ML19120A230

Ltr. 04/29/19 LaSalle County Station, Units 1 and 2 - Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000373/2019012; 05000374/2019012 (DRS-M.Jones)

ML19120A230
Person / Time
Site:	LaSalle
Issue date:	04/29/2019
From:	Michael Jones Division of Reactor Safety III
To:	Bryan Hanson Exelon Generation Co
References
IR 2019012
Download: ML19120A230 (9)

See also: IR 05000373/2019012

Text

April 29, 2019

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2

-REQUEST FOR INFORMATION

FOR AN NRC TRIENNIAL BASELINE DESIGN BA

SES ASSURANCE INSPECTION (TEAM);

INSPECTION

REPORT 05000373/2019012; 05000374/2019012

Dear Mr. Hanson: On July 22, 2019 , the U. S. Nuclear Regulatory Commission (NRC) will begin a Triennial Baseline Design Bases Assurance Inspection (T

eam) at LaSalle County Station, Units 1

and 2. This inspection will be performed in accordance with NRC Baseline Inspection Procedure 71111.21 M. The Design Bases Assurance Inspection 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 modifications 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 and modifications to be reviewed during this baseline inspection will be identified as part of the

preparation for the inspection and finalized during the in-office preparation week that occurs prior to the first onsite inspection

week. In addition, operating experience issues, associated with the component samples, will also be selected for review. The inspection team may request scenarios to be performed on the simulator. This request would require support from you

r 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 six NRC inspectors wh

o will focus on engineering/maintenance

/operations

of the selected components and modifications. The current inspection schedule is as follows:

Preparation week: July 15

-19, 2019; Onsite weeks:

July 22-26, 2019, and August 5-9, 2019.

B. Hanson -2- Experience with previous baseline design/modification

inspections of similar depth and length has shown that th

is 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 three 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

June 10 2019. By June 24, 2019, the lead inspector will communicate the initial selected set of approximately seven components

and seven modifications. The second group of documents requested is

those items needed to support our

in-office preparation activities. This set of documents, including the calculations associated with the initia

l l y selected components

and the modification packages associated with the initially selected modifications, should be provided to the lead inspector at the Regional Office no later than

July 8, 2019

. During the in

-office preparation activities, the team may identify additional information needed to support the inspection.

The last group includes the additional information above as well as plant specific reference material. This information should be available to the team onsite on July 22, 2019. It is also requested that corrective action documents and/or questions developed during the inspection be provided to the lead

inspector as the documents

are generated.

The lead inspector for this inspection is

Mr. Michael A. Jones Jr.

We understand that our licensing contact for this inspection is

James Patterson

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

-829-9745 or via e-mail at Michael.Jones@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.

B. Hanson -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 Title 10 of the Code of Federal Regulations , Part 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely, /RA/ Michael A. Jones Jr., Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50

-373; 50-374 License Nos. NPF

-11; NPF-18 Enclosure:

Document Request for Design Bases

Assurance Inspection

cc: Distribution via LISTSERV

B. Hanson -4- Letter to Bryan C. Hanson from Michael A. Jones Jr. dated April

29, 2019. SUBJECT: LASALLE COUNTY STATION, UNITS 1 AND 2

-REQUEST FOR INFORMATION

FOR AN NRC TRIENNIAL BASELINE DESIGN BA

SES ASSURANCE INSPECTION (TEAM);

INSPECTION

REPORT 05000373/2019012; 05000374/2019012

DISTRIBUTION

Michael McCoppin

RidsNrrDorlLpl3

RidsNrrPMLaSalle

RidsNrrDirsIrib Resource

Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRPIII DRSIII ADAMS Accession Number: ML19120A230

OFFICE RIII NAME MJones:cl DATE 04/29/19 OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

Enclosure Inspection Report : 05000373/2019012; 05000374/2019012

Inspection Dates

July 22-26, 2019, and August 5-9, 2019 Inspection Procedure

71111.21 M , "Design Bases Assurance Inspection (Team)

" Lead Inspector

Michael A. Jones Jr.

63 0-829-9745 Michael.Jones@nrc.gov

I. Information Requested for Selection of Components/Modifications

The following information is requested by

June 10, 2019

, or sooner, to facilitate inspection preparation. If you have any questions regarding this information, please call the lead inspector

as soon as possible. (Please provide the information electronically in "pdf" files, Excel, or other searchable formats, preferably on some portable electronic media (e.g., CD-ROM, DVD, etc.). The portable electronic media

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. Risk-ranking of top

2 50 components from your site specific probabilistic safety

analysis (PSA) sorted by Risk

-Achievement Worth. Include values for Birnbaum Importance, Risk

-Reduction Worth, and Fussell

-Veseley (as applicable).

2. Risk-ranking of top 100 containment

-related components (i.e., Large Early

Release Frequency) from your site specific PSA sorted by

Risk-Achievement

Worth. See examples in Inspection Manual Chapter 0609, Appendix H, Table 4.1, "Containment

-Related SSCs

[Structures, Systems, and Components]

Considered for

LERF [Large Early Release Frequency]

Implications.

" 3. Provide a list of the top 200 cut

-sets from your PSA.

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.

