ML22276A156

Notification of Commercial Grade Dedication Inspection 05000298/2023011 and Request for Information

ML22276A156
Person / Time
Site:	Cooper
Issue date:	10/05/2022
From:	Vincent Gaddy NRC/RGN-IV/DORS/EB1
To:	Dent J Nebraska Public Power District (NPPD)
Braisted J
References
IR 2023011
Download: ML22276A156 (8)

See also: IR 05000298/2023011

Text

October 5, 2022

Mr. John Dent, Jr.

Vice President and Chief Nuclear Officer

Nebraska Public Power District

Cooper Nuclear Station

72676 648A Avenue

P.O. Box 98

Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION - NOTIFICATION OF COMMERCIAL GRADE

DEDICATION INSPECTION (05000298/2023011) AND REQUEST FOR

INFORMATION

Dear Mr. Dent:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff

will conduct the commercial grade dedication baseline inspection at Cooper Nuclear Station,

beginning on January 30, 2023. The inspection team will be composed of three personnel from

the NRC Region IV office. The inspection will be conducted in accordance with NRC inspection

procedure (IP) 71111.21N.03, Commercial Grade Dedication, dated June 28, 2022.

The inspection will evaluate the implementation of Cooper Nuclear Stations process for

dedicating commercial-grade items, as required in applicable portions of Appendix B to Title 10

of the Code of Federal Regulations (10 CFR) Part 50 (Appendix B), to ensure reasonable

assurance is provided that these items will perform their intended safety function. Additionally,

this inspection will evaluate implementation of Cooper Nuclear Stations procurement process

for safety-related components, as required in Appendix B.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

Onsite Information Gathering Visit: January 9-13, 2023

Offsite Preparation Week: January 23-27, 2023

Onsite Inspection Weeks: January 30-February 3, 2023, and February 13-17, 2023

The purpose of the information gathering visit is to meet with your staff to become familiar with

the process for dedicating commercial-grade items and the process for procuring safety-related

components at Cooper Nuclear Station. This visit may include a tour of onsite commercial-grade

item dedication facilities, receipt inspection facilities, storage facilities, and installed plant

components associated with potential inspection samples. During the visit, the team lead will

also review the information provided in the initial information request to select a list of potential

inspection samples. The team lead may also identify other information needed to support the

inspection during this visit.

J. Dent, Jr.

To minimize the impact on your staff and to ensure a productive inspection, we have enclosed

two separate requests for information. The first request (Enclosure 1) is generally for information

that will be used to choose the inspection samples or information that will be applicable to all

inspection samples throughout the inspection. This information should be made available to the

team lead prior to the information gathering visit. The second request (Enclosure 2) is for

information that is specific to an individual sample and should be made available prior to the

offsite preparation week.

Additional information requests, interviews with your staff, and/or walkdowns of facilities or

installed plant components will be made by the team throughout the inspection to complete their

review of the selected inspection samples. It is important that all documentation provided to the

team is complete and up-to-date to minimize the number of additional documents requested

during the preparation and/or the onsite portions of the inspection. Additionally, to facilitate an

efficient inspection, we request that a contact individual be assigned to each inspector to ensure

information requests, questions, and concerns are addressed in a timely manner.

If there are any questions about the inspection or the information requested, please contact the

team lead, Jonathan Braisted, by telephone at 817-200-1469 or by email at

Jonathan.Braisted@nrc.gov. Enclosure 3 contains additional contact information for the

inspection team.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of

Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct nor 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 OMB control number.

This letter, its enclosure, and your response (if any) 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 Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

Signed by Gaddy, Vincent

on 10/05/22

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Operating Reactor Safety

2

J. Dent, Jr.

Docket No. 05000298

License No. DPR-46

Enclosures:

1. Documents Requested Prior Information Gathering Visit

2. Documents Requested Prior to Inspection Preparation Week

3. Inspection Team Contact Information

cc w/ encl: Distribution via LISTSERV

3

ML22276A156

X Non-Sensitive X Publicly Available

X SUNSI Review

Sensitive Non-Publicly Available

OFFICE BC:DORS/EB1 SRI:DORS/EB1

NAME VGaddy JBraisted

DATE 10/5/2022 10/5/2022

Enclosure 1

Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both onsite and offsite during the information gathering visit.

