ML19037A484
| 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:
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ADAMS Accession Number: ML19037A484
OFFICE RIII
NAME NFéliz-Adorno:cl
DATE 02/04/19
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
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.
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
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.
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
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.
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
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.
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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION
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.
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