ML21053A314

Information Request for a Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000317/2021010 and 05000318/2021010

ML21053A314
Person / Time
Site:	Calvert Cliffs
Issue date:	02/22/2021
From:	Mel Gray Engineering Region 1 Branch 1
To:	Rhoades D Exelon Generation Co, Exelon Nuclear
Gray M
References
IR 2021010
Download: ML21053A314 (8)

See also: IR 05000317/2021010

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PENNSLYVANIA 19406-2713

February 22, 2021

Mr. David P. Rhoades

Senior Vice President

Exelon Generation Company, LLC

President and Chief Nuclear Officer

Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 -

INFORMATION REQUEST FOR A TRIENNIAL BASELINE DESIGN BASES

ASSURANCE INSPECTION (TEAM); INSPECTION REPORT

05000317/2021010 AND 05000318/2021010

Dear Mr. Rhoades:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

Region I staff will conduct a Design Bases Assurance Inspection (DBAI) at Calvert Cliffs, Units 1

and 2. Paul Cataldo, a Senior Reactor Inspector from the NRCs Region I Office, will lead the

inspection team. The inspection will be conducted in accordance with Inspection Procedure 71111.21M, Design Bases Assurance Inspection (Team), dated December 8, 2016 (ADAMS

Accession No. ML16340B000).

The inspection will evaluate the capability of risk-significant/low-margin components to function

as designed to support proper system operation. The inspection will also include a review of

selected modifications, operating experience, and as applicable, operator actions.

During a telephone conversation on February 16, 2021, with Mr. Kenneth Greene, Calvert Cliffs

Regulatory Assurance, we confirmed arrangements for the receipt of scoping documents for

information gathering and remote review, and the two-week onsite inspection(**), as follows:

• Information gathering and remote review: Weeks of March 22 through April 26, 2021

• Onsite weeks**: Weeks of June 7 and June 21, 2021

• • Due to the current Covid PHE, some activities may be conducted remotely.

The purpose of the information-gathering and remote review is to identify risk-significant

components, modifications, operator actions, and operating experience items. Information and

documentation needed to support the inspection will also be identified. Frank Arner, a Region I

Senior Risk Analyst, will support Paul Cataldo during the information-gathering visit and remote

review, to evaluate probabilistic risk assessment data and identify components to be examined

during the inspection.

D. Rhoades 2

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

has shown this type of inspection is 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 two groups:

• The first group lists information necessary for our initial inspection scoping activities.

After discussion with Mr. Greene, in recognition of the outage-related activities in March

2021, a majority of this information that should be easily and readily available for

uploading to Sharefile, should be provided to the lead inspector by the week of

March 22, 2021. Additionally, the remainder of the documents not uploaded due to

outage conflicts should be available to the lead inspector by April 12, 2021. By the week

of April 26, 2021, 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, specific to the selected components

and modifications, should be provided to the lead inspector no later than May 28, 2021.

During the in-office preparation activities, the team may identify additional information

needed to support the inspection, and those items will be communicated directly to

Mr. Greene.

If there are any questions about the inspection or the material requested in the enclosure,

please contact the lead inspector at 603-395-5536 or via e-mail at pcc1@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.

D. Rhoades 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,

X /RA/

Signed by: Melvin K. Gray

Mel Gray, Chief

Engineering Branch 1

Division of Reactor Safety

Docket Nos. 05000317 and 05000318

License Nos. DPR-53 and DPR-69

Enclosure:

Document Request for Design Bases

Assurance Inspection

cc: Distribution via ListServ

ML21053A314

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DRS RI/DRS RI/DRS

NAME PCataldo FArner MGray

DATE 2/17/21 2/17/21 2/22/21

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

Inspection Report: 05000317/2021010 and 05000318/2021010

Onsite Inspection Dates: June 7 through June 11, 2021; and

June 21 through June 25, 2021

Inspection Procedure: Inspection Procedure 71111.21M, Design Bases Assurance

Inspection (Team)

Lead Inspector: Paul Cataldo, Senior Reactor Inspector

603-395-5536

PCC1@nrc.gov

I. Information Requested for Selection of Components and Modifications

The following information is requested by March 22, 2021 (and April 12, 2021 for remaining

documents not provided due to outage-related conflicts) to facilitate inspection preparation.

Feel free to contact the lead inspector as soon as possible if you have any questions

regarding this information request. Please provide the information electronically

(Certrec/Sharefile) in pdf files, Excel, or other searchable formats. Also, we understand

the prevailing use of Sharefile for inspection-related information for the Exelon fleet,

therefore, the files should contain descriptive names, and indexed and hyperlinked to

facilitate ease of use by the inspectors. Information in lists should contain enough

information to be easily understood by someone who has knowledge of light water reactor

technology.

1. The site probabilistic risk analysis (PRA) System Notebook and latest PRA Summary

Document.

