ML23037A919

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Request for Information for the NRC Quadrennial Comprehensive Engineering Team Inspection: Inspection Report 05000237/2023011 and 05000249/2023011
ML23037A919
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 02/07/2023
From: Jorge Corujo-Sandin
NRC/RGN-III/DORS/EB1
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
References
IR 2023011
Download: ML23037A919 (1)
v • d • e


See also: IR 05000237/2023011

Text

David Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION - REQUEST FOR INFORMATION

FOR THE NRC QUADRENNIAL COMPREHENSIVE ENGINEERING TEAM

INSPECTION: INSPECTION REPORT 05000237/2023011 AND

05000249/2023011

Dear David Rhoades:

On July 17, 2023, the U.S. Nuclear Regulatory Commission (NRC) will begin a quadrennial

baseline Comprehensive Engineering Team Inspection (CETI) at Dresden Nuclear Power

Station. This inspection will be performed in accordance with NRC Inspection Procedure

71111.21M.

The CETI 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 changes 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,

modifications, 50.59 Evaluations, 50.59 Screenings and Operating Experiences to be reviewed

during this baseline inspection will be identified as part of the preparation for the inspection and

finalized during the first onsite inspection week. Additionally, 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.February 7, 2023

D. Rhoades - 2 -

The inspection will include 2 weeks onsite. The inspection team will consist of seven NRC

inspectors who will focus on engineering/maintenance/operations of the selected components

modifications, 50.59 Evaluations, 50.59 Screenings and Operating Experiences. The current

inspection schedule is as follows:

Preparation week: July 10 - 14, 2023

Onsite weeks: July 17 - 21, 2023 and July 31 - August 4, 2023

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 five groups, with their respective due

dates:

March 6, 2023 - The First Group lists information necessary for our initial

risk-informed scoping activities.

March 27, 2023 - The Second Group lists information necessary for our initial

inspection scoping activities (preliminary sample selections).

  • May 5, 2023 - The lead inspector will communicate the preliminary samples

selected. This will include Components, Modifications, 50.59 Evaluations and

50.59 Screenings.

June 30, 2023 - The Third Group of documents requested are those items needed to

support our in-office preparation activities. During the in-office preparation activities,

the team may identify additional information needed to support the inspection.

July 17, 2023 - The Fourth Group includes the additional information identified during

the in-office preparation as well as plant-specific reference material. This information

should be available to the team onsite.

After July 17, 2023 - The Fifth 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 Jorge Corujo-Sandin. We understand that our licensing

contact for this inspection is Tara Noah of your organization. If there are any questions about

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

630-829-9741 or via email at Jorge.Corujo-Sandin@nrc.gov.

D. Rhoades - 3 -

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.

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,

Jorge Corujo-Sandin

Senior Reactor Engineer

Engineering Branch 1

Division of Operating Reactor Safety

Docket Nos. 05000237 and 05000249

License Nos. DPR-19 and DPR-25

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

Signed by Corujo-Sandin, Jorge

on 02/07/23

D. Rhoades - 4 -

Letter to David Rhoades from Jorge Corujo-Sandin dated February 7, 2023.

SUBJECT: DRESDEN NUCLEAR POWER STATION - REQUEST FOR INFORMATION

FOR AN NRC QUADRENNIAL COMPREHENSIVE ENGINEERING TEAM

INSPECTION: INSPECTION REPORT 05000237/2023011 AND

05000249/2023011

DISTRIBUTION:

Jessie Quichocho

Marc Ferdas

RidsNrrDorlLpl3

RidsNrrPMDresden Resource

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Diana Betancourt-Roldan

Allan Barker

R3-DORS

ADAMS Accession Number: ML23037A919

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME JCorujo-

Sandin:gmp

DATE 02/07/2023

OFFICIAL RECORD COPY

COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

COMPREHENSIVE ENGINEERING TEAM INSPECTION

REQUEST FOR INFORMATION

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000237/2023011 and 05000249/2023011

Onsite Inspection Dates: July 17 - 21, 2023 and July 31 - August 4, 2023

Inspection Procedure: IP 71111.21M, Comprehensive Engineering Team Inspection

Jorge Corujo-Sandin, Senior Reactor Inspector

Lead Inspector: RIII/DORS

630-829-9741

Jorge.Corujo-Sandin@nrc.gov

Matthew Domke, Reactor Inspector, RIII/DORS

Jasmine Gilliam, Senior Reactor Inspector, RIII/DORS

Edison Fernandez, Senior Reactor Inspector, RIII/DORS

Teammates: Kevin Fay, Reactor Inspector, RIII/DORS

Megan Gangewere, Reactor Inspector, RIII/DORS

Muzammil Siddiqui, Reactor Inspector, RIII/DORS

Gokul Vasudevamurthy, Observer, RIII/DORS

II. LOGISTICS

Email the following inspection logistics to the lead inspector by June 20, 2023, or sooner:

1. Entrance meeting time and location.

2. Room number/name and location of the room to be used by the inspection team

while onsite.

