ML24089A258
| ML24089A258 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/01/2024 |
| From: | Jorge Corujo-Sandin NRC/RGN-III/DORS/EB2 |
| To: | Tony Brown Energy Harbor Nuclear Corp |
| References | |
| IR 2024010 | |
| Download: ML24089A258 (1) | |
See also: IR 05000346/2024010
Text
Terry Brown
Site Vice President
Energy Harbor Nuclear Corp.
Davis-Besse Nuclear Power Station
5501 N. State Rte. 2, Mail Stop A-DB-3080
Oak Harbor, OH 43449-9760
SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION - REQUEST FOR INFORMATION
FOR THE NRC QUADRENNIAL COMPREHENSIVE ENGINEERING TEAM
INSPECTION: INSPECTION REPORT 05000346/2024010
Dear Terry Brown:
On September 9, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a quadrennial
baseline Comprehensive Engineering Team Inspection (CETI) at Davis-Besse Nuclear Power
Station. This inspection will be performed in accordance with NRC Inspection Procedure
The CETI focuses on the design, maintenance, and operation of risk significant components
with low margin, or associated with an accident scenario, or a specific system. The inspection
also monitors the implementation of changes to structures, systems, and components as
modifications to one system may also affect the design bases and functioning of interfacing
systems as well as introduce the potential for common cause failures. The components,
modifications, 50.59 Evaluations, 50.59 Screenings and Operating Experiences to be reviewed
during this baseline inspection will be identified as part of the preparation for the inspection and
finalized during the first onsite inspection week. Additionally, the inspection team may request
scenarios to be performed on the simulator. This request would require support from your
simulator staff to validate scenarios, simulator time, and a crew to perform the actions which
would most likely occur during the second onsite week. The team will work closely with your
staff early on during the inspection process to ensure this activity can be accomplished with
minimal impact.
The inspection will include two weeks onsite. The inspection team will consist of seven NRC
inspectors who will focus on engineering/maintenance/operations of the selected components,
modifications, 50.59 Evaluations, 50.59 Screenings, and Operating Experiences. The current
inspection schedule is as follows:
- Preparation week: September 2 - 6, 2024
- Onsite weeks: Week 1: September 9 - 13, 2024
Week 2: September 23 - 27, 2024April 1, 2024
T. Brown 2
Experience with previous baseline design/modification 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. 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, with their respective due
dates:
- May 14, 2024 - The first group lists information necessary for our initial inspection
scoping activities (preliminary sample selections).
- July 15, 2024 - The lead inspector will communicate the preliminary
samples selected. This will include Components, Modifications, 50.59
Evaluations and 50.59 Screenings.
- August 21, 2024 - The second group of documents requested are those items needed
to support our in-office preparation activities. During the in-office preparation activities,
the team may identify additional information needed to support the inspection.
- September 9, 2024 - The third group includes the additional information identified during
the in-office preparation as well as plant-specific reference material. This information
should be available to the team onsite.
- After September 9, 2024 - The fourth group includes supporting information to be
provided throughout the 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 Jorge Corujo-Sandin. We understand that our licensing
contact for this inspection is Gerry Wolf of your organization. If there are any questions about
the inspection or the material requested in the enclosure, please contact the lead inspector at
630-829-9741 or via email at Jorge.Corujo-Sandin@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.
T. Brown 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,
Senior Reactor Inspector
Engineering Branch 1
Division of Operating Reactor Safety
Docket No. 05000346
License No. NPF-3
Enclosure:
Comprehensive Engineering Team
Inspection - Request for Information
cc w/ encl: Distribution via LISTSERV
Rodriguez, Lionel signing on behalf
of Corujo-Sandin, Jorge
on 04/01/24
T. Brown 4
Letter to Terry Brown from Jorge Corujo-Sandin dated April 1, 2024.
SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION - REQUEST FOR INFORMATION
FOR THE NRC QUADRENNIAL COMPREHENSIVE ENGINEERING TEAM
INSPECTION: INSPECTION REPORT 05000346/2024010
DISTRIBUTION:
RidsNrrPMDavisBesse Resource
RidsNrrDorlLpl3
RidsNrrDroIrib Resource
R3-DORS
ADAMS Accession Number: ML24089A258
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII RIII
NAME LRodriguez for
JCorujo-Sandin:gmp
DATE 04/01/2024
OFFICIAL RECORD COPY
COMPREHENSIVE ENGINEERING TEAM INSPECTION
REQUEST FOR INFORMATION
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000346/2024010
Onsite Inspection Dates: September 9 - 13, 2024 and September 23 - 27, 2024
Inspection Procedure: IP 71111.21M, Comprehensive Engineering Team Inspection
Jorge Corujo-Sandin, Senior Reactor Inspector
Lead Inspector: RIII/DORS/EB1
630-829-9741
Jorge.Corujo-Sandin@nrc.gov
Benny Jose, Senior Reactor Inspector, RIII/DORS/EB2
Ijaz Jesse Hafeez, Senior Reactor Inspector, RIII/DORS/EB2
Teammates: Kevin Barclay, Senior Reactor Inspector, RIII/DORS/EB1
Lionel Rodriguez, Senior Reactor Inspector, RIII/DORS/EB1
Edison Fernandez, Senior Reactor Inspector, RIII/DORS/ERPB
Thomas Briley, Senior Project Engineer, RIII/DORS/TSS
Elba Sanchez Santiago, Senior Project Engineer, RIII/DORS/TSS
Observers: Anthony Valiaveedu, Reactor Inspector, RIII/DORS/EB2
Stephanie Liska, Reactor Inspector, RIII/DORS/EB2
II. INSPECTION LOGISTICS
Email the following inspection logistics to the lead inspector by August 12, 2024, or sooner:
1. Inspection room name/number, and phone number. If possible, also provide an interview
room name/number;
2. Response team contact information (names and phone numbers), team roles (e.g.,
management sponsor, lead, inspector counterpart), and normal working hours;
3. Any site access/badging and dosimetry actions needed for each inspector/observer;
4. Entrance meeting time and location;
5. Confirmation that the team will have Wi-Fi access, and access to a licensee computer
with a nearby printer;
6. Cafeteria location and hours (if any);
7. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff
meetings); and
8. Available times, during the Monday and Tuesday of the second onsite week, to use the
simulator to run scenarios. An operations crew to support this effort will also be required.
9. Current management and engineering organizational chart.
Enclosure
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 Preliminary Selection of Samples
The following information is requested by May 14, 2024, or sooner, to facilitate the initial
sample selection.
Note: If you are unable to provide the items below as requested, please reach out to the
Team Lead as soon as possible.
1.1. Risk-Ranking of the top 250 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 250 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 250 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. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook,
Internal Flood scenario notebook and latest internal event PSA summary
document.
1.6. List of systems, system numbers/designators, and corresponding system names.
1.7. List of high-risk Maintenance Rule systems/components based on engineering or
expert panel judgment (i.e., those systems/components not identified high-risk in
the PSA).
1.8. Electronic copies of simplified plant drawings (if available). Note: these may be
uncontrolled documents such as big notes, training diagrams, etc.
2
1.9. Electronic copies of updated final safety analysis report (UFSAR), Technical
Specifications, Technical Specifications Bases, and Technical Requirements
Manual.
1.10. Provide copies of the emergency operating procedures and abnormal operating
procedures.
1.11. Provide the in-service testing (IST) program document. Include the IST Program
Basis document, or equivalent (if any).
1.12. Copies of procedures addressing the following: modifications, design changes, set
point changes, equivalency evaluations or suitability analyses, post-modification
testing, 10 CFR 50.59 evaluations and screenings, and UFSAR updates.
1.13. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)
category for the last 4 years.
