ML082120112
| ML082120112 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/29/2008 |
| From: | Ann Marie Stone NRC/RGN-III/DRS/EB2 |
| To: | Schwarz C Entergy Nuclear Operations |
| References | |
| IR-08-009 | |
| Download: ML082120112 (9) | |
See also: IR 05000255/2008009
Text
July 29, 2008
Mr. Christopher J. Schwarz
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANT REQUEST FOR INFORMATION FOR AN NRC
TRIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION (CDBI)
INSPECTION REPORT 05000255/2008009(DRS)
Dear Schwarz:
On November 3, 2008, the NRC will begin a triennial baseline Component Design Bases
Inspection (CDBI) at Palisades Nuclear Plant. A team of six inspectors will perform this 3-week
inspection. This inspection will be performed in accordance with NRC Baseline Inspection
Procedure (IP) 71111.21.
The CDBI focuses on components that 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 three weeks on-site. The inspection team will consist of six NRC
inspectors, of which five will focus on engineering and one on operations. The current
inspection schedule is as follows:
- On-site weeks: November 3-7, 2008;
November 17-21, 2008; and
December 1-5, 2008.
The team will be preparing for the inspection, mainly during the week of October 27-31, 2008,
as discussed in the attached enclosure. A Region III Senior Reactor Analyst may accompany
the inspection team during the week of November 3-7, 2008, 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 this type of inspection is 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. Schwarz -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 provided to the lead inspector no later than September 29, 2008.
By October 8, 2008, 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 provided to the lead inspector at the Regional Office
no later than October 21, 2008. 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 onsite on November 3 - 7, 2008.
It is also requested that corrective action documents and/or questions developed during the
inspection be provided to the lead inspector as the documents are generated.
The lead inspector for this inspection is Mr. James Neurauter. We understand that our licensing
contact for this inspection is Ms. Barb Dotson 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) 829-9828 or via e-mail at james.neurauter@nrc.gov.
In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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. 50-255
License No. DPR-20
Enclosure: Information Request for Component Design Bases Inspection (CDBI)
DISTRIBUTION
See next page
Letter to Christopher J. Schwarz from Ms. A. M. Stone dated July 29, 2008.
SUBJECT: PALISADES NUCLEAR PLANT REQUEST FOR INFORMATION FOR AN NRC
TRIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION (CDBI)
INSPECTION REPORT 05000255/2008009(DRS)
cc w/encl: Senior Vice President
Vice President Oversight
Senior Manager, Nuclear Safety & Licensing
Senior Vice President and COO
Assistant General Counsel
Manager, Licensing
W. DiProfio
W. Russell
G. Randolph
Supervisor, Covert Township
Office of the Governor
T. Strong, State Liaison Officer
Michigan Department of Environmental Quality
Michigan Office of the Attorney General
C. Schwarz -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 provided to the lead inspector no later than September 29, 2008. By October 8, 2008, the
lead inspector will communicate the initial selected set of approximately 30 high risk components.
- The second group of documents requested is 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 provided to the lead inspector at the Regional Office no later than October 21,
2008. 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 onsite on November 3-7, 2008. It is also requested
that corrective action documents and/or questions developed during the inspection be provided to the
lead inspector as the documents are generated.
The lead inspector for this inspection is Mr. James Neurauter. We understand that our licensing contact
for this inspection is Ms. Barb Dotson 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) 829-9828
or via e-mail at james.neurauter@nrc.gov.
In accordance with 10 CFR 2.390 of the NRCs 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 NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Ann Marie Stone, Chief
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure: Information Request for Component Design Bases Inspection (CDBI)
DISTRIBUTION
See next page
DOCUMENT NAME: G:\DRS\Work in Progress\Ltr. 07__08 Palisades CDBI RFI JEN.doc
9 Publicly Available 9 Non-Publicly Available 9 Sensitive 9 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
NAME JNeurauter: ls AMStone
DATE 07/29/08 07/29/08
OFFICIAL RECORD COPY
Letter to Christopher J. Schwarz from Ms. A. M. Stone dated July 29, 2008.
SUBJECT: PALISADES NUCLEAR PLANTREQUEST FOR INFORMATION FOR AN NRC
TRIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION (CDBI)
INSPECTION REPORT 05000255/2008009(DRS)
cc w/encl: Senior Vice President
Vice President Oversight
Senior Manager, Nuclear Safety & Licensing
Senior Vice President and COO
Assistant General Counsel
Manager, Licensing
W. DiProfio
W. Russell
G. Randolph
Supervisor, Covert Township
Office of the Governor
T. Strong, State Liaison Officer
Michigan Department of Environmental Quality
Michigan Office of the Attorney General
DISTRIBUTION:
RidsNrrDirsIrib Resource
Mark Satorius
Kenneth Obrien
DRPIII
DRSIII
Patricia Buckley
ROPreports@nrc.gov
INFORMATION REQUEST FOR
COMPONENT DESIGN BASES INSPECTION (CDBI)
Inspection Report: 05000255/2008009(DRS)
Inspection Dates: November 3-7, 2008;
November 17-21, 2008; and
December 1-5, 2008.
