ML23055B056

Request for Information for NRC Commercial Grade Dedication Inspection Inspection Report 05000282/2023010 and 05000306/2023010

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

February 27, 2023

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.

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,

Signed by Bozga, John

on 02/27/23

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

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:

Jessie Quichocho

Marc Ferdas

Paul Zurawski

RidsNrrPMPrairieIsland Resource

RidsNrrDorlLpl3

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Diana Betancourt-Roldan

Allan Barker

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

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

John V. Bozga

Lead Inspector:

Senior Reactor Inspector, RIII/DORS/ERPB

630-829-9613

Matthew Domke, Reactor Inspector, RIII/DORS/ERPB

Teammates:

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

Enclosure

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.

2

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.

3

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;

4

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

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); 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.

5

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.

6