ML20027D540

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Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information; Inspection Report 05000461/2020002
ML20027D540
Person / Time
Site: Clinton Constellation icon.png
Issue date: 01/27/2020
From: Lionel Rodriguez
NRC/RGN-III
To: Bryan Hanson
Exelon Generation Co
References
IR 2020002
Download: ML20027D540 (8)


See also: IR 05000461/2020002

Text

January 27, 2020

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATIONNOTIFICATION OF AN NRC TRIENNIAL HEAT

SINK PERFORMANCE INSPECTION AND REQUEST FOR INFORMATION;

INSPECTION REPORT 05000461/2020002

Dear Mr. Hanson:

On April 6, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite

portion of the Triennial Heat Sink Performance inspection at your Clinton Power Station. This

inspection will be performed in accordance with NRC Baseline Inspection Procedure 71111.07.

In order to minimize the impact that the inspection has on the site and to ensure a

productive inspection, we have enclosed a request for documents needed for the

inspection. The documents have been divided into two groups.

The first group lists information necessary for our initial inspection scoping activities.

This information should be available to the lead inspector no later than February 25, 2020.

By February 28, 2020, the inspector will communicate the initial selected set of

approximately 2-3 risk significant heat exchangers.

The second group is needed to support our in-office preparation activities. This set of

documents, including the calculations associated with the selected heat exchangers,

should be available to the inspector no later than March 27, 2020. This information

should be separated for each selected component, especially if provided electronically

(e.g., folder with component name that includes calculations, condition reports, maintenance

history, etc.). During the in-office preparation activities, the inspector may identify additional

information needed to support the inspection.

It is also requested that corrective action documents and/or responses developed during the

inspection be provided to the inspector as the documents are generated.

All requested documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous Heat Sink Performance

inspection. If no activities were accomplished in that time period, then the request applies to the

last applicable document in the previous time period. It is important that these documents be as

complete as possible, in order to minimize the number of documents requested during the

preparation week or during the onsite inspection.

B. Hanson

-2-

The lead inspector for this inspection is Lionel Rodriguez. We understand that our licensing

contact for this inspection is Nicholas Santos 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) 829-9609 or via e-mail at Lionel.Rodriguez@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.

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/

Lionel Rodriguez, Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Triennial Heat Sink Performance

Inspection Document Request

cc: Distribution via LISTSERV

B. Hanson

-3-

Letter to Bryan C. Hanson from Lionel Rodriguez dated January 27, 2020.

SUBJECT: CLINTON POWER STATIONNOTIFICATION OF AN NRC TRIENNIAL HEAT

SINK PERFORMANCE INSPECTION AND REQUEST FOR INFORMATION;

INSPECTION REPORT 05000461/2020002

DISTRIBUTION:

Jessie Quichocho

Omar Lopez-Santiago

RidsNrrDorlLpl3

RidsNrrPMClinton Resource

RidsNrrDroIrib Resource

Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRSIII

DRPIII

ADAMS Accession Number: ML20027D540

OFFICE

RIII

NAME

LRodriguez:jw

DATE

01/27/20

OFFICIAL RECORD COPY

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000461/2020002

Inspection Dates:

April 6-10, 2020

Inspection Procedure:

IP 71111.07, Heat Sink Performance

Lead Inspector:

Lionel Rodriguez

(630) 829-9609

Lionel.Rodriguez@nrc.gov

Please provide the information electronically in pdf files, Excel, or other searchable formats,

preferably on some portable electronic media (e.g., CD-ROM, DVD). The portable electronic

media should contain descriptive names, and be indexed and hyperlinked to facilitate ease of

use. The information can also be provided via an internet file sharing system, so long as the

inspectors are provided access to the system throughout the inspection process and the system

allows the files to be downloaded. Information in lists should contain enough information to be

easily understood by someone who has knowledge of light water reactor technology.

I.

Information Requested by February 25, 2020

1.

List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting

Safety-Related Equipment, heat exchangers in order of risk significance.

2.

