ML19056A113
| ML19056A113 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/25/2019 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DRS/EB2 |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| Download: ML19056A113 (8) | |
See also: IR 05000255/2019010
Text
February 25, 2019
Mr. Charles Arnone
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: PALISADES NUCLEAR PLANTREQUEST FOR INFORMATION DESIGN
BASES ASSURANCE INSPECTION (PROGRAM); NRC INSPECTION
REPORT 05000255/2019010
Dear Mr. Arnone:
On July 15, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial
Baseline Design Bases Assurance Inspection (Program) at Palisades Nuclear Plant.
This inspection will be performed in accordance with NRC Baseline Inspection
Procedure 71111.21N, Attachment 1.
The Design Bases Assurance Inspection will focus on the implementation of the Electrical
Equipment Environmental Qualification (EQ) Program to verify you are maintaining the qualified
status of equipment during the life of the plant. The final selection of EQ components to be
reviewed during this baseline inspection will be identified during the inoffice preparation week
that occurs prior to the first onsite inspection week.
The inspection will include 2 weeks onsite. The inspection team will consist of three NRC
inspectors. The current inspection schedule is as follows:
- Team preparation week: July 8, 2019, through July12, 2019;
- Onsite inspection weeks: July 15, 2019, though July 19, 2019; and
July 29, 2019, through August 2, 2019.
Experience with previous baseline design inspections of similar depth and length has shown 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. Arnone -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 four 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, 2019.
The lead inspector will communicate the initial selected EQ components no later than
May 17, 2019.
- The second group of documents requested is those items needed to support our
in-office preparation activities. This set of documents should be provided to the lead
inspector at the Regional Office no later than June 5, 2019. During the in-office
preparation activities, the team may identify additional information needed to support
the inspection.
- The third group includes the additional information above. This information should be
available to the team onsite on July 15, 2019.
- The last group includes supporting information to be provided throughout the inspection.
Specifically, corrective action documents and questions developed during the inspection
are requested to be provided as the documents are generated.
In addition, the enclosure includes information and requests addressing inspection logistics.
The lead inspector for this inspection is Néstor J. Féliz-Adorno. We understand that our
licensing contact for this inspection is 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 630-829-9739 or via e-mail at Nestor.Feliz-Adorno@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. Arnone -3-
This letter, its enclosure, and your response (if any) 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/
Néstor J. Féliz-Adorno, Senior Reactor Engineer
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-255;72-007
License No. DPR-20
Enclosure:
Document Request for Design Bases
Assurance Inspection EQ Program
cc: Distribution via LISTSERV
C. Arnone -4-
Letter to Charles Arnone from Néstor J. Féliz-Adorno dated February 25, 2019.
SUBJECT: PALISADES NUCLEAR PLANTREQUEST FOR INFORMATION DESIGN
BASES ASSURANCE INSPECTION (PROGRAM); NRC INSPECTION
REPORT 05000255/2019010
DISTRIBUTION:
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RidsNrrDirsIrib Resource
DRPIII
DRSIII
ADAMS Accession Number: ML19056A113
OFFICE RIII
NAME NFéliz-Adorno:jw
DATE 02/25/19
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000255/2019010
July 15, 2019, through July 19, 2019; and
Onsite Inspection Dates:
July 29, 2019, through August 2, 2019.
71111.21N, Design Bases Assurance Inspection (Program),
Attachment 1, Environmental Qualification under Title 10 of
Inspection Procedure:
the Code of Federal Regulations, Part 50.49, Programs,
Processes, and Procedures
Néstor J. Féliz-Adorno
Lead Inspector: 630-829-9739
Nestor.Feliz-Adorno@nrc.gov
John Bozga, Senior Reactor Engineer, RIII/DRS
Teammate Inspectors:
Michael Greenleaf, Reactor Engineer, RII/DRS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by June 5, 2019, or sooner:
1. Inspection room name/number, directions from the main access facility, and
phone number;
2. Interview room name/number;
3. Response team contact information (names and phone numbers) and team roles
(e.g., management sponsor, lead, inspector counterpart);
4. Any site access/badging actions needed for each inspector;
5. Any dosimetry actions needed for each inspector;
6. Entrance meeting time (preferably after 11:00 a.m. Eastern Time) and location;
7. Confirmation that the team will have access to a licensee computer with a nearby
printer;
8. Confirmation that the team will have Wi-Fi access;
9. Cafeteria location and hours;
10. Engineering staff normal working hours; and
11. Any potential resource conflicts during the inspection (e.g., emergency drills and
all-staff meetings).
Enclosure
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
III. INFORMATION REQUEST
Contact the lead inspector as soon as possible if you have any questions regarding this
information request. Provide the information electronically in pdf files, Excel, or other
searchable formats, preferably on some portable electronic media (e.g., CD-ROM,
DVD). The files 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. Information Requested for Initial Inspection Scoping Activities
The following information is requested by April 12, 2019, or sooner, to facilitate
the initial sample selection.