3. Current management and engineering organizational chart.

4. Response team contact information (names and phone numbers) and team roles

(e.g., management sponsor, lead, inspector counterpart).

5. Any potential resource conflicts during the inspection (e.g., emergency drills and

all-staff meetings).

6. Available times, during the Monday and Tuesday of the second onsite week, to use

the simulator to run scenarios. An operations crew to support this effort will also be

required.

Due to the ongoing COVID-19 situation, additional logistics related with inspector presence

onsite will be coordinated closer to the actual start of the inspection. Reach out to the Team

Lead for questions or comments.

Enclosure

COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

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 to Support Risk Informed Selections

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

initial risk scoping required to support the sample selections.

Note: If you are unable to provide items 1.1. through 1.6.2. as requested, please

reach out to the Team Lead as soon as possible.

1.1. Risk-Ranking of the top 250 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 250 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 250 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. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook,

Internal Flood scenario notebook and latest internal event PSA summary

document.

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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

1.6. List of systems, system numbers/designators, and corresponding system

names.

1.7. 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).

1.8. 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 Preliminary Selection of Samples

The following information is requested by March 27, 2023, or sooner, to facilitate

the initial sample selection.

2.1. Electronic copies of updated final safety analysis report (UFSAR), Technical

Specifications, Technical Specifications Bases, and Technical Requirements

Manual.

2.2. Provide copies of the emergency operating procedures and abnormal operating

procedures.

2.3. Provide the in-service testing (IST) program document. Include the IST Program

Basis document, or equivalent (if any).

2.4. Copies of procedures addressing the following: modifications, design changes,

set point changes, equivalency evaluations or suitability analyses,

post-modification testing, 10 CFR 50.59 evaluations and screenings, and

UFSAR updates.

2.5. Structures, systems, and components (SSCs) in the Maintenance Rule

(a)(1) category for the last 4 years.

2.6. A list of operating experience evaluations for the last 4 years.

2.7. Information of any common cause failure of components experienced in the

last 4 years at your facility.

2.8. List of Root Cause Evaluations associated with component failures or design

issues initiated/completed in the last 4 years.

2.9. List of open operability evaluations.

2.10. Procedures addressing time critical and/or risk significant operator actions. If

not part of the procedure, include a list of all time critical and/or risk significant

operator actions. Identify those actions that do not have job performance

measures.

2.11. List of permanent plant modifications to SSCs that are field work complete.

Do not include canceled or still in process modifications. For the purpose of this

inspection, permanent plant modifications include permanent:

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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

2.11.1 Plant changes, design changes, set point changes, completed in the last

4 years;

2.11.2 Equivalency evaluations, and suitability analyses completed in the

last 4 years;

2.11.3 Procedure changes for Emergency Operating Procedures (EOPs),

Abnormal Operating Procedures (AOPs), surveillances, and test

procedures in the last 4 years; and

2.11.4 Calculation changes that have been issued for use in the last 4 years.

2.12. A list of corrective action documents (open and closed) in the last 4 years that

address permanent plant modifications issues, concerns, or processes. These

documents should also include the corrective action documents associated

with the modification implementation.

2.13. List of all 10 CFR 50.59 completed evaluations involving (a) calculations,

(b) procedure revisions, (c) changes to the facility (modifications),

(d) non-routine operating configurations, or (e) departures in methods of

analyses. The list should NOT include any evaluations which concluded a

license amendment was required. Include evaluations performed over the last

4 years. This list should include 50.59 evaluations for the following:

2.13.1 Changes that have been made under the provisions of 10 CFR 50.59

that have been updated in accordance with 10 CFR 50.71(e)(4);

2.13.2 Modifications that are field work complete; and

2.13.3 Changes to calculations (or initiation of new calculations) that have

been issued. The list should contain the number and title of each

document, a brief description of the change, and the corresponding

number and type of the affected document (i.e., the modification or

procedure to which the evaluation applies).

2.14. A list of all 10 CFR 50.59 changes that have been screened out as not

requiring a full evaluation involving (i.e., just a 50.59 Screening):

(a) calculations; (b) procedure revisions; (c) changes to the facility

(modifications); (d) non-routine operating configurations; or (e) departures in

methods of analyses.

The list should contain the number and title of each document, a brief

description of the change, and the corresponding number and type of the

affected document (i.e., the modification or procedure to which the evaluation

applies).

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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

2.15. A list of any modifications, procedure revisions, or the UFSAR changes where

it was determined that 10 CFR 50.59 did not apply.

