ML22116A127

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Unit 2 RFI for an NRC Triennial Heat Exchanger/Sink Performance Inspection and RFI IR 05000454/2022002 05000455/2022002
ML22116A127
Person / Time
Site: Byron  Constellation icon.png
Issue date: 04/26/2022
From: Sanchez-Santiago E
NRC/RGN-III/DRS/EB2
To: Rhodes D
Constellation Energy Generation
References
IR 2022002
Download: ML22116A127 (11)


See also: IR 05000454/2022002

Text

Mr. David Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

BYRON STATION UNIT 1 AND UNIT 2 - REQUEST FOR INFORMATION

FOR AN NRC TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE

INSPECTION AND REQUEST FOR INFORMATION; INSPECTION

REPORT 05000454/2022002; 05000455/2022002

Dear Mr. Rhoades:

On June 13, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite portion

of the Triennial Heat Exchanger/Sink Performance Inspection at Byron Station. This inspection

will be performed in accordance with NRC baseline Inspection Procedure 71111.07.

The Triennial Heat Exchanger/Sink Performance Inspection focuses on service water cooled

heat exchangers, closed loop heat exchangers and the ultimate heat sink (UHS). The

inspection verifies that the selected service water cooled heat exchanger(s), closed loop heat

exchanger(s) and the UHS remain capable of performing their intended safety functions.

The inspection includes 1 week onsite. The inspection team will consist of three NRC

inspectors. The current inspection schedule is as follows:

Preparation week:

June 6 - 10, 2022

Onsite week:

June 13 - 17, 2022

In order to minimize the impact that the inspection has on the site and to ensure a productive

inspection, a request for documents needed for the inspection is enclosed. The information

request has been divided into three groups:

The first group lists information necessary for the initial inspection scoping activities.

This information should be available to the lead inspector no later than May 16,

2022. The lead inspector will communicate the initial selected set of approximately

2-3 risk significant heat exchangers by May 17, 2022.

The second group is needed to support the in-office preparation activities. This set

of documents, including the calculations associated with the selected heat

exchangers, should be available at the Regional Office no later than June 6, 2022.

This information should be separated for each selected component, especially if

provided electronically (e.g., folder with component name that includes calculations,

April 26, 2022

D. Rhoades

- 2 -

condition reports, maintenance history, etc.). During the in-office preparation

activities, the inspector 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 also be available to the inspector on

June 6, 2022. It is also requested that corrective action documents and/or questions

developed during the inspection be provided to the inspector as the documents are

generated.

All requested documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous Heat Sink Performance

Inspection. If no activities were accomplished in that time period, then the request applies to the

last applicable document in the previous time period. It is important that these documents be as

complete as possible, in order to minimize the number of documents requested during the

preparation week or during the onsite inspection.

The lead inspector for this inspection is Elba Sanchez Santiago. We understand that our

licensing contact for this inspection is Zoe Cox of your organization. If there are any questions

about the inspection or the material requested in the enclosure, please contact the lead

inspector at 630-829-9520 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.

D. Rhoades

- 3 -

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of

this letter and its enclosure will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRCs

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

Elba Sanchez Santiago, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-454 and 50-455

License Nos. NPF-37 and NPF-66

Enclosure:

Triennial Heat Sink Performance Inspection

Document Request

cc: Distribution via LISTSERV

Signed by Sanchez Santiago, Elba

on 04/26/22

D. Rhoades

- 4 -

Letter to David Rhoades from Elba Sanchez Santiago dated April 26, 2022.

SUBJECT:

BYRON STATION UNITS 1 AND 1 - REQUEST FOR INFORMATION FOR

AN NRC TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE

INSPECTION AND REQUEST FOR INFORMATION; INSPECTION

REPORT 05000454/2022002; 05000455/2022002

DISTRIBUTION:

Jessie Quichocho

Linda Howell

RidsNrrDorlLpl3

RidsNrrPMByron Resource

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Shelbie Lewman

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML22116A127

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

OFFICE

RIII

NAME

ESanchezSantiago:

mb

DATE

04/26/2022

OFFICIAL RECORD COPY

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

Enclosure

HEAT EXCHANGER/SINK PERFORMANCE

REQUEST FOR INFORMATION

I.

ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000454/2022002; 05000455/2022002

Onsite Inspection Dates:

June 13 - 17, 2022

Inspection Procedure:

IP 71111.07, HEAT EXCHANGER/SINK PERFORMANCE

Lead Inspector:

Elba Sanchez Santiago, Senior Reactor Inspector, DRS

630-829-9520

Elba.sanchezsantiago@nrc.gov

Teammates:

Megan Gangewere, Reactor Inspector, RIII/DRS

Muzammil Siddiqui, Reactor Inspector, RIII/DRS

I.

Information Requested by: May 16, 2022

1.

List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting

Safety-Related Equipment, heat exchangers in order of risk significance.

a.

Identify if the heat exchanger is service water cooled or a closed loop heat

exchanger.

2.

Copy of heat exchanger performance trending data tracked for each GL 89-13 heat

exchanger.