1.1. Risk-ranking of top 250 components required to meet environmental
qualifications (EQ) from your site specific probabilistic safety analysis
sorted by Risk-Achievement Worth. Include values for Birnbaum
Importance, Risk-Reduction Worth, and Fussell-Veseley (as applicable).
Provide any basic event mapping used to develop the ranking of
components.
1.2. Probabilistic Safety Analysis listing of top ten risk significant systems.
1.3. U.S. Nuclear Regulatory Commission Safety Evaluation Reports
associated with EQ.
1.4. Updated Final Safety Analysis Report, Technical Specifications,
Technical Specifications Bases, and Technical Requirements Manual.
If any of these documents is not available electronically, contact the lead
inspector. Specifically identify which Updated Final Safety Analysis
Report sections address EQ (including seismic).
1.5. Identify the various EQ standards (including year, edition, or revision) that
the station is committed to.
1.6. Site (and corporate if applicable) procedures associated with the Title 10
of the Code of Federal Regulations, Part 50.49, EQ Program for electrical
components. Include procedures for procurement of qualified equipment,
maintenance of qualified equipment, modification to qualified equipment
(including Equivalency or Commercial Grade Dedication (CGD)
Programs), and material storage and shelf life controls.
1.7. Environmental Qualifications Design Basis Document, if applicable.
1.8. Any open licensing commitments related to EQ, if applicable.
1.9. Equipment Qualification Master List (EQML). Specific issues
to be identified include: safety classification (safety-related or
non safety-related), Regulatory Guide 1.97 instrumentation,
EQ qualification (e.g., DOR, NUREG-588, 50.49), original or replaced
after implementation of 50.49, plant location, and qualified life.
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
1.10. List of any installed equipment removed from the EQML and basis for
removal.
1.11. List of EQ solenoid valves that are normally continuously energized.
1.12. If EQ files were reviewed for Aging Management effects of license
renewal, identify which EQ files were modified/changed to incorporate
appropriate actions for the period of extended operation. Include any
EQ Aging Management Program documents.
1.13. List or drawings of plant areas that are subjected to EQ, identifying design
(limiting) temperature, high energy line break, radiation levels, etc. that
the associated equipment will have to be qualified to meet EQ. If the
reactor unit has obtained a power uprate (greater than 5 percent) provide
same information pre-update (earliest available if multiple uprates).
1.14. List of CGD evaluations performed, for which the dedicated parts have
been issued for installation (parts issued for the last 10 years) on EQ
applications in the plant. Include CGD evaluation number, name of part,
component ID or description of the component the part was issued to
repair, work order, and date issued or installed.
1.15. List of Corrective Action Documents related to the EQ Program or EQ of
specific components for the last 5 years.
1.16. Any self-assessment and/or audit of the EQ Program in the last 3 years.
1.17. Current management and engineering organizational chart.
1.18. Licensing point of contact information (name, phone number, and email).
2. Information Requested to Support Inspection Preparation Activities
The following information is requested by June 5, 2019, or sooner, to facilitate
the final inspection preparation. This information request is associated with the
selected components and should be separated by component (e.g., folder with
component name that includes EQ files, Qualification Test Reports, calculations,
corrective action documents, and maintenance history).
2.1. Component/subcomponent EQ summary report.
2.2. Qualification Maintenance Requirement Sheet or equivalent.
2.3. List of corrective action documents associated with each selected
component for the last 5 years.
2.4. Photos of any component in containment or high radiation areas,
if available.
2.5. EQ file, including associated Qualification Test Reports.
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
2.6. Vendor manual. If an electronic copy is not available, include a statement
explaining this and provide a hard copy during the onsite phase of the
inspection.
2.7. Preventive maintenance template.
2.8. Last two performed work order (WO) for each associated EQ preventive
maintenance.
2.9. List of corrective maintenance WOs for the last 10 years. Include WO
number, date performed, and brief one line description.
2.10. If repair work (e.g., a motor rewind) was performed under a purchase
order, provide the purchase order.
2.11. Thermal life calculation.
3. Additional Information to Be Provided Onsite
During the in-office preparation activities, the team 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 July 8, 2019.
4. Information Requested to Be Provided Throughout the Inspection
4.1. Any corrective action documents generated as a result of the teams
questions during this inspection as the documents are generated.
4.2. List of questions and/or document requests submitted by the team and
their status (e.g., open, closed) sorted by inspector. Provide daily by
2:30 p.m. to each inspector. It is recommended to provide the team
leader with a master list sorted by inspector and each inspector with
a list containing only the items originated by that inspector.
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