

4.

Provide a list of modifications associated with each of the selected components.

This list should include a descriptive paragraph on the purpose of the

modification. Please ensure this list only includes design completed (not

canceled) modifications.

5.

Provide copies of electrical single-lines and mechanical piping and

instrumentation drawings.

6.

Provide copies of operability evaluations associated with each of the selected

components and plans for restoring operability, if applicable.

COMPONENT DESIGN BASES INSPECTION

INFORMATION REQUEST

Enclosure

3

7.

Provide copies of any operator work-around evaluations associated with each of

the selected components and plans for resolution, if applicable.

8.

Provide copies of any open temporary modifications associated with each of the

selected components, if applicable.

9.

Provide trend data on the selected electrical/mechanical components

performance for last three years (For example, pumps performance including

in-service testing, other vibration monitoring, oil sample results, etc., as

applicable).

10.

Provide System Health Reports, System Descriptions, and/or Design Basis

Documents that are associated with each of the selected components.

11.

Provide copies of operating experience evaluations associated with the selected

components for the last three years.

12.

Provide copies of any simulator scenarios, lesson plans, or job performance

measures for the selected operator actions.

13.

Provide copies of the emergency operating procedures, normal and abnormal

operating procedures, and any alarm response procedures for the selected

operator actions.

14.

Provide a copy of any engineering or operations related audits completed in the

last two years which addressed the selected components.

15.

Provide a copy of the current management and engineering organizational chart.

Highlight or otherwise provide the names of any inspection contacts or inspector

shadows.

16.

Provide electronic copies of Updated Final Safety Analysis Report, Technical

Specifications, Technical Specifications Bases, and Technical Requirements

Manual; if available.

17.

Provide a copy of any internal/external self-assessments and associated

corrective action documents generated in preparation for the inspection.

III.

Additional Information to be Provided on July 23, 2007 On-site (for final 15 - 20

selected components)

1.

A request for any additional information needed will be provided during the week

of July 16, 2007. The lead inspector will provide a list of added information.

Enclosure

4

The lead inspectors may request hard copies of information provided

electronically, especially drawings and calculations.

2.

One complete set of piping and instrumentation drawings (P and IDs) and

one-line electrical drawings (paper copies).

3.

The following background materials may be requested. It is recommended that

these materials be identified and located prior to the inspection:

IPE/PRA report;

Procurement documents for components selected;

Plant procedures (normal, abnormal, emergency, surveillance, etc.); and

Vendor manuals.

4.

Please arrange for an overview walkdown of the selected components. This

should include any required radiological briefings. For any components not

normally accessible, please arrange for a briefing on what conditions prevent

access to the components.

5.

If plant information, such as corrective action documents or procedures, is

available electronically onsite, please consider providing access for the

inspectors, along with simple instructions.

IV.

Information Requested to be provided throughout the inspection

1

Provide copies of any corrective action documents generated as a result of

the teams questions or queries during this inspection. This includes and

licensee-identified corrective action documents generated while answering an

inspector question. Please provide two copies: one to the inspector and one to

the lead inspector. At the end of the inspection, please provide the lead

inspector with a complete list of all corrective action documents generated as a

result of the inspection.

2

Provide copies of the list of questions submitted by the team members and the

status/resolution of the information requested. Each inspector should receive at

least a copy of his/her open questions, while the lead inspector should receive a

complete list. At the end of the inspection, please provide the lead inspector with

a complete electronic copy of the database.

If you have questions regarding any of the information requested, please contact the lead

inspector.