1.14. A list of operating experience evaluations for the last 4 years.
1.15. Information of any common cause failure of components experienced in the last
4 years at your facility.
1.16. List of Root Cause Evaluations associated with component failures or design
issues initiated/completed in the last 4 years.
1.17. List of open operability evaluations.
1.18. Procedures addressing time critical and/or risk significant operator actions. If not
part of the procedure, include a list of all time critical and/or risk significant operator
actions. Identify those actions that do not have job performance measures.
1.19. List of permanent plant modifications to SSCs that are field work complete. Do
not include canceled or still in process modifications. For the purpose of this
inspection, permanent plant modifications include permanent:
1.19.1 Plant changes, design changes, set point changes, completed in the last
4 years;
1.19.2 Equivalency evaluations, and suitability analyses completed in the last
4 years;
1.19.3 Procedure changes for Emergency Operating Procedures (EOPs),
Abnormal Operating Procedures (AOPs), surveillances, and test
procedures in the last 4 years; and
1.19.4 Calculation changes that have been issued for use in the last 4 years.
1.20. A list of corrective action documents (open and closed) in the last 4 years that
address permanent plant modifications issues, concerns, or processes. These
documents should also include the corrective action documents associated with
the modification implementation.
3
1.21. List of all 10 CFR 50.59 completed evaluations involving (a) calculations,
(b) procedure revisions, (c) changes to the facility (modifications), (d) non-routine
operating configurations, or (e) departures in methods of analyses. The list should
NOT include any evaluations which concluded a license amendment was required.
Include evaluations performed over the last 4 years. This list should include 50.59
evaluations for the following:
1.21.1 Changes that have been made under the provisions of 10 CFR 50.59 that
have been updated in accordance with 10 CFR 50.71(e)(4);
1.21.2 Modifications that are field work complete; and
1.21.3 Changes to calculations (or initiation of new calculations) that have been
issued. The list should contain the number and title of each document, a
brief description of the change, and the corresponding number and type of
the affected document (i.e., the modification or procedure to which the
evaluation applies).
1.22. A list of all 10 CFR 50.59 changes that have been screened out as not requiring a
full evaluation involving (i.e., just a 50.59 Screening): (a) calculations; (b)
procedure revisions; (c) changes to the facility (modifications); (d) non-routine
operating configurations; or (e) departures in methods of analyses.
The list should contain the number and title of each document, a brief description
of the change, and the corresponding number and type of the affected document
(i.e., the modification or procedure to which the evaluation applies.)
1.23. A list of any modifications, procedure revisions, or the UFSAR changes where it
was determined that 10 CFR 50.59 did not apply.
1.24. A list of corrective action documents (open and closed) that address 10 CFR 50.59
issues, concerns, or processes. These documents should also include the
associated corrective action documents and the 50.59 change implementation.
The list should contain the number, title, and revision (or date) of each document,
the affected system and corresponding documentation (if applicable).
1.25. UFSAR updates submitted in accordance with 10 CFR 50.71(e)(4). Provide copies
of the complete submittal.
1.26. Copy of the UFSAR change log or a synopsis of the changes. This should include
all of the changes made to the UFSAR that were incorporated in the last
10 CFR 50.71(e)(4) submittal.
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2. Information Requested for the Preliminary Selected Samples to be Available by
August 21, 2024
This information should be separated for each selected sample, especially if provided
electronically (e.g., folder with component or modification name that includes calculations,
condition reports, maintenance history, etc.).
2.1. Corrective Action Program procedures, including the operability/functionality
determination procedure.
2.2. Quality Assurance Program document/procedure.
2.3. A copy of any internal/external self-assessments and associated corrective action
documents generated in preparation for the inspection.
2.4. A copy of engineering/operations related audits completed in the last 2 years.
For the selected Components:
2.5. System Health Reports, System Descriptions, Design Basis Documents, and/or
Training Lesson Plans associated with each of the selected components.
2.6. List of condition reports (corrective action documents) associated with each of the
selected components for the last 4 years. (Excel format preferred.)
