ML24220A277
| ML24220A277 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/07/2024 |
| From: | Hartman T NRC/RGN-III/DORS/ERPB |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2025010 | |
| Download: ML24220A277 (1) | |
See also: IR 05000461/2025010
Text
David Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CLINTON POWER STATION - REQUEST FOR INFORMATION FOR THE NRC
QUADRENNIAL COMPREHENSIVE ENGINEERING TEAM INSPECTION:
INSPECTION REPORT 05000461/2025010
Dear David P. Rhoades:
On January 27, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a quadrennial
baseline Comprehensive Engineering Team Inspection (CETI) at Clinton Power Station. This
inspection will be performed in accordance with NRC Inspection Procedure 71111.21M.
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 2 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: January 20 - 25, 2025
- Onsite weeks: January 27 - 31, 2025 and February 10 - 14, 2025August 7, 2024
D. Rhoades 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. 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
needed for the inspection.
It is important that all of these documents are up-to-date and complete in order 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 five groups, with their respective due
dates:
- September 2, 2024 - The First Group lists information necessary for our initial
risk-informed scoping activities.
- September 23, 2024 - The Second Group lists information necessary for our initial
inspection scoping activities (preliminary sample selections).
- November 8, 2024 - The lead inspector will communicate the preliminary
samples selected. This will include Components, Modifications,
50.59 Evaluations and 50.59 Screenings.
- January 10, 2025 - The Third 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.
- January 27, 2025 - The Fourth 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 January 27, 2025 - The Fifth Group includes supporting information to be
provided throughout the inspection. Specifically, corrective action documents and
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 Thomas Hartman. We understand that our licensing
contact for this inspection is Jerry Armstrong of your organization. If there are any questions
about the inspection or the material requested in the enclosure, please contact the lead
inspector at 630-829-9884 or via email at Thomas.Hartman@nrc.gov.
D. Rhoades 3
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.
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,
Thomas Hartman
Senior Project Engineer
Engineering & Reactor Projects Branch
Division of Operating Reactor Safety
Docket Nos. 05000461
License Nos. NPF-62
Enclosure:
Design Bases Assurance Inspection
Document Request
cc: Distribution via LISTSERV
Signed by Hartman, Thomas
on 08/07/24
D. Rhoades 4
Letter to David Rhoades from Thomas Hartman dated August 07, 2024.
SUBJECT: CLINTON POWER STATION - REQUEST FOR INFORMATION FOR THE NRC
QUADRENNIAL COMPREHENSIVE ENGINEERING TEAM INSPECTION:
INSPECTION REPORT 05000461/2025010
DISTRIBUTION:
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RidsNrrPMClinton Resource
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R3-DORS
ADAMS Accession Number: ML24220A277
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
OFFICE RIII
NAME THartman:gmp
DATE 08/07/2024
OFFICIAL RECORD COPY
COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
COMPREHENSIVE ENGINEERING TEAM INSPECTION
REQUEST FOR INFORMATION
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number: 05000461/2025010
Onsite Inspection Dates: January 27 - 31, 2025 and February 10 - 14, 2025
Inspection Procedure: IP 71111.21M, Comprehensive Engineering Team Inspection
Thomas Hartman, Senior Project Engineer, RIII/DORS
Lead Inspector: 630-829-9884
Thomas.Hartman@nrc.gov
Jorge Corujo-Sandin, Senior Reactor Inspector, RIII/DORS
Lionel Rodriguez, Senior Reactor Inspector, RIII/DORS
Teammates: Kevin Barclay, Senior Reactor Inspector, RIII/DORS
Eric Magnuson, Reactor Inspector, RIII/DORS
Eucherius Rosario, Reactor Inspector, RIII/DORS
Musab Abuhamdan, Reactor Inspector, RIII/DORS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by December 20, 2024, or
sooner:
1. Entrance meeting time and location.
2. Room number/name and location of the room to be used by the inspection team
while onsite.
3. Current management and engineering organizational chart.
4. Response team contact information (names and phone numbers) and team roles
(e.g., management sponsor, lead, inspector counterpart).
5. Any potential resource conflicts during the inspection (e.g., emergency drills and
all-staff meetings).
6. 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.
Any additional logistics related with inspector presence onsite will be coordinated closer to
the actual start of the inspection. Reach out to the Team Lead for questions or comments.
Enclosure
COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
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 to Support Risk Informed Selections
The following information is requested by September 2, 2024, or sooner, to facilitate
the initial risk scoping required to support the sample selections.
Note: If you are unable to provide items 1.1. through 1.6.2. as requested, please
reach out to the Team Lead 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. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook,
Internal Flood scenario notebook and latest internal event PSA summary
document.
1.6. For Fire PSA Model:
1.6.1 Provide the fire Probabilistic Risk Assessment (PRA) quantification
notebook.
1.6.2 Provide importance measures ranked preferably by Birnbaum but if not
available by Risk-Achievement Worth (RAW) for the top 500 basic
events for the fire PRA. (Provide in Excel format.).
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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
1.7. List of systems, system numbers/designators, and corresponding system
names.
1.8. 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).
