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Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000266/2020-011 and 05000301/2020-011
	ML20100G890
Person / Time
Site:	Point Beach
Issue date:	04/07/2020
From:	Sanchez-Santiago E; NRC/RGN-III
To:	Craven R; Point Beach
References
	IR 2020011
	Download: ML20100G890 (10)
	v • d • e

April 7, 2020

Mr. Robert Craven

Site Director

NextEra Energy Point Beach, LLC

6610 Nuclear Road

TWO RIVERS, WI 54241-9516

SUBJECT: POINT BEACH NUCLEAR PLANT REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):

INSPECTION REPORT 05000266/2020-011 AND 05000301/2020-011

Dear Mr. Craven:

On June 22, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial

baseline Design Bases Assurance Inspection (Team) at Point Beach Nuclear Plant. 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, 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: June 15 - 19, 2020

Onsite weeks: June 22 - 26, 2020, and July 6 - 10, 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.

R. Craven -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 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 May 11, 2020.

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

May 26, 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 June 8, 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

June 22, 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 Elba Sanchez Santiago. We understand that our

licensing contact for this inspection is Kim Locke of your organization. If there are any

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

lead inspector at 630-829-9520 or via e-mail at elba.sanchezsantiago@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.

R. Craven -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/

Elba Sanchez Santiago, Senior Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-266 and 50-301

License Nos. DPR-24 and DPR-27

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

R. Craven -4-

Letter to Robert Craven from Elba Sanchez Santiago dated April 7, 2020.

SUBJECT: POINT BEACH NUCLEAR PLANT REQUEST FOR INFORMATION FOR AN NRC

TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION (TEAM):

INSPECTION REPORT 05000266/2020011; 05000301/2020011

DISTRIBUTION:

Jessie Quichocho

Omar Lopez-Santiago

RidsNrrDorlLpl3

RidsNrrPMPointBeach

RidsNrrDroIrib Resource

DRPIII

DRSIII

ADAMS Accession Number: ML20100G890

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME ESanchez

Santiago:mb via

email

DATE 04/07/2020

OFFICIAL RECORD COPY

DESIGN BASES ASSURANCE INSPECTION (TEAMS)

REQUEST FOR INFORMATION

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000266/2020011; 05000301/2020011

Onsite Inspection Dates: June 22-26, 2020, and July 5-10, 2020

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

Elba Sanchez Santiago, Senior Reactor Inspector, DRS

Lead Inspector: 630-829-9520

elba.sanchezsantiago@nrc.gov

Alan Dahbur, Senior Reactor Inspector, RIII/DRS

Benny Jose, Senior Reactor Inspector, RIII/DRS

Teammates: Lionel Rodriguez, Reactor Inspector, RIII/DRS

Mathew Domke, Reactor Inspector, RIII/DRS

Craig Baron, NRC Mechanical Contractor

II. LOGISTICS

Email the following inspection logistics to the lead inspector by May 11, 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

Enclosure

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

meetings).

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 May 11, 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).

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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).

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.

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

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

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

selected modifications) to be Available by June 8, 2020, (will be reviewed by the

team in the Regional office during the week of June 15, 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

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vibration monitoring, oil sample results, etc., for valves: stroke time and leak rate

results, diagnostic trend data, etc.).

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 June 22, 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

June 15, 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.

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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.

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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ML20100G890

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