ML20183A285

Request for Information for an NRC Triennial Baseline Bases Assurance Inspection (Team): Inspection Report 05000254/2020011 and 05000265/2020011

ML20183A285
Person / Time
Site:	Quad Cities
Issue date:	07/01/2020
From:	James Neurauter NRC/RGN-III/DRS/EB1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2020011
Download: ML20183A285 (10)

See also: IR 05000254/2020011

Text

July 01, 2020

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: QUAD CITIES NUCLEAR POWER STATION REQUEST FOR INFORMATION

FOR AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE

INSPECTION (TEAM): INSPECTION REPORT 05000254/2020011 AND

05000265/2020011

Dear Mr. Hanson:

On August 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial

baseline Design Bases Assurance Inspection (Team) at Quad Cities Nuclear 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 inoffice

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 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: August 24 - 28, 2020

• Onsite weeks: August 31 - September 4, 2020, and September 14 - 18, 2020

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.

B. Hanson -2-

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 July 17, 2020.

The lead inspector will communicate the initial selected set of samples no later than

July 31, 2020.

• The second group of documents requested is those items needed to support our in-

office preparation activities. This set of documents should be provided to the lead

inspector at the Regional Office no later than August 14, 2020. 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 as well as plant specific

reference material. This information should be available to the team onsite on

August 31, 2020.

• The last group includes supporting information to be provided throughout the inspection.

Specifically, corrective action documents and 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 James Neurauter. We understand that our licensing

contact for this inspection is Richard Swart of your organization. If there are any questions

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

inspector at 630-829-9828 or via e-mail at james.neurauter@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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

James E. Neurauter, Senior Reactor Inspector

Engineering Branch 1

Division of Reactor Safety

Docket Nos. 50-254; 50-265

License Nos. DPR-29; DPR-30

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

B. Hanson -4-

Letter to Bryan C. Hanson from James E. Neurauter, dated July 01, 2020.

SUBJECT: QUAD CITIES NUCLEAR POWER STATION REQUEST FOR INFORMATION

FOR AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE

INSPECTION (TEAM): INSPECTION REPORT 05000254/2020011;

05000265/2020011

DISTRIBUTION:

Jessie Quichocho

Elise Burket

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RidsNrrPMQuadCities Resource

RidsNrrDroIrib Resource

John Giessner

Kenneth OBrien

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML20183A285

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME JNeurauter:mb via

e-mail

DATE 07/01/2020

OFFICIAL RECORD COPY

DESIGN BASES ASSURANCE INSPECTION (TEAMS)

REQUEST FOR INFORMATION

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000254/2020011; 05000265/2020011

Onsite Inspection Dates: August 31-September 4, 2020; and September 14-18, 2020

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

James Neurauter, Senior Reactor Inspector, DRS

Lead Inspector: 630-829-9828

james.neurauter@nrc.gov

Jamie Benjamin, Senior Reactor Inspector, RIII/DRS

Benny Jose, Senior Reactor Inspector, RIII/DRS

Teammates: Matthew Domke, Reactor Inspector, RIII/DRS

Vance Petrella, Reactor Inspector, RIII/DRS

William Hopf, NRC Electrical Contractor

II. LOGISTICS

Email the following inspection logistics to the lead inspector by August 14, 2020, 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 (preferably after 1:30 p.m. Central 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. Current management and engineering organizational chart;

11. Engineering staff normal working hours; and

12. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff

meetings).

Enclosure

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 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. Information Requested for Selection of Components/Modifications

The following information is requested by July 17, 2020, or sooner, to facilitate the initial

sample selection.

1.1. Risk-ranking of top 250 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). Provide any

basic event mapping used to develop the ranking of components.

1.2. Risk-ranking of top 100 containment-related components (i.e. Large Early Release

Frequency (LERF)) from your site-specific PSA sorted by RAW. See examples in

Inspection Manual Chapter 0609, Appendix H, Table 4.1, Containment-Related SSCs

Considered for LERF Implications. Provide any basic event mapping used to develop

the ranking of components.

1.3. Provide a list of the top 200 cut-sets from your PSA. Provide the descriptions of the

basic events in the list of cut-sets.

