ML20302A460
| ML20302A460 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/28/2020 |
| From: | Jorge Corujo-Sandin NRC/RGN-III/DRS/EB2 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2021010 | |
| Download: ML20302A460 (9) | |
See also: IR 05000237/2021010
Text
October 28, 2020
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Co., LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR
INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES
ASSURANCE INSPECTION (TEAM): INSPECTION REPORT 05000237/2021010;
Dear Mr. Hanson:
On January 11, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial baseline
Design Bases Assurance Inspection (Team) at Dresden Nuclear Power Station. 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 in-office 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: January 4 - 8, 2021
- Onsite weeks: January 11 - 15, 2021; and January 25 - 29, 2021
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.
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 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 November 13, 2020.
The lead inspector will communicate the initial selected set of samples no later than
December 2, 2021.
- 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 no
later than December 29, 2020. 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 as well as plant specific reference
material. This information should be available to the team onsite on January 11, 2021.
- 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 Mr. J. Corujo-Sandin. We understand that our licensing
contact for this inspection is Mr. D. Walker of your organization. If there are any questions about the
inspection or the material requested in the enclosure, please contact the lead inspector at
630-829-9741 or via e-mail at Jorge.Corujo-Sandin@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.
B. Hanson -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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jorge Corujo-Sandin, Senior Reactor Engineer
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-237 and 50-249
License Nos. DPR-19 and DPR-25
Enclosure:
Design Bases Assurance Inspection
Document Request
cc: Distribution via LISTSERV
B. Hanson -4-
Letter to Bryan C. Hanson from Jorge Corujo-Sandin dated October 28, 2020.
SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR
INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES
ASSURANCE INSPECTION (TEAM): INSPECTION REPORT 05000237/2021010;
DISTRIBUTION:
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RidsNrrPMDresden Resource
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Kenneth OBrien
DRPIII
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ADAMS Accession Number: ML20302A460
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII
NAME JCorujo-Sandin:mb
via e-mail
DATE 10/28/2020
OFFICIAL RECORD COPY
DESIGN BASES ASSURANCE INSPECTION (TEAMS)
REQUEST FOR INFORMATION
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000237/2021010; 05000249/2021010
Onsite Inspection Dates: January 11-15, 2021; and January 25-29, 2021
Inspection Procedure: IP 71111.21M, Design Bases Assurance Inspection (Team)
Jorge Corujo-Sandin, Senior Reactor Inspector, DRS
Lead Inspector: 630-829-9741
Jorge.Corujo-Sandin@nrc.gov
Jamie Benjamin, Senior Reactor Inspector, RIII/DRS
Robert Daley, Senior Reactor Inspector, RIII/DRS
Teammates: Mel Holmberg, Senior Reactor Inspector, RIII/DRS
Joon Park, Reactor Inspector, RIII/DRS
Kevin Barclay, Reactor Inspector, RIII/DRS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by December 11, 2020, or sooner:
1. Entrance meeting time and location.
2. Current management and engineering organizational chart.
3. Response team contact information (names and phone numbers) and team roles (e.g.,
management sponsor, lead, inspector counterpart).
4. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff
meetings).
Due to the ongoing COVID-19 situation, additional logistics related with inspector presence on-site
will be coordinated closer to the actual start of the inspection. Reach out to the Team Lead for
questions or comments.
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 via an electronic sharing service (CERTREC, ShareFile, Box, etc.). If you do
not have access to any of these services or similar, we can provide you access to Box, which
can be used to upload/download and share documents. 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.
Enclosure
1. Information Requested for Selection of Components/Modifications
The following information is requested by November 13, 2020, or sooner, to facilitate the initial
sample selection.
1.1. Risk-ranking of top 250 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).
Provide any basic event mapping used to develop the ranking of components.
1.2. Risk-ranking of top 100 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
SSCs Considered for LERF Implications. Provide any basic event mapping used to
develop the ranking of components.
1.3. Provide a list of the top 200 cut-sets from your PSA. Provide the descriptions of the
basic events in the list of cut-sets.
1.4. Provide a list of the top 100 cut-sets for each initiator modeled in the PSA that
contributes more than 5 percent to the baseline plant core damage frequency.
1.5. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook, and
latest PSA summary document.
1.6. 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).
1.7. Provide copies of the emergency operating procedures and abnormal operating
procedures.
1.8. Electronic copy of the site Individual Plant Examination of External Events, if
available.
1.9. Provide the in-service testing program (IST) 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).
1.10. 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).
1.11. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)
category for the last 3 years.
1.12. A list of operating experience evaluations for the last 3 years.
1.13. Information of any common cause failure of components experienced in the last
5 years at your facility.
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1.14. List of Root Cause Evaluations associated with component failures or design issues
initiated/completed in the last 5 years.