Copy of heat exchanger performance trending data tracked for each GL 89-13 heat

exchanger.

3.

List of Corrective Action Program (CAP) documents (with a short description)

associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling,

aging, heat exchanger testing, ultimate heat sink (UHS), and safety-related service

water systems for the previous three years or since the last CAP document list was

sent to the U.S. Nuclear Regulatory Commission for the previous heat sink

performance inspection. The list should include all corrective action program

documents not on the last CAP document list.

4.

Copy of any self-assessment done on any of the GL 89-13 heat exchangers, UHS,

and safety-related service water systems since the last heat sink performance

inspection.

5.

Last two System Health Report(s) and maintenance rule system notebooks for all

the GL 89-13 heat exchangers, UHS, and safety-related service water systems.

6.

List of engineering-related operator workarounds (with a short description)

associated with GL 89-13 heat exchangers. The requested documents are to be for

the time period from the onsite inspection period back to the documents that were

provided in response to the previous heat sink performance inspection.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

2

7.

List of permanent and temporary modifications (with a short description) associated

with GL 89-13 heat exchangers, UHS, and safety-related service water systems.

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous heat

sink performance inspection.

8.

A schedule of all inspections, cleanings, maintenance, or testing of any

safety-related plant heat exchanger to be performed during the on-site portion

of the inspection.

9.

Electronic copies of the current Final Safety Analysis Report (FSAR), Technical

Specifications, Technical Specifications Basis, and Technical Report Manual.

Information Requested by March 27, 2020

1.

Copies of the GL 89-13 responses.

2.

Copies of procedures developed to implement the recommendations of GL 89-13

(e.g., the GL 89-13 Heat Exchanger Program description).

3.

For the specific heat exchangers selected:

a. Copy of system description and design basis document for the heat exchangers

(as applicable).

b. Copy of the design specification, heat exchanger data sheets, and vendor

documents including component drawings applicable for the selected heat

exchangers.

c. Copies of normal, abnormal, and emergency operating procedures associated

with the selected heat exchangers.

d. Copy of the operating procedure that ensures that the maximum cooling water

system inlet temperature limit is not exceeded.

e. Copies of the Aging Management Programs (AMP) and the implementing

procedures that manage aging of the selected heat exchangers (as applicable).

f. Information regarding any alarms which monitor on-line performance.

g. Copy of the document which identifies the current number of tubes in service for

each heat exchanger.

h. Provide a list of calculations (with a short description) which currently apply to

each heat exchanger.

i.

Provide the calculations or evaluations that:

i. establish the limiting (maximum) design basis heat load required to be

removed by each of these heat exchangers;

ii. demonstrate the heat exchangers capacity to remove the limiting heat

load;

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

3

iii. correlate surveillance testing and/or inspection results from these heat

exchangers with design basis heat removal capability (e.g., basis for

surveillance test and/or inspection acceptance criteria);

iv. establish the maximum number of tubes which can be plugged in each

heat exchanger;

v. evaluate the potential for water hammer in each heat exchanger or

associated piping; and

vi. evaluate excessive tube vibration in each heat exchanger and the

documents that describe the controls that prevent heat exchanger

degradation due to excessive flow induced vibration during operation.

j.

Copies of the two most recent completed tests and evaluation data confirming

thermal performance for those heat exchangers which are performance tested.

Include documentation and procedures that identify the types, accuracy, and

location of any special instrumentation used for the two most recently completed

thermal performance tests for the heat exchangers (e.g., high accuracy ultrasonic

flow instruments or temperature instruments). Include calibration records for the

instruments used during these tests.

k. Copy of the document describing the inspection results of each heat exchanger.

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

l.

Copies of the documents that verify the structural integrity of the heat exchanger

(e.g., eddy current summary sheets, ultrasonic testing results, and visual

inspection results).

m. The thermal performance testing, cleaning, and inspection maintenance

schedule for each heat exchanger for the next 5 years.

n. Copy of the periodic flow testing at or near maximum design flow. The requested

documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink

performance inspection.

o. Copies of those documents that describe the methods taken to control water

chemistry in the heat exchangers.

p. Copy of any operability determinations or other documentation of degradation

associated with the heat exchangers or the systems that support the operation

for the selected heat exchangers.

