ML19037A484

Ltr. 02/04/19 Fermi Power Plant, Unit 2 - Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000341/2019012 (DRS-N.Feliz-Adorno)

ML19037A484
Person / Time
Site:	Fermi
Issue date:	02/04/2019
From:	Nestor Feliz-Adorno NRC/RGN-III
To:	Polson K DTE Electric Company
References
IR 2019012
Download: ML19037A484 (9)

See also: IR 05000341/2019012

Text

February 4, 2019

Mr. Keith Polson, Senior VP

and Chief Nuclear Officer

DTE Energy Company

Fermi 2 - 260 TAC

6400 North Dixie Highway

Newport, MI 48166

SUBJECT: FERMI POWER PLANT, UNIT 2REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000341/2019012

Dear Mr. Polson:

On May 6, 2019, the U. S. Nuclear Regulatory Commission (NRC) will begin a triennial baseline

Design Bases Assurance Inspection (Team) at Fermi Power Plant, Unit 2. 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 inoffice

preparation week that occurs prior to the first onsite inspection week. In addition, operating

experience issues will 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: April 29, 2019, though May 3, 2019

Onsite weeks: May 6, 2019, through May 10, 2019; and

May 20, 2019, through May 24, 2019.

K. Polson

-2-

Experience with previous baseline design/modification inspections of similar depth and length

has shown 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 March 11, 2019.

By March 22, 2019, the lead inspector will communicate the initial selected set of

components and 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 April 19, 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

May 6, 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 Néstor J. Féliz-Adorno. We understand that our

licensing contact for this inspection is Elaine M. Harrison of your organization. If there are any

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

inspector at 630-829-9739 or via e-mail at Nestor.Feliz-Adorno@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.

K. Polson

-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/

Néstor J. Féliz-Adorno, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-341

License Nos. NPF-43

Enclosure:

Document Request for Design Bases

Assurance Inspection

cc: Distribution via LISTSERV

K. Polson

-4-

Letter to Keith Polson from Néstor J. Féliz-Adorno dated February 4, 2019.

SUBJECT: FERMI POWER PLANT, UNIT 2REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM);

INSPECTION REPORT 05000341/2019012

DISTRIBUTION:

Aida Rivera-Varona

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RidsNrrPMFermi2 Resource

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Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML19037A484

OFFICE

RIII

NAME

NFéliz-Adorno:cl

DATE

02/04/19

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

2

Inspection Report: 05000341/2019012

Inspection Dates:

May 6, 2019, through May 10, 2019; and

May 20, 2019, through May 24, 2019.

Inspection Procedure:

Inspection Procedure 71111.21M, Design Bases Assurance

Inspection (Team)

Lead Inspector:

Néstor J. Féliz-Adorno, Senior Reactor Inspector

630-829-9739

Nestor.Feliz-Adorno@nrc.gov

I.

Information Requested for Selection of Components and Modifications

The following information is requested by March 11, 2019, or sooner, to facilitate

inspection preparation. 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 on some portable electronic

media (e.g., CD-ROM, DVD). 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.

Risk-ranking of top 250 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). Provide

any basic event mapping used to develop the ranking of components.

2.

Risk-ranking of top 250 components from your site specific PSA sorted by Large

Early Release Frequency. Provide any basic event mapping used to develop the

ranking of components.

3.

List of the top 200 cut-sets from your PSA. Provide the descriptions of the basic

events in the list of cut-sets.

4.

List of the top 200 cut-sets for each initiator modeled in the PSA that contributes

more than 5 percent to the baseline plant core damage frequency.

5.

PSA system notebooks and latest PSA summary document.

6.

Emergency and abnormal 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 and flood zone description.

8.

Individual Plant Examination of External Events, if available.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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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.

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.

11.

Provide the In-Service Testing Program (IST) 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).

12.

List of high-risk Maintenance Rule systems/components based on engineering or

expert panel judgment (i.e., those systems/components not identified as having

high risk in the PSA).

13.

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

category for the last 3 years.

14.

Site top 10 issues list, if available.

15.

Information of any common cause failure of SSCs experienced in the last 5 years

at your facility.

16.

List of Root Cause Evaluations associated with SSCs failures or design issues

initiated/completed in the last 5 years.

17.

List of open operability evaluations.

18.

List of SSCs considered operable but degraded/nonconforming.

19.

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.

20.

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

21.

List of all time critical and/or risk significant operator actions.

22.

Procedures addressing the following: modifications, design changes, set point

changes, equivalency evaluations or suitability analyses, commercial grade

dedications, and post-modification testing.

23.

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

address permanent plant modifications issues, concerns, or processes.

24.

Current management and engineering organizational chart.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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25.

Updated Final Safety Analysis Report, Technical Specifications, Technical

Specifications Bases, and Technical Requirements Manual. If any of these

documents is not available electronically, contact the lead inspector.

26.

Major one line electrical drawings (ac and dc) and key diagrams. If these

documents are not available electronically, contact the lead inspector.

27.

Piping and Instrumentation Drawings, if available electronically. If these

documents are not available electronically, contact the lead inspector.

28.

Simplified drawings (e.g., training schematics), if available electronically. If

these documents are not available electronically, contact the lead inspector.

II.

Information Requested to Be Available by April 19, 2019

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 1-12 are associated with the selected components and item 13 for the

selected modifications.

1.

List of corrective action documents associated with each selected component for

the last 6 years.

2.

Maintenance history (e.g., corrective, preventive, and elective) associated with

each selected component for the last 10 years. Identify frequency of preventive

maintenance activities.

3.

Aging Management Program documents applicable to each selected component.

4.

Calculations associated with each selected component, excluding data files.

Pipe stress calculations are excluded from this request.

5.

System Health Reports (last 2 performed), System Descriptions, Design Basis

Documents, and/or Training Lesson Plans associated with each selected

component.

6.

A list of modifications, including equivalency evaluations and setpoint changes,

associated with each selected component. This list should include a description

of the purpose of the modification. Ensure this list only includes completed

modifications.

7.

Operability evaluations (open and closed) for last 3 years associated with each

selected component and associated corrective action documents.

8.

Operator work-around evaluations associated with each selected component and

plans for resolution, if applicable.

9.

Any open temporary modifications associated with each selected component, if

applicable.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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10.

Trend data on the selected components performance for the last 3 years

(e.g., pumps performance including IST, other vibration monitoring, oil sample

results).

11.

Normal operating and alarm response procedures associated with each selected

component.

12.

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.

13.

For each selected modification, 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, and preventive maintenance requirements and procedures.

14.

Procedures addressing time critical and/or risk significant operator actions.

Identify those actions that do not have job performance measures.

15.

Corrective Action Program procedures, including the operability/functionality

determination procedure.

16.

Quality Assurance Program document/procedure.

17.

Any internal/external self-assessments and associated corrective action

documents generated in preparation for the inspection.

18.

Engineering/operations related audits (last 2 performed).

III.

Additional Information to Be Provided Onsite on May 6, 2019

1.

During the in-office preparation activities, the team will be making final sample

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 April 29, 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.

Any corrective action documents generated as a result of the teams questions

during this inspection as the documents are generated.

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 2:30 p.m. during

the inspection 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.

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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3.

If available in hardcopy form, one complete set of Piping and Instrumentation

Drawings and simplified drawings (e.g., training schematics). If any of these

documents is not available in hardcopy form, contact the lead inspector.

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.);

d.

Historical revisions of the Final Safety Analysis Report; and

e.

Vendor manuals.

Contact the lead inspector if you have questions regarding the information requested.