ML21333A083
| ML21333A083 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/29/2021 |
| From: | Jorge Corujo-Sandin NRC/RGN-III/DRS/EB2 |
| To: | Rhoads D Exelon Generation Co LLC, Exelon Nuclear |
| References | |
| IR 2022010 | |
| Download: ML21333A083 (10) | |
See also: IR 05000461/2022001
Text
November 29, 2021
Mr. David Rhoades
Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CLINTON POWER STATION - REQUEST FOR INFORMATION FOR AN NRC
TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):
INSPECTION REPORT 05000461/2022010
Dear Mr. Rhoades:
On February 14, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial
baseline Design Bases Assurance Inspection (Team) at Clinton 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 two 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: February 7 - 11, 2022
Onsite weeks: February 14 - 18, 2022, and February 28 - March 4, 2022
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.
D. Rhoades -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
December 27, 2021. The lead inspector will communicate the initial selected set
of samples no later than January 7, 2022.
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 January 31, 2022. 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
February 14, 2022.
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 Jorge Corujo-Sandin. We understand that our licensing
contact for this inspection is Chelsie Miller 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.
D. Rhoades -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,
Signed by Corujo-Sandin, Jorge
on 11/29/21
Senior Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-461
License No. NPF-62
Enclosure:
Design Bases Assurance Inspection
Document Request
cc: Distribution via LISTSERV
D. Rhoades -4-
Letter to David Rhoades from Jorge Corujo-Sandin dated November 29, 2021.
SUBJECT: CLINTON POWER STATION - REQUEST FOR INFORMATION FOR AN NRC
TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):
INSPECTION REPORT 05000461/2022010
DISTRIBUTION:
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ADAMS Accession Number: ML21333A083
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII
NAME JCorujo-Sandin:mb
DATE 11/29/2021
OFFICIAL RECORD COPY
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
DESIGN BASES ASSURANCE INSPECTION (TEAMS)
REQUEST FOR INFORMATION
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000461/2022010
Onsite Inspection Dates: February 14 - 18, 2022; and February 28 - March 4, 2022
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
Elba Sanchez Santiago, Senior Reactor Inspector, RIII/DRS
Robert Daley, Senior Reactor Inspector, RIII/DRS
Teammates: Matthew Domke, Reactor Inspector, RIII/DRS
Ijaz Hafeez, Reactor Inspector, RIII/DRS
Michael Jones, Reactor Inspector, RIII/DRS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by January 7, 2022, 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.). Specific Excel formats for various Enclosure items may be requested to
assist in Inspection Sample Selection. 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
Enclosure
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
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. Information Requested for Selection of Components/Modifications.
The following information is requested by December 27, 2021, or sooner, to facilitate
the initial sample selection.
Note: If you are unable to provide items 1.1. through 1.6.2. as requested, please
reach out to the Team Lead as soon as possible.
1.1. Risk-ranking of the top 500 components from your site-specific probabilistic
safety analysis (PSA) sorted by Birnbaum Worth. Include values for Risk
Achievement Worth, 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 the top 500 components (i.e., Large Early Release Frequency
(LERF)) from your site-specific PSA similar to the request in item 1.1. (Provide
in Excel format.)
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 Fire PSA Model:
1.6.1 Provide the fire 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).
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
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.
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.
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
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.
2. Information Requested (for the approximate seven selected components and
seven selected modifications) to Be Available by January 31, 2022, (will be
reviewed by the team in the Regional office during the week of February 7,
2022).
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.
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
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.).
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 February 14, 2022, 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.
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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
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 1:30 p.m. CT
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.
6