ML21099A087
| ML21099A087 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/08/2021 |
| From: | Santiago E NRC/RGN-III/DRS/EB2 |
| To: | Penfield R Energy Harbor Nuclear Corp |
| References | |
| IR 2021012 | |
| Download: ML21099A087 (9) | |
See also: IR 05000440/2021012
Text
April 8, 2021
Mr. Rod Penfield
Site Vice President
Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant
10 Center Road,
Perry, OH 44081
SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC DESIGN BASES
ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR
INFORMATION: INSPECTION REPORT 05000440/2021012
Dear Mr. Penfield:
On June 28, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline Design
Bases Assurance Inspection (Programs) at Fermi Power Plant, Unit 2. This inspection will be
performed in accordance with NRC Baseline Inspection Procedure 71111.21N, Design Bases
Assurance Inspection (Programs), Attachment 2, Design-Basis Capability of Power-Operated
Valves Under 10 CFR 50.55a Requirements.
This inspection will evaluate the reliability, functional capability, and design basis of
risk-important power-operated valves (POVs) as required by 10 CFR 50.55a and applicable
10 CFR Part 50, Appendix A and Appendix B, requirements. In conducting this inspection, the
team will select risk-important POVs used to prevent and mitigate the consequences of a design
basis accident.
The inspection will include two weeks of onsite inspection. The inspection team will consist of
three NRC inspectors. The current inspection schedule is as follows:
- Preparation week: June 21 - 25, 2021
- Onsite weeks: June 28, 2021 - July 2, 2021, and July 12 - 16, 2021
Experience with previous baseline engineering inspections of similar depth and length has
shown 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 three 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 May 10, 2021.
By May 14, 2021, the lead inspector will communicate the initial selected
R. Penfield -2-
samples and any additional information needed to support the in-office preparation
activities.
- 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 June 14, 2021. During the preparation activities, the team may
identify additional information needed to support the inspection.
- The last group includes the additional information above as well as plant-specific
reference material. This information should be available to the team onsite on June 28,
2021. It is also requested that corrective action documents and answers to questions
developed during the inspection be provided to the lead inspector as the documents are
generated.
In addition, the enclosure includes information and requests addressing inspection logistics.
The lead inspector for this inspection is Elba Sanchez Santiago. We understand that our
licensing contact for this inspection is Sean Fahnestock of your organization. If there are any
questions about the inspection or the material requested in the enclosure, contact the lead
inspector at 630-829-9520 or via e-mail at Elba.SanchezSantiago@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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Elba Sanchez Santiago, Senior Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure:
Design Bases Assurance Inspection
(Programs) Document Request
cc: Distribution via LISTSERV
R. Penfield -3-
Letter to Rod Penfield from Elba Sanchez Santiago dated April 8, 2021.
SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC DESIGN BASES
ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR
INFORMATION: INSPECTION REPORT 05000440/2021012
DISTRIBUTION:
RidsNrrPMPerry Resource
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RidsNrrDroIrib Resource
Kenneth OBrien
DRPIII
DRSIII
ADAMS Accession Number: ML21099A087
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII
NAME ESanchez
Santiago:mb
via e-mail
DATE 04/08/2021
OFFICIAL RECORD COPY
DESIGN BASES ASSURANCE INSPECTION - POV PROGRAM
REQUEST FOR INFORMATION
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000440/2021012
Onsite Inspection Dates: June 28, 2021 - July 2, 2021 and July 12 - 16, 2021
IP 71111.21N, Design Bases Assurance Inspection
Inspection Procedure: (Programs), Attachment 2, Design-Basis Capability of
Power-Operated Valves Under 10 CFR 50.55a Requirements
Elba Sanchez Santiago, Senior Reactor Inspector, RIII/DRS
Lead Inspector: 630-829-9520
Elba.SanchezSantiago@nrc.gov
Robert Daley, Senior Reactor Inspector, RIII/DRS
Teammate Inspectors:
Kevin Barclay, Reactor Inspector, RIII/DRS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by June 14, 2021, or sooner:
1. Inspection room name/number, directions from the main access facility, and phone
number;
2. Interview room name/number;
3. Response team contact information (names and phone numbers) and team roles (e.g.,
management sponsor, lead, inspector counterpart);
4. Any site access/badging actions needed for each inspector;
5. Any dosimetry actions needed for each inspector;
6. Entrance meeting time and location;
7. Confirmation that the team will have access to a licensee computer with a nearby printer;
8. Confirmation that the team will have Wi-Fi access;
9. Cafeteria location and hours;
10. Inspection response team normal working hours; and
11. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff
meetings).
