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| {{#Wiki_filter:April 8, 2021 | | {{#Wiki_filter: |
| Mr. Rod Penfield
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| Site Vice President
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| Energy Harbor Nuclear Corp.
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| Perry Nuclear Power Plant
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| 10 Center Road,
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| Perry, OH 44081
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| SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC DESIGN BASES
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| ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR
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| INFORMATION: INSPECTION REPORT 05000440/2021012
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| Dear Mr. Penfield:
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| On June 28, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline Design
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| Bases Assurance Inspection (Programs) at Fermi Power Plant, Unit 2. This inspection will be
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| performed in accordance with NRC Baseline Inspection Procedure 71111.21N, Design Bases
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| Assurance Inspection (Programs), Attachment 2, Design-Basis Capability of Power-Operated
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| Valves Under 10 CFR 50.55a Requirements.
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| This inspection will evaluate the reliability, functional capability, and design basis of
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| risk-important power-operated valves (POVs) as required by 10 CFR 50.55a and applicable
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| 10 CFR Part 50, Appendix A and Appendix B, requirements. In conducting this inspection, the
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| team will select risk-important POVs used to prevent and mitigate the consequences of a design
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| basis accident.
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| The inspection will include two weeks of onsite inspection. The inspection team will consist of
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| three NRC inspectors. The current inspection schedule is as follows:
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| * Preparation week: June 21 - 25, 2021
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| * Onsite weeks: June 28, 2021 - July 2, 2021, and July 12 - 16, 2021
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| Experience with previous baseline engineering inspections of similar depth and length has
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| shown this type of inspection is extremely resource intensive, both for the NRC inspectors and
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| the licensee staff. In order to minimize the inspection impact on the site and to ensure a
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| productive inspection for both parties, we have enclosed a request for information needed for
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| the inspection. It is important that all of these documents are up-to-date and complete in order
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| to minimize the number of additional documents requested during the preparation and/or the
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| onsite portions of the inspection. Insofar as possible, this information should be provided
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| electronically to the lead inspector. The information request has been divided into three groups:
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| * The first group lists information necessary for our initial inspection scoping activities.
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| This information should be provided to the lead inspector no later than May 10, 2021.
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| By May 14, 2021, the lead inspector will communicate the initial selected
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| R. Penfield -2-
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| samples and any additional information needed to support the in-office preparation
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| activities.
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| * The second group of documents requested is those items needed to support our
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| in-office preparation activities. This set of documents should be provided to the lead
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| inspector no later than June 14, 2021. During the preparation activities, the team may
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| identify additional information needed to support the inspection.
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| * The last group includes the additional information above as well as plant-specific
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| reference material. This information should be available to the team onsite on June 28,
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| 2021. It is also requested that corrective action documents and answers to questions
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| developed during the inspection be provided to the lead inspector as the documents are
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| generated.
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| In addition, the enclosure includes information and requests addressing inspection logistics.
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| The lead inspector for this inspection is Elba Sanchez Santiago. We understand that our
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| licensing contact for this inspection is Sean Fahnestock of your organization. If there are any
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| questions about the inspection or the material requested in the enclosure, contact the lead
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| inspector at 630-829-9520 or via e-mail at Elba.SanchezSantiago@nrc.gov.
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| This letter does not contain new or amended information collection requirements subject to
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| the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
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| requirements were approved by the Office of Management and Budget, Control
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| Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
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| respond to, a request for information or an information collection requirement unless the
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| requesting document displays a currently valid Office of Management and Budget Control
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| Number.
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| This letter and its enclosure will be made available for public inspection and copying at
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| http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in
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| accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
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| Sincerely,
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| /RA/
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| Elba Sanchez Santiago, Senior Reactor Inspector
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| Engineering Branch 2
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| Division of Reactor Safety
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| Docket No. 50-440
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| License No. NPF-58
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| Enclosure:
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| Design Bases Assurance Inspection
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| (Programs) Document Request
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| cc: Distribution via LISTSERV
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| R. Penfield -3-
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| Letter to Rod Penfield from Elba Sanchez Santiago dated April 8, 2021.
