ML20149K412

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Request for Information for a Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000220/2020010 and 05000410/2020010
ML20149K412
Person / Time
Site: Nine Mile Point  
Issue date: 05/29/2020
From: Mel Gray
NRC Region 1
To: Bryan Hanson
Exelon Generation Co
References
IR 2020010
Download: ML20149K412 (8)


See also: IR 05000220/2020010

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PENNSLYVANIA 19406-2713

May 29, 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:

NINE MILE POINT NUCLEAR STATION - REQUEST FOR INFORMATION FOR

A TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000220/2020010 AND 05000410/2020010

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 Nine Mile Point

Nuclear Station. 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 a phone conversation on May 21, with Denise Wolniak, Principal Regulatory Engineer,

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 August 31

Onsite weeks: Weeks of October 19 and November 2

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.

B. Hanson

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 two groups:

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

This information should be provided to the lead inspector by August 31. By

September 8, the lead inspector will communicate the initial selected set of components

and modifications.

The second group of documents requested are those items 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 Regional Office no

later than October 12. 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 Denise Wolniak.

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,

X /RA/

Signed by: Melvin K. Gray

Mel Gray, Chief

Engineering Branch 1

Division of Reactor Safety

Docket Nos. 05000220 and 05000410

License Nos. DPR-63 and NPF-69

B. Hanson

3

Enclosure:

Document Request for Design Bases

Assurance Inspection

cc: Distribution via ListServ

ML20149K412

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

OFFICE

RI/DRS

RI/DRS

RI/DRS

NAME

JSchoppy

FArner per email

MGray

DATE

5/21/20

5/26/20

5/29/20

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

Inspection Report: 05000220/2020010 and 05000410/2020010

Onsite Inspection Dates:

October 19 through October 23; and

November 2 through November 6

Inspection Procedure:

Inspection Procedure 71111.21M, Design Bases Assurance

Inspection (Team)

Lead Inspector:

Joe Schoppy, Senior Reactor Inspector

610-337-5286

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 for both units.

2.

Risk ranking of top 250 basic events sorted by Risk Achievement Worth (>/= 1.3) for

both units. 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 for both units.

4.

If you have an External Events PRA Model, provide the information requested in Item 2

for external events for both units. Provide narrative description of each coded event,

including flood zone description.

5.

List of time-critical and/or risk significant operator actions for both units.

6.

List of emergency and abnormal operating procedures for both units.

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) for both units.

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 October 5,

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) for both

units.

10. The age and capacity of the safety-related DC batteries for both units.

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) for both units.

12. Access to IST trend data for the following pumps: U1 core spray, U1 containment spray,

U1 CSS raw water, U1 DG raw water, U1 SLC, U2 HPCS, U2 LPCS, U2 LPCI, U2

RCIC, U2 SLC, and U2 SW pumps. [Note: needed for each discrete component

(e.g. for each SW pump)]

13. Listing of MR (a)(1) systems, date entered into (a)(1) status, and brief description of

why (a)(1).

14. List of MRFFs evaluations completed since October 5, 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): SR 4KV for both units, SR 600 Vac for both units, U2 HPCS,

U2 RCIC, U2 LPCS, U2 LPCI, U2 SW, U1 emergency cooling system, U1 core spray,

U1 containment spray, U1 CSS raw water, U1 DG raw water, SR 125 Vdc for both

units, SLC for both units, and EDGs for both units.

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

October 5, 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 October 5, 2017.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

21. Corrective Action Program procedure.

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 October 5, 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 for both units.

26. Electrical simple one-line drawings for U1 & U2 4KV, 600V, 345KV, and 115KV; and U2

13.8KV (11 X 17 preferred).

27. Copy of Exelons internal response to the following NRC Information Notices: 2017-03,

2018-07, and 2019-02.

28. A list of NRC Part 21 Reports, determined to be applicable to NMP, since October 5,

2017.

29. An electronic copy of the following DBDs (if applicable & available): SR 4KV for both

units, SR 600 Vac for both units, U2 HPCS, U2 RCIC, U2 LPCS, U2 LPCI, U2 SW, U1

emergency cooling system, U1 core spray, U1 containment spray, U1 CSS raw water,

U1 DG raw water, SR 125 Vdc for both units, SLC for both units, and EDGs for both

units.

II. Information Requested to Be Available by October 12

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

October 5, 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.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

5.

System Health Report (last completed) and Design Basis Document associated with

each selected component, as applicable.

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 October 5, 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

October 5, 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.