2.16. A list of corrective action documents (open and closed) that address

10 CFR 50.59 issues, concerns, or processes. These documents should also

include the associated corrective action documents and the 50.59 change

implementation.

The list should contain the number, title, and revision (or date) of each

document, the affected system and corresponding documentation (if

applicable).

2.17. UFSAR updates submitted in accordance with 10 CFR 50.71(e)(4). Provide

copies of the complete submittal.

2.18. Copy of the UFSAR change log or a synopsis of the changes. This should

include all of the changes made to the UFSAR that were incorporated in the

last 10 CFR 50.71(e)(4) submittal.

3. Information Requested for the Preliminary Selected Samples to be Available by

June 30, 2023.

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

provided electronically (e.g., folder with component or modification name that

includes calculations, condition reports, maintenance history, etc.).

3.1. Corrective Action Program procedures, including the operability/functionality

determination procedure.

3.2. Quality Assurance Program document/procedure.

3.3. A copy of any internal/external self-assessments and associated corrective

action documents generated in preparation for the inspection.

3.4. A copy of engineering/operations related audits completed in the last 2 years.

For the selected Components:

3.5. System Health Reports, System Descriptions, Design Basis Documents, and/or

Training Lesson Plans associated with each of the selected components.

3.6. List of condition reports (corrective action documents) associated with each of

the selected components for the last 4 years. (Excel format preferred.)

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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

3.7. For each selected component list of the maintenance history (corrective,

preventive, and elective) over the last 10 years. Identify frequency of preventive

maintenance activities.

3.8. Aging Management Program documents applicable to each selected

component.

3.9. Provide an all-inclusive list of calculation revisions in effect associated with

each of the selected components. Include document number, title, and

revision number.

3.10. Copies of calculations associated with each of the selected components,

excluding data files. If number of applicable responses under this request, for a

specific component, is excessive (e.g., more than 10 calculations), you may

reach out to the Team Lead to for an alternative. [Pipe stress calculations

excluded from this request.]

3.11. Electronic copies of electrical drawings (ac and dc) and key diagrams.

3.12. Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available).

3.13. Copies of operability evaluations (open/closed for last 4 years) associated with

each of the selected components and plans for restoring operability, if

applicable.

3.14. Copies of operator work-around evaluations associated with each of the

selected components and plans for resolution, if applicable.

3.15. Copies of any open temporary modifications associated with each of the

selected components, if applicable.

3.16. Trend data on the selected electrical/mechanical components performance for

last 4 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.)

3.17. Provide copies of the normal and alarm response procedures associated with

the selected components and selected scenarios (if any).

3.18. If available electronically, provide the vendor manual. Otherwise refer to

section 5 of this RFI.

3.19. 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. For those specific tests or

surveillances performed at a periodicity resulting in excessive responses to this

request, you may reach out to the Team Lead for an alternative.

6

COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

For the selected Modifications, 50.59 Evaluations and 50.59 Screenings:

3.20. For each of the selected modifications, provide the engineering change

package. Include any associated 50.59 Screening and/or 50.59 Evaluation.

3.21. Provide a copy of each selected 50.59 Evaluation.

3.22. Provide copies of the selected 50.59 Screenings.

3.23. The selected Modifications, 50.59 Evaluations and 50.59 Screenings will be

further filtered by the inspectors until the final samples are selected. Once

these are selected (during the preparation week and the first onsite week) the

site should be prepared to provide other supporting documents for the selected

item. Examples of supporting documents include:

  • Design drawings supporting the change
  • Procedures, calculations, etc. affected by the change
  • Post-modification test packages
  • UFSAR change papers generated (e.g., marked off pages)

4. Additional Information to be Provided on July 17, 2023, When the Team is

Onsite

4.1. During the in-office preparation activities, the team will be making final

selections and may identify additional information needed to support the

inspection.

4.2. Schedule of any testing/maintenance activities to be conducted on the

selected components during the two onsite inspection weeks.

5. Information Requested to be Provided Throughout the Inspection

5.1. Any corrective action documents generated as a result of the teams questions

during this inspection as the documents are generated.

5.2. List of questions and/or document requests submitted by the team and their

status (e.g., open, closed) sorted by inspector. Provide daily by 2:00 p.m., plant

local time, 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.

5.3. 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.

7

COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST

5.4. 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:

5.4.1 Individual Plant Examination/Probabilistic Risk Assessment report;

5.4.2 Procurement documents for components and modifications selected

(verify retrievable);

5.4.3 Plant procedures (normal, abnormal, emergency, surveillance, etc.);

5.4.4 Vendor manuals;

5.4.5 Historical revisions of the Final Safety Analysis Report (FSAR),

including the Original FSAR and Original Safety Evaluation Report; and

5.4.6 Copy of electrical drawings, key diagrams, and isometrics

(paper copies).

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

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