ML19290E548
| ML19290E548 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 10/17/2019 |
| From: | Jamie Benjamin NRC/RGN-III/DRS/EB2 |
| To: | Dean Curtland NextEra Energy Duane Arnold |
| References | |
| IR 2020010 | |
| Download: ML19290E548 (9) | |
See also: IR 05000331/2020010
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, IL 60532-4352
October 17, 2019
Mr. Dean Curtland
Director of Site Operations
NextEra Energy Duane Arnold, LLC
3277 DAEC Road
Palo, IA 52324-9785
SUBJECT: DUANE ARNOLD ENERGY CENTERREQUEST FOR INFORMATION FOR
AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION
(TEAM); INSPECTION REPORT 05000331/2020010
Dear Mr. Curtland:
On January 13, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin a Triennial
Baseline Design Bases Assurance Inspection (Team) at Duane Arnold Energy Center.
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, 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 four NRC
inspectors who will focus on engineering/maintenance/operations of the selected components
and modifications. The current inspection schedule is as follows:
Preparation week:
January 6, 2020, through January 10, 2020
Onsite weeks:
January 13, 2020 through January 17, 2020; and
January 27, 2020, through January 31, 2020
D. Curtland
-2-
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.
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 November 29,
2019. By December 13, 2019, the lead inspector will communicate the initial selected
set of approximately ten components and ten 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 December 27, 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
January 13, 2020. 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 Jamie Benjamin. We understand that our licensing
contact for this inspection is Tracy Weaver (319-851-7250) of your organization. If there are
any questions about the inspection or the material requested in the enclosure, please contact
the lead inspector at 630-829-9747 or via e-mail at Jamie.Benjamin.@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. Curtland
-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/
Jamie Benjamin, Senior Reactor Engineer
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-331
License No. DPR-49
Enclosure:
Design Bases Assurance Inspection
Document Request
cc: Distribution via LISTSERV
D. Curtland
-4-
Letter to Dean Curtland from Jamie Benjamin dated October xx, 2019.
SUBJECT: DUANE ARNOLD ENERGY CENTERREQUEST FOR INFORMATION FOR
AN NRC TRIENNIAL BASELINE DESIGN BASES ASSURANCE INSPECTION
(TEAM); INSPECTION REPORT 05000331/2020010
DISTRIBUTION:
RidsNrrDorlLpl3
RidsNrrPMDuaneArnold Resource
RidsNrrDirsIrib Resource
DRPIII
DRSIII
ADAMS ACCESSION: ML19290E548
DOCUMENT NAME: Ltr 10xx19 Duane Arnold 2020 010 DBA Inspection RFI (DRS-
J.Benjamin).docx
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE
RIII
NAME
JBenjamin:jw
DATE
10/17/19
OFFICIAL RECORD COPY
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000331/2020010
Inspection Dates:
January 13, 2020 through January 17, 2020; and
January 27, 2020, through January 31, 2020
Inspection Procedure:
IP 71111.21M, Design Bases Assurance Inspection (Team)
Lead Inspector:
Jamie Benjamin, Senior Reactor Engineer, DRS
630-829-9747
Jamie.benjamin@nrc.gov
I.
Information Requested for Selection of Components/Modifications
The following information is requested by November 29, 2019, or sooner, to facilitate
inspection preparation. If you have any questions regarding this information, please call
the lead inspector as soon as possible. (Please provide the information electronically in
pdf files, Excel, or other searchable formats, preferably on some portable electronic
media (e.g., CD-ROM, DVD, etc.). The portable electronic media 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 100 components (total) associated with spent fuel pool cooling,
control room heating and ventilation and filtration, reactor building closed cooling
water, demineralized water, well water, instrument air and 4kV essential busses and
switchgear systems 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).
2. Provide copies of the emergency operating procedures.
3. Provide a list of the abnormal operating procedures.
4. Any pre-existing evaluation or list of components and associated calculations with
low design margins, (i.e., 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 etc.).