3.

List of corrective action program documents (with a short description) associated with

GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or heat exchanger

testing, for the previous 3 years or since the last corrective action program document list

was sent to the NRC for the previous heat sink performance inspection. The list should

include all corrective action program documents not on the last corrective action

program document list.

4.

Copy of any self-assessment done on any of GL 89-13 heat exchangers.

5.

Last two System Health Report(s) and maintenance rule system notebooks for all the

GL 89-13 heat exchangers.

6.

List of engineering-related operator workarounds (with a short description) associated

with GL 89-13 heat exchangers. The requested documents are to be for the time period

from the onsite inspection period back to the documents that were provided in response

to the previous heat sink performance inspection.

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

2

7.

List of permanent and temporary modifications (with a short description) associated with

GL 89-13 heat exchangers. The requested documents are to be for the time period from

the onsite inspection period back to the documents that were provided in response to the

previous heat sink performance inspection.

8.

Provide a list of all corrective action documents, with a short description, associated with

the UHS for the previous three years or since the last corrective action program

document list was sent to the NRC for the previous Triennial Heat Sink Performance

Inspection.

II.

Information Requested by: June 6, 2022

1.

Copies of the GL 89-13 responses.

2.

Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the

GL 89-13 Heat Exchanger Program.

3.

Copies of procedures developed to implement the recommendations of GL 89-13 (e.g., the

GL 89-13 Heat Exchanger Program description).

4.

Copies of the selected corrective action program documents.

5.

For the specific heat exchangers selected:

a.

Copies of the UFSAR sections applicable for each heat exchanger.

b.

Copy of system description and design basis document for the heat exchangers

(as applicable).

c.

Provide a list of calculations (with a short description) which currently apply to

each heat exchanger.

i.

Establish the limiting design basis heat load required to be removed by

each of these heat exchangers;

ii.

Demonstrate the heat exchangers capacity to remove the limiting heat

load;

iii.

Correlate surveillance testing and/or inspection results from these heat

exchangers with design basis heat removal capability (e.g., basis for

surveillance test and/or inspection acceptance criteria);

iv.

Evaluate the potential for water hammer in each heat exchanger or

associated piping; and

v.

Evaluate excessive tube vibration in each heat exchanger.

d.

Copy of any operability determinations or other documentation of degradation

associated with the heat exchangers or the systems that support the operation

for the selected heat exchangers.

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

3

e.

Copy of the construction code, Design Specification, heat exchanger data

sheets, and vendor documents including component drawings applicable for the

heat exchangers.

f.

Copies of normal, abnormal, and emergency operating procedures associated

with the selected heat exchangers.

6.

For the ultimate heat sink (UHS):

a.

Copies of the applicable UFSAR sections.

b.

Copy of system description and design basis document (as applicable).

c.

Copy of any operability determinations or other documentation of degradation

associated with the UHS.

d.

Copy of the document (e.g., UFSAR, Technical Requirements Manual or

procedure) that states the maximum cooling water system inlet temperature limit

that still allows full licensed power operation of the nuclear reactor.

e.

Copy of system description and design basis document (as applicable).

f.

Copy of the construction code and Design Specification.

g.

Copies of normal, abnormal, and emergency operating procedures associated

with the UHS including procedures for loss of this systems.

h.

Provide a list of calculations (with a short description), which currently apply to

UHS.

i.

Provide a list of instruments (with a short description) associated with automatic

or alarm functions for the UHS.

j.

Provide a list of any design change (with a short description) performed on the

UHS since the last heat sink performance inspection.

7.

A schedule of all inspections, cleanings, maintenance, or testing of any safety-related plant

heat exchanger to be performed during the on-site portion of the inspection.

III. Information Requested to be Available for Inspection Preparation by: May 6, 2022

1.

For the specific service water cooled heat exchangers selected:

a.

Copy of the calculation which correlates surveillance testing results from these

heat exchangers with design basis heat removal capability (e.g., basis for

surveillance test acceptance criteria).

b.

Copies of the two most recent completed tests and evaluation data confirming

thermal performance for those heat exchangers which are performance tested.

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

4

c.

Documentation and procedures that identify the types, accuracy, and location of

any instrumentation used for the two most recently completed thermal

performance tests for the heat exchangers (e.g., high accuracy ultrasonic flow

instruments or temperature instruments). Include calibration records for the

instruments used during these tests.

d.

Information regarding any alarms which monitor on-line performance.

e.

Copy of the document describing the inspection results of each heat exchanger.

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

f.

The cleaning and inspection maintenance schedule for each heat exchanger for

the next 5 years.

g.

Copy of the design specification and heat exchanger data sheets for each heat

exchanger.

h.

Copy of the vendor manuals including component drawings for each heat

exchanger.

i.

Copy of the calculation which establishes the limiting (maximum) design basis

heat load which is required to be removed by each of these heat exchangers.

j.

Copy of the operating procedures that ensure that the maximum cooling water

system inlet temperature limit is not exceeded.

k.

