ML20055D853

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Request for Information to Support Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05-277/20-011 and 05-278/20-011
ML20055D853
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 02/24/2020
From: Mel Gray
Engineering Region 1 Branch 1
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Gray M
References
IR 2020011
Download: ML20055D853 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PENNSLYVANIA 19406-2713 February 24, 2020 Mr. Bryan C. Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - REQUEST FOR INFORMATION TO SUPPORT TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM); INSPECTION REPORT 05000277/2020011 AND 05000278/2020011

Dear Mr. Hanson:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region I staff will conduct a Design Bases Assurance Inspection (DBAI) at Peach Bottom Atomic Power Station, Units 2 and 3. Joe Schoppy, a Senior Reactor Inspector from the NRCs Region I Office, will lead the inspection team. The inspection will be conducted in accordance with Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team), dated December 8, 2016 (ADAMS Accession No. ML16340B000).

The inspection will evaluate the capability of risk-significant/low-margin components to function as designed to support proper system operation. The inspection will also include a review of selected modifications, operating experience, and as applicable, operator actions.

During an onsite conversation on February 18, with Dan Dullum, we confirmed arrangements for an information-gathering site visit and the two-week onsite inspection. The schedule is as follows:

Information-gathering visit: Week of April 20 Onsite weeks: Weeks of July 13, and July 27 The purpose of the information-gathering visit is to meet with members of your staff to identify risk-significant components, modifications, operator actions, and operating experience items.

Information and documentation needed to support the inspection will also be identified.

Frank Arner, a Region I Senior Risk Analyst, will support Joe Schoppy during the information-gathering visit to review probabilistic risk assessment data and identify components to be examined during the inspection.

Experience with previous baseline design/modification inspections of similar depth and length has shown this type of inspection is 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.

2 B. Hanson 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 two groups:

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

This information should be provided to the lead inspector by April 20. By April 27, the lead inspector will communicate the initial selected set of components and modifications.

The second group of documents requested are needed to support our in-office preparation activities. This set of documents, specific to the selected components and modifications, should be provided to the lead inspector at the Region I Office no later than July 6. During the in-office preparation activities, the team may identify additional information needed to support the inspection, and those items will be communicated directly to Dan Dullum.

If there are any questions about the inspection or the material requested in the enclosure, please contact the lead inspector at 610-337-5286 or via e-mail at jgs@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/

Mel Gray, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56

Enclosure:

Document Request for Design Bases Assurance Inspection cc: Distribution via ListServ

ML20055D853 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE NAME JSchoppy/JS FArner/FJA MGray/MG DATE 02/18/2020 02/19/2020 02/24/2020 DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION Inspection Report: 05000277/2020011 and 05000278/2020011 Onsite Inspection Dates: July 13, through July 17; and July 27, through July 31 Inspection Procedure: Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector: Joe Schoppy, Senior Reactor Inspector Phone: 610-337-5286 Email: jgs@nrc.gov I. Information Requested for Selection of Components and Modifications The following information is requested by April 20 to facilitate inspection preparation. Feel free to contact the lead inspector as soon as possible if you have any questions regarding this information request. 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 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. The site probabilistic risk analysis (PRA) System Notebook and latest PRA Summary Document.
2. Risk ranking of top 250 basic events sorted by Risk Achievement Worth (>/= 1.3).

Include values for Risk Reduction Worth, Birnbaum Importance, and Fussell-Vesely (as applicable). Please provide in an excel spreadsheet or other sortable format and include an understandable definition of the coded basic events.

3. Risk-ranking of top 100 components from site specific PRA sorted by Large Early Release Frequency.
4. If you have an External Events PRA Model, provide the information requested in Item 2 for external events. Provide narrative description of each coded event, including flood zone description.
5. List of time-critical and/or risk significant operator actions.
6. List of emergency and abnormal operating procedures.
7. If available, any pre-existing evaluation or list of components and associated calculations with low design margins (e.g., 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).