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.

1.5. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook, and

latest PSA summary document.

1.6. 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).

1.7. Provide copies of the emergency operating procedures and abnormal operating

procedures.

1.8. Electronic copy of the site Individual Plant Examination of External Events, if available.

1.9. 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).

1.10. 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

PSA).

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

for the last 3 years.

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

1.13. Information of any common cause failure of components experienced in the last 5

years at your facility.

1.14. List of Root Cause Evaluations associated with component failures or design issues

initiated/completed in the last 5 years.

1.15. List of open operability evaluations.

1.16. List of permanent plant modifications to SSCs that are field work complete. For the

purpose of this inspection, permanent plant modifications include permanent:

1.16.1 Plant changes, design changes, set point changes, completed in the last 5

years;

1.16.2 Equivalency evaluations, suitability analyses, and commercial grade

dedications completed in the last 3 years;

1.16.3 Procedure changes for EOPs, AOPs, surveillances, and test procedures in the

last 3 years; and

1.16.4 Calculation changes that have been issued for use in the last 3 years.

Note: Items 1.16.1. through 1.16.4. should be provided as separate, individual lists and

each list should contain the number of each document, title, revision/date, and the

affected system.

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

that do not have job performance measures.

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

point changes, equivalency evaluations or suitability analyses, commercial grade

dedications, and post-modification testing.

1.19. 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.

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

Technical Specifications Bases, and Technical Requirements Manual.

1.21. Electronic copies of simplified plant drawings (if available). Note: these may be

uncontrolled documents such as big notes, training diagrams, etc.

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2. Information Requested (for the approximate 7 selected components and 7 selected

modifications) to be Available by August 14, 2020, (will be reviewed by the team in the

Regional office during the weeks of August 17 and August 24, 2020)

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 2.1- 2.16 are

associated with the selected components and item 2.17 for the selected modifications.

2.1. List of condition reports (corrective action documents) associated with each of the

selected components for the last 6 years.

2.2. 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.

2.3. Aging Management Program documents applicable to each selected component.

2.4. Copies of calculations associated with each of the selected components, excluding

data files. [Pipe stress calculations excluded from this request].

2.5. Provide an all-inclusive list of calculation revisions in effect associated with each of the

selected components. Include document number, title, and revision number.

2.6. Electronic copies of electrical drawings (ac and dc) and key diagrams.

2.7. Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available).

2.8. System Health Reports, System Descriptions, Design Basis Documents, and/or

Training Lesson Plans associated with each of the selected components.

2.9. 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.

2.10. Copies of operability evaluations (open/closed for last 3 years) associated with each of

the selected components and plans for restoring operability, if applicable.

2.11. Copies of selected operator work-around evaluations associated with each of the

selected components and plans for resolution, if applicable.

2.12. Copies of any open temporary modifications associated with each of the selected

components, if applicable.

2.13. 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.).

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2.14. Provide copies of the normal and alarm response procedures associated with the

selected components and selected scenarios.

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

2.16. 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.

2.17. 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.

2.18. Corrective Action Program procedures, including the operability/functionality

determination procedure.

2.19. Quality Assurance Program document/procedure.

2.20. A copy of any internal/external self-assessments and associated corrective action

documents generated in preparation for the inspection.

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

3. Additional Information to be Provided on August 31, 2020 Onsite (for final selected

components and modifications)

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

August 24, 2020.

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

components during the two onsite inspection weeks.

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 2:30 p.m. 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.

4.3. If available in hardcopy form, one complete set of P&IDs and simplified drawings (e.g.,

training schematics). If any of these documents is not available in hardcopy form,

contact the lead inspector.

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4.4. Please ensure that other supporting documents for the selected items have been

located and are readily retrievable as the inspection team will likely be requesting

these documents during the inspection. Examples of supporting documents are:

4.4.1 Individual Plant Examination/Probabilistic Risk Assessment report;

4.4.2 Procurement documents for components and modifications selected (verify

retrievable);

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

4.4.4 Vendor manuals;

4.4.5 Historical revisions of the Final Safety Analysis Report; and

4.4.6 Copy of electrical drawings, key diagrams and isometrics (paper copies).

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

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