ML17363A437
| ML17363A437 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/29/2017 |
| From: | Jamie Benjamin NRC/RGN-III/DRS/EB2 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2018012 | |
| Download: ML17363A437 (8) | |
See also: IR 05000237/2018012
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, ILLINOIS 60532-4352
December 29, 2017
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Co., LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: DRESDEN REQUEST FOR INFORMATION FOR AN NRC TRIENNIAL
BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):
INSPECTION REPORT 05000237/2018-012; 05000249/2018-012
Dear Mr. Hanson:
On March 5, 2018, the U. S. Nuclear Regulatory Commission (NRC) will begin a Triennial
Baseline Design Bases Assurance Inspection (Team) at Dresden. This inspection will be
performed in accordance with NRC Baseline Inspection Procedure 71111.21M.
The Design Bases Assurance Inspection focuses on the design, maintenance, and operation of
risk-significant components with low margin, or associated with an accident scenario, or a
specific system. The inspection also monitors the implementation of modifications to structures,
systems, and components as modifications to one system may also affect the design bases and
functioning of interfacing systems as well as introduce the potential for common cause failures.
The components and modifications to be reviewed during this baseline inspection will be
identified as part of the preparation for the inspection and finalized during the in-office
preparation week that occurs prior to the first onsite 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 onsite 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 2 weeks onsite. The inspection team will consist of 6 NRC
inspectors who will focus on engineering/maintenance/operations of the selected components
and modifications. The current inspection schedule is as follows:
Preparation week: February 26, 2018;
Onsite weeks: March 5-9, 2018; and March 19-23, 2018
Experience with previous baseline design/modification 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.
B. Hanson -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 onsite 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 January 29, 2018.
By February 12, 2018 the lead inspector will communicate the initial selected set of
approximately seven components and seven modifications.
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 initially selected components and the modification packages associated with the
initially selected modifications, should be provided to the lead inspector at the Regional
Office no later than February 19, 2018. 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 March 5, 2018. 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. Jamie Benjamin. We understand that our licensing
contact for this inspection is Mr. D. Walker of your organization. If there are any questions
about the inspection or the material requested in the enclosure, please contact the lead
inspector at 630-829-9747 or via e-mail at Jamie.Benjamin@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.
This letter and its enclosure 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA Mark Jeffers for/
Jamie Benjamin, Senior Reactor Engineer
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-237; 50-249
Enclosure:
Design Bases Assurance Inspection
Document Request
cc: Distribution via LISTSERV
B. Hanson -2-
Letter to Bryan C. Hanson from Jamie Benjamin dated December 29, 2017
SUBJECT: DRESDEN REQUEST FOR INFORMATION FOR AN NRC TRIENNIAL
BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):
INSPECTION REPORT 05000237/2018-012; 05000249/2018-012
DISTRIBUTION:
RidsNrrDorlLpl3
RidsNrrPMDresden Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
Kenneth OBrien
DRPIII
DRSIII
ADAMS Accession Number ML17363A437
OFFICE RIII RIII RIII RIII
NAME MJeffers for
JBenjamin:cl
DATE 12/29/17
OFFICIAL RECORD COPY
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
Inspection Report: 05000237/2018012; 05000249/2018012
Inspection Dates: March 5-9, 2018; and
March 19-23, 2018.
Inspection Procedure: IP 71111.21M, Design Bases Assurance Inspection (Team)
Lead Inspector: Jamie Benjamin, Senior Reactor Engineer, DRS
630-829-9747
Jamie.Benjamin@nrc.gov
I. Information Requested for Selection of Components/Modifications
The following information is requested by January 29, 2018, 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 on some portable electronic
media (e.g., CD-ROM, DVD, 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. Include values for Birnbaum
Importance, Risk-Reduction Worth, and Fussell-Veseley (as applicable).
2. Risk-ranking of top 100 containment-related components (i.e., Large Early
Release Frequency) from your site specific PSA sorted by Risk-Achievement
Worth. See examples in Inspection Manual Chapter 0609, Appendix H,
Table 4.1, Containment-Related Structures, Systems, and Components
Considered for Large Early Release Frequency Implications.
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.
5. Copies of PSA system notebooks and latest PSA summary document.
6. Provide copies of the emergency operating procedures.
7. 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).
