ML22108A280
| ML22108A280 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/19/2022 |
| From: | Jamie Benjamin NRC/RGN-III/DRS/EB2 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2022011 | |
| Download: ML22108A280 (10) | |
See also: IR 05000373/2022011
Text
Mr. David P. Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 - INFORMATION REQUEST FOR
AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION
(TEAM): INSPECTION REPORT 05000373/2022011; 05000374/2022011
Dear Mr. Rhoades:
On September 19, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial
baseline Design Bases Assurance Inspection (Team) at LaSalle County Station Units 1 and 2.
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 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:
September 12, 2022
Onsite weeks:
September 19 and October 3, 2022
April 18, 2022
D. Rhoades
- 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 19, 2022.
The lead inspector will communicate the initial selected set of samples no later than
July 24, 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 at the Regional Office no later than September 5, 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
September 19, 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 Jamie Benjamin. If there are any questions about the
inspection or the material requested in the enclosure, please contact the lead inspector at
630-829-9747 or via e-mail at Jamie.Benjamin@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,
Jamie Benjamin, Senior Reactor Engineer
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-373; 50-374
Enclosure:
Design Bases Assurance Inspection
Document Request
cc: Distribution via LISTSERV
Signed by Benjamin, Jamie
on 04/18/22
D. Rhoades
- 4 -
Letter to David P. Rhoades from Jamie Benjamin dated April 18, 2022.
SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2 - INFORMATION REQUEST FOR
AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION
(TEAM): INSPECTION REPORT 05000373/2022011; 05000374/2022011
DISTRIBUTION:
RidsNrrDorlLpl3
RidsNrrPMLaSalle Resource
RidsNrrDroIrib Resource
DRPIII
DRSIII
ADAMS Accession Number: ML22108A280
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
JBenjamin:mb
DATE
04/18/2022
OFFICIAL RECORD COPY
Enclosure
DESIGN BASES ASSURANCE INSPECTION (TEAMS)
REQUEST FOR INFORMATION
I.
ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
05000373/2022011; 05000374/2022011
Onsite Inspection Dates:
September 19-23, 2022; October 3-7, 2022
Inspection Procedure:
IP 71111.21M, Design Bases Assurance Inspection (Team)
Lead Inspector:
Jamie Benjamin, Senior Reactor Inspector, RIII/DRS/EB2
630-829-9747
Jamie.Benjamin@nrc.gov
II.
LOGISTICS
Email the following inspection logistics to the lead inspector by September 12, 2022, or
sooner:
1.
Inspection room name/number, directions from the mail 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 (after 10:00 a.m. Central Time on September 19, 2022) 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. Current management and engineering organizational chart; and
11. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff
meetings).
2
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 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.
Information Requested for Selection of Components/Modifications
The following information is requested by June 19, 2022, 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.
(Share with Senior Reactor Analyst (SRA) for if needed.)
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. (Share with SRA for if needed.)
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. (Share with SRA for if needed.)
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.
(Share with SRA for if needed.)
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 all abnormal operating
procedures.
1.8. Electronic copy of the site Individual Plant Examination of External Events, if
available. (Share with SRAs to determine if needed.)
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).
3
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.
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.
4
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 seven selected components and
seven selected modifications) to be Available by September 5, 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.).
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.
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 for selected
components.
2.7
Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available) of
selected components.
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 quality as 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.
5
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 operating and alarm response procedures associated
with the selected components.
2.15 Procedures addressing time critical and/or risk significant operator actions for
selected components.
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 the modification package,
engineering changes, 50.59 screening and evaluation (if applicable), calculations,
post-modification test packages, corrective action documents, design drawings,
preventive maintenance requirements and normal and alarm response procedures.
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 September 19, 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. The
team inspectors will request this information throughout the week of September 12,
2022 as needed.
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.
6
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 2:30 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.