ML22357A030

Request for Information for NRC Commercial Grade Dedication Inspection: Inspection Report 05000346/2023010

ML22357A030
Person / Time
Site:	Davis Besse
Issue date:	12/23/2022
From:	Lionel Rodriguez NRC/RGN-III/DORS/EB1
To:	Brown T Energy Harbor Nuclear Corp
References
IR 2023010
Download: ML22357A030 (1)

See also: IR 05000346/2023010

Text

December 23, 2022

Terry Brown

Site Vice President

Energy Harbor Nuclear Corp.

Davis-Besse Nuclear Power Station

5501 N. State Rte. 2, Mail Stop A-DB-3080

Oak Harbor, OH 43449-9760

SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION - REQUEST FOR

INFORMATION FOR NRC COMMERCIAL GRADE DEDICATION

INSPECTION: INSPECTION REPORT 05000346/2023010

Dear Terry Brown:

On April 3, 2023, the U.S. Nuclear Regulatory Commission (NRC) will begin a commercial

grade dedication (CGD) inspection at Davis-Besse. This inspection will be performed in

accordance with NRC Inspection Procedure 71111.21N.03, Commercial Grade Dedication.

The inspection will evaluate the implementation of Davis-Besses process for dedicating

commercial-grade items, as required in applicable portions of Title 10 of the Code of Federal

Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power

Plants and Fuel Reprocessing Plants, to ensure reasonable assurance is provided that these

items will perform their intended safety function. Additionally, the inspection will evaluate

implementation of Davis-Besses procurement process for safety-related components, as

required in Appendix B.

The inspection may include an onsite information gathering visit by the lead inspector. The

inspection will include 2 weeks onsite and will consist of three NRC inspectors (including the

lead inspector). The current inspection schedule is as follows:

Potential information gathering visit: February 20-24, 2023

Preparation week: March 27-31, 2023

Onsite weeks: April 3-7, 2023, and April 17-21, 2023

The purpose of the information gathering visit would be to meet with knowledgeable

individuals of your staff to become familiar with the process for dedicating commercial-grade

items, and the process for procuring safety-related components at Davis-Besse. This visit

would also allow the lead inspector to meet with procurement engineering and other site

individuals responsible for the inspection to ensure a common understanding of expectations

for the inspection. 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 (if performed), the lead inspector

will also review the information provided in the initial information request and may request

additional information needed to support the inspection.

T. Brown 2

Experience with previous baseline 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

February 6, 2023. The lead inspector will communicate the initial selected set of

samples no later than February 24, 2023.

The second group of documents requested are those items needed to support

our in-office preparation activities. This set of documents should be provided to

the lead inspector no later than March 24, 2023. 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, a schedule of plant

activities associated with the inspection during the onsite period, and any

additional requests resulting from the potential information gathering visit. This

information should be available to the team onsite on April 3, 2023.

The fourth group includes supporting information to be provided throughout the

onsite inspection. Specifically, corrective action documents and answers to

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 Lionel Rodriguez. We understand that our licensing

contact for this inspection is Gerald Wolf of your organization. If there are any questions about

the inspection or the material requested in the enclosure, please contact the lead inspector at

630-829-9609 or via email at Lionel.Rodriguez@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.

T. Brown 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 Rodriguez, Lionel

on 12/23/22

Lionel Rodriguez, Senior Reactor

Inspector

Engineering Branch 1

Division of Operating Reactor Safety

Docket No. 50-346

License No. NPF-3

Enclosure:

Commercial Grade Dedication

Inspection

Request for Information

cc: Distribution via LISTSERV

T. Brown 4

Letter to Terry Brown from Lionel Rodriguez dated December 23, 2022.

SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION - REQUEST FOR INFORMATION

FOR NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION

REPORT 05000346/2023010

DISTRIBUTION:

Jessie Quichocho

Marc Ferdas

RidsNrrDorlLpl3

RidsNrrPMDavisBesse Resource

RidsNrrDroIrib Resource

John Giessner

Julio Lara

Diana Betancourt-Roldan

Allan Barker

R3-DORS

ADAMS Accession Number: ML22357A030

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME LRodriguez:sw

DATE 12/23/2022

OFFICIAL RECORD COPY

COMMERCIAL GRADE DEDICATION INSPECTION

REQUEST FOR INFORMATION

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000346/2023010

Onsite Inspection Dates: April 3-7, 2023, and April 17-21, 2023

Inspection Procedure: IP 71111.21N.03, Commercial Grade Dedication

Lionel Rodriguez, Senior Reactor Inspector, RIII/DORS/EB1

Lead Inspector: 630-829-9609

Lionel.Rodriguez@nrc.gov

Benny Jose, Senior Reactor Inspector, RIII/DORS/EB2

Teammates: Thomas Briley, Senior Project Engineer, RIII/DORS/TSS

II. LOGISTICS

Email the following inspection logistics to the lead inspector by March 20, 2023, 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.

11. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff

meetings).

12. Current management and engineering organizational chart.

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 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 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 Samples

The following information is requested by February 6, 2023, or sooner, to facilitate the initial

sample selection.