Inspection Procedure: IP 71111.21 Component Design Bases Inspection
Lead Inspector: James Neurauter, Lead Inspector
(630) 829-9828
james.neurauter@nrc.gov
I. Information Requested Prior to the On-site Information Gathering/Inspection Week
The following information is requested by September 29, 2008, or sooner, to facilitate
inspection preparation. If you have any questions regarding this information, please call
the team leader as soon as possible. (Please provide the information electronically in
pdf files, Excel, or other searchable formats, preferably 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 knowledge of light water reactor technology).
1. 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).
2. Provide a list of the top 200 cut-sets from your PSA.
3. Risk ranking of operator actions from your site specific PSA sorted by RAW.
Provide copies of your human reliability worksheets for these items.
4. 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).
5. 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.).
6. List of available design (setup) margins for valves in the motor-operated valve
(MOV) and air-operated valve (AOV) programs.
1 Enclosure
INFORMATION REQUEST FOR
COMPONENT DESIGN BASES INSPECTION (CDBI)
7. List of high risk Maintenance Rule systems/components based on engineering or
expert panel judgment.
8. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)
category.
9. Site top ten issues list (if applicable).
10. A list of operating experience evaluations for the last 3 years.
11. Information of any common cause failure of components experienced in the last
5 years at your facility.
12. List of Root Cause Evaluations associated with component failures or design
issues initiated/completed in the last 5 years.
13. List of open operability evaluations.
14. Current management and engineering organizational chart.
15. Electronic copies of Updated Final Safety Analysis Report, Technical
Specifications, Technical Specifications Bases, and Technical Requirements
Manual.
16. One line electrical drawings (ac and dc) and key diagrams (paper copies).
II. Information requested (for the approx. 30 selected components) to be available by
October 21, 2008, (will be reviewed by the team in the Regional office during the
week of October 27 - 31, 2008).
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).
1. List of condition reports (corrective action documents) associated with each of
the selected components for the last 4 years.
2. The corrective maintenance history associated with each of the selected
components for the last 4 years.
3. Copies of calculations associated with each of the selected components (if not
previously provided), excluding data files. Please review the calculations and
also provide copies of important referenced material (such as drawings,
engineering requests, and vendor letters).
4. System Health Reports, System Descriptions, and/or Design Basis Documents
that are associated with each of the selected components.
2 Enclosure
INFORMATION REQUEST FOR
COMPONENT DESIGN BASES INSPECTION (CDBI)
5. 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.
6. Copies of operability evaluations (open/closed for last 3 years) associated with
each of the selected components and plans for restoring operability, if applicable.
7. Copies of selected operator work-around evaluations associated with each of the
selected components and plans for resolution, if applicable.
8. Copies of any open temporary modifications associated with each of the selected
components, if applicable.
9. Trend data on the selected electrical/mechanical components performance for
last 3 years (For example, pumps performance including in-service testing, other
vibration monitoring, oil sample results, etc., as applicable).
10. A copy of any internal/external self-assessments and associated corrective
action documents generated in preparation for the inspection.
11. A copy of engineering/operations related audits completed in the last 2 years.
12. Provide list of PRA assumptions regarding operator actions and the associated
procedures.
13. Provide copies of any simulator scenarios, lesson plans, or job performance
measures for the selected operator actions.
14. Provide copies of the results of any time-dependent simulator scenarios or job
performance measures for operator crews/individuals for the selected operator
actions.
15. Provide copies of the emergency operating procedures, normal and abnormal
operating procedures and any alarm response procedures for the selected
operator actions. Also provide copies of the conduct for operations and
operability determination procedures.
3 Enclosure
INFORMATION REQUEST FOR
COMPONENT DESIGN BASES INSPECTION (CDBI)
III. Additional Information to be provided on November 3, 2008 on-site (for final 15 -
20 selected components)
During the in-office preparation activities, the team will be making final selections
and may identify additional information needed to support the inspection. The lead
inspector will provide a list of the additional information needed during the week of
October 27-31, 2008.
IV. Information Requested to be provided throughout the inspection
1. Copies of any corrective action documents generated as a result of the teams
questions or queries during this inspection.
2. Copies of the list of questions submitted by the team members and the
status/resolution of the information requested (provide daily during the inspection
to each team member).
3. One complete set of P&IDs (paper copies).
4. Reference materials. (make available if needed during all on-site weeks):
- IPE/PRA report;
- Procurement documents for components selected (verify retrievable);
- Plant procedures (normal, abnormal, emergency, surveillance, etc.); and
- Vendor manuals.
If you have questions regarding the information requested, please contact the lead inspector.
4 Enclosure