ML18305A354
| ML18305A354 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/31/2018 |
| From: | Jorge Corujo-Sandin NRC/RGN-III/DRS/EB2 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2019010 | |
| Download: ML18305A354 (9) | |
See also: IR 05000456/2019010
Text
October 31, 2018
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2REQUEST FOR INFORMATION FOR
AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION
(TEAM); INSPECTION REPORT 05000456/2019010; 05000457/2019010
Dear Mr. Hanson:
On January 14, 2019, the U. S. Nuclear Regulatory Commission (NRC) will begin a triennial
baseline Design Bases Assurance Inspection (Team) at Braidwood Station, Unit 1 and 2.
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 functions 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 inoffice 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 six NRC
inspectors who will focus on engineering/maintenance/operations of the selected components
and modifications. The current inspection schedule is as follows:
Preparation week:
January 7-11, 2019;
Onsite weeks:
January 14-18, 2019, and January 28, 2019-February 1, 2019.
B. Hanson
-2-
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.
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 and sample
selection activities. This information should be provided to the lead inspector no later
than November 23, 2018. By December 10, 2018, the lead inspector will communicate
the initial selected set of approximately seven components and seven modifications.
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 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 December 28, 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
January 14, 2019. 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 Jorge Corujo-Sandin. We understand that our licensing
contact for this inspection is Richard Schliessmann of your organization. If there are any
questions about the inspection or the material requested in the enclosure, please contact the
lead inspector at 630-829-9741 or via e-mail at Jorge.Corujo-Sandin@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.
B. Hanson
-3-
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 Title 10 of the Code of Federal Regulations, Part 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jorge Corujo-Sandin, Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-456; 50-457
Enclosure:
Document Request for Design Bases
Assurance Inspection
B. Hanson
-4-
Letter to Bryan C. Hanson from Jorge Corujo-Sandin dated October 31, 2018.
SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2REQUEST FOR INFORMATION FOR
AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION
(TEAM); INSPECTION REPORT 05000456/2019010; 05000457/2019010
DISTRIBUTION:
RidsNrrDorlLpl3
RidsNrrPMBraidwood Resource
RidsNrrDirsIrib Resource
DRPIII
DRSIII
ADAMS Accession Number: ML18305A354
OFFICE
RIII
NAME
JCorujo-Sandin:cl
DATE
10/31/18
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
Enclosure
Inspection Report: 05000456/2019010; 05000457/2019010
Inspection Dates:
January 14-18, 2019; and
January 28, 2019, through February 1, 2019.
Inspection Procedure:
Inspection Procedure 71111.21M, Design Bases Assurance
Inspection (Team)
Lead Inspector:
Jorge Corujo-Sandin, Reactor Inspector, DRS
630-829-9741
Jorge.Corujo-Sandin@nrc.gov
I.
Information Requested for Selection of Components/Modifications
The following information is requested by November 23, 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. Please provide at least two copies of
the portable electronic media).
1.
Risk-ranking of top 250 basic events from your internal events site
specific probabilistic safety analysis (PSA) sorted by Birnbaum Importance,
Risk-Reduction Worth, Risk-Achievement Worth, and Fussell-Veseley (as
applicable). (Provide in Excel format)
2.
Risk-ranking of top 100 containment-related basic events from your Level 2
internal events model (i.e., Large Early Release Frequency) sorted by
Risk Achievement Worth, if available. These basic events should be similar to
those found in Inspection Manual Chapter 0609, Appendix H, Table 4.1,
Containment-Related SSCs Considered for LERF Implications. (Provide in
Excel format)
3.
Provide a list of the top 200 cut-sets from your internal events PSA, including
descriptors for the associated basic events. (Provide in Excel format)
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.
(Provide in Excel format)
5.
Copies of PSA system notebooks and latest PSA summary document.
6.
Provide copies of the emergency operating procedures.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
2
7.
If you have an External Events and/or Fire PSA Model, provide the information
requested in Items 1 and 2 for external events and/or fire. (Provide in Excel
format)
8.
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.).
9.
Electronic copy of the site Individual Plant Examination of External Events, if
available.
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 ten 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, title,
revision/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.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
3
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.
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 December 28, 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 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.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
4
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.).
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.
If available, please include associated human reliability worksheets for these
items. 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.
16.
Provide a list of all abnormal /off normal operating procedures. Please include
procedure identifier/number and title.
III.
Additional Information to be Provided on January 14, 2019, 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 January 7, 2019.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
5
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).
4.
Reference materials. (make available if needed 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.