Electronic format is the preferred media. If electronic media is made available via an internet

based remote document management system, then the remote document access must allow

inspectors to download, save, and print the documents in the NRC's regional office. Electronic

media on compact disc or paper records (hardcopy) are acceptable. At the end of the

inspection, the documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents Requested by January 2, 2023:

1. Licensing basis documents such as the updated final safety analysis report and

technical specifications.

2. Procedures for dedicating commercial-grade items and for procurement of safety-

related components.

3. List of items commercial-grade items, with a brief description of application, that have

been dedicated for safety-related applications. These items may be dedicated by

Cooper Nuclear Station or dedicated by a vendor (or other licensee) and procured by

Cooper Nuclear Station. Please note whether the item has been installed in the

plant. The list should encompass the past six years of dedication activities.

4. List of components procured as safety-related, with descriptions, if not included

above. Please note whether the item has been installed in the plant. The list should

encompass the past six years of procurement activities.

5. List of corrective action program documents, with descriptions, related to

commercial-grade items, procurement, or storage, including any items that failed

after completing the dedication process. The list should encompass the past six

years of these activities.

6. List of systems, system numbers/designators, and corresponding names.

7. List of site contacts that will be associated with the inspection.

Enclosure

Enclosure 2

Documents Requested Prior to Inspection Preparation Week

For the samples identified by the team lead, the documents and information requested below

should generally be made available to the inspection team for the team's use both onsite and

offsite during the inspection. Electronic format is the preferred media. If electronic media is

made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hardcopy) are

acceptable. At the end of the inspection, the documents in the team's possession will not be

retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all of the

listed documents. In addition, your plant specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents Requested by January 23, 2023:

1. Purchase requisition and purchase orders.

2. Other pertinent vendor/licensee correspondence.

3. Original and updated design specifications.

4. Catalog specifications.

5. Procurement basis evaluation such as like-for-like, equivalency, plant design change

packages, drawing and specification updates.

6. 10 CFR 50.59 documentation, if required.

7. Material receiving reports, packing lists/invoices, and other shipping documents.

8. Receipt inspection reports and any related test reports.

9. Other documents to trace the item from the time it was dedicated to the time it was

installed, tested, and accepted.

10. Certificates of conformance/compliance/quality.

11. Vendor test and inspection reports.

12. Third-party or subvendor test and inspection reports.

13. Shelf-life information.

14. Vendor dedication/partial dedication information.

Enclosure 2

15. Design/material/process change history information.

16. Completed commercial-grade dedication document including safety classification,

identification of safety functions/application requirements, identification of critical

characteristics, identification of verification methods and acceptance criteria for the

critical characteristics, evaluation of credible failure modes, if applicable, and

identification of the suppliers quality assurance program that meets 10 CFR Part 50,

Appendix B.

17. Any deviation from design, material, and performance characteristics relevant to the

safety function (nonconformance dispositions).

18. Documents showing objective evidence such as special test and inspection

procedures and results, commercial-grade survey reports -item, design, material,

and specific performance characteristic (relevant to safety function), and source

inspection reports.

19. Completed post-installation test procedure and results.

20. Completed stock or material issue forms and installation work orders or reports.

21. Historical performance information.

2

Enclosure 3

Inspection Team Contact Information

Inspection Team:

Jonathan Braisted (Lead) Gerond George Dustin Bryen

Senior Reactor Inspector Senior Reactor Inspector Reactor Inspector

817-200-1469 817-200-1562 817-200-1078

Jonathan.Braisted@nrc.gov Gerond.George@nrc.gov Dustin.Bryen@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Jonathan Braisted

1600 East Lamar Blvd.

Arlington, TX 76011-4511

Enclosure 3