Copy of the calculations or documents which evaluate the potential for water

hammer in each heat exchanger or associated piping.

l.

Copy of the calculations that evaluate excessive tube vibration in each heat

exchanger and the documents that describe the controls that prevent heat

exchanger degradation due to excessive flow induced vibration during operation.

m.

Copy of the periodic flow testing at or near maximum design flow. The requested

documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink

performance inspection.

n.

Copy of the document which identifies the current number of tubes in service for

each heat exchanger and the supporting calculation which establishes the

maximum number of tubes which can be plugged in each heat exchanger.

o.

Copy of the document establishing the repair criteria (plugging limit) for degraded

tubes which are identified in each heat exchanger.

p.

Copies of the documents that verify the structural integrity of the heat exchanger

(e.g., eddy current summary sheets, ultrasonic testing results, and visual

inspection results).

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

5

2.

For the specific closed loop heat exchangers selected:

a.

Copy of the design specification and heat exchanger data sheets for each heat

exchanger.

b.

Copy of the vendor manuals including component drawings for each heat

exchanger.

c.

Copy of the calculation which establishes the limiting (maximum) design basis

heat load which is required to be removed by each of these heat exchangers.

d.

Copy of the operating procedures that ensure that the maximum cooling water

system inlet temperature limit is not exceeded.

e.

Copy of the calculations or documents which evaluate the potential for water

hammer in each heat exchanger or associated piping.

f.

Copy of the calculations that evaluate excessive tube vibration in each heat

exchanger and the documents that describe the controls that prevent heat

exchanger degradation due to excessive flow induced vibration during operation.

g.

Copy of the periodic flow testing at or near maximum design flow. The requested

documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous heat sink

performance inspection.

h.

Copy of the document which identifies the current number of tubes in service for

each heat exchanger and the supporting calculation which establishes the

maximum number of tubes which can be plugged in each heat exchanger.

i.

Copy of the document establishing the repair criteria (plugging limit) for degraded

tubes which are identified in each heat exchanger.

j.

Copies of the documents that verify the structural integrity of the heat exchanger

(e.g., eddy current summary sheets, ultrasonic testing results, and visual

inspection results).

k.

Copies of those documents that describe the methods taken to control water

chemistry in the heat exchangers.

3.

For review of the operation of the service water system and UHS:

a.

Copies of any design change performed on the UHS. The requested documents

are to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous heat sink performance

inspection.

b.

Copies of any design change performed on the safety-related service water

system. The requested documents are to be for the time period from the onsite

inspection period back to the documents that were provided in response to the

previous heat sink performance inspection.

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

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c.

Copies of procedures for a loss of UHS. Provide documentation that the

instrumentation, which is relied on for decision-making is available and

functional.

d.

Copies of procedures for a loss of service water system.

e.

Inspections and/or maintenance related to preventing macrofouling (e.g., silt,

dead mussel shells, or debris) and biotic fouling (e.g., fish, algae, grass, or kelp).

The requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

heat sink performance inspection.

f.

Copies of chemistry procedures that monitor for pH, calcium hardness, etc. Also,

provide copies of the associated results. The requested documents are to be for

the time period from the onsite inspection period back to the documents that

were provided in response to the previous heat sink performance inspection.

g.

Copies of documents associated with the monitoring of pump performance for

potential strong-pump vs. weak-pump interaction.

4.

For the review associated with the system walkdown of the selected service water

and/or closed cooling water systems:

a.

Copies of the testing, inspection, or monitoring program procedures for buried or

inaccessible piping and the associated results. The requested documents are to

be for the time period from the onsite inspection period back to the documents

that were provided in response to the previous heat sink performance inspection.

b.

Copies of the ultrasonic test results and/or visual inspections that verify the

structural integrity of the piping.

c.

Copies of the procedures to monitor, assess, and disposition active thru wall pipe

leaks, including structural evaluations and/or planned corrective actions.

d.

History of any thru wall pipe leak on the system. The requested documents are

to be for the time period from the onsite inspection period back to the documents

that were provided in response to the previous heat sink performance inspection.

e.

Copies of the documents associated with the periodic inspection program used to

detect protective coating failure, corrosion, and erosion.

f.

Copies of the in-service testing (IST) vibration monitoring results and operational

history for deep draft vertical pumps, if applicable. The requested documents are

to be for the time period from the onsite inspection period back to the documents

that were provided in response to the previous heat sink performance inspection.

g.

Copies of surveillance procedures and testing results performed on the service

water pump bay water level instruments. The requested documents are to be for

the time period from the onsite inspection period back to the documents that

were provided in response to the previous heat sink performance inspection.

TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST

7

h.

Copies of procedures associated with operating during adverse weather

conditions (e.g., icing, high temperatures, or low level).

i.

Copy of the evaluation for the potential effects of low flow/level on underwater

weir walls intended to limit silt or sand intake, if applicable.

If the information requested above will not be available, please contact Elba Sanchez Santiago

as soon as possible at 630-829-9520 or via e-mail at elba.sanchezsantiago@nrc.gov.