ML100340816

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Ltr. 02/03/10 Clinton, Request for Information for an NRC Triennial Baseline Component Design Bases Inspection (CDBI) Inspection Report 05000461-10-006(DRS)
ML100340816
Person / Time
Site: Clinton 
Issue date: 02/03/2010
From: Jamie Benjamin
NRC/RGN-III/DRS/EB2
To: Pardee C
Exelon Generation Co, Exelon Nuclear
References
IR-10-006
Download: ML100340816 (8)


See also: IR 05000461/2010006

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

February 3, 2010

Mr. Charles G. Pardee

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer (CNO), Exelon Nuclear

4300 Winfield Road

SUBJECT:

CLINTON POWER STATION, REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION (CDBI)

INSPECTION REPORT 05000461/2010006(DRS)

Dear Mr. Pardee:

On May 24, 2010, the NRC will begin a triennial baseline Component Design Bases Inspection

(CDBI) at Clinton Power Station. 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: May 24 - 28, 2010;

June 7 - 11, 2010; and

June 21 - 25, 2010.

The team will be preparing for the inspection, mainly during the week of May 17 - 21, 2010, as

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

inspection team during the week of May 24 - 28, 2010, to review probabilistic risk assessment

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

inspection.

C. Pardee

-2-

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.

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 April 12, 2010. By

April 26, 2010, 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 May 12, 2010. 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 May 24, 2010. 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 Andrew Dunlop. We understand that our licensing

contact for this inspection is Mr. Ron Franz 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) 829-9726 or via e-mail at andrew.dunlop@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-

0011.

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 number.

C. Pardee

-3-

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/

Jamie C. Benjamin, Acting Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Information Request for Component Design Bases Inspection (CDBI)

cc w/encl:

Distribution via ListServ

INFORMATION REQUEST FOR

COMPONENT DESIGN BASES INSPECTION (CDBI)

Enclosure

1

Inspection Report: 05000461/2010006(DRS)

Inspection Dates:

May 24 - 28, 2010; June 7 - 11, 2010; and

June 21 - 25, 2010

Inspection Procedure:

IP 71111.21 Component Design Bases Inspection

Lead Inspector:

Andrew Dunlop, Lead Inspector

(630) 829-9726

andrew.dunlop@nrc.gov

I.

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

The following information is requested by April 12, 2010, 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 some portable electronic

media (e.g. CDROM, DVD, flash drive, etc.). The portable electronic media 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 top 50 components based on Large Early Release Frequency

(LERF), if available.

4.

Risk ranking of operator actions from your site specific PSA sorted by RAW.

Provide copies of your human reliability worksheets for these items.

5.

List of time critical operator actions. Identify those actions that do not have job

performance measures (JPMs).

6.

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).

INFORMATION REQUEST FOR

COMPONENT DESIGN BASES INSPECTION (CDBI)

Enclosure

2

7.

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.).

8.

List of available design (setup) margins in both the open and closed direction

(identify safety-related direction) for valves in the motor-operated valve (MOV)

and air-operated valve (AOV) programs. Identify the basis for how the margin

was determined.

9.

List of high risk Maintenance Rule systems/components based on engineering or

expert panel judgment (i.e. those systems/components not identified in the PRA).

10.

Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)

category for the last 3 years.

11.

Site top ten issues list (if applicable).

12.

A list of operating experience evaluations for the last 3 years.

13.

Information of any common cause failure of components experienced in the last

5 years at your facility.

14.

List of Root Cause Evaluations associated with component failures or design

issues initiated/completed in the last 5 years.

15.

List of open operability evaluations.

16.

Current management and engineering organizational chart.

17.

Electronic copies of Updated Final Safety Analysis Report, Technical

Specifications, Technical Specifications Bases, and Technical Requirements

Manual.

18.

Major one line electrical drawings (ac and dc) and key diagrams (paper copies).

19.

Electronic copy of P&IDs (if available).

INFORMATION REQUEST FOR

COMPONENT DESIGN BASES INSPECTION (CDBI)

Enclosure

3

II.

Information requested (for the approx. 30 selected components) to be available by

May 12, 2010, (will be reviewed by the team in the Regional office during the week

of May 17 - 21, 2010).

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 four 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, Design Basis Documents, and/or

Training Lesson Plans that are associated with each of the selected components.

5.

A list of modifications, including equivalency evaluations and setpoint changes,

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.

INFORMATION REQUEST FOR

COMPONENT DESIGN BASES INSPECTION (CDBI)

Enclosure

4

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.

III.

Additional Information To Be Provided On May 24, 2010, 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 May 17 - 21,

2010.

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.

C. Pardee

-3-

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,

Jamie C. Benjamin, Acting Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Information Request for Component Design Bases Inspection (CDBI)

cc w/encl:

Distribution via ListServ

DISTRIBUTION:

Susan Bagley

RidsNrrDorlLpl3-2 Resource

RidsNrrPMClinton Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Steven Orth

Jared Heck

Allan Barker

Carole Ariano

Linda Linn

DRSIII

DRPIII

Patricia Buckley

Tammy Tomczak

ROPreports Resource

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OFFICE: RIII

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RIII

NAME:

ADunlop:ls

JCBenjamin

DATE:

02/03/10

02/03/10

OFFICIAL RECORD COPY