ML23055B056
| ML23055B056 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/27/2023 |
| From: | John Bozga NRC/RGN-III/DORS/ERPB |
| To: | Domingos C Northern States Power Company, Minnesota |
| References | |
| IR 2023010 | |
| Download: ML23055B056 (1) | |
See also: IR 05000282/2023010
Text
Christopher P. Domingos
Site Vice President
Prairie Island Nuclear Generating Plant
Northern States Power Company, Minnesota
1717 Wakonade Drive East
Welch, MN 55089-9642
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - REQUEST FOR
INFORMATION FOR NRC COMMERCIAL GRADE DEDICATION INSPECTION:
INSPECTION REPORT 05000282/2023010 AND 05000306/2023010
Dear Christopher Domingos:
On June 12, 2023, the U.S. Nuclear Regulatory Commission (NRC) will begin a
commercial grade dedication (CGD) inspection at Prairie Island. This inspection will be
performed in accordance with NRC Inspection Procedure 71111.21N.03, Commercial
Grade Dedication.
The inspection will evaluate the implementation of Prairie Islands 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 Prairie Islands 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 3 NRC inspectors (including
the lead inspector). The current inspection schedule is as follows:
Potential information gathering visit:
March 27-31, 2023
Preparation week:
June 5-9, 2023
Onsite weeks:
June 12-16, 2023, and June 26-30, 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
Prairie Island. 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.
February 27, 2023
C. Domingos
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 March 24, 2023. The lead
inspector will communicate the initial selected set of samples no later than April 7, 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 June 2, 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 June 12, 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 John V. Bozga. We understand that our licensing
contact for this inspection is Carrie Seipp of your organization. If there are any questions
about the inspection or the material requested in the enclosure, please contact the lead
inspector at 630-829-9613.
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.
C. Domingos
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,
John V. Bozga, Senior Reactor Inspector
Engineering Reactor and Projects Branch
Division of Operating Reactor Safety
Docket Nos. 05000282 and 05000306
License Nos. DPR-42 and DPR-60
Enclosure:
Commercial Grade Dedication Inspection
Request for Information
cc: Distribution via LISTSERV
Signed by Bozga, John
on 02/27/23
C. Domingos
4
Letter to Christopher P. Domingos from John V. Bozga dated February 27, 2023.
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - REQUEST FOR
INFORMATION FOR NRC COMMERCIAL GRADE DEDICATION INSPECTION:
INSPECTION REPORT 05000282/2023010 AND 05000306/2023010
DISTRIBUTION:
RidsNrrPMPrairieIsland Resource
RidsNrrDorlLpl3
RidsNrrDroIrib Resource
R3-DORS
ADAMS Accession Number: ML23055B056
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
JBozga:mb
DATE
02/27/2023
OFFICIAL RECORD COPY
Enclosure
COMMERCIAL GRADE DEDICATION INSPECTION
REQUEST FOR INFORMATION
I.
ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
05000282/2023010 AND 05000306/2023010
Onsite Inspection Dates:
June 12-16, 2023, and June 26-30, 2023
Inspection Procedure:
IP 71111.21N.03, Commercial Grade Dedication
Lead Inspector:
John V. Bozga
Senior Reactor Inspector, RIII/DORS/ERPB
630-829-9613
Teammates:
Matthew Domke, Reactor Inspector, RIII/DORS/ERPB
Eucherius Rosario, Reactor Inspector, RIII/DORS/EB1
II.
LOGISTICS
Email the following inspection logistics to the lead inspector by June 2, 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); and
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12. Current management and engineering organizational chart.
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 March 24, 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.
3
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
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
Item 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 June 2, 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; and
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); and
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;
and
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.
3.
Additional Information to be Provided on June 12, 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
2 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.
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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.