ML19003A191

Request for Information for an NRC Triennial Baeline Design Bases Assurance Inspection; Inspection Report 05000461/2019011

ML19003A191
Person / Time
Site:	Clinton
Issue date:	01/03/2019
From:	Jamie Benjamin NRC/RGN-III/DRS/EB2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019011
Download: ML19003A191 (9)

See also: IR 05000461/2019011

Text

January 3, 2019

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATIONREQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000461/2019011

Dear Mr. Hanson:

On March 11, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial

Baseline Design Bases Assurance Inspection (Team) at Clinton Power Station. This inspection

will be performed in accordance with NRC Baseline Inspection Procedure 71111.21M.

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 will also be selected for review. 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 six NRC

inspectors who will focus on engineering/maintenance/operations of the selected components

and modifications. The current inspection schedule is as follows:

• Preparation week: March 4, 2019, through March 8, 2019;

• Onsite weeks: March 11, 2019, through March 15, 2019; and

March 25, 2019, through March 29, 2019.

B. Hanson -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 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 January 28, 2019.

By February 18, 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 initially 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 February 25, 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

March 11, 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 Jamie Benjamin. We understand that our licensing

contact for this inspection is Nicholas Santos of your organization. If there are any questions

about the inspection or the material requested in the enclosure, please contact the lead

inspector at 630-829-9747 via e-mail at Jamie.Benjamin@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/

Jamie Benjamin, Senior Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

B. Hanson -4-

Letter to Bryan C. Hanson from Jamie Benjamin dated January 3, 2019.

SUBJECT: CLINTON POWER STATIONREQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000461/2019011

DISTRIBUTION:

Stacey Rosenberg

RidsNrrDorlLpl3

RidsNrrPMClinton Resource

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Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRSIII

DRPIII

ADAMS Accession Number: ML19003A191

OFFICE RIII

NAME JBenjamin:jw

DATE 01/03/19

OFFICIAL RECORD COPY

DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

Inspection Report: 05000461/2019011

Inspection Dates: March 11, 2019, through March 15, 2019; and

March 25, 2019, through March 29, 2019.

Inspection Procedure: 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector: Jamie Benjamin

630-829-9747

Jamie.Benjamin@nrc.gov

I. Information Requested for Selection of Components/Modifications

The following information is requested by January 28, 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 on a CD-ROM. 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. Core Damage Frequency Risk-ranking of top 500 components from your site specific

probabilistic safety analysis (PSA) sorted by Risk-Achievement Worth (RAW).

Include values for Birnbaum Importance, Risk-Reduction Worth, and Fussell-Veseley

(as applicable).

2. Large Early Release Frequency Risk-ranking of top 500 from your site specific PSA

sorted by RAW. Include values for Birnbaum Importance, Risk-Reduction Worth,

and Fussell-Veseley (as applicable).

3. Provide a list of the top 500 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 a risk ranking of operator actions from your PSA, sorted by RAW.

Include values for Birnbaum importance, Risk-Reduction Worth, and

Fussell-Veseley.

7. Provide a copy of the internal flooding PSA notebook.

8. Provide copies of the emergency operating procedures.

9. Provide a list of all abnormal/off-normal procedures.

Enclosure

DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

10. 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).

11. 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.).

12. Electronic copy of the site Individual Plant Examination of External Events,

if available.

13. List of available design (setup) margins in both the open and closed direction

(identify safety-related direction) for valves in the Motor-Operated Valve and

Air-Operated Valve Programs. Identify the basis for how the margin was determined.

14. 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).

15. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)

category within the last 3 years.

16. Site top 10 issues list (if applicable).

17. A list of operating experience evaluations for the last 3 years.

18. Information of any common cause failure of components experienced in the last

5 years at your facility.

19. List of Root Cause and Common Cause Evaluations associated with component

failures or design issues initiated/completed in the last 5 years.

20. List of open operability evaluations.

21. List of SSCs considered operable but degraded/nonconforming.

22. 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.

23. A list of calculation changes that have been issued for use in the last 3 years.

24. Copies of procedures addressing the following: modifications, design changes,

set point changes, equivalency evaluations or suitability analyses, commercial

grade dedications, and post-modification testing.

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

address permanent plant modifications issues, concerns, or processes. These

documents should also include the corrective action documents associated with

the modification implementation.

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

26. Current management, engineering, operation, and maintenance organizational chart.

27. Electronic copies of Updated Final Safety Analysis Report, Technical Specifications,

Technical Specifications Bases, Technical Requirements Manual, and Operational

Requirements Manual.

28. Major one line electrical drawings (ac and dc) and key diagrams (electronic and

paper copies).

29. Electronic copy of big notes/horse notes.

30. Electronic copy of Piping and Instrumentation Drawings (if available).

II. Information Requested (for the approximate 7 selected components, 7 selected

modifications, and operational experience) to be Available by February 25, 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 1-12 are

associated with the selected components and Item 13 for the selected modifications.

1. List of condition reports (both corrective action program and non-corrective action

program) associated with each of the selected components for the last 6 years.

2. The maintenance history (corrective, preventive, predictive, and elective) associated

with each of the selected components for the last 10 years. Identify frequency of any

periodic 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).

4. System Health Reports, System Descriptions, Design Basis Documents, System

Notebooks, and/or Training Lesson Plans associated with each of the selected

components.

5. A list of modifications, including equivalency evaluations and set point 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 related 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.

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

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.

11. List of completed timed time critical or risk-significant operator actions associated

the with components for the last 5 years. 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 within the last 3 years including any assessment in response

to preparation for the inspection.

15. A copy of engineering/operations related audits completed in the last 3 years.

III. Additional Information to be Provided on March 11, 2019, Onsite (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 team will

provide a list of the additional information needed during the week of March 4, 2019.

2. Schedule of any testing/maintenance activities to be conducted on the selected

components during the two 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 teams

questions or queries during this inspection.

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DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST

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,

large enough to be easily readable).

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;

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.

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