Enclosure
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 searchable formats, if possible.
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.
Important Note: For the purpose of this inspection, POVs are valves with power actuators.
Examples include motor-operated valves (MOVs), air-operated valves (AOVs),
hydraulic-operated valves (HOVs), solenoid-operated valves (SOVs), and
pyrotechnic-operated valves (e.g., squib valves).
1. Information Requested for Initial Inspection Scoping Activities
The following information is requested by May 10, 2021, or sooner, to facilitate the initial
sample selection.
1.1. List of systems, system numbers/designators, and corresponding system names.
1.2. Probabilistic safety analysis (PSA) system notebooks and latest PSA summary
document. Also, identify the top ten risk significant functions per the PSA.
1.3. List of POVs from your site-specific PSA sorted by Risk-Achievement Worth
(RAW). Include values for Birnbaum Importance, Risk-Reduction Worth, and
Fussell-Veseley (as applicable). The list should include (a) component
identification number; (b) applicable plant system; (c) ASME Boiler and Pressure
Vessel Code (BPV Code) Class; (d) safety-related or nonsafety-related
classification; (e) valve type, size, and manufacturer; and (f) actuator type, size,
and manufacturer. If the NRC has granted a license amendment to categorize
structures, systems, and component in accordance with 10 CFR 50.69, please
provide the Risk Informed Safety Category of the component.
1.4. All corrective action documents, evaluations, and NRC correspondence, including
any associated NRC requests for additional information (RAIs) and Safety
Evaluation Report(s), generated in response to the NRC communications listed
below. Also, any NRC inspection reports that were conducted to close out the
sites associated responses.
1.4.1. Generic Letter (GL) 89-10;
1.4.2. GL 96-05;
1.4.3. GL 95-07;
1.4.4. Bulletin 85-03;
1.4.5. Regulatory Issue Summary (RIS) 2000-03; and
1.4.6. GL 88-14.
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1.5. NRC Safety Evaluation Report(s) associated with the In-Service Testing (IST)
Program and relief and alternative requests submitted in accordance with
10 CFR 50.55a for POVs. Identify the edition of the ASME Operation and
Maintenance of Nuclear Power Plants (OM Code) that is the Code of record for the
current 10-year IST Program interval, as well as any self-imposed standards
related to the IST Program elements applicable to POVs.
1.6. IST Program documents, including implementing procedures, IST plan, and the
document that identifies the in-scope valves and the associated IST Program
requirements for each valve (e.g., IST valve table identifying category,
active/passive function).
1.7. Any NRC correspondence regarding the stations POV programs other than the
IST Program, including any associated NRC RAIs and any NRC Safety Evaluation
Report(s). Identify any self-imposed standards related to these programs.
1.8. Site (and corporate if applicable) procedures associated with implementation of the
POV programs required by 10 CFR 50.55a(b)(3)(ii) and/or ASME OM Code
Mandatory Appendix III.
1.9. List of any valve removed from a POV program and basis for removal.
1.10. List of corrective action documents related to the POV programs for the last
5 years, including the document identifier and brief description. Provide a separate
list for each POV program.
1.11. List of POVs in the Maintenance Rule (a)(1) category for the last 5 years. The list
should include a brief description of the surrounding circumstances.
1.12. Current list of operator workarounds.
1.13. List of open operability evaluations related to POVs.
1.14. List of permanent plant modifications to POVs completed in the last 5 years. 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
modification identifier, title, revision/date, the affected system, completion date, and
a brief modification description.
1.15. Any self-assessment and/or audit of POV programs completed in the last 5 years.
1.16. Updated Final Safety Analysis Report, Technical Specifications, Technical
Specifications Bases, and Technical Requirements Manual.
