ML19123A036
| ML19123A036 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/03/2019 |
| From: | Jasmine Gilliam Engineering Branch 3 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2019012 | |
| Download: ML19123A036 (7) | |
See also: IR 05000454/2019012
Text
May 3, 2019
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: BYRON STATION, UNITS 1 AND 2REQUEST FOR INFORMATION
FOR AN NRC DESIGN BASES ASSURANCE INSPECTION (PROGRAM):
IMPLEMENTATION OF THE ENVIRONMENTAL QUALIFICATION PROGRAM
INSPECTION REPORT 05000454/2019012; 05000455/2019012
Dear Mr. Hanson:
On August 26, 2019, the U. S. Nuclear Regulatory Commission (NRC) will begin a triennial
baseline Design Bases Assurance Inspection (Program) at Byron Station. 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 Program to verify you are maintaining the qualified
status of equipment during the life of the plant. The final selection of environmental
qualifications 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 two weeks onsite. The inspection team will consist of three NRC
inspectors. The current inspection schedule is as follows:
Team preparation week: August 19-23, 2019
Onsite inspection weeks: August 26-30, 2019; and September 9-13, 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.
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 June 10, 2019.
The lead inspector will communicate the initial selected EQ components no later than
June 24, 2019.
B. Hanson
-2-
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 July 22, 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 August 26, 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 Jasmine Gilliam. 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
630-829-9831 or via e-mail at Jasmine.Gilliam@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.
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 Robert Daley Acting for/
Jasmine Gilliam, Reactor Engineer
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-454; 50-455
Enclosure:
Document Request for Design Bases
Assurance Inspection EQ Program
cc: Distribution via LISTSERV
B. Hanson
-3-
Letter to Bryan C. Hanson from Jasmine Gilliam dated May 3, 2019.
SUBJECT: BYRON STATION, UNITS 1 AND 2REQUEST FOR INFORMATION
FOR AN NRC DESIGN BASES ASSURANCE INSPECTION (PROGRAM):
IMPLEMENTATION OF THE ENVIRONMENTAL QUALIFICATION PROGRAM
INSPECTION REPORT 05000454/2019012; 05000455/2019012
DISTRIBUTION:
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ADAMS Accession Number: ML19123A036
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DATE
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OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
Enclosure
I. ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
05000454/2019012; 05000455/2019012
Onsite Inspection Dates:
August 26-30, 2019, and September 9-13, 2019
Inspection Procedure:
71111.21N, Design Bases Assurance Inspection (Program),
Attachment 1, Environmental Qualification (EQ) under
10 CFR 50.49 Programs, Processes, and Procedures
Lead Inspector:
Jasmine Gilliam, Reactor Engineer, RIII/DRS
630-829-9831
Jasmine.Gilliam@nrc.gov
Teammate Inspectors:
Benny Jose, Senior Reactor Engineer, RIII/DRS
Jorge Corujo-Sandin, Reactor Engineer, RIII/DRS
II. LOGISTICS
Email the following inspection logistics to the lead inspector by July 22, 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 am) 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).
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
2
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 June 10, 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 10 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.
EQ Design Basis Document, if applicable.
1.8.
Any open licensing commitments related to EQ, if applicable.
1.9.
EQ Master List. Specific issues to be identified include: safety classification
(safety-related or nonsafety-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.
1.10. List of any installed equipment removed from the EQ Master List and basis for
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
3
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 July 22, 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.
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.
DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM
4
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 August 19, 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.