ML24150A024
| ML24150A024 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/29/2024 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024012 | |
| Download: ML24150A024 (1) | |
See also: IR 05000352/2024012
Text
May 29, 2024
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:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - NOTIFICATION OF
COMMERCIAL GRADE DEDICATION INSPECTION (05000352/2024012 AND
05000353/2024012) AND REQUEST FOR INFORMATION
Dear David Rhoades:
The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff
will conduct the commercial grade dedication baseline inspection at Limerick Generating Station
(Limerick), Units 1 and 2, beginning on September 16, 2024. The inspection team will be
composed of three personnel from the NRC Region I office. The inspection will be conducted in
accordance with NRC Inspection Procedure 71111.21N.03, Commercial Grade Dedication,
dated February 16, 2023.
The inspection will evaluate the implementation of Limericks 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 Limericks procurement process for safety-related 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 5-8, 2024
Offsite Preparation Week: September 9-13, 2024
Onsite Inspection Weeks: September 16-20, 2024, and September 30-October 4, 2024
The purpose of the onsite information gathering visit is to meet with staff expected to support
this inspection, and to become familiar with the process for dedicating commercial-grade items
and the process for procuring safety-related components at Limerick. We are aware that
portions of the commercial grade dedication and safety-related procurement process may be
handled at locations other than your site, and we will coordinate the best dates, times, and
location(s) for the onsite information gathering visit with your staff. This visit may include a tour
D. Rhoades
2
of onsite commercial-grade item dedication facilities, receipt inspection facilities, storage
facilities, and installed plant components associated with potential inspection samples. The
team lead will also review your plans for onsite inspection logistics including resources that will
be provided to the team while onsite (e.g., conference rooms, network access, printers,
monitors, etc.) and how information requests will be tracked and processed.
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 before August 5, 2024. The team lead will use this information to support preparation
for the onsite information gathering visit and selection of a list of potential inspection samples.
The second request (Enclosure 2) is for information that is more specific to the selected
inspection samples and should be made available before September 9, 2024.
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 up-to-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 Jordan Rajan from your Regulatory Assurance organization is our contact
for this inspection. If there are any questions about the inspection or the information requested,
please contact the team lead, Eric C. Miller, by telephone at (610) 337-5116 or by email at
Eric.Miller2@nrc.gov. Enclosure 3 contains additional contact information for the inspection
team.
PAPERWORK REDUCTION ACT STATEMENT
This letter contains mandatory 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). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, 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.
D. Rhoades
3
This letter, its enclosures, 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Operating Reactor Safety
Docket Nos. 05000352 and 05000353
License Nos. NPF-39 and NPF-85
Enclosures:
1. Documents Requested Prior to Information
Gathering Visit
2. Documents Requested Prior to Inspection
Preparation Week
3. Inspection Team Contact Information
cc w/ encls: Distribution via LISTSERV
Glenn T.
Dentel
Digitally signed by Glenn
T. Dentel
Date: 2024.05.29
08:58:27 -04'00'
x
SUNSI Review
x
Non-Sensitive
Sensitive
x
Publicly Available
Non-Publicly Available
OFFICE RI/DORS
RI/DORS
NAME
EMiller
GDentel
DATE
5/29/2024
5/29/2024
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 (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,
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. We also request that the information provided be sorted by the list below.
Documents requested by August 5, 2024 (Prior to the Information Gathering Visit):
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. This should include procedure for controlling counterfeit,
fraudulent, and suspect items and, if applicable, procedures that address
requirements associated with the parts quality initiative (PQI).
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 Limerick
Generating Station, Units 1 and 2 or dedicated by a vendor (or other licensee) and
procured by Limerick Generating Station, Units 1 and 2. Please note whether the
item has been installed in the plant. The list should encompass the past six years of
dedication activities. The list should identify the systems/components where the
items were installed or were intended to be installed for use. It should also identify
whether the item has been installed.
4.
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. The list should identify the
systems/components where the items were installed or were intended to be installed
for use. It should also identify whether the item has been installed.
5.
List of corrective action program documents, with descriptions, associated with
commercial-grade items, safety-related procurement, receipt, or storage. The list
should include any items that failed while in service after completing the dedication
or safety-related procurement process. It should encompass the past six years of
these activities and should identify the systems/components where the items were
installed. The list should also identify the vendor who supplied the associated item.
2
6.
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. The list should identify the systems/components where the
items were intended to be installed for use.
7.
List of components procured as safety-related or commercial-grade items dedicated
for safety-related applications, in the past six years, where the
procurement/dedication process was expedited to support rapid turnaround (less
than seven days). If possible, the list should identify the systems in which these
items were intended for use.
8.
List of systems, system numbers/designators, corresponding names, and risk-
ranking.
9.
Copies of any self-assessments/audits of the safety-related procurement or the
commercial-grade dedication and procurement processes that were completed within
the two-years prior to the start date of this inspection.
10.
List of site contacts that will be associated with the inspection and a 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 six years.
Enclosure 2
Enclosure 2
Documents Requested Prior to Inspection Preparation Week
For the samples selected by the team lead and provided to your point of contact following the
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
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. Paper
records (hard copy) are acceptable when necessary. 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,
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. We also request that the information provided be sorted by the list below for
each sample.
Documents requested by September 9, 2024 (Prior to Preparation Week):
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.
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.
2
15.
Design/material/process change history information.
16.
Completed commercial-grade dedication document including safety classification,
identification of safety functions/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-item, design, material, and
specific performance characteristic (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.
Enclosure 3
Enclosure 3
Inspection Team Contact Information
Eric C. Miller (Lead)
Reactor Inspector
(610) 337-5116
Eric.Miller2@nrc.gov
Senior Reactor Inspector
(610) 337-6927
Juan.Ayala@nrc.gov
Senior Reactor Inspector
(610) 337-5365
Paul.Cataldo@nrc.gov
Mailing Address:
U.S. NRC, Region I
Attn: Eric C. Miller
475 Allendale Road
STE 102
King of Prussia, PA 19406-1415