ML23108A337

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Notification of Commercial Grade Dedication Inspection (05000528/2023012, 05000529/2023012, and 05000530/2023012) and RFI
ML23108A337
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/19/2023
From: Vincent Gaddy
NRC/RGN-IV/DORS/PBD
To: Heflin A
Arizona Public Service Co
Reinert D
References
IR 2023012
Download: ML23108A337 (8)


See also: IR 05000528/2023012

Text

April 19, 2023

Adam Heflin, Executive Vice President

and Chief Nuclear Officer

Arizona Public Service

P.O. Box 52034, MS 7602

Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NOTIFICATION OF

COMMERCIAL GRADE DEDICATION INSPECTION (05000528/2023012,

05000529/2023012, AND 05000530/2023012) AND REQUEST FOR

INFORMATION

Dear Adam Heflin:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

staff will conduct the commercial grade dedication baseline inspection at Palo Verde Nuclear

Generating Station, beginning on September 11, 2023. The inspection team will be composed

of three personnel from the NRC Region IV office. The inspection will be conducted in

accordance with NRC inspection procedure (IP) 71111.21N.03, Commercial Grade

Dedication, dated February 16, 2023.

The inspection will evaluate the implementation of Palo Verde Nuclear Generating Stations

process for dedicating commercial grade items, as required in applicable portions of Appendix B

to Title 10 of the Code of Federal Regulations Part 50, to ensure reasonable assurance is

provided that these items will perform their intended safety function. Additionally, this inspection

will evaluate implementation of Palo Verde Nuclear Generating Stations procurement process

for safety-related structures, systems, and components, as required in Appendix B.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

Onsite Information Gathering Visit: August 14 -18, 2023

Offsite Preparation Week: September 4 - 8, 2023

Onsite Inspection Weeks: September 11 - 15, 2023 and September 25 - 29, 2023

The purpose of the information gathering visit is to meet with your staff to become familiar with

the process for dedicating commercial grade items and the process for procuring safety-related

structures, systems, and components at Palo Verde Nuclear Generating Station. 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, the team lead will also review the information provided in the initial information

A. Heflin

2

request to select a list of potential inspection samples. The team lead may also identify other

information needed to support the inspection during this visit.

To minimize the impact on your staff and to ensure an effective and efficient inspection, we

have enclosed two separate requests for information needed prior to the onsite information

gathering visit and offsite inspection preparation week. The first request (Enclosure 1) is

generally for information that will be used to choose the inspection samples or information that

will be applicable to all inspection samples throughout the inspection. This information should

be made available to the team lead prior to the information gathering visit. The second request

(Enclosure 2) is for information that is specific to an individual sample and should be made

available prior to the offsite preparation week.

Additional information requests, interviews with your staff, and/or walkdowns of facilities or

installed plant components will be made by the team throughout the inspection to complete their

review of the selected inspection samples. It is important that all documentation provided to the

team is complete and upto-date to minimize the number of additional documents requested

during the preparation and/or the onsite portions of the inspection. Additionally, to facilitate an

efficient inspection, we request that a contact individual be assigned to each inspector to ensure

information requests, questions, and concerns are addressed in a timely manner.

We understand that Tracy Rychlyk from your Regulatory Affairs organization is our contact for

this inspection. If there are any questions about the inspection or the information requested,

please contact the team lead, by telephone at 817-200-1534 or by email at

Dustin.Reinert@nrc.gov. Enclosure 3 contains additional contact information for the inspection

team.

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, under 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.

In accordance with 10 CFR 2.390 of the NRC rules and practices, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC public document

room or from the publicly available records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC website.

Sincerely,

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Operating Reactor Safety

Signed by Gaddy, Vincent

on 04/19/23

A. Heflin

3

Docket Nos. 050000528, 05000529, 05000530

License Nos. NPF-41, NPF-51, NPF-74

Enclosures:

1.

Documents Requested Prior to

Information Gathering Visit

2.

Documents Requested Prior to

Inspection Preparation Week

3.

Inspection Team Contact Information

cc w/ encl: Distribution via LISTSERV

ML23108A337

X

SUNSI Review

X

Non-Sensitive

Sensitive

X

Publicly Available

Non-Publicly Available

OFFICE

SRI:DORS/EB1

BC:DORS/EB1

NAME

DReinert

VGaddy

DATE

04/19/23

04/19/23

Enclosure 1

Enclosure 1

Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both onsite and offsite during the information gathering visit.

Electronic format is the preferred media. If electronic media is made available via an internet

based remote document management system, then the remote document access must allow

inspectors to download, save, and print the documents in the NRC's regional office. Electronic

media on compact disc or paper records (hardcopy) are acceptable.