4.

For the ultimate heat sink (UHS) and the safety-related service water systems

(or equivalent):

a. Copy of system description and design basis document (as applicable).

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

4

b. Copy of any operability determinations or other documentation of degradation

associated with the UHS and the safety-related service water systems.

c. Copy of the document (e.g., UFSAR or Technical Requirements Manual) that

states the maximum cooling water system inlet temperature limit that still allows

full licensed power operation of the nuclear reactor.

d. Copy of the construction code and design specification.

e. Copies of normal, abnormal, and emergency operating procedures associated

with the UHS and safety-related service water systems including procedures for

loss of these systems.

f. Copies of the AMPs and the implementing procedures that manage aging of the

UHS (including the intake structure) and the safety-related service water systems

(as applicable).

g. Copies of CAP documents associated with water hammer or hydraulic transients

in the safety-related service water systems since the last heat sink performance

inspection.

h. If available, provide an electronic copy of piping and instrumentation diagrams

(P&IDs) for the safety-related service water systems, including the intake

structure.

i.

Provide a list of calculations (with a short description), which currently apply to

UHS and safety-related service water systems.

j.

Provide a list of instruments (with a short description) associated with automatic

or alarm functions for the UHS and safety-related service water systems.

k. Provide a list of any design change (with a short description) performed on

the UHS or safety-related service water systems since the last heat sink

performance inspection.

l.

For the review of the performance testing of the safety-related service water

system (or equivalent) and the UHS:

i. Copies of the last two performance tests, such as the ASME in-service

test (IST), for the pumps, valves, and, if applicable, the cooling tower fans

in the safety-related service water system. Include the IST program basis

document for each component. If the components are not performance

tested, please provide documentation verifying performance by the

methods actually used.

ii. Copies of the documents that demonstrate that flow balance testing was

performed during the last three years. If the last flow test was performed

longer than three years, then provide the last flow test.

iii. Copies of the documents that demonstrate that flow balance testing will

continue to be periodically done in the future.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

5

iv. Copies of procedures used to monitor interface valves between:

(1) the safety related section of the service water system and the

non-safety related section; and (2) separate trains of the service water

system (i.e., train cross tie valves). Include completed results of the

monitoring. The requested documents are to be for the time period from

the onsite inspection period back to the documents that were provided in

response to the previous heat sink performance inspection.

v. Copies of the procedures that verify the performance of risk significant

non-safety functions of the safety-related service water system (or

equivalent) and the UHS. Include completed results of the verifications.

The requested documents are to be for the time period from the onsite

inspection period back to the documents that were provided in response

to the previous heat sink performance inspection.

m. For the review associated with the system walkdown of the service water system:

i. Copies of the testing, inspection, or monitoring program results for buried

or inaccessible piping and the associated implementing procedures. The

requested documents are to be for the time period from the onsite

inspection period back to the documents that were provided in response

to the previous heat sink performance inspection.

ii. Copies of the ultrasonic test results and/or visual inspections that verify

the structural integrity of the piping.

iii. Copies of the results for monitoring, assessing, and dispositioning active

thru wall pipe leaks, including structural evaluations and/or planned

corrective actions. Include the implementing procedures.

iv. History of any thru wall pipe leak on the system. The requested

documents are to be for the time period from the onsite inspection period

back to the documents that were provided in response to the previous

heat sink performance inspection.

v. Copies of the documents associated with the periodic inspection program

used to detect protective coating failure, corrosion, and erosion.

vi. Copies of the IST vibration monitoring results and operational history for

deep draft vertical pumps, if applicable. The requested documents are

to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous heat sink

performance inspection.

If the information requested above will not be available by the dates specified, please contact

Lionel Rodriguez as soon as possible at (630) 829-9609 or e-mail Lionel.Rodriguez@nrc.gov.