ML23094A135
| ML23094A135 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/04/2023 |
| From: | James Park NRC/RGN-III/DORS/ERPB |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023010 | |
| Download: ML23094A135 (1) | |
See also: IR 05000456/2023010
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: BRAIDWOOD GENERATING STATION - REQUEST FOR INFORMATION FOR
NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION
REPORT 05000456/2023010; 05000457/2023010
Dear David Rhoades:
On August 14, 2023, the U.S. Nuclear Regulatory Commission (NRC) will begin a commercial
grade dedication (CGD) inspection at Braidwood Generating Station. This inspection will be
performed in accordance with NRC Inspection Procedure 71111.21N.03, Commercial Grade
Dedication.
The inspection will evaluate the implementation of Braidwoods 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 Braidwoods 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) along with one observer. The current inspection schedule is as follows:
Information Gathering Visit: June 12-16, 2023
Preparation week: August 7- August 11, 2023
Onsite weeks: August 14-18, 2023 and August 28-September 1, 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 Braidwood. 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.April 4, 2023
D. Rhoades -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 June 9, 2023.
The lead inspector will communicate the initial selected set of samples no later than
June 30, 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 July 28, 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 August 14, 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 Joon S. Park. We understand that our licensing contact
for this inspection is Steve Mitchell of your organization. If there are any questions about the
inspection or the material requested in the enclosure, please contact the lead inspector
at 630-829-9715 or via e-mail at Joon.Park@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.
D. Rhoades -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,
Joon S. Park, Reactor Inspector
Engineering Reactor and Projects Branch
Division of Operating Reactor Safety
Docket Nos. 50-456; 50-457
Enclosure:
Commercial Grade Dedication Inspection
Request for Information
cc: Distribution via LISTSERV
Signed by Park, Joon
on 04/04/23
D. Rhoades -4-
Letter to David Rhoades from Joon S. Park dated April 4, 2023.
SUBJECT: BRAIDWOOD GENERATING STATION - REQUEST FOR INFORMATION FOR
NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION
REPORT 05000456/2023010; 05000457/2023010
DISTRIBUTION:
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RidsNrrPMBraidwood Resource
RidsNrrDroIrib Resource
R3-DORS
ADAMS Accession Number: ML23094A135
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII
NAME JPark:mb
DATE 04/04/2023
OFFICIAL RECORD COPY
COMMERCIAL GRADE DEDICATION INSPECTION
REQUEST FOR INFORMATION
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000456/2023010; 05000457/2023010
Onsite Inspection Dates: August 14-18, 2023 and August 28-September 1, 2023
Inspection Procedure: IP 71111.21N.03, Commercial Grade Dedication
Joon S. Park, Reactor Inspector, RIII/DORS/ERPB
Lead Inspector: 630-829-9715
Joon.Park@nrc.gov
Benny Jose, Senior Reactor Inspector, RIII/DORS/EB2
Teammates: Eucherius Rosario, Reactor Inspector, RIII/DORS/EB1
Thomas Hartman, Senior Reactor Inspector, RIII/DORS/ERPB
(Observer)
II. LOGISTICS
Email the following inspection logistics to the lead inspector by August 11, 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 June 9, 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.
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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 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). If possible, the list should identify the systems and
equipment in which these items were intended for use.
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 July 28, 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
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2.16.2 identification of safety functions/application requirements
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;
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 August 14, 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 August 7, 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
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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 2:00 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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