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 the

listed documents. In addition, your plant-specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents requested by August 4, 2023:

1.

Copy of procedures for dedicating commercial grade items/services, procuring

safety-related structures, systems, and components (SSCs), performing receipt

inspections, and controlling counterfeit, fraudulent, and suspect items.

2.

Sortable list of commercial grade items/services that completed the dedication

process within the past six years. These items/services may have been dedicated

by Palo Verde Nuclear Generating Station or by a vendor (or other licensee) and

procured by Palo Verde Nuclear Generating Station. Include, as applicable, relevant

information such as the item/services material/catalog identification number and

description, parent/host equipment identification number and description, purchase

order number, installation work order/job number, and date of issue/installation.

3.

Sortable list of SSCs that were procured as safety-related within the past six years.

Include, as applicable, relevant information such as the SSCs material/catalog

identification number and description, parent/host equipment identification number

and description, purchase order number, installation work order/job number, date of

issue/installation, and end-use safety classification.

4.

Sortable list of dedicated commercial grade items/services or procured safety-related

SSCs that were placed on hold within the past six years because of concerns

identified during receipt, dedication, or from operating experience or the corrective

action program as applicable.

5.

Sortable list of dedicated commercial grade items/services or procured safety-related

SSCs, with a brief description, where dedication/procurement activities were

expedited within the past six years.

6.

Sortable list of dedicated commercial grade-items/services or procured safety-related

SSCs that failed after completing dedication/procurement activities or required

corrective maintenance within the past six years.

2

7.

Sortable list of corrective action program documents, with a brief description, related

to commercial grade item/service dedication, safety-related SSC procurement,

receipt inspection, and storage activities within the past six years.

8.

Copy of any self-assessments or audits of commercial grade item/service dedication

and/or safety-related SSC procurement activities performed within the past six years.

9.

Copy of the updated final safety analysis report, technical specifications, and

technical requirements manual, including applicable bases documents.

10.

Sortable list of systems, including identifying designators and corresponding names.

11.

List of individuals who will be supporting the inspection and their contact information.

Enclosure 2

Enclosure 2

Documents Requested Prior to Inspection Preparation Week

For the samples identified by the team lead, the documents and information requested below

should generally be made available to the inspection team for the team's use both onsite and

offsite during the inspection. Electronic format is the preferred media. If electronic media is

made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hardcopy) are

acceptable.

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 the

listed documents. In addition, your plant-specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents requested by August 28, 2023:

1.

Complete commercial grade item dedication package including relevant

documentation such as the following, as applicable: description of item/service,

identification of safety functions and safety classifications of item/parent component,

like-for-like or equivalency evaluations, credible failure modes/failure modes and

effects analysis, critical characteristics and acceptance criteria, identification of the

suppliers commercial quality assurance program or other documented controls.

2.

Complete purchase order including relevant documentation such as the following, as

applicable: purchase requisition, catalog specifications, item product data

sheets/vendor manuals, shelf-life information, service/qualified life information,

certificates of conformance/compliance/quality, vendor test and inspection reports,

third-party or sub vendor test and inspection results, vendor dedication or partial

dedication information, material receiving reports, packing list/invoices or other

shipping documents, and other pertinent vendor/licensee correspondence.

3.

Receipt inspection reports and any related test reports, documents noting any

deviations from design, material, and performance characteristics relevant to the

safety function (nonconformance dispositions).

4.

Documents showing objective evidence of special test and inspection procedures

used to verify technical and quality requirements have been met, commercial grade

survey reports, or source verification reports; any other documents to trace the item

from the time it was dedicated to the time it was installed, tested, and accepted.

5.

Completed installation work orders and stock or material issue forms; completed

post-installation test procedures and results.

2

6.

Design basis information of the inspection sample or parent/host component such

as: normal/accident service environment, normal/accident performance

requirements, design basis document/system description, relevant UFSAR/technical

specification sections, calculation/drawing/procedure updates, etc.

7.

10 CFR 50.59 documentation, if required.

8.

Sortable list of corrective action program documents, with a brief description,

associated with the inspection sample or parent/host equipment.

Enclosure 3

Enclosure 3

Inspection Team Contact Information

Dustin Reinert (Lead)

Senior Reactor Inspector

817-200-1534

Dustin.Reinert@nrc.gov

Chase Franklin

Reactor Inspector

404-997-4717

Chase.Franklin@nrc.gov

Dustin Bryen

Reactor Inspector

817-200-1078

Dustin.Bryen@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Dustin Reinert

1600 East Lamar Blvd.

Arlington, TX 76011-4511