1.9. Electronic copies of simplified plant drawings (if available). Note: these may be
uncontrolled documents such as big notes, training diagrams, etc.
1.10. Electronic copies of updated final safety analysis report (UFSAR), Technical
Specifications, Technical Specifications Bases, and Technical Requirements
Manual.
2. Information Requested for Preliminary Selection of Samples
The following information is requested by September 23, 2023, or sooner, to
facilitate the initial sample selection.
2.1. Provide copies of the emergency operating procedures and abnormal operating
procedures.
2.2. Provide the in-service testing (IST) program document.
2.3. Copies of procedures addressing the following: modifications, design changes,
set point changes, equivalency evaluations or suitability analyses, commercial
grade dedications, post-modification testing, 10 CFR 50.59 evaluations and
screenings, and UFSAR updates.
2.4. Structures, systems, and components (SSCs) in the Maintenance Rule
(a)(1) category for the last 4 years.
2.5. A list of operating experience evaluations for the last 4 years.
2.6. Information of any common cause failure of components experienced in the
last 4 years at your facility.
2.7. List of Root Cause Evaluations associated with component failures or design
issues initiated/completed in the last 4 years.
2.8. List of open operability evaluations.
2.9. 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.
2.10. 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:
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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
2.10.1 Plant changes, design changes, set point changes, completed in the last
4 years;
2.10.2 Equivalency evaluations, and suitability analyses completed in the
last 4 years;
2.10.3 Procedure changes for Emergency Operating Procedures (EOPs),
Abnormal Operating Procedures (AOPs), surveillances, and test
procedures in the last 4 years; and
2.10.4 Calculation changes that have been issued for use in the last 4 years.
2.11. 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.
2.12. 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:
2.12.1 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);
2.12.2 Modifications that are field work complete; and
2.12.3 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).
2.13. 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).
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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
2.14. A list of any modifications, procedure revisions, or the UFSAR changes where
it was determined that 10 CFR 50.59 did not apply.
2.15. 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).
2.16. UFSAR updates submitted in accordance with 10 CFR 50.71(e)(4). Provide
copies of the complete submittal.
2.17. 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.
3. Information Requested for the Preliminary Selected Samples to be Available by
January 10, 2025.
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.).
3.1. Corrective Action Program procedures, including the operability/functionality
determination procedure.
3.2. Quality Assurance Program document/procedure.
3.3. A copy of any internal/external self-assessments and associated corrective
action documents generated in preparation for the inspection.
3.4. A copy of engineering/operations related audits completed in the last 2 years.
For the selected Components:
3.5. System Health Reports, System Descriptions, Design Basis Documents, and/or
Training Lesson Plans associated with each of the selected components.
3.6. List of condition reports (corrective action documents) associated with each of
the selected components for the last 4 years. (Excel format preferred.)
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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
3.7. For each selected component list of the maintenance history (corrective,
preventive, and elective) over the last 10 years. Identify frequency of preventive
maintenance activities.
3.8. Aging Management Program documents applicable to each selected
component.
3.9. Provide an all-inclusive list of calculation revisions in effect associated with
each of the selected components. Include document number, title, and
revision number.
3.10. 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.]
3.11. Electronic copies of electrical drawings (ac and dc) and key diagrams.
3.12. Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available).
3.13. Copies of operability evaluations (open/closed for last 4 years) associated with
each of the selected components and plans for restoring operability, if
applicable.
3.14. Copies of operator work-around evaluations associated with each of the
selected components and plans for resolution, if applicable.
3.15. Copies of any open temporary modifications associated with each of the
selected components, if applicable.
3.16. 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.)
3.17. Provide copies of the normal and alarm response procedures associated with
the selected components and selected scenarios (if any).
3.18. 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.
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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
For the selected Modifications, 50.59 Evaluations and 50.59 Screenings:
3.19. For each of the selected modifications, provide the engineering change
package.
3.20. Provide a copy of each selected 50.59 Evaluation.
3.21. Provide copies of the selected 50.59 Screenings.
3.22. 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 onsite 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)
4. Additional Information to be Provided on January 27, 2025, When the Team is
Onsite
4.1. During the in-office preparation activities, the team will be making final
selections and may identify additional information needed to support the
inspection.
4.2. Schedule of any testing/maintenance activities to be conducted on the
selected components during the two onsite inspection weeks.
5. Information Requested to be Provided Throughout the Inspection
5.1. Any corrective action documents generated as a result of the teams questions
during this inspection as the documents are generated.
5.2. 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.
5.3. 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.
5.4. 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:
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COMPREHENSIVE ENGINEERING TEAM INSPECTION DOCUMENT REQUEST
5.4.1 Individual Plant Examination/Probabilistic Risk Assessment report;
5.4.2 Procurement documents for components and modifications selected
(verify retrievable);
5.4.3 Plant procedures (normal, abnormal, emergency, surveillance, etc.);
5.4.4 Vendor manuals;
5.4.5 Historical revisions of the Final Safety Analysis Report (FSAR),
including the Original FSAR and Original Safety Evaluation Report; and
5.4.6 Copy of electrical drawings, key diagrams, and isometrics
(paper copies).
If you have questions regarding the information requested, please contact the lead inspector.
8