ML23184A035
| ML23184A035 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie |
| Issue date: | 06/30/2023 |
| From: | Division of Reactor Safety II |
| To: | Coffey R Florida Power & Light Co |
| References | |
| IR 2023010 | |
| Download: ML23184A035 (7) | |
See also: IR 05000335/2023010
Text
June 30, 2023
Mr. Robert Coffey
Vice President, Nuclear Division
and Chief Nuclear Officer
Florida Power & Light Company
Mail Stop: EX/JB
700 Universe Blvd.
Juno Beach, FL 33408
SUBJECT: NOTIFICATION OF ST. LUCIE UNITS 1 & 2 - FOCUSED ENGINEERING
INSPECTION (FEI) 05000335/2023010 AND 05000389/2023010 AND INITIAL
INFORMATION REQUEST
Inspection Procedure:
71111.21N,03, Focused Engineering Inspection (FEI),
Attachment 21N.03, Commercial Grade Dedication, dated June
28, 2022 (ADAMS ML22075A251)
Inspection Report: 05000335/2023010 AND 05000389/2023010
(Standalone Inspection Report)
Inspectors:
T. Fanelli (Lead)
J. Hamman (Elec/CGD)
Inspect 3 (TBD)
The purpose of this letter is to notify St. Lucie that three inspectors from Region II will conduct
an inspection at your site in accordance with Inspection Procedure 71111.21N.03, Focused
Engineering Inspection (FEI), Attachment 21N.03, Commercial Grade Dedication,
Commercial Grade Dedication. This is not considered a team inspection. The inspection will
evaluate Watts Bars process for dedicating commercial-grade items, as required in applicable
portions of Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50
(Appendix B), to ensure reasonable assurance is provided that these items will perform their
intended safety function. Additionally, this inspection will evaluate implementation of Watts
Bars procurement process for safety-related components, as required in Appendix B. The
inspectors will select samples of components that are risk significant and within the scope of the
program.
During a 6/30/2023, phone call Mr. Tim Falkiewicz, PSL Regulatory Affairs, we confirmed
arrangements for an information-gathering site visit and the two-week onsite inspection. The
schedule is as follows:
Information Gathering Visit: November 6, 2023; Preparation Week: November 20, 2023.
Onsite Weeks of November 27 and December 11, 2023.
On November 6, 2023, Mr. Theo Fanelli, a Senior Reactor Inspector from the NRCs Region II
office, will begin the inspection with an information gathering visit to the site. The purpose of the
R. Coffey
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visit is to become familiar with the process for dedicating commercial-grade items and the
process for procuring safety-related components at ST. Lucie. 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 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 a productive 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 specific to individual samples and should be made available prior to the offsite
preparation week.
Please provide the information requested in Enclosure 1 to the Region II Office or a file sharing
site by October 30, 2023. Additional documents may be requested during the information
gathering visit. The inspectors will try to minimize your administrative burden by specifically
identifying only those documents required for inspection preparation. The additional information
should be provided to the Inspectors in the Region II office or a file sharing site by November
20, 2023.
During the information gathering visit, Mr. Fanelli will also discuss the following inspection
support administrative details: (1) availability of knowledgeable plant engineering and licensing
personnel to serve as points of contact during the inspection, (2) method of tracking inspector
requests during the inspection, (3) computer access, (4) working space, (5) arrangements for
site access, and (6) other applicable information.
R. Coffey
3
INFORMATION REQUEST FOR ST. LUCIE UNITS 1 & 2 - FOCUSED ENGINEERING
INSPECTION (FEI) COMMERCIAL GRADE DEDICATION
Prior to the information gathering visit, please provide the information electronically in .pdf
files, Excel, or other searchable format on CDROM (or FTP site, SharePoint, etc.). The
CDROM (or website) should be indexed and hyperlinked to facilitate ease of use.
Contact Information: T. Fanelli
(404) 997-4433
tnf1@nrc.gov
Information Gathering Visit: An information gathering visit is currently scheduled the week of
November 6, 2023. During this visit, we would like to identify the component samples for this
inspection. Wed like to meet with procurement and dedication specialists to discuss the
upcoming inspection and our sample selection process. Purposes of the site visit are to: (a)
discuss the scope of the planned inspection; (b) obtain advance information to review in
preparation for the inspection; (c) ensure that the information to be reviewed is available at the
beginning of the inspection; and (d) verify that logistical issues (such as obtaining both site and
computer system access and arranging the location of the inspection team working area) will be
resolved prior to inspector arrival. Please reserve a room during the scheduled inspection
dates. We request the room have a telephone, wireless internet access, and a licensee
computer with access to procedures, corrective action program documents, and a printer.
