ML24281A150
| ML24281A150 | |
| Person / Time | |
|---|---|
| Site: | Byron  (NPF–037, NPF–066) |
| Issue date: | 10/07/2024 |
| From: | James Park NRC/RGN-III/DORS/RPB3 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| Download: ML24281A150 (1) | |
See also: IR 05000454/2025010
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:
BYRON STATION - REQUEST FOR INFORMATION FOR NRC
COMMERCIAL-GRADE DEDICATION INSPECTION: INSPECTION REPORT
05000454/2025010; 05000455/2025010
Dear David Rhoades:
On January 27, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a
commercial-grade dedication (CGD) inspection at Byron Station. This inspection will be
performed in accordance with NRC Inspection Procedure 71111.21N.03, Commercial Grade
The inspection will evaluate the implementation of Byrons 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 Byrons 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 2weeks onsite and will consist of three NRC inspectors (including the
lead inspector) along with one observer. The current inspection schedule is as follows:
Information Gathering Visit:
January 8-10, 2025
Preparation week:
January 21-24, 2025
Onsite weeks:
January 27-31, 2025, and February 10-14, 2025
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 Byron. This visit would also allow the lead
inspector to meet with Procurement Engineering and other site individuals responsible for the
inspection to ensure a 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.
October 7, 2024
D. Rhoades
2
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 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 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
November 13, 2024. The lead inspector will communicate the initial selected set of
samples no later than November 27, 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 December 20, 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 January 27, 2025.
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 Joon S. Park. We understand that our licensing contact
for this inspection is Gerald 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
630-829-9715 or via email at Joon.Park@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.
D. Rhoades
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,
Joon S. Park, Reactor Inspector
Engineering Reactor and Projects Branch
Division of Operating Reactor Safety
Docket Nos. 50-454; 50-455
Enclosure:
Commercial-Grade Dedication Inspection
Request for Information
cc: Distribution via LISTSERV
Signed by Park, Joon
on 10/07/24
D. Rhoades
4
Letter to David P. Rhoades from Joon S. Park dated October 07, 2024.
SUBJECT:
BYRON STATION - REQUEST FOR INFORMATION FOR NRC
COMMERCIAL-GRADE DEDICATION INSPECTION: INSPECTION REPORT
05000454/2025010; 05000455/2025010
DISTRIBUTION:
RidsNrrDorlLpl3
RidsNrrPMByron Resource
RidsNrrDroIrib Resource
R3-DORS
ADAMS Accession Number: ML24281A150
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
Jpark:anm
DATE
10/07/2024
OFFICIAL RECORD COPY
Enclosure
COMMERCIAL-GRADE DEDICATION INSPECTION REQUEST FOR INFORMATION
I.
ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Numbers:
05000454/2025010; 05000455/2025010
Onsite Inspection Dates:
January 27-31, 2025, and February 10-14, 2025
Inspection Procedure:
IP 71111.21N.03, Commercial Grade Dedication
Lead Inspector:
Joon S. Park, Reactor Inspector, RIII/DORS/ERPB
630-829-9715
Joon.Park@nrc.gov
Teammates:
Benny Jose, Senior Reactor Inspector, RIII/DORS/EB2
Muzammil Siddiqui, Reactor Inspector, RIII/DORS/EB1
II.
LOGISTICS
Email the following inspection logistics to the lead inspector by January 17, 2025, 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.
11. Any potential resource conflicts during the inspection (e.g., emergency drills
and all-staff meetings).
12. Current management and engineering organizational chart.
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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 November 13, 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-Vesely. 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 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
six 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 six years of
dedication activities;
3
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 six 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 six 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 six 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
commercial-grade dedication, safety-related component procurement, and/or
receipt inspection/testing activities within the past six years.
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2.
Information Requested to Support Inspection Preparation Activities
The following information is requested by December 20, 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:
2.16.1 safety classification;
2.16.2 identification of safety functions/application requirements;
5
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
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;
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 January 27, 2025, 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 January 20, 2025.
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.).
6
3.3. Schedule of separate interviews with knowledgeable plant personnel
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.