Note: If you are unable to provide items 1.1. through 1.16. as requested, please reach out to

the lead inspector 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. List of commercial-grade items, with a brief description of application, that have

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

the site or dedicated by a vendor (or other licensee) and procured by the site.

Please note whether the item has been installed in the plant. Please include the

component equipment identification of the proposed or installed item location

which can be correlated to the lists provided in Items 1.1 and 1.2. The list should

encompass the past 6 years of dedication activities.

1.6. List of any commercial grade-items that failed after completing the dedication

process. The list should encompass the past 6 years of dedication activities.

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

above. Please note whether the component has been installed in the plant. Please

include the component equipment identification of the proposed or installed

location which can be correlated to the lists provided in Items 1.1 and 1.2. The list

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should encompass the past 6 years of procurement activities.

1.8. 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

6 years of these activities.

1.9. List components procured as safety-related or commercial-grade items intended to

be dedicated for safety-related applications that are on hold because of concerns

identified during receipt, dedication, or from operating experience/corrective action

program as applicable. If possible, the list should identify the systems and

equipment in which these items were intended for use.

1.10. List of components procured as safety-related or commercial-grade items

dedicated for safety-related applications, in the past 6 years, where the

procurement/dedication process was expedited to support rapid turnaround (less

than 7 days). Please include the component equipment identification of the

proposed or installed location which can be correlated to the lists provided in Items

1.1 and 1.2.

1.11. Procedures for dedicating commercial-grade items and for procurement of

safety-related components. Also include procedures controlling counterfeit,

fraudulent, and suspect items.

1.12. Electronic copies of Updated Final Safety Analysis Report, Technical Specifications,

Technical Specifications Bases, and Technical Requirements Manual.

1.13. Electronic copies of simplified plant drawings (if available). Note: these may be

uncontrolled documents such as big notes, training diagrams, etc.

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

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

1.16. Copy of qualifications, as applicable, of personnel who performed commercial-grade

dedication, safety-related component procurement, and/or receipt inspection/testing

activities within the past 6 years.

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2. Information Requested to Support Inspection Preparation Activities

The following information is requested by March 24, 2023, or sooner, to facilitate inspection

preparation.

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.

This information should be separated for each selected sample, especially if provided

electronically (e.g., folder with sample name that includes specifications, inspection reports,

dedication information, etc.).

2.1. purchase requisitions and purchase orders

2.2. other pertinent vendor/licensee correspondence

2.3. original and updated design specifications

2.4. catalog specifications

2.5. procurement basis evaluation such as like-for-like, equivalency, plant design

change packages, drawing and specification updates

2.6. 10 CFR 50.59 documentation, if applicable

2.7. material receiving reports, packing lists/invoices, and other shipping documents

2.8. receipt inspection reports and any related test reports

2.9. other documents to trace the item from the time it was dedicated to the time it

was installed, tested, and accepted

2.10. certificates of conformance/compliance/quality

2.11. vendor test and inspection reports

2.12. third-party or sub-vendor test and inspection reports

2.13. shelf-life information

2.14. vendor dedication/partial dedication information

2.15. design/material/process change history information

2.16. completed commercial-grade dedication documentation including:

2.16.1 safety classification

2.16.2 identification of safety functions/application requirements

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2.16.3 identification of critical characteristics

2.16.4 identification of verification methods and acceptance criteria for the critical

characteristics

2.16.5 evaluation of credible failure modes, if applicable

2.16.6 identification of the suppliers quality assurance program that meets

10 CFR Part 50, Appendix B

2.17. any deviation from design, material, and performance characteristics relevant to

the safety function (nonconformance dispositions)

2.18. documents showing objective evidence:

2.18.1 special test and inspection procedures and results

2.18.2 commercial-grade survey reports -item, design, material, and specific

performance characteristic (relevant to safety function)

2.18.3 source inspection reports

2.19. completed post-installation test procedure and results

2.20. completed stock or material issue forms and installation work orders or reports

2.21. historical performance information, including corrective action documents,

maintenance rule performance, failure analysis or root cause analysis for any

failed components, and system health reports related to the installed components

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3. Additional Information to be Provided on April 3, 2023, Onsite

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 lead inspector will provide a list of the additional information

needed during the week of March 27, 2023.

3.2. Schedule of any activities to be conducted on the selected samples during the

two onsite inspection weeks (e.g., installation, testing, inspection, etc.).

3.3. Schedule of separate interviews with knowledgeable plant personnel for each

of the components selected during the beginning of the first onsite week.

Interviews will discuss the dedication/procurement process, selected critical

characteristics of each sample, installation, and performance of installed

items. This can include, but is not limited to, plant personnel from procurement

engineering, other engineering disciplines, operations, maintenance, or any

other departments that are cognizant of the dedication/procurement,

installation, and acceptance criteria/methods of each component including

component/system health.

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.

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 p.m. to each inspector. It

is recommended to provide the lead inspector with a master list sorted by inspector

and each inspector with a list containing only the items originated by that inspector.

If you have questions regarding the information requested, please contact the lead inspector.

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