Enclosure 1

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

8. If applicable, copy of any self-assessments and/or Quality Assurance assessments of low margin structures, systems and components (SSCs) completed since February 10, 2017.
9. List of available design margins in both the open and closed direction for valves in the motor-operated valve and air-operated valve programs (related to GL 96-05, looking for resultant output - matrix of risk vs margin for MOVs and AOVs, as applicable).
10. The age and capacity of the safety-related DC batteries.
11. The In-Service Testing (IST) Program Basis document identifying the in-scope valves and pumps, and the associated IST Program requirements for each component (e.g., IST valve table identifying category, active/passive function).
12. Access to IST trend data for the following pumps for both units: RHR pumps, HPCI pumps, RCIC pumps, SLC pumps, HPSW pumps, and ESW pumps. [Note: needed for each discrete component (e.g. for each RHR pump)]
13. Listing of MR (a)(1) systems, date entered into (a)(1) status, and brief description of why in (a)(1) status.
14. List of Maintenance Rule Functional Failure (MRFF) evaluations completed since February 10, 2017 (include those determined not to be a MRFF).
15. A copy of the most recent System Health and/or trending reports for the following systems (as applicable): Safety Related (SR) 4KV, SR 480 Vac, HPCI, RCIC, RHR, HPSW, ESW, SR 125 Vdc, SR 250 Vdc, SLC, and EDGs.
16. A copy of the most recent Program Health and/or trending reports for the following programs, as applicable: GL 89-10 (MOVs), GL 89-13, IST, AOVs, breakers, relays.
17. List of open operability evaluations.
18. List of current operator work arounds/burdens.
19. List of permanent plant modifications to SSCs that are field work complete since February 10, 2017. 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 (sufficient to understand the purpose of the modification), revision/date, and the affected system.

20. List of calculation changes (including new calculations) that have been issued for use since February 10, 2017.
21. Corrective Action Program procedure.

Enclosure 2

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

22. Procedures addressing the following: modifications, design changes, set point changes, equivalency evaluations or suitability analyses, commercial grade dedications, and post-modification testing.
23. List of corrective action documents (open and closed) since February 10, 2017, that address permanent plant modifications issues, concerns, or processes.
24. Any internal/external self-assessments and associated corrective action documents generated in preparation for this inspection.
25. Updated Final Safety Analysis Report, Technical Specifications, Technical Specifications Bases, and Technical Requirements Manual.
26. Electrical simple one-line drawings for 4KV, 480V, 500KV, 230KV & 13KV (page size of 11 X 17 preferred).
27. Copy of Exelons internal response to the following NRC Information Notices: 2017-03, 2017-05 (and 2017-05 Rev. 1), 2018-07, and 2019-02.
28. A list of NRC Part 21 Reports, determined to be applicable to Peach Bottom, since February 10, 2017.
29. An electronic copy of the following Design Basis Documents (DBDs) (if applicable &

available): SR 4KV, SR 480 Vac, HPCI, RCIC, RHR, HPSW, ESW, SR 125 Vdc, SR 250 Vdc, SLC, and EDGs.

II. Information Requested to Be Available by July 6 This information should be separated for each selected component and modification, especially if provided electronically (e.g., a folder for each component and modification named after the component or modification that includes the information requested below).

Items 1 through 11 are associated with the selected components and Item 12 is for the selected modifications.

1. List of corrective action documents associated with each selected component since February 10, 2017.
2. Maintenance history (e.g., corrective, preventive, and elective) associated with each selected component for the last five years. Identify frequency of preventive maintenance activities.
3. Aging Management Program documents and/or License Renewal committed inspection results applicable to each selected component.
4. List of calculations associated with each selected component, excluding data files.

Pipe stress calculations are excluded from this request.

5. System Health Report (last completed) and Design Basis Document associated with each selected component, as applicable.

Enclosure 3

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

6. Access to or copy of vendor manual(s) for each selected component.
7. List of open temporary modifications associated with each selected component, if applicable.
8. Trend data/graphs on the selected components performance since February 10, 2017 (e.g., pump performance including IST, other vibration monitoring, oil sample results).
9. List of normal operating and alarm response procedures associated with each selected component.
10. Last completed tests and surveillances for each selected component performed since February 10, 2017. For those tests and surveillances performed at a periodicity of greater than three years, provide the latest test performed.
11. Schedule of surveillance testing of selected components that occur during the onsite inspection weeks.
12. For each selected modification, copies of associated documents such as modification package, engineering changes, 50.59 screening or evaluation, relevant calculations, post-modification test packages, associated corrective action documents, design drawings, and new/revised preventive maintenance requirements.

Enclosure 4