ML19190A137
| ML19190A137 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/08/2019 |
| From: | Nestor Feliz-Adorno NRC/RGN-III/DRS/EB2 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| References | |
| IR 2019012 | |
| Download: ML19190A137 (8) | |
See also: IR 05000346/2019012
Text
July 8, 2019
Mr. Mark Bezilla
Site Vice President
FirstEnergy Nuclear Operating Co.
Davis-Besse Nuclear Power Station
5501 N. State Rte. 2, Mail Stop A-DB-3080
Oak Harbor, OH 43449-9760
SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1REQUEST FOR
INFORMATION FOR AN NRC DESIGN BASES ASSURANCE INSPECTION
(PROGRAM): IMPLEMENTATION OF THE ENVIRONMENTAL QUALIFICATION
PROGRAM; INSPECTION REPORT 05000346/2019012
Dear Mr. Arnone:
On October 21, 2019, the U. S. Nuclear Regulatory Commission (NRC) will begin a triennial
baseline Design Bases Assurance Inspection (Program) at Davis-Besse Nuclear Power Station,
Unit 1. 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 two weeks onsite. The inspection team will consist of three NRC
inspectors. The current inspection schedule is as follows:
Team preparation week: October 15-18, 2019
Onsite inspection weeks: October 21-25, 2019; and
November 4-8, 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.
M. Bezilla
-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 August 9, 2019. The lead inspector will communicate the initial selected
EQ components no later than August 23, 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 September 30, 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 October 21, 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 Gerry Wolf 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.
M. Bezilla
-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/
Néstor J. Féliz Adorno, Senior Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-346
License No. NPF-3
Enclosure:
Document Request for Design Bases
Assurance Inspection EQ Program
cc: Distribution via LISTSERV
M. Bezilla
-4-
Letter to Mark Bezilla from Néstor J. Féliz Adorno dated July 8, 2019.
SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1REQUEST FOR
INFORMATION FOR AN NRC DESIGN BASES ASSURANCE INSPECTION
(PROGRAM): IMPLEMENTATION OF THE ENVIRONMENTAL QUALIFICATION
PROGRAM; INSPECTION REPORT 05000346/2019012
DISTRIBUTION:
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ADAMS Accession Number: ML19190A137
OFFICE
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NAME
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DATE
07/08/19
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
Enclosure
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
Onsite Inspection Dates:
October 21-25, 2019; and November 4-8, 2019
Inspection Procedure:
71111.21N, Design Bases Assurance Inspection (Program),
Attachment 1, Environmental Qualification (EQ) under
10 CFR 50.49 Programs, Processes, and Procedures
Lead Inspector:
Néstor J. Féliz Adorno, Senior Reactor Inspector, RIII/DRS
630-829-9739
Nestor.Feliz-Adorno@nrc.gov
Teammate Inspectors:
Benny Jose, Senior Reactor Engineer, RIII/DRS
Ijaz Hafeez, Reactor Engineer, RIII/DRS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by September 30, 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 1:00 pm 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).
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
2
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 August 9, 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 (RAW). 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.
EQ Design Basis Document, if applicable.
1.8.
Any open licensing commitments related to EQ, if applicable.
1.9.
Equipment Qualification Master List. Specific issues to be identified include:
safety classification (safety-related or nonsafety-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.
1.10. List of any installed equipment removed from the Equipment Qualification Master List
and basis for removal.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
3
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 September 30, 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.
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.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
4
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 October 15, 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.