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Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000255/2020011
	ML19357A275
Person / Time
Site:	Palisades
Issue date:	12/23/2019
From:	Benny Jose; NRC/RGN-III
To:	Corbin D; Entergy Nuclear Operations
References
	IR 2020011
	Download: ML19357A275 (8)
	v • d • e

December 23, 2019

Mr. Darrell Corbin

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 FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000255/2020011

Dear Mr. Corbin:

On March 2, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin a

Triennial Baseline Design Bases Assurance Inspection (Team) at Palisades Nuclear

Plant. 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 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: February 24 - 28, 2020

Onsite weeks: March 2 - 6, 2020; and

March 16 - 20, 2020.

D. Corbin -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 activities.

This information should be provided to the lead inspector no later than January 24, 2020.

By January 31, 2020, 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 17, 2020. 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 2, 2020. 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 Benny Jose. We understand that our licensing contact

for this inspection is Barbara 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

630-829-9756 or via e-mail at benny.jose@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.

D. Corbin -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/

Benny Jose, Senior Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket No. 05000255

License No. DPR-20

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

D. Corbin -4-

Letter to Darrell Corbin from Benny Jose dated December 23 2019.

SUBJECT: PALISADES NUCLEAR PLANT REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000255/2020011

DISTRIBUTION:

Jessie Quichocho

RidsNrrPMPalisades Resource

RidsNrrDorlLpl3

RidsNrrDroIrib Resource

DRPIII

DRSIII

ADAMS Accession Number: ML19357A275

OFFICE RIII

NAME BJose:jw

DATE 12/23/2019

OFFICIAL RECORD COPY

DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

Inspection Report: 05000255/2020011

Inspection Dates: March 2 - 6, 2020; and

March 16 - 20, 2020.

Inspection Procedure: IP 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector: Benny Jose, Senior Reactor Engineer, DRS

630-829-9756

benny.jose@nrc.gov

I. Information Requested for Selection of Components/Modifications

The following information is requested by January 24, 2020, 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 100 components from your site-specific probabilistic safety

analysis (PSA) sorted by Risk-Achievement Worth (RAW). Include values for

Birnbaum Importance, Risk-Reduction Worth, and Fussell-Veseley (as applicable).

2. Risk-ranking of top 25 containment-related components (i.e., Large Early Release

Frequency (LERF)) from your site-specific PSA sorted by RAW. See examples in

Inspection Manual Chapter 0609, Appendix H, Table 4.1, Containment-Related

Structures, Systems, and Components (SSCs) Considered for LERF Implications.

3. Provide a list of the top 100 cut-sets from your PSA.

4. Provide a list of the top 25 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. 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.).

Enclosure

DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

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. The 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.

22. A list of corrective action documents (open and closed) in the last 3 years that

address permanent plant modification 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 (P&IDs) (if available).

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

II. Information Requested (for the approximate 7 selected components and

7 selected modifications) to be Available by February 17, 2020, (will be reviewed

by the team in the Regional office during the week of February 24, 2020).

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 3 years.

2. The maintenance history (corrective, preventive, and elective) associated with each

of the selected components for the last 3 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.

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.

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.

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

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 2, 2020 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 24, 2020.

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 P&IDs (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.

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ML19357A275

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