8. Electronic copy of the site Individual Plant Examination of External Events, if
available.
Enclosure
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
9. 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.).
10. List of available design (setup) margins in both the open and closed direction
(identify safety-related direction) for valves in the Motor-Operated Valve and
Air-Operated Valve Programs. Identify the basis for how the margin was
determined.
11. List of high risk Maintenance Rule systems/components based on engineering or
expert panel judgment (i.e., those systems/components not identified high risk in
the PSA).
12. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)
category for the last 3 years.
13. Site top 10 issues list (if applicable).
14. A list of operating experience evaluations for the last 3 years.
15. Information of any common cause failure of components experienced in the last
5 years at your facility.
16. List of Root Cause Evaluations associated with component failures or design
issues initiated/completed in the last 5 years.
17. List of open operability evaluations.
18. List of SSCs considered operable but degraded/nonconforming.
19. List of permanent plant modifications to SSCs that are field work complete in
the last 3 years. (For the purpose of this inspection, permanent plant
modifications include permanent: plant changes, design changes, set point
changes, equivalency evaluations, suitability analyses, and commercial grade
dedications.) The list should contain the number of each document, the title, the
revision (or date), and the affected system.
20. A list of calculation changes that have been issued for use in the last 3 years.
21. Copies of procedures addressing the following: modifications, design changes,
set point changes, equivalency evaluations or suitability analyses, commercial
grade dedications, and post-modification testing.
22. A list of corrective action documents (open and closed) in the last 3 years that
address permanent plant modifications issues, concerns, or processes. These
documents should also include the corrective action documents associated with
the modification implementation.
23. Current management and engineering organizational chart.
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
24. Electronic copies of Updated Final Safety Analysis Report, Technical
Specifications, Technical Specifications Bases, and Technical Requirements
Manual.
25. Major one line electrical drawings (ac and dc) and key diagrams (paper copies).
26. Electronic copy of Piping and Instrumentation Drawings (if available).
II. Information Requested (for the approximate 7 selected components and
7 selected modifications) to be Available by February 19, 2018, (will be reviewed
by the team in the Regional office during the week of February 26, 2018.
This information should be separated for each selected component or modification,
especially if provided electronically (e.g., folder with component or modification name
that includes calculations, condition reports, maintenance history, etc.). Items 1-12 are
associated with the selected components and item 13 for the selected modifications.
1. List of condition reports (corrective action documents) associated with each of
the selected components for the last 6 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). [Pipe stress calculations are excluded
from this request]
4. System Health Reports, System Descriptions, Design Basis Documents, and/or
Training Lesson Plans 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, diagnostic trend data, etc.).
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
10. Provide copies of the normal and abnormal operating procedures associated with
the selected components and selected scenarios.
11. List of time critical or risk significant operator actions associated with
components. Identify those actions that do not have job performance measures.
12. Copy of latest completed tests and surveillances for each component, for
example:
a. Pumps: comprehensive test, quarterly test, flow balance, etc.
b. Valves: stroke time testing, diagnostic testing, leak testing, interlocks, etc.
c. Heat Exchangers/Room Coolers: thermal performance, clean/inspect, fan
flows, etc.
d. Components: Technical Specification surveillances.
e. Acceptance criteria basis calculations should also be included.
13. For each of the selected modifications, copies of associated documents such as
modification package, engineering changes, 50.59 screening or evaluation,
calculations, post-modification test packages, corrective action documents,
design drawings, preventive maintenance requirements and procedures, etc.
14. A copy of any internal/external self-assessments and associated corrective
action documents generated in preparation for the inspection.
15. A copy of engineering/operations related audits completed in the last 2 years.
III. Additional Information to be Provided on March 5, 2018, Onsite (for final selected
components and modifications)
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 February 26, 2017
2. Schedule of any testing/maintenance activities to be conducted on the selected
components during the two 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 by 2:00 p.m.
during the inspection to each team member).
3. One complete set of Piping and Instrumentation Drawings (paper copies).
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
4. Reference materials. (make available during all onsite weeks):
a. Individual Plant Examination/Probabilistic Risk Assessment report;
b. Procurement documents for components and modifications selected (verify
retrievable);
c. Plant procedures (normal, abnormal, emergency, surveillance, etc.); and
d. Vendor manuals.
If you have questions regarding the information requested, please contact the lead inspector.
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