ML23360A608

County Station Request for Information for NRC Commercial Grade Dedication Inspection: Inspection Report 05000373/2024010 and 05000374/2024010

ML23360A608
Person / Time
Site:	LaSalle
Issue date:	12/27/2023
From:	Lionel Rodriguez NRC/RGN-III/DORS/EB1
To:	Rhoades D Constellation Energy Generation
References
IR 2024010
Download: ML23360A608 (1)

See also: IR 05000373/2024010

Text

December 27, 2023

David P. Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LASALLE COUNTY STATION - REQUEST FOR INFORMATION FOR

NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION

REPORT 05000373/2024010 AND 05000374/2024010

Dear David Rhoades:

On April 15, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a

commercial grade dedication (CGD) inspection at LaSalle County 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 LaSalles 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 LaSalles 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:

• Potential Information Gathering Visit: March 18 - 22, 2024

• Preparation week: April 8 - 12, 2024

• Onsite weeks: April 15 - 19, 2024 and April 29 - May 3, 2024

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

LaSalle. This visit would also allow the lead inspector to meet with procurement

engineering and other site individuals responsible for the inspection to ensure a

D. Rhoades 2

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. 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.

It is important that all these documents are up-to-date and complete 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 4, 2024. The lead inspector will communicate the initial selected

set of samples no later than March 25, 2024.

• 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 April 5, 2024. 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 April 15, 2024.

• 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 Lionel Rodriguez. We understand that our

licensing contact for this inspection is Jereme Greenblott of your organization. If there are

any questions about the inspection or the material requested in the enclosure, please

contact the lead inspector at 630-829-9609 or via email at Lionel.Rodriguez@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

D. Rhoades 3

unless the requesting document displays a currently valid Office of Management and

Budget Control Number.

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 Rodriguez, Lionel

on 12/27/23

Lionel Rodriguez

Senior Reactor Inspector

Engineering Branch 1

Division of Operating Reactor Safety

Docket Nos. 05000373; 05000374

License Nos. NPF-11; NPF-18

Enclosure:

Commercial Grade Dedication Inspection

Request for Information

cc: Distribution via LISTSERV

D. Rhoades 4

Letter to David Rhoades from Lionel Rodriguez dated December 27, 2023.

SUBJECT: LASALLE COUNTY STATION - REQUEST FOR INFORMATION FOR

NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION

REPORT 05000373/2024010 AND 05000374/2024010

DISTRIBUTION:

Jeffrey Hamman

RidsNrrDorlLpl3

RidsNrrPMLaSalle Resource

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Diana Betancourt-Roldan

Allan Barker

David Curtis

Jared Heck

Jefferson Clark

R3-DORS

ADAMS Accession Number: ML23360A608

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII RIII

NAME LRodriguez:gmp

DATE 12/27/2023

OFFICIAL RECORD COPY

COMMERCIAL GRADE DEDICATION INSPECTION

REQUEST FOR INFORMATION

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000373/2024010 AND 05000374/2024010

Onsite Inspection Dates: April 15 - 19, 2024 and April 29 - May 3, 2024

Inspection Procedure: IP 71111.21N.03, Commercial Grade Dedication

Lionel Rodriguez, Senior Reactor Inspector

Lead Inspector:

RIII/DORS/EB1 630-829-9609

Lionel.Rodriguez@nrc.gov

Alan Dahbur, Senior Reactor Inspector, RIII/DORS/EB2

Teammates:

Megan Gangewere, Reactor Inspector, RIII/DORS/EB1

Cory Padilla, Reactor Inspector, RIII/DORS/EB1 (Observer)

II. LOGISTICS

Email the following inspection logistics to the lead inspector by April 8, 2024, 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;

Enclosure

11. Any potential resource conflicts during the inspection (e.g., emergency

drills and all-staff meetings); and

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 4, 2024, 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

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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.

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

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commercial-grade dedication, safety-related component procurement,

and/or receipt inspection/testing activities within the past 6 years.

2. Information Requested to Support Inspection Preparation Activities

The following information is requested by April 5, 2024, 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:

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2.16.1 Safety classification

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 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)

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 April 15, 2024, 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 April 8, 2024.

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

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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.

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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