1.15. List of open operability evaluations.
1.16. List of permanent plant modifications to SSCs that are field work complete. For the
purpose of this inspection, permanent plant modifications include permanent:
1.16.1 Plant changes, design changes, set point changes, completed in the last 5 years;
1.16.2 Equivalency evaluations, suitability analyses, and commercial grade dedications
completed in the last 3 years;
1.16.3 Procedure changes for Emergency Operating Procedures (EOPs), Abnormal
Operating Procedures (AOPs), surveillances, and test procedures in the last
3 years; and
1.16.4 Calculation changes that have been issued for use in the last 3 years.
Note: Items 1.16.1. through 1.16.4. should be provided as separate, individual lists and
each list should contain the number of each document, title, revision/date, and the affected
system.
1.17. List of all time critical and/or risk significant operator actions. Identify those actions
that do not have job performance measures.
1.18. Copies of procedures addressing the following: modifications, design changes, set
point changes, equivalency evaluations or suitability analyses, commercial grade
dedications, and post-modification testing.
1.19. A list of corrective action documents (open and closed) in the last 3 years that
address permanent plant modifications issues, concerns, or processes. These
documents should also include the corrective action documents associated with the
modification implementation.
1.20. Electronic copies of Updated Final Safety Analysis Report, Technical Specifications,
Technical Specifications Bases, and Technical Requirements Manual.
1.21. Electronic copies of simplified plant drawings (if available). Note: these may be
uncontrolled documents such as big notes, training diagrams, etc.
2. Information Requested (for the approximate 7 selected components and 7
selected modifications) to be Available by December 29, 2020, (will be reviewed
by the team in the Regional office during the week of January 4, 2021).
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 2.1-2.16 are associated with
the selected components and item 2.17 for the selected modifications.
2.1. List of condition reports (corrective action documents) associated with each of the
selected components for the last 6 years.
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2.2. The maintenance history (corrective, preventive, and elective) associated with each
of the selected components for the last 10 years. Identify frequency of preventive
maintenance activities.
2.3. Aging Management Program documents applicable to each selected component.
2.4. Copies of calculations associated with each of the selected components, excluding
data files. [Pipe stress calculations excluded from this request].
2.5. Provide an all-inclusive list of calculation revisions in effect associated with each of
the selected components. Include document number, title, and revision number.
2.6. Electronic copies of electrical drawings (ac and dc) and key diagrams.
2.7. Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available).
2.8. System Health Reports, System Descriptions, Design Basis Documents, and/or
Training Lesson Plans associated with each of the selected components.
2.9. 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.
2.10. Copies of operability evaluations (open/closed for last 3 years) associated with each
of the selected components and plans for restoring operability, if applicable.
2.11. Copies of selected operator work-around evaluations associated with each of the
selected components and plans for resolution, if applicable.
2.12. Copies of any open temporary modifications associated with each of the selected
components, if applicable.
2.13. 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.).
2.14. Provide copies of the normal and alarm response procedures associated with the
selected components and selected scenarios.
2.15. Procedures addressing time critical and/or risk significant operator actions.
2.16. Completed tests and surveillances for each selected component performed during
the last 3 years. For those tests and surveillances performed at a periodicity of
greater than 3 years, provide the latest two performed. Include the associated
acceptance criteria basis calculations.
2.17. 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.
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2.18. Corrective Action Program procedures, including the operability/functionality
determination procedure.
2.19. Quality Assurance Program document/procedure.
2.20. A copy of any internal/external self-assessments and associated corrective action
documents generated in preparation for the inspection.
2.21. A copy of engineering/operations related audits completed in the last 2 years.
3. Additional Information to be Provided on January 11, 2021 Onsite (for final
selected components and modifications)
3.1. During the in-office preparation activities, the team will be making final selections and
may identify additional information needed to support the inspection.
3.2. Schedule of any testing/maintenance activities to be conducted on the selected
components during the two onsite inspection weeks.
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 2:15 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.
4.3. If available in hardcopy form, one complete set of P&IDs and simplified drawings (e.g.,
training schematics). If any of these documents is not available in hardcopy form,
contact the lead inspector.
4.4. Please ensure that other supporting documents for the selected items have been
located and are readily retrievable as the inspection team will likely be requesting
these documents during the inspection. Examples of supporting documents are:
4.4.1 Individual Plant Examination/Probabilistic Risk Assessment report;
4.4.2 Procurement documents for components and modifications selected (verify
retrievable);
4.4.3 Plant procedures (normal, abnormal, emergency, surveillance, etc.);
4.4.4 Vendor manuals;
4.4.5 Historical revisions of the Final Safety Analysis Report; and
4.4.6 Copy of electrical drawings, key diagrams and isometrics (paper copies).
If you have questions regarding the information requested, please contact the lead inspector.
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