ML22357A030
| ML22357A030 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/23/2022 |
| From: | Lionel Rodriguez NRC/RGN-III/DORS/EB1 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2023010 | |
| Download: ML22357A030 (1) | |
See also: IR 05000346/2023010
Text
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.
December 23, 2022
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,
Lionel Rodriguez, Senior Reactor
Inspector
Engineering Branch 1
Division of Operating Reactor Safety
Docket No. 50-346
License No. NPF-3
Enclosure:
Inspection
Request for Information
cc: Distribution via LISTSERV
Signed by Rodriguez, Lionel
on 12/23/22
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:
RidsNrrDorlLpl3
RidsNrrPMDavisBesse Resource
RidsNrrDroIrib Resource
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
Enclosure
COMMERCIAL GRADE DEDICATION INSPECTION
REQUEST FOR INFORMATION
I.
ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
Onsite Inspection Dates:
April 3-7, 2023, and April 17-21, 2023
Inspection Procedure:
IP 71111.21N.03, Commercial Grade Dedication
Lead Inspector:
Lionel Rodriguez, Senior Reactor Inspector, RIII/DORS/EB1
630-829-9609
Lionel.Rodriguez@nrc.gov
Teammates:
Benny Jose, Senior Reactor Inspector, RIII/DORS/EB2
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.
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 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
3
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
5
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
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.