ML21085A858

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Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000263/2021010
ML21085A858
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 03/26/2021
From: Atif Shaikh
Division of Reactor Safety III
To: Conboy T
Northern States Power Company, Minnesota
References
IR 2021010
Download: ML21085A858 (10)


See also: IR 05000263/2021010

Text

March 26, 2021

Mr. Thomas Conboy

Site Vice President

Monticello Nuclear Generating Plant

Northern States Power Company, Minnesota

2807 West County Road 75

Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCELAR GENERATING PLANT - REQUEST FOR

INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES

ASSURANCE INSPECTION (TEAM): INSPECTION REPORT

05000263/2021010

Dear Mr. Conboy:

On August 16, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial

baseline Design Bases Assurance Inspection (Team) at Monticello Nuclear Generating 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:

August 9 - 13, 2021

Onsite weeks:

August 16 - 20, 2021, and August 30 - September 3, 2021

T. Conboy

-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 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

June 11, 2021. The lead inspector will communicate the initial selected set of

samples no later than July 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 July 30, 2021. 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

August 16, 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. A. Shaikh. We understand that our licensing contact

for this inspection is Mr. G. Hernandez of your organization. If there are any questions about

the inspection or the material requested in the enclosure, please contact the lead inspector at

630-829-9824 or via e-mail at Atif.Shaikh@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.

T. Conboy

-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/

Atif Shaikh, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket No. 50-263

License No. DPR-22

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

T. Conboy

-4-

Letter to Thomas Conboy from Atif Shaikh dated March 26, 2021.

SUBJECT:

MONTICELLO NUCELAR GENERATING PLANT - REQUEST FOR

INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES

ASSURANCE INSPECTION (TEAM): INSPECTION REPORT

05000263/2021010

DISTRIBUTION:

Brett Titus

Mark Haire

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RidsNrrDroIrib Resource

John Giessner

Kenneth OBrien

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML21085A858

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

OFFICE

RIII

RIII

NAME

LKozak:mb via

e-mail

AShaikh via

e-mail

DATE

03/26/2021

03/26/2021

OFFICIAL RECORD COPY

Enclosure

DESIGN BASES ASSURANCE INSPECTION (TEAMS) REQUEST FOR INFORMATION

I.

ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number:

05000263/2021010

Onsite Inspection Dates:

August 16 - 20, 2021; and August 30 - September 3, 2021

Inspection Procedure:

IP 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector:

Atif Shaikh, Senior Reactor Inspector, DRS

630-829-9824

Atif.Shaikh@nrc.gov

Teammates:

Robert Daley, Senior Reactor Inspector, RIII/DRS

Joon Park, Reactor Inspector, RIII/DRS

Javier Branch, Reactor Inspector, RI/DRS

Susan Gardner, Electrical Engineering Contractor

TBD

II. LOGISTICS

Email the following inspection logistics to the lead inspector by July 30, 2021, 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

onsite 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.

2

1. Information Requested for Selection of Components/Modifications

The following information is requested by June 11, 2021, or sooner, to facilitate the initial

sample selection.

Note: If you are unable to provide items 1.1. through 1.6.3. as requested, please reach

out to the Team Lead as soon as possible.

1.1. Risk-ranking of top 500 components from your site-specific probabilistic safety

analysis (PSA) sorted by Birnbaum Importance. Include values for Risk

Achievement Worth (RAW), Risk-Reduction Worth, and Fussell-Veseley. Please

provide the ranking in an Excel spreadsheet that contains the importance

measures and the description of the basic event (e.g., not just the basic event

designator).

1.2. Risk-ranking of top 500 components (i.e. Large Early Release Frequency (LERF))

from your site-specific PSA similar to the request in item 1.1.

1.3. Provide a list of the top 500 cut-sets from your PSA. Provide the descriptions of

the basic events in the list of cut-sets. (Provide in Excel format.)

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.

(Provide in Excel format.)

1.5. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook,

Internal Flood scenario notebook, and latest internal event PSA summary

document.

1.6. For the Fire PSA Model:

1.6.1

Provide the fire Probabilistic Risk Analysis (PRA) quantification notebook.

1.6.2

Provide importance measures ranked preferably by Birnbaum but if not

available by RAW for the top 500 basic events for the fire PRA. (Provide in

Excel format.)

1.7. Provide copies of the emergency operating procedures and abnormal operating

procedures.

1.8. 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).

1.9. 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).

1.10. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)

category for the last 3 years.

3

1.11. A list of operating experience evaluations for the last 3 years.

1.12. Information of any common cause failure of components experienced in the last

5 years at your facility.

1.13. List of Root Cause Evaluations associated with component failures or design issues

initiated/completed in the last 5 years.

1.14. List of open operability evaluations.

1.15. List of permanent plant modifications to SSCs that are field work complete. For

the purpose of this inspection, permanent plant modifications include permanent:

1.15.1 Plant changes, design changes, set point changes, completed in the last

5 years;

1.15.2 Equivalency evaluations, suitability analyses, and commercial grade

dedications completed in the last 3 years;

1.15.3 Procedure changes for Emergency Operating Procedures (EOPs),

Abnormal Operating Procedures (AOPs), surveillances, and test

procedures in the last 3 years; and

1.15.4 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.

1.16. List of all time critical and/or risk significant operator actions. Identify those actions

that do not have job performance measures.

1.17. Copies of procedures addressing the following: modifications, design changes, set

point changes, equivalency evaluations or suitability analyses, commercial grade

dedications, and post-modification testing.

1.18. 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.

1.19. Electronic copies of Updated Final Safety Analysis Report, Technical

Specifications, Technical Specifications Bases, and Technical Requirements

Manual.

1.20. Electronic copies of simplified plant drawings (if available). Note: these may be

uncontrolled documents such as big notes, training diagrams. etc.

4

2. Information Requested (for the approximate seven selected components and

seven selected modifications) to Be Available by July 30, 2021, (will be reviewed

by the team in the Regional office during the week of August 9, 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.

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 IST, other vibration

monitoring, oil sample results, etc., for valves: stroke time and leak rate results,

diagnostic trend data, etc.).

5

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.

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 August 16, 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 2:00 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.

6

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.