Logistics:
Information gathering visit: week of November 6, 2023
Onsite inspection weeks: weeks of November 27 and December 11, 2023
Please schedule an entrance meeting for around 2:00 p.m. on Monday, November 27, 2023
(approximately 15 minutes). The date and time of the exit meeting will be discussed later. In
addition, Id like to have a daily debrief with your inspection support staff at a convenient time in
the afternoons for both onsite inspection weeks (Time TBD, approximately 30 minutes).
We will need a conference room as workspace for the inspectors. We will also need an area
available for conducting interviews.
Please provide access to your document system (preferably at least one computer in our
conference room), nearby printers, and Wi-Fi access.
During the information gathering visit, please provide info on (1) conference room location &
phone number, (2) cafeteria location/hours, and (3) procurement and engineering staff normal
working hours. Also, please let me know if there are any potential resource conflicts during our
scheduled inspection weeks (Fridays off, EP drills, management retreats) and well do our best
to accommodate.
R. Coffey
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Team Members:
Theo Fanelli (Inspection Lead)
J. Hamman (Elec/CGD)
Inspect 3 (TBD)
Please verify the status of access authorization and requirements for unescorted access for
each inspector. Please provide me with a list of exceptions, and I will address them.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains voluntary information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections (approval number 3150-0011). The burden to the public
for these information collections is estimated to average 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per response. Send
comments regarding this information collection to the Information Services Branch, Office of the
Chief Information Officer, Mail Stop: T6A10M, U.S. Nuclear Regulatory Commission,
Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk
Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of
Management and Budget, Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct nor 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 OMB control number.
This letter, its enclosure, and your response (if any) 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 Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Enclosure
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 on-site and off-site 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 (hard copy) are acceptable. At the end of
the inspection, the documents in the team's possession will not be retained.
This document request is based on typical documents that a generic plant might have. As such,
it 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 October 30, 2023:
1. Licensing basis documents such as the updated final safety analysis report and
technical specifications.
2. Procedures for dedicating commercial-grade items and for procurement of safety-related
components. Procedure controlling counterfeit, fraudulent, and suspect items.
3. 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 Site or
dedicated by a vendor (or another licensee) and procured by the Site. Please note
whether the item has been installed in the plant. The list should encompass the past six
years of dedication activities.
4. List of any commercial grade-items that failed after completing the dedication process.
The list should encompass the past six years of dedication activities.
5. List of components procured as safety-related, with descriptions, if not included above.
Please note whether the item has been installed in the plant. The list should encompass
the past six years of procurement activities.
6. 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 six years of these activities.
7. List of systems, system numbers/designators, and corresponding names.
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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 on-site and
off-site 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 (hard copy) are
acceptable. At the end of the inspection, the documents in the team's possession will not be
retained.
This document request is based on typical documents that a generic plant might have. As such,
it 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 November 20, 2023:
1. Purchase requisition and purchase orders.
2. Other pertinent vendor/licensee correspondence.
3. Original and updated design specifications.
4. Catalog specifications.
5. Procurement basis evaluation such as like-for-like, equivalency, plant design change
packages, drawing and specification updates.
6. 10 CFR 50.59 documentation, if required.
7. Material receiving reports, packing lists/invoices, and other shipping documents.
8. Receipt inspection reports and any related test reports and evaluations (similarity etc.).
9. Other documents to trace the item from the time it was dedicated to the time it was
installed, tested, and accepted.
10. Certificates of conformance/compliance/quality.
11. Vendor test and inspection reports.
12. Third-party or sub-vendor test and inspection reports.
13. Shelf-life information.
14. Vendor dedication/partial dedication information.
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15. Design/material/process change history information.
16. Completed commercial-grade dedication document, including safety classification;
identification of safety function/application requirements; identification of critical
characteristics; identification of verification methods and acceptance criteria for the
critical characteristics, evaluation of credible failure modes (if applicable); and
identification of the suppliers quality assurance program that meets 10 CFR Part 50,
Appendix B.
17. Any deviation from design, material, and performance characteristics relevant to the
safety function (nonconformance dispositions).
18. Documents showing objective evidence such as: special test and inspection procedures
and results; commercial-grade survey reports, showing item, design, material, and
specific performance characteristics (relevant to safety function); and source inspection
reports.
19. Completed post-installation test procedure and results.
20. Completed stock or material issue forms and installation work orders or reports.
21. Historical performance information.