5. Copies of PSA "system notebooks" and latest PSA summary document.

6. Provide copies of the emergency operating procedures.

7. If you have an External Events or Fire PSA Model, provide the information requested in Items 1 and 2 for external events and fire. Provide narrative description of each coded event (including fire, flood zone description)

.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

2 8. Any pre-existing evaluation or list of components and associated calculations with low design margins, (i.e., 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 etc.).Electronic copy of the site Individual Plant Examination of External Events, if available.

9. List of available design (setup) margins in both the

open and closed direction (identify safety

-related direction) for valves

in t he Motor-Operated Valve

and Air-Operated Valve Programs

. Identify the basis for how the margin was determined. 10. 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 P S A). 11. SSCs in the Maintenance Rule (a)(1) category

for the last

3 years. 12. Site top ten issues list (if applicable)

. 13. A list of operating experience evaluations for the last

3 years. 14. Information of any common cause failure of components experienced in the last

5 years at your facility

. 15. List of Root Cause Evaluations associated with component failures or design issues initiated/completed in the last

5 years. 16. List of open operability evaluations.

17. List of SSCs considered operable but degraded/non

-conforming.

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, revision

/date, and the affected system.

19. A list of calculation changes that have been issued for use

in the last 3 years

. 20. Copies of procedures addressing the following: modifications, design changes, set point changes, equivalency evaluations or suitability analyses, commercial grade dedications, and post-modification testing

. 21. A list of corrective action documents (open and closed) in the last 3 years

that address permanent plant modification

s issues, concerns, or processes.

These documents should also include the corrective action documents associated with the modification implementation.

22. Current management and engineering organizational chart

. 23. Electronic copies of Updated Final Safety Analysis Repo

rt, Technical Specifications, Technical Specifications Bases, and Technical Requirements Manual.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

3 24. Major one line electrical drawings (ac and dc) and key diagrams (paper copies).

25. Electronic copy of Piping and Instrumentation Drawings

(if available).

II. Information Requested (for the approximate 7 selected components

and 7 selected modifications) to be Available by

July 8, 2019, (will be reviewed by the team in the Regional office during the week of

July 15, 2019). This information

should be separated for each selected component

or modification , especially if provided electronically (e.g., folder with component or modification name that includes calculations, condition reports, maintenance history, etc

.). Items 1-1 2 are associated with the selected components and item 1

3 for the selected modifications.

1. List of condition reports (corrective action documents) associated with each of the selected components for the last

6 years. 2. The maintenance history (corrective, preventive, and elective) associated with each of the selected components for the last 10 years. Identify frequency of preventive maintenance activities.

3. Copies of calculations associated with each of the selected components (if not previously provided), excluding data files. Please review the calculations and also provide copies of important referenced material (such as drawings, engineering requests, and vendor letters). [Pipe stress calculations excluded from this request]

4. System Health Reports, System Descriptions, Design Basis Documents, and/or Training Lesson Plans associated with each of the selected components.

5. A list of modifications, including equivalency evaluations and setpoint changes, associated with each of the selected components. This list should include a descriptive paragraph on the purpose of the modification. Please ensure this list only includes design completed (not canceled) modifications.

6. Copies of operability evaluations (open/closed for last 3 years) associated with each of the selected components and plans for restoring operability, if applicable.

7. Copies of selected operator work

-around evaluations associated with each of the selected components and plans for resolution, if applicable.

8. Copies of any open temporary modifications associated with each of the selected components, if applicable.

9. Trend data on the selected electrical/mechanical components' performance for last

3 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.). 10. Provide copies of the normal and abnormal operating procedures associated with the selected components and selected scenarios.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

4 11. List of time critica

l or risk significant operator actions associated with components. Identify those actions that do not have job performance measures.

12. Copy of latest completed tests and surveillances for each component, for example:

a. Pumps: comprehensive test, quarterly test, flow balance, etc.

b. Valves: stroke time testing, diagnostic testing, leak testing, interlocks, etc. c. Heat exchangers/room coolers

thermal performance, clean/inspect, fan flows, etc. d. Components:

Technical Specification surveillances.

e. Acceptance criteria basis calculations should also be included.

13. For each of the selected modifications, copies of associated

documents such

as modification package, engineering changes, 50.59 screening or evaluation, calculations, post

-modification test packages, corrective action documents, design drawings, preventive maintenance requirements and procedures, etc. 14. A copy of any internal/external self

-assessments and associated corrective action documents generated in preparation for the inspection.

15. A copy of engineering/operations related audits completed in the last 2 years.

III. Additional Information to be

Provided on July 22, 2019

, On site (for final selected components

and modifications

) 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 July 15, 2019. 2. Schedule of any

testing/maintenance activities to be conducted on the selected components during the t

wo onsite inspection weeks.

IV. Information Requested to be Provided Throughout the Inspection

1. Copies of any corrective action documents generated as a result of the

team's questions or queries during this inspection

. 2. Copies of the list of questions submitted by the team members and the status/resolution of the information requested (provide daily by 2:00 p.m. during the inspection to each team member)

. 3. One complete set of Piping and Instrumentation Drawings

(paper copies)

.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

5 4. Reference materials. (make available if needed during all onsite weeks):

a. Individual Plant Examination/Probabilistic Risk Assessment report; b. Procurement documents for components

and modifications selected (verify retrievable);

c. Plant procedures (normal, abnormal, emergency, surveillance, etc.); and

d. Vendor manuals.

If you have questions regarding the information requested, please contact the lead inspector.