2. Risk ranking of top 250 basic events sorted by Risk Achievement Worth (>/= 1.3).

Include values for Risk Reduction Worth, Birnbaum Importance, and Fussell-Vesely (as

applicable). Please provide in an excel spreadsheet or other sortable format, and to

include an understandable definition of the coded, basic events.

3. Risk-ranking of top 100 components from site-specific PRA sorted by Large Early

Release Frequency.

4. If you have an External Events or Fire PRA 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 descriptions.

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

6. List of emergency and abnormal operating procedures.

7. 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

Enclosure

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

pressure, diesel generator close to design required output, heat exchangers close to

rated design heat removal).

8. If applicable, copy of any self-assessments and/or Quality Assurance assessments of

low margin structures, systems and components (SSCs) completed since July 1, 2018.

9. List of available design margins in both the open and closed direction for valves in the

motor-operated valve and air-operated valve programs (related to GL 96-05, looking for

resultant output - matrix of risk vs margin for MOVs and AOVs, as applicable); the fleet

or Calvert Cliffs-specific MOV Program procedure.

10. The age and capacity of the safety-related DC batteries.

11. The In-Service Testing (IST) Program Basis 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. Access to IST trend data for the following pumps for both units: AFW pumps, HPSI

pumps, LPSI/RHS pumps, and SW pumps. [Note: needed for each discrete component

(e.g. for each RHR pump)]

13. Listing of MR (a)(1) systems, date entered into (a)(1) status, and brief description of

why (a)(1); if not included as part of Item 15 below, please include the latest System

Health report for those systems in (a)(1) status.

14. List of MRFFs evaluations completed since July 1, 2018 (include those determined not

to be a MRFF).

15. A copy of the most recent System Health and/or trending reports for the following

systems (as applicable): SR 4KV, SR 480 Vac, HPSI, LPSI/RHS, SW, SR 125 Vdc, and

EDGs.

16. A copy of the most recent Program Health and/or trending reports for the following

programs, as applicable: GL 89-10 (MOVs), GL 89-13, IST, AOVs, breakers, relays.

17. List of open operability evaluations, and the associated implementing procedure for

degraded and non-conforming conditions/operability evaluations; List of formal

operability evaluations performed for the last 4 years.

18. List of current operator work arounds/burdens.

19. List of permanent plant modifications to SSCs that are field work complete since

July 1, 2018. 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 (sufficient to understand the purpose of the

modification), revision/date, and the affected system. Please provide the design change

procedure that governs the implementation of the listed and applicable methods.

20. List of calculation changes (including new calculations) that have been issued for use

since July 1, 2018.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

21. Corrective Action Program procedure.

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

equivalency evaluations or suitability analyses, commercial grade dedications, and

post-modification testing.

23. List of corrective action documents (open and closed) that address permanent plant

modifications issues, concerns, or processes, for the past four years; MOV-related

deficiencies, and any plant-level events that generated root or causal evaluations,

and/or associated Licensee Event Reports in the last four years.

24. Any internal/external self-assessments and associated corrective action documents

generated in preparation for this inspection.

25. Updated Final Safety Analysis Report, Technical Specifications, Technical

Specifications Bases, and Technical Requirements Manual.

26. Electrical simple one-line drawings for 4KV, 480V, & 345KV (scalable for electronic

viewing preferred).

27. Copy of Exelons internal responses to any applicable NRC Information Notices,

Generic Letters, or Regulatory Issue Summaries for the past four years.

28. A list of NRC Part 21 Reports, determined to be applicable to Calvert Cliffs, for the past

4 years.

29. DBDs (if applicable & available): SR 4KV, SR 480 Vac, HPSI, LPSI/RHS, SW, SR 125

Vdc, and EDGs.

II. Information Requested to Be Available by May 28, 2021

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 through 11

are associated with the selected components and Item 12 is for the selected modifications.

1. List of corrective action documents associated with each selected component for the

past four years.

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

selected component for the last five years. Identify frequency of preventive

maintenance activities.

3. Aging Management Program documents and/or License Renewal committed inspection

results applicable to each selected component.

4. List of calculations associated with each selected component, excluding data files. Pipe

stress calculations are excluded from this request.

5. System Health Report (last completed) and Design Basis Document associated with

each selected component, as applicable.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION

6. Access to or copy of vendor manual(s) for each selected component.

7. List of open temporary modifications associated with each selected component, if

applicable.

8. Trend data/graphs on the selected components performance for the past three years

(e.g., pump performance including IST, other vibration monitoring, oil sample results).

9. List of normal operating and alarm response procedures associated with each selected

component.

10. Last completed tests and surveillances for each selected component performed for the

past three years. For those tests and surveillances performed at a periodicity of greater

than three years, provide the latest test performed.

11. Schedule of surveillance testing of selected components that occur during the onsite

and offsite inspection weeks.

12. For each selected modification, copies of associated documents such as modification

package, engineering changes, 50.59 screening or evaluation, relevant calculations,

post-modification test packages, associated corrective action documents, design

drawings, and new/revised preventive maintenance requirements.

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