ML24254A248
| ML24254A248 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/10/2024 |
| From: | Mel Gray Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2025010 | |
| Download: ML24254A248 (1) | |
See also: IR 05000352/2025010
Text
September 10, 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 - INFORMATION
REQUEST FOR QUADRENNIAL BASELINE COMPREHENSIVE
ENGINEERING TEAM INSPECTION; NOTIFICATION TO PERFORM
INSPECTION 05000352/2025010 AND 05000353/2025010
Dear David Rhoades:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
Region I staff will conduct a Comprehensive Engineering Team Inspection (CETI) at your
Limerick Generating Station, Units 1 and 2. Jeffrey Kulp, a Senior Reactor Inspector from the
NRCs Region I office, will lead the inspection team. The inspection will be conducted in
accordance with Inspection Procedure (IP) 71111.21M, Comprehensive Engineering Team
Inspection (CETI), dated January 1, 2023 (ADAMS Accession No. ML19084A030). This
inspection combines elements of the Design Basis Assurance Inspection (Teams), the Heat
Exchanger/Sink Performance inspection (IP 71111.07T), and the Evaluations of Changes, Tests
and Experiments inspection (IP 71111.17).
The inspection will evaluate the capability of risk-significant/low-margin components to function
as designed to support proper system operation. The inspection will also include a review of
selected modifications, operating experience, and as applicable, operator actions.
On August 28, 2024, the NRC team leader confirmed arrangements for an information-gathering
site visit and the two-week onsite inspection with Charles Wheeler, Limerick Regulatory
Assurance. The schedule is as follows:
Information-gathering visit: November 12-15, 2024
Onsite weeks: Weeks of January 13, 2025 and January 27, 2025
The purpose of the information-gathering visit is to meet with members of your staff to identify
risk-significant components, modifications, operator actions, and operating experience items.
Information and documentation needed to support the inspection will also be identified.
Carey Bickett, a Region I Senior Risk Analyst, will support Jeff during the information-gathering
visit to review probabilistic risk assessment data and identify components to be examined during
the inspection.
D. Rhoades
2
Experience with previous baseline design/modification inspections of similar depth and length
has shown this type of inspection is 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.
Ensuring these documents are up-to-date and complete will support the more efficient conduct
of the inspection. Insofar as possible, this information should be provided electronically to the
lead inspector. The information request has been divided into two groups:
The first group lists information necessary for our initial inspection scoping activities.
This information should be provided to the lead inspector by November 11, 2024. By
November 29, 2024, the lead inspector will communicate the selected set of
components, modifications, 50.59 screenings, and operating experience samples.
The second group of documents requested is those items needed to support our in-
office preparation activities. This set of documents, specific to the selected components
and modifications, should be provided to the lead inspector at the Regional Office no
later than January 6, 2025. During the in-office preparation activities, the team may
identify additional information needed to support the inspection, and those items will be
communicated directly to Charles Wheeler.
If there are any questions about the inspection or the material requested in the enclosure,
please contact the lead inspector at (610) 547-2603 or via email at jak2@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.
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 Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,
Exemptions, Requests for Withholding.
Sincerely,
Mel Gray, Chief
Engineering Branch 1
Division of Operating Reactor Safety
Docket Nos. 05000352 and 05000353
License Nos. NPF-39 and NPF-85
Enclosure:
Document Request for Comprehensive
Engineering Team Inspection
cc w/encl: Distribution via ListServ
Melvin K.
Gray
Digitally signed by Melvin
K. Gray
Date: 2024.09.10
09:44:11 -04'00'
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RI/DORS
RI/DORS
NAME
JKulp
MGray
DATE
9/09/2024
9/05/2024
DOCUMENT REQUEST FOR COMPEHENSIVE ENGINEERING TEAM INSPECTION
Enclosure
Onsite Inspection Dates:
January 13, 2025 through January 17, 2025; and
January 27, 2025 through January 31, 2025
Inspection Procedure:
Inspection Procedure 71111.21M, Comprehensive Engineering
Team Inspection (CETI)
Lead Inspector:
Jeffrey Kulp, Senior Reactor Inspector
(610) 547-2603
jak2@nrc.gov
Inspection Report: 05000352/2025010 and 05000353/2025010
I.
Information Requested for Sample Selection Process
The following information is requested by November 11, 2024, to facilitate inspection
preparation. Feel free to contact the lead inspector as soon as possible if you have any
questions regarding this information request. Please provide the information electronically in
pdf files, Word, Excel, or other searchable format. 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.
The site probabilistic risk analysis (PRA) System Notebook and latest PRA Summary
Document.
2.
Risk-ranking of top 250 basic events sorted by Risk Achievement Worth (>/= 1.3).
Include values for Risk Reduction Worth, Birnbaum Importance, and Fussell-Vesely (as
applicable). Please provide in an excel spreadsheet or other sortable format, and
include an understandable definition of the coded basic events.
3.
Risk-ranking of top 100 components from site specific PRA sorted by Large Early
Release Frequency. Provide any basic event mapping used to develop the ranking of
components.
4.
List of the top 200 cut-sets from your PRA. Provide the descriptions of the basic events
in the list of cut-sets.
