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Request for Information Design Bases Assurance Inspection (Program); NRC Inspection Report 05000255/2019010 (DRS-N. Feliz-Adorno)
	ML19056A113
Person / Time
Site:	Palisades
Issue date:	02/25/2019
From:	Nestor Feliz-Adorno; NRC/RGN-III/DRS/EB2
To:	Arnone C; Entergy Nuclear Operations
References
	Download: ML19056A113 (8)
	v • d • e

February 25, 2019

Mr. Charles Arnone

Vice President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANTREQUEST FOR INFORMATION DESIGN

BASES ASSURANCE INSPECTION (PROGRAM); NRC INSPECTION

REPORT 05000255/2019010

Dear Mr. Arnone:

On July 15, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial

Baseline Design Bases Assurance Inspection (Program) at Palisades Nuclear Plant.

This inspection will be performed in accordance with NRC Baseline Inspection

Procedure 71111.21N, Attachment 1.

The Design Bases Assurance Inspection will focus on the implementation of the Electrical

Equipment Environmental Qualification (EQ) Program to verify you are maintaining the qualified

status of equipment during the life of the plant. The final selection of EQ components to be

reviewed during this baseline inspection will be identified during the inoffice preparation week

that occurs prior to the first onsite inspection week.

The inspection will include 2 weeks onsite. The inspection team will consist of three NRC

inspectors. The current inspection schedule is as follows:

Team preparation week: July 8, 2019, through July12, 2019;

Onsite inspection weeks: July 15, 2019, though July 19, 2019; and

July 29, 2019, through August 2, 2019.

Experience with previous baseline design 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.

C. Arnone -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 April 12, 2019.

The lead inspector will communicate the initial selected EQ components no later than

May 17, 2019.

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 5, 2019. 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. This information should be

available to the team onsite on July 15, 2019.

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 Néstor J. Féliz-Adorno. We understand that our

licensing contact for this inspection is Barb Dotson of your organization. If there are any

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

the lead inspector at 630-829-9739 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.

C. Arnone -3-

This letter, its enclosure, and your response (if any) 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 Engineer

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-255;72-007

License No. DPR-20

Enclosure:

Document Request for Design Bases

Assurance Inspection EQ Program

cc: Distribution via LISTSERV

C. Arnone -4-

Letter to Charles Arnone from Néstor J. Féliz-Adorno dated February 25, 2019.

SUBJECT: PALISADES NUCLEAR PLANTREQUEST FOR INFORMATION DESIGN

BASES ASSURANCE INSPECTION (PROGRAM); NRC INSPECTION

REPORT 05000255/2019010

DISTRIBUTION:

Michael McCoppin

RidsNrrPMPalisades Resource

RidsNrrDorlLpl3

RidsNrrDirsIrib Resource

DRPIII

DRSIII

ADAMS Accession Number: ML19056A113

OFFICE RIII

NAME NFéliz-Adorno:jw

DATE 02/25/19

OFFICIAL RECORD COPY

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number: 05000255/2019010

July 15, 2019, through July 19, 2019; and

Onsite Inspection Dates:

July 29, 2019, through August 2, 2019.

71111.21N, Design Bases Assurance Inspection (Program),

Attachment 1, Environmental Qualification under Title 10 of

Inspection Procedure:

the Code of Federal Regulations, Part 50.49, Programs,

Processes, and Procedures

Néstor J. Féliz-Adorno

Lead Inspector: 630-829-9739

Nestor.Feliz-Adorno@nrc.gov

John Bozga, Senior Reactor Engineer, RIII/DRS

Teammate Inspectors:

Michael Greenleaf, Reactor Engineer, RII/DRS

II. LOGISTICS

Email the following inspection logistics to the lead inspector by June 5, 2019, 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 11:00 a.m. Eastern 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. Engineering staff normal working hours; and

11. Any potential resource conflicts during the inspection (e.g., emergency drills and

all-staff meetings).

