ML13038A312
| ML13038A312 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/07/2013 |
| From: | Ann Marie Stone NRC/RGN-III/DRS/EB2 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| References | |
| IR-13-008 | |
| Download: ML13038A312 (8) | |
See also: IR 05000461/2013008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
February 7, 2013
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CLINTON POWER STATION REQUEST FOR INFORMATION FOR AN NRC
TRIENNIAL BASELINE COMPONENT DESIGN BASES INSPECTION
INSPECTION REPORT 05000461/2013008
Dear Mr. Pacilio:
On May 20, 2013, the U. S. Nuclear Regulatory Commission (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 the design, maintenance, and operation of risk-significant components
associated with one or more accident scenario. The components to be reviewed during this
baseline inspection will be identified during the inoffice preparation week that occurs prior to the
first on-site inspection week. In addition, operating experience issues, associated with the
component samples, will also be selected for review. The inspection team may request
scenarios to be performed on the simulator. This request would require support from your
simulator staff to validate scenarios, simulator time, and a crew to perform the actions which
would most likely occur during the second on-site week. The team will work closely with your
staff early on during the inspection process to ensure this activity can be accomplished with
minimal impact.
The inspection will include three weeks on-site. The inspection team will consist of six NRC
inspectors, of which five will focus on engineering/maintenance and one on operations. The
current inspection schedule is as follows:
- On-site weeks: May 20 - 24, 2013;
June 3 - 7, 2013; and
June 17 - 21, 2013.
The team will be preparing for the inspection, mainly during the week of May 13, 2013, as
discussed in the attached enclosure.
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.
M. Pacilio -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 April 9, 2013. By
April 19, 2013, the lead inspector will communicate the initial selected set of approximately
20 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 8, 2013. 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 20, 2013. 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 Ron Frantz 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.
M. Pacilio -2-
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 Systems (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. 50-461
License No. NPF-62
Enclosure: Component Design Bases Inspection Request for Information Documents
cc w/encl: Distribution via ListServ'
COMPONENT DESIGN BASES INSPECTION REQUEST FOR INFORMATION DOCUMENTS
Inspection Report: 05000461/2013008
Inspection Dates: May 20 - 24, 2013;
June 3 - 7, 2013; and
June 17 - 21, 2013.
Inspection Procedure: Inspection Procedure 71111.21 Component Design Bases
Inspection
Lead Inspector: Andrew Dunlop, Senior Reactor Engineer, DRS
(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 9, 2013, 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 250 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. Risk-ranking of top 100 containment-related components from your site specific
PSA sorted by Large Early Release Frequency (LERF).
3. Provide a list of the top 200 cut-sets from your PSA.
4. Provide a list of the top 100 cut-sets for each initiator modeled in the PSA that
contributes more than 5 percent to the baseline plant core damage frequency
(CDF).
5. Copies of PSA system notebooks and latest PSA summary document.
6. List of time critical operator actions. Identify those actions that do not have job
performance measures (JPMs).
7. Provide copies of the emergency operating procedures (EOPs).
1 Enclosure
COMPONENT DESIGN BASES INSPECTION REQUEST FOR INFORMATION DOCUMENTS
8. 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).
9. Electronic copy of the site IPEEE, if available.
10. 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.).
11. 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.
12. 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).
13. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)
category for the last 3 years.
14. Site top ten issues list (if applicable).
15. A list of operating experience evaluations for the last 3 years.
16. Information of any common cause failure of components experienced in the last
5 years at your facility.
17. List of Root Cause Evaluations associated with component failures or design
issues initiated/completed in the last 5 years.
18. List of open operability evaluations.
19. List of components/systems considered operable but degraded/nonconforming.
20. Current management and engineering organizational chart.
21. Electronic copies of Updated Final Safety Analysis Report, Technical
Specifications, Technical Specifications Bases, and Technical Requirements
Manual.
22. Major one line electrical drawings (ac and dc) and key diagrams (paper copies).
23. Electronic copy of P&IDs (if available).
2 Enclosure
COMPONENT DESIGN BASES INSPECTION REQUEST FOR INFORMATION DOCUMENTS
II. Information Requested (for the approx. 20 selected components) to be Available
by May 8, 2013, (will be reviewed by the team in the Regional Office during the
week of May 13, 2013).
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 maintenance history (corrective, preventive, and elective) associated with
each of the selected components for the last 10 years. Identify frequency of
preventive maintenance activities.
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., for valves: stroke time and leak rate
results, etc.).
10. Copy of latest completed surveillance tests for each component (for example, for
pumps this would include: comprehensive test, quarterly test, flow balance, etc.
for valves: stroke time testing, diagnostic testing, leak testing, etc.). Acceptance
criteria basis calculations should also be included.
11. Provide copies of the normal and abnormal operating procedures associated with
the selected components and selected scenarios.
3 Enclosure
COMPONENT DESIGN BASES INSPECTION REQUEST FOR INFORMATION DOCUMENTS
12. A copy of any internal/external self-assessments and associated corrective
action documents generated in preparation for the inspection.
13. A copy of engineering/operations related audits completed in the last 2 years.
III. Additional Information to be Provided on May 20, 2013, On-Site (for final selected
components)
1. 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 13, 2013.
2. Schedule of any testing/maintenance activities to be conducted on the selected
components during the three onsite inspection weeks.
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
M. Pacilio -2-
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 Systems (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. 50-461
License No. NPF-62
Enclosure: Component Design Bases Inspection Request for Information Documents
cc w/encl: Distribution via ListServ'
Docket No. 50-461
License No. NPF-62
Enclosure: Information Request for Component Design Bases Inspection (CDBI)
cc w/encl: Distribution via ListServ'
DISTRIBUTION:
John Cassidy
RidsNrrDorlLpl3-2 Resource
RidsNrrPMClinton Resource
RidsNrrDirsIrib Resource
Chuck Casto
Cynthia Pederson
DRSIII
DRPIII
DOCUMENT NAME: G:\DRSIII\DRS\Work in Progress\Ltr. 020713 Clinton CDBI RFI AXD.docx
Publicly Available Non-Publicly Available Sensitive 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 ADunlop:ls AMStone
DATE 02/05/13 02/07/13
OFFICIAL RECORD COPY