5.
List of the top 200 cut-sets for each initiator modeled in the PRA that contributes more
than 5 percent to the baseline plant core damage frequency.
6.
If you have an External Events or Fire PRA Model, provide the information requested in
Items 1 and 2 for external events and fire. Provide narrative description of each coded
event, including fire and flood zone description.
7.
List of time-critical and/or risk-significant operator actions.
8.
List of emergency and abnormal operating procedures.
DOCUMENT REQUEST FOR COMPREHENSIVE ENGINEERING TEAM INSPECTION
2
9.
If available, any pre-existing evaluation or list of components and associated
calculations with low design margins (e.g., pumps closest to the design limit for flow or
pressure, diesel generator close to design required output, heat exchangers close to
rated design heat removal).
10. If applicable, copy of any self-assessments and/or Quality Assurance assessments of
low-margin structures, systems, and components (SSC), completed in the last 3 years.
11. List of available design margins in both the open and closed direction for valves in the
motor-operated valve and air-operated valve programs. Identify the safety-related
direction and the basis for how the margin was determined.
12. The age and capacity of the safety-related DC batteries.
13. The In-Service Testing Program (IST) Basis document identifying the in-scope valves
and pumps, and the associated IST Program requirements for each component (e.g.,
IST valve table identifying category, active/passive function).
14. SSCs in the Maintenance Rule (a)(1) category in the last 3 years.
15. List of Root Cause Evaluations associated with SSCs failures or design issues
initiated/completed in the last 4 years.
16. List of formal operability evaluations in the last 4 years.
17. List of current operator work arounds/burdens.
18. List of permanent plant modifications to SSCs that are field work complete in the last 3
years. For the purpose of this inspection, permanent plant modifications include
permanent: plant changes, design changes, set point changes, equivalency
evaluations, suitability analyses, and commercial grade dedications. The list should
contain the number of each document, title (sufficient to understand the purpose of the
modification), revision/date, and the affected system.
19. List of calculation changes that have been issued for use in the last 3 years.
20. Programmatic Procedures.
Corrective Action Program Procedure.
Permanent Plant Modifications and Design Changes
In-service Testing
Setpoint Changes
Post-Maintenance Testing
50.69 Screening/Program
Maintenance Rule
21. List of corrective action documents (open and closed) in the last 3 years associated with
permanent plant modifications issues, concerns, or processes.
DOCUMENT REQUEST FOR COMPREHENSIVE ENGINEERING TEAM INSPECTION
3
22. Any internal/external self-assessments and associated corrective action documents
generated in preparation for this inspection.
23. Corrective Action Program documents (e.g., condition reports) associated with
inspection findings from the last performance of NRC Inspection Procedure 71111.21M
(CETI/DBAI).
24. Updated Final Safety Analysis Report, Technical Specifications, Technical
Specifications Bases, and Technical Requirements Manual.
25. One line safety-related electrical drawings (AC and DC), and Piping and
Instrumentation Drawings of emergency core cooling systems, ultimate heat sink, and
auxiliary feedwater system.
26. List of 50.59 Evaluations and Screenings performed since January 2022.
27. Equipment Listings (Preferably in Excel Spreadsheet format, if available)
If implemented, listing of 50.69 RISC 1, 2 and 3 components.
Listing of equipment classified under the Conduct of Equipment Reliability Manual
showing the Tier level.
Listing of equipment classified under the Maintenance Rule showing HSS/LSS
classifications.
II. Information Requested to Be Available by January 6, 2025, following sample
selection.
This information should be separated for each selected component and modification,
especially if provided electronically (e.g., a folder for each component and modification
named after the component or modification that includes the information requested below).
Items 1 through 11 are associated with the selected components and Item 12 is for the
selected modifications.
1.
List of corrective action documents associated with each selected component for the
last 4 years.
2.
Maintenance history (e.g., corrective, preventive, and elective) associated with each
selected component for the last 6 years. Identify frequency of preventive maintenance
activities.
3.
Aging Management Program documents applicable to each selected component.
4.
List of calculations associated with each selected component, excluding data files. Pipe
stress calculations are excluded from this request.
5.
System Health Report (last completed) and Design Basis Document associated with
each selected component.
6.
Access to or copy of vendor manual(s) for each selected component.
DOCUMENT REQUEST FOR COMPREHENSIVE ENGINEERING TEAM INSPECTION
4
7.
List of open temporary modifications associated with each selected component, if
applicable.
8.
Trend data/graphs on the selected components performance for the last 3 years (e.g.,
pump performance including IST, other vibration monitoring, oil sample results).
9.
List of normal operating and alarm response procedures associated with each selected
component.
10. Last 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 three years, provide the latest test performed.
11. Schedule of surveillance testing of selected components that occur during the onsite
inspection weeks.
12. For each selected modification, copies of associated documents such as modification
package, engineering changes, 50.59 screening or evaluation, relevant calculations,
post-modification test packages, associated corrective action documents, design
drawings, and new/revised preventive maintenance requirements.
13. A copy of the evaluation or screening document for each of the selected 50.59
evaluation/screens. A copy of the modification package if the evaluation/screen pertains
to a modification.