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Ltr. 07/08/19 Davis-Besse Nuclear Power Station, Unit 1 - Request for Information for an NRC Design Bases Assurance Inspection (Program): Implementation of the Environmental Qualification Program; Inspection Report 05000346/2019012 (DRS-N.F
	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)
	v • d • e

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:

Douglas Dodson

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DRPIII

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ADAMS Accession Number: ML19190A137

OFFICE RIII

NAME NFelizAdorno:cl

DATE 07/08/19

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000346/2019012

Onsite Inspection Dates: October 21-25, 2019; and November 4-8, 2019

71111.21N, Design Bases Assurance Inspection (Program),

Inspection Procedure: Attachment 1, Environmental Qualification (EQ) under

10 CFR 50.49 Programs, Processes, and Procedures

Néstor J. Féliz Adorno, Senior Reactor Inspector, RIII/DRS

Lead Inspector: 630-829-9739

Nestor.Feliz-Adorno@nrc.gov

Benny Jose, Senior Reactor Engineer, RIII/DRS

Teammate Inspectors:

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).

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 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.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

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.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

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.

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ML19190A137

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