1.17. The lead inspector will deliver forms to the licensee point of contact identified in the
letter for approximately 30 valves. Fill out the valve characteristics in the form
fields. It is possible that not all fields can be completed. For those fields that
cannot be filled, leave the fields blank.
1.18. All emergency and abnormal operating procedures.
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1.19. Current management and engineering organizational chart.
2. Information Requested to Support Inspection Preparation Activities
The following information is requested by June 14, 2021, or sooner, to facilitate the final
inspection preparation.
2.1. Preventive Maintenance (PM) Program document, implementing procedures, and
PM templates applicable to POVs.
2.2. Title 10 CFR 50, Appendix J Program document and implementing procedures.
2.3. Corrective Action Program procedures, including the operability/functionality
determination procedure.
2.4. Quality Assurance Program document.
2.5. Procedure for addressing issues captured in 10 CFR 21 notifications.
2.6. Joint Owners Group (JOG) MOV program classification evaluation.
2.7. For each selected POV, including its actuator (the response should be separated
by POV such as by creating a folder for each valve that includes the associated
documents):
2.7.1. Procurement and design specifications, and Certificate of Conformance.
2.7.2. Vendor documents addressing installation, operation, and maintenance.
2.7.3. Piping and instrumentation drawings (PI&Ds) for the associated system.
2.7.4. Electrical diagrams, including control logic diagrams.
2.7.5. Valve and actuator component drawings.
2.7.6. System description and/or training documents associated with the POV.
2.7.7. Operations procedures that direct operators to control the valve, including
alarm response procedures.
2.7.8. Applicable Maintenance Rule scoping document and the Maintenance
Rule performance criteria which would cause the system or component to
be moved from (a)(2) status to (a)(1) status. Also, documents (e.g.,
corrective action and work orders) associated with any instance the POV
was placed in (a)(1) status during the last 5 years.
2.7.9. List of tests, including technical specification surveillances. The list
should identify the test periodicity and test procedure identifier.
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2.7.10. Completed tests and surveillances performed during the last 5 years. For
those tests and surveillances performed at a periodicity of less than
1 year or greater than 5 years, provide the latest three performed.
Include the associated acceptance criteria basis calculations.
2.7.11. Completed preservice testing (PST).
2.7.12. List of applicable PMs. The list should identify the PM periodicity and last
completion date, and briefly describe the PM.
2.7.13. Completed PMs performed during the last 5 years, including any post
maintenance testing. For those PMs performed at a periodicity of less
than 1 year or greater than 5 years, provide the latest three performed.
2.7.14. Corrective maintenance work orders performed on the POV during the
last 5 years, including any post maintenance testing.
2.7.15. An all-inclusive list of calculation revisions in effect associated with the
POV. The list should include the document identifier, title, and revision
number.
2.7.16. Calculations associated with the POV. Data files may be excluded.
Calculation examples include (as applicable):
- Minimum available and required voltage at transient and steady state;
- Thermal overload sizing evaluation;
- Critical setpoint calculations (e.g., limit switch settings);
- Required thrust/torque;
- Maximum allowed leakage;
- Maximum differential pressure;
- Ambient room temperature under normal and accident conditions;
- Environmental qualification (EQ) file;
- (For AOVs) Pneumatic supply sizing and setpoint calculations;
- System hydraulic calculations;
- Pressure locking/thermal binding evaluations; and
- Valve weak link/seismic weak link analysis.
2.7.17. History of permanent modifications performed on the POV since
installation. Include modification identifier and brief modification
description.
2.7.18. List of corrective action documents associated with the POV for the last
5 years. The list should include the document identifier, brief description,
and status (e.g., open or completed).
2.7.19. Open and closed operability evaluations originated during the last 5
years.
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3. Additional Information to Be Provided Onsite
3.1. During the in-office preparation activities, the team may identify additional
information needed to support the inspection. The lead inspector will provide a list
of the additional information needed during the week of June 21, 2021.
3.2. Information requested to be provided throughout the inspection:
3.2.1. Any corrective action documents generated as a result of the teams
questions during this inspection as the documents are generated.
3.2.2. List of questions and/or document requests submitted by the team and
their status (e.g., open, closed) sorted by inspector. Provide to each
inspector daily 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> prior to the daily debrief. 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.
3.2.3. 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.
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