Enclosure

DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

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 Initial Inspection Scoping Activities

The following information is requested by April 12, 2019, or sooner, to facilitate

the initial sample selection.

1.1. Risk-ranking of top 250 components required to meet environmental

qualifications (EQ) from your site specific probabilistic safety analysis

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.

1.2. Probabilistic Safety Analysis listing of top ten risk significant systems.

1.3. U.S. Nuclear Regulatory Commission Safety Evaluation Reports

associated with EQ.

1.4. 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. Specifically identify which Updated Final Safety Analysis

Report sections address EQ (including seismic).

1.5. Identify the various EQ standards (including year, edition, or revision) that

the station is committed to.

1.6. Site (and corporate if applicable) procedures associated with the Title 10

of the Code of Federal Regulations, Part 50.49, EQ Program for electrical

components. Include procedures for procurement of qualified equipment,

maintenance of qualified equipment, modification to qualified equipment

(including Equivalency or Commercial Grade Dedication (CGD)

Programs), and material storage and shelf life controls.

1.7. Environmental Qualifications Design Basis Document, if applicable.

1.8. Any open licensing commitments related to EQ, if applicable.

1.9. Equipment Qualification Master List (EQML). Specific issues

to be identified include: safety classification (safety-related or

non safety-related), Regulatory Guide 1.97 instrumentation,

EQ qualification (e.g., DOR, NUREG-588, 50.49), original or replaced

after implementation of 50.49, plant location, and qualified life.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

1.10. List of any installed equipment removed from the EQML and basis for

removal.

1.11. List of EQ solenoid valves that are normally continuously energized.

1.12. If EQ files were reviewed for Aging Management effects of license

renewal, identify which EQ files were modified/changed to incorporate

appropriate actions for the period of extended operation. Include any

EQ Aging Management Program documents.

1.13. List or drawings of plant areas that are subjected to EQ, identifying design

(limiting) temperature, high energy line break, radiation levels, etc. that

the associated equipment will have to be qualified to meet EQ. If the

reactor unit has obtained a power uprate (greater than 5 percent) provide

same information pre-update (earliest available if multiple uprates).

1.14. List of CGD evaluations performed, for which the dedicated parts have

been issued for installation (parts issued for the last 10 years) on EQ

applications in the plant. Include CGD evaluation number, name of part,

component ID or description of the component the part was issued to

repair, work order, and date issued or installed.

1.15. List of Corrective Action Documents related to the EQ Program or EQ of

specific components for the last 5 years.

1.16. Any self-assessment and/or audit of the EQ Program in the last 3 years.

1.17. Current management and engineering organizational chart.

1.18. Licensing point of contact information (name, phone number, and email).

2. Information Requested to Support Inspection Preparation Activities

The following information is requested by June 5, 2019, or sooner, to facilitate

the final inspection preparation. This information request is associated with the

selected components and should be separated by component (e.g., folder with

component name that includes EQ files, Qualification Test Reports, calculations,

corrective action documents, and maintenance history).

2.1. Component/subcomponent EQ summary report.

2.2. Qualification Maintenance Requirement Sheet or equivalent.

2.3. List of corrective action documents associated with each selected

component for the last 5 years.

2.4. Photos of any component in containment or high radiation areas,

if available.

2.5. EQ file, including associated Qualification Test Reports.

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DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM

2.6. Vendor manual. If an electronic copy is not available, include a statement

explaining this and provide a hard copy during the onsite phase of the

inspection.

2.7. Preventive maintenance template.

2.8. Last two performed work order (WO) for each associated EQ preventive

maintenance.

2.9. List of corrective maintenance WOs for the last 10 years. Include WO

number, date performed, and brief one line description.

2.10. If repair work (e.g., a motor rewind) was performed under a purchase

order, provide the purchase order.

2.11. Thermal life calculation.

3. Additional Information to Be Provided Onsite

During the in-office preparation activities, the team 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 8, 2019.

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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ML19056A113

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