ML23360A608
| ML23360A608 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/27/2023 |
| From: | Lionel Rodriguez NRC/RGN-III/DORS/EB1 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2024010 | |
| Download: ML23360A608 (1) | |
See also: IR 05000373/2024010
Text
David P. Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
LASALLE COUNTY STATION - REQUEST FOR INFORMATION FOR
NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION
REPORT 05000373/2024010 AND 05000374/2024010
Dear David Rhoades:
On April 15, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a
commercial grade dedication (CGD) inspection at LaSalle County Station. This inspection
will be performed in accordance with NRC Inspection Procedure 71111.21N.03,
The inspection will evaluate the implementation of LaSalles process for dedicating
commercial-grade items, as required in applicable portions of Title 10 of the Code of
Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants, to ensure reasonable assurance
is provided that these items will perform their intended safety function. Additionally, the
inspection will evaluate implementation of LaSalles procurement process for
safety-related components, as required in Appendix B.
The inspection may include an onsite information gathering visit by the lead inspector.
The inspection will include 2 weeks onsite and will consist of 3 NRC inspectors
(including the lead inspector) along with one observer. The current inspection schedule
is as follows:
Potential Information Gathering Visit:
March 18 - 22, 2024
Preparation week:
April 8 - 12, 2024
Onsite weeks:
April 15 - 19, 2024 and April 29 - May 3, 2024
The purpose of the information gathering visit would be to meet with knowledgeable
individuals of your staff to become familiar with the process for dedicating
commercial-grade items and the process for procuring safety-related components at
LaSalle. This visit would also allow the lead inspector to meet with procurement
engineering and other site individuals responsible for the inspection to ensure a
December 27, 2023
D. Rhoades
2
common understanding of expectations for the inspection. This visit may include a tour
of onsite commercial-grade item dedication facilities, receipt inspection facilities, storage
facilities, and installed plant components associated with potential inspection samples.
During the visit (if performed), the lead inspector will also review the information
provided in the initial information request and may request additional information
needed to support the inspection. Experience with previous baseline 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.
It is important that all these documents are up-to-date and complete 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 March 4, 2024. The lead inspector will communicate the initial selected
set of samples no later than March 25, 2024.
The second group of documents requested are those items needed to support
our in-office preparation activities. This set of documents should be provided to
the lead inspector no later than April 5, 2024. 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, a schedule of plant
activities associated with the inspection during the onsite period, and any
additional requests resulting from the potential information gathering visit. This
information should be available to the team onsite on April 15, 2024.
The fourth group includes supporting information to be provided throughout the
onsite inspection. Specifically, corrective action documents and answers to
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 Lionel Rodriguez. We understand that our
licensing contact for this inspection is Jereme Greenblott of your organization. If there are
any questions about the inspection or the material requested in the enclosure, please
contact the lead inspector at 630-829-9609 or via email at Lionel.Rodriguez@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
D. Rhoades
3
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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
Senior Reactor Inspector
Engineering Branch 1
Division of Operating Reactor Safety
Docket Nos. 05000373; 05000374
Enclosure:
Commercial Grade Dedication Inspection
Request for Information
cc: Distribution via LISTSERV
Signed by Rodriguez, Lionel
on 12/27/23
D. Rhoades
4
Letter to David Rhoades from Lionel Rodriguez dated December 27, 2023.
SUBJECT:
LASALLE COUNTY STATION - REQUEST FOR INFORMATION FOR
NRC COMMERCIAL GRADE DEDICATION INSPECTION: INSPECTION
REPORT 05000373/2024010 AND 05000374/2024010
DISTRIBUTION:
RidsNrrDorlLpl3
RidsNrrPMLaSalle Resource
RidsNrrDroIrib Resource
R3-DORS
ADAMS Accession Number: ML23360A608
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
RIII
NAME
LRodriguez:gmp
DATE
12/27/2023
OFFICIAL RECORD COPY
Enclosure
COMMERCIAL GRADE DEDICATION INSPECTION
REQUEST FOR INFORMATION
I.
ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
05000373/2024010 AND 05000374/2024010
Onsite Inspection Dates:
April 15 - 19, 2024 and April 29 - May 3, 2024
Inspection Procedure:
IP 71111.21N.03, Commercial Grade Dedication
Lead Inspector:
Lionel Rodriguez, Senior Reactor Inspector
RIII/DORS/EB1 630-829-9609
Lionel.Rodriguez@nrc.gov
Teammates:
Alan Dahbur, Senior Reactor Inspector, RIII/DORS/EB2
Megan Gangewere, Reactor Inspector, RIII/DORS/EB1
Cory Padilla, Reactor Inspector, RIII/DORS/EB1 (Observer)
II.
LOGISTICS
Email the following inspection logistics to the lead inspector by April 8, 2024, 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 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. Inspection response team normal working hours;
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11. Any potential resource conflicts during the inspection (e.g., emergency
drills and all-staff meetings); and
12. Current management and engineering organizational chart.
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 via an electronic sharing
service (CERTREC, ShareFile, Box, etc.). Specific Excel formats for various
enclosure items may be requested to assist in inspection sample selection. If you
do not have access to any of these services or similar, we can provide you
access to Box, which can be used to upload/download and share documents.
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 Selection of Samples
The following information is requested by March 4, 2024, or sooner, to
facilitate the initial sample selection.
Note: If you are unable to provide items 1.1. through 1.16. as requested,
please reach out to the lead inspector as soon as possible.
1.1.
Risk-Ranking of the top 500 components from your site-specific
probabilistic safety analysis (PSA) sorted by Birnbaum Worth. Include
values for Risk Achievement Worth, Risk-Reduction Worth, and
Fussell-Veseley. Please provide the ranking in an excel spreadsheet
that contains the importance measures and the description of the
basic event (e.g., not just the basic event designator).
1.2.
Risk-ranking of the top 500 components (i.e., Large Early Release
Frequency (LERF)) from your site-specific PSA similar to the request in
Item 1.1. (Provide in Excel format.)
1.3.
Provide a list of the top 500 cut-sets from your PSA. Provide the
descriptions of the basic events in the list of cut-sets. (Provide in Excel
format.)
1.4.
Provide a list of the top 100 cut-sets for each initiator modeled in the
PSA that contributes more than 5 percent to the baseline plant core
damage frequency. (Provide in Excel format.)
1.5.
List of commercial-grade items, with a brief description of application,
that have been dedicated for safety-related applications. These items
may be dedicated by the site or dedicated by a vendor (or other
licensee) and procured by the site. Please note whether the item has
been installed in the plant. Please include the component equipment
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identification of the proposed or installed item location which can be
correlated to the lists provided in Items 1.1 and 1.2. The list should
encompass the past 6 years of dedication activities.
1.6.
List of any commercial grade-items that failed after completing the
dedication process. The list should encompass the past 6 years of
dedication activities.
1.7.
List of components procured as safety-related, with descriptions, if not
included above. Please note whether the component has been installed
in the plant. Please include the component equipment identification of
the proposed or installed location which can be correlated to the lists
provided in Items 1.1 and 1.2. The list should encompass the past
6 years of procurement activities.
1.8.
List of corrective action program documents, with descriptions, related
to commercial-grade items, procurement, or storage, including any
items that failed after completing the dedication process. The list
should encompass the past 6 years of these activities.
1.9.
List components procured as safety-related or commercial-grade items
intended to be dedicated for safety-related applications that are on hold
because of concerns identified during receipt, dedication, or from
operating experience/corrective action program as applicable. If
possible, the list should identify the systems and equipment in which
these items were intended for use.
1.10. List of components procured as safety-related or commercial-grade
items dedicated for safety-related applications, in the past 6 years,
where the procurement/dedication process was expedited to support
rapid turnaround (less than 7 days). If possible, the list should
identify the systems and equipment in which these items were
intended for use.
1.11. Procedures for dedicating commercial-grade items and for
procurement of safety-related components. Also include procedures
controlling counterfeit, fraudulent, and suspect items.