2.7. For each selected component list of the maintenance history (corrective,
preventive, and elective) over the last 10 years. Identify frequency of preventive
maintenance activities.
2.8. Aging Management Program documents applicable to each selected component.
2.9. Provide an all-inclusive list of calculation revisions in effect associated with each
of the selected components. Include document number, title, and revision number.
2.10. Copies of calculations associated with each of the selected components, excluding
data files. If number of applicable responses under this request, for a specific
component, is excessive (e.g., more than 10 calculations), you may reach out to
the Team Lead to for an alternative. [Pipe stress calculations excluded from this
request.]
2.11. Electronic copies of electrical drawings (ac and dc) and key diagrams.
2.12. Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available).
2.13. Copies of operability evaluations (open/closed for last 4 years) associated with
each of the selected components and plans for restoring operability, if applicable.
2.14. Copies of operator work-around evaluations associated with each of the selected
components and plans for resolution, if applicable.
5
2.15. Copies of any open temporary modifications associated with each of the selected
components, if applicable.
2.16. Trend data on the selected electrical/mechanical components performance for
last 4 years. (For example, pumps performance including in-service testing, other
vibration monitoring, oil sample results, etc., for valves: stroke time and leak rate
results, diagnostic trend data, etc.)
2.17. Provide copies of the normal and alarm response procedures associated with the
selected components and selected scenarios (if any).
2.18. If available electronically, provide the vendor manual. Otherwise refer to section 4
of this RFI.
2.19. Completed tests and surveillances for each selected component performed during
the last 3 years. For those tests and surveillances performed at a periodicity of
greater than 3 years, provide the latest two performed. Include the associated
acceptance criteria basis calculations. For those specific tests or surveillances
performed at a periodicity resulting in excessive responses to this request, you
may reach out to the Team Lead for an alternative.
For the selected Modifications, 50.59 Evaluations and 50.59 Screenings:
2.20. For each of the selected modifications, provide the engineering change package.
Include any associated 50.59 Screening and/or 50.59 Evaluation.
2.21. Provide a copy of each selected 50.59 Evaluation.
2.22. Provide copies of the selected 50.59 Screenings.
2.23. The selected Modifications, 50.59 Evaluations and 50.59 Screenings will be
further filtered by the inspectors until the final samples are selected. Once these
are selected (during the preparation week and the first on-site week) the site
should be prepared to provide other supporting documents for the selected item.
Examples of supporting documents include:
- Design drawings supporting the change
- Procedures, calculations, etc. affected by the change
- Post-modification test packages
- UFSAR change papers generated (e.g., marked off pages)
6
3. Additional Information to be Provided on September 9, 2024, When the Team is
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.
3.2. Schedule of any testing/maintenance activities to be conducted on the selected
components or installed modifications during the two onsite inspection weeks.
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., plant local
time, to each inspector. It is recommended to provide the team leader with a
master list sorted by inspector and each inspector with a list containing only the
items originated by that inspector.
4.3. If available in hardcopy form, one complete set of P&IDs and simplified drawings
(e.g., training schematics). If any of these documents is not available in hardcopy
form, contact the lead inspector.
4.4. Please ensure that other supporting documents for the selected items have been
located and are readily retrievable as the inspection team will likely be requesting
these documents during the inspection. Examples of supporting documents are:
4.4.1 Individual Plant Examination/Probabilistic Risk Assessment report;
4.4.2 Procurement documents for components and modifications selected (verify
retrievable);
4.4.3 Plant procedures (normal, abnormal, emergency, surveillance, etc.);
4.4.4 Vendor manuals;
4.4.5 Historical revisions of the Final Safety Analysis Report (FSAR), including
the Original FSAR and Original Safety Evaluation Report; and
4.4.6 Copy of electrical drawings, key diagrams, and isometrics (paper copies).
If you have questions regarding the information requested, please contact the lead inspector.
7