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 2REQUEST FOR

INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES

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 (Team) at LaSalle County Station, Units 1

and 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, 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: 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 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 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 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 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 2REQUEST FOR

INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES

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

Inspection Report: 05000373/2019012; 05000374/2019012

Inspection Dates: July 22-26, 2019, and August 5-9, 2019

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

Lead Inspector: Michael A. Jones Jr.

630-829-9745

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 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).

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).

Enclosure

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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 the 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

PSA).

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 modifications 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 Report, Technical Specifications,

Technical Specifications Bases, and Technical Requirements Manual.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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 1-12 are

associated with the selected components and item 13 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.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

11. List of time critical 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, 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 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 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.

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).

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

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.

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