1.12. Electronic copies of Updated Final Safety Analysis Report, Technical
Specifications, Technical Specifications Bases, and Technical
Requirements Manual.
1.13. Electronic copies of simplified plant drawings (if available). Note: these
may be uncontrolled documents such as big notes, training diagrams,
etc.
1.14. List of systems, system numbers/designators, and corresponding names.
1.15. List of site contacts that will be associated with the inspection.
1.16. Copy of qualifications, as applicable, of personnel who performed
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commercial-grade dedication, safety-related component procurement,
and/or receipt inspection/testing activities within the past 6 years.
2. Information Requested to Support Inspection Preparation Activities
The following information is requested by April 5, 2024, or sooner, to facilitate
inspection preparation.
This document request is based on typical documents that a generic plant
might have. As such, this document request is not meant to imply that any
specific plant is required to have all of the listed documents. In addition, your
plant specific document titles may vary from the document titles listed below.
This information should be separated for each selected sample, especially
if provided electronically (e.g., folder with sample name that includes
specifications, inspection reports, dedication information, etc.).
2.1.
Purchase requisitions and purchase orders;
2.2.
Other pertinent vendor/licensee correspondence;
2.3.
Original and updated design specifications;
2.4.
Catalog specifications;
2.5.
Procurement basis evaluation such as like-for-like, equivalency, plant
design change packages, drawing and specification updates;
2.6.
10 CFR 50.59 documentation, if applicable;
2.7.
Material receiving reports, packing lists/invoices, and other
shipping documents;
2.8.
Receipt inspection reports and any related test reports;
2.9.
Other documents to trace the item from the time it was dedicated to the
time it was installed, tested, and accepted;
2.10. Certificates of conformance/compliance/quality;
2.11. Vendor test and inspection reports;
2.12. Third-party or sub-vendor test and inspection reports;
2.13. Shelf-life information;
2.14. Vendor dedication/partial dedication information;
2.15. Design/material/process change history information;
2.16. Completed commercial-grade dedication documentation including:
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2.16.1 Safety classification
2.16.2 Identification of safety functions/application requirements
2.16.3 Identification of critical characteristics
2.16.4 Identification of verification methods and acceptance criteria
for the critical characteristics
2.16.5 Evaluation of credible failure modes, if applicable
2.16.6 Identification of the suppliers quality assurance program that
meets 10 CFR Part 50, Appendix B
2.17. Any deviation from design, material, and performance
characteristics relevant to the safety function
(nonconformance dispositions).
2.18. Documents showing objective evidence:
2.18.1 Special test and inspection procedures and results
2.18.2 Commercial-grade survey reports -item, design, material, and
specific performance characteristic (relevant to safety
function)
2.18.3 Source inspection reports
2.19. Completed post-installation test procedure and results;
2.20. Completed stock or material issue forms and installation work orders or
reports; and
2.21. Historical performance information, including corrective action
documents, maintenance rule performance, failure analysis or root
cause analysis for any failed components, and system health reports
related to the installed components.
3.
Additional Information to be Provided on April 15, 2024, Onsite
3.1.
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 April 8, 2024.
3.2.
Schedule of any activities to be conducted on the selected samples
during the two onsite inspection weeks (e.g., installation, testing,
inspection, etc.).
3.3.
Schedule of separate interviews with knowledgeable plant personnel
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for each of the components selected during the beginning of the first
onsite week. Interviews will discuss the dedication/procurement
process, selected critical characteristics of each sample, installation,
and performance of installed items. This can include, but is not limited
to, plant personnel from Procurement Engineering, other Engineering
disciplines, Operations, Maintenance, or any other departments that
are cognizant of the dedication/procurement, installation, and
acceptance criteria/methods of each component including
component/system health.
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
2:00 p.m. to each inspector. It is recommended to provide the lead
inspector with a master list sorted by inspector and each inspector with
a list containing only the items originated by that inspector.
If you have questions regarding the information requested, please contact the lead inspector.