5. List of available design (setup) margins in both the open and closed direction
(identify safety-related direction) for valves in the motor-operated valve and air-
operated valve programs. Identify the basis for how the margin was determined.
6. 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).
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
2
7. Structures, systems, and components (SSCs) associated with the systems described
in Item 1 in the Maintenance Rule (a)(1) category for the last 3 years.
8. Site top ten issues list (if applicable).
9. A list of operating experience evaluations for the last 3 years associated with
system/components described in Item 1.
10. Information of any common cause failure of components experienced in the last
5 years at your facility.
11. List of root cause evaluations associated with component failures or design issues
initiated/completed in the last 5 years.
12. List of open operability evaluations.
13. List of SSCs considered operable but degraded/nonconforming.
14. 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.
15. A list of calculation changes that have been issued for use in the last 3 years.
16. Copies of procedures addressing the following: modifications, design changes, set
point changes, equivalency evaluations or suitability analyses, commercial grade
dedications, and post-modification testing.
17. 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.
18. Current management and engineering organizational chart.
19. Electronic copies of Updated Final Safety Analysis Report, Technical Specifications,
Technical Specifications Bases, and Technical Requirements Manual.
20. Major one-line electrical drawings (ac and dc) and key diagrams (paper copies)
associated with the systems described in Item 1.
21. Electronic copy of Piping and Instrumentation Drawings (if available) associated with
the systems described in Item 1.
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
3
II.
Information Requested (for the approximate 10 selected components and
10 selected modifications) to be Available by December 27, 2019, (will be
reviewed by the team in the Regional office during the week of January 6, 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.).
1. List of condition reports (corrective action documents) associated with each of the
selected components for the last 3 years.
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.
3. Copies of calculations associated with each of the selected components
(if not previously provided), excluding data files. Please review the calculations and
also provide copies of important referenced material (such as drawings, engineering
requests, and vendor letters). [Pipe stress calculations excluded from this request]
4. System Health Reports, System Descriptions, Design Basis Documents, and/or
Training Lesson Plans associated with each of the selected components.
5. 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.
6. Copies of operability evaluations (open/closed for last 3 years) associated with each
of the selected components and plans for restoring operability, if applicable.
7. Copies of selected operator work-around evaluations associated with each of the
selected components and plans for resolution, if applicable.
8. Copies of any open temporary modifications associated with each of the selected
components, if applicable.
9. Trend data on the selected electrical/mechanical components performance for
last 3 years (For example, pumps performance including in-service testing, other
vibration monitoring, oil sample results, etc., for valves: stroke time and leak rate
results, diagnostic trend data, etc.).
10. Provide copies of the normal and abnormal operating procedures associated with
the selected components and selected scenarios.
11. List of time critical or risk significant operator actions associated with components.
Identify those actions that do not have job performance measures.
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
4
12. Copy of latest completed tests and surveillances for each component, for example:
a. Pumps: comprehensive test, quarterly test, flow balance, etc.
b. Valves: stroke time testing, diagnostic testing, leak testing, interlocks, etc.
c. Heat Exchangers/room coolers: thermal performance, clean/inspect, fan flows,
etc.
d. Components: Technical Specification surveillances.
e. Acceptance criteria basis calculations should also be included.
13. 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.
14. A copy of any internal/external self-assessments and associated corrective action
documents generated in preparation for the inspection.
15. A copy of engineering/operations related audits completed in the last 2 years.
III.
Additional Information to be Provided on January 13, 2020, Onsite (for final
selected components and modifications)
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
January 6, 2020.
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. Copies of any corrective action documents generated as a result of the teams
questions or queries during this inspection.
2. Copies of the list of questions submitted by the team members and the
status/resolution of the information requested (provide daily by 2:00 p.m.
during the inspection to each team member).
3. One complete set of Piping and Instrumentation Drawings (paper copies).
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);
DESIGN BASES ASSURANCE INSPECTION DOCUMENT REQUEST
5
c. Plant procedures (normal, abnormal, emergency, surveillance, etc.); and
d. Vendor manuals.
If you have questions regarding the information requested, please contact the lead inspector.