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| SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC DESIGN BASES
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| ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR
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| INFORMATION: INSPECTION REPORT 05000440/2021012
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| DISTRIBUTION:
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| Jessie Quichocho
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| Mark Haire
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| RidsNrrPMPerry Resource
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| RidsNrrDorlLpl3
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| RidsNrrDroIrib Resource
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| John Giessner
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| Kenneth OBrien
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| Jamnes Cameron
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| Allan Barker
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| DRPIII
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| DRSIII
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| ADAMS Accession Number: ML21099A087
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| Publicly Available Non-Publicly Available Sensitive Non-Sensitive
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| OFFICE RIII
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| NAME ESanchez
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| Santiago:mb
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| via e-mail
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| DATE 04/08/2021
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| OFFICIAL RECORD COPY
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| DESIGN BASES ASSURANCE INSPECTION - POV PROGRAM
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| REQUEST FOR INFORMATION
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| I. ADMINISTRATIVE INSPECTION INFORMATION
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| Inspection Report Number: 05000440/2021012
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| Onsite Inspection Dates: June 28, 2021 - July 2, 2021 and July 12 - 16, 2021
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| IP 71111.21N, Design Bases Assurance Inspection
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| Inspection Procedure: (Programs), Attachment 2, Design-Basis Capability of
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| Power-Operated Valves Under 10 CFR 50.55a Requirements
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| Elba Sanchez Santiago, Senior Reactor Inspector, RIII/DRS
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| Lead Inspector: 630-829-9520
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| Elba.SanchezSantiago@nrc.gov
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| Robert Daley, Senior Reactor Inspector, RIII/DRS
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| Teammate Inspectors:
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| Kevin Barclay, Reactor Inspector, RIII/DRS
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| II. LOGISTICS
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| Email the following inspection logistics to the lead inspector by June 14, 2021, or sooner:
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| 1. Inspection room name/number, directions from the main access facility, and phone
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| number;
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| 2. Interview room name/number;
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| 3. Response team contact information (names and phone numbers) and team roles (e.g.,
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| management sponsor, lead, inspector counterpart);
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| 4. Any site access/badging actions needed for each inspector;
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| 5. Any dosimetry actions needed for each inspector;
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| 6. Entrance meeting time and location;
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| 7. Confirmation that the team will have access to a licensee computer with a nearby printer;
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| 8. Confirmation that the team will have Wi-Fi access;
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| 9. Cafeteria location and hours;
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| 10. Inspection response team normal working hours; and
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| 11. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff
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| meetings).
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| Enclosure
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| III. INFORMATION REQUEST
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| Contact the lead inspector as soon as possible if you have any questions regarding this
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| information request. Provide the information electronically in searchable formats, if possible.
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| The files should contain descriptive names, and be indexed and hyperlinked to facilitate
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| ease of use. Information in lists should contain enough information to be easily
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| understood by someone who has knowledge of light water reactor technology.
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| Important Note: For the purpose of this inspection, POVs are valves with power actuators.
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| Examples include motor-operated valves (MOVs), air-operated valves (AOVs),
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| hydraulic-operated valves (HOVs), solenoid-operated valves (SOVs), and
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| pyrotechnic-operated valves (e.g., squib valves).
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| 1. Information Requested for Initial Inspection Scoping Activities
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| The following information is requested by May 10, 2021, or sooner, to facilitate the initial
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| sample selection.
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| 1.1. List of systems, system numbers/designators, and corresponding system names.
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| 1.2. Probabilistic safety analysis (PSA) system notebooks and latest PSA summary
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| document. Also, identify the top ten risk significant functions per the PSA.
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| 1.3. List of POVs from your site-specific PSA sorted by Risk-Achievement Worth
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| (RAW). Include values for Birnbaum Importance, Risk-Reduction Worth, and
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| Fussell-Veseley (as applicable). The list should include (a) component
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| identification number; (b) applicable plant system; (c) ASME Boiler and Pressure
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| Vessel Code (BPV Code) Class; (d) safety-related or nonsafety-related
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| classification; (e) valve type, size, and manufacturer; and (f) actuator type, size,
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| and manufacturer. If the NRC has granted a license amendment to categorize
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| structures, systems, and component in accordance with 10 CFR 50.69, please
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| provide the Risk Informed Safety Category of the component.
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| 1.4. All corrective action documents, evaluations, and NRC correspondence, including
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| any associated NRC requests for additional information (RAIs) and Safety
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| Evaluation Report(s), generated in response to the NRC communications listed
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| below. Also, any NRC inspection reports that were conducted to close out the
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| sites associated responses.
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| 1.4.1. Generic Letter (GL) 89-10;
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| 1.4.2. GL 96-05;
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| 1.4.3. GL 95-07;
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| 1.4.4. Bulletin 85-03;
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| 1.4.5. Regulatory Issue Summary (RIS) 2000-03; and
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| 1.4.6. GL 88-14.
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| 2
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| 1.5. NRC Safety Evaluation Report(s) associated with the In-Service Testing (IST)
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| Program and relief and alternative requests submitted in accordance with
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| 10 CFR 50.55a for POVs. Identify the edition of the ASME Operation and
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| Maintenance of Nuclear Power Plants (OM Code) that is the Code of record for the
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| current 10-year IST Program interval, as well as any self-imposed standards
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| related to the IST Program elements applicable to POVs.
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| 1.6. IST Program documents, including implementing procedures, IST plan, and the
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| document that identifies the in-scope valves and the associated IST Program
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| requirements for each valve (e.g., IST valve table identifying category,
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| active/passive function).
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| 1.7. Any NRC correspondence regarding the stations POV programs other than the
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| IST Program, including any associated NRC RAIs and any NRC Safety Evaluation
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| Report(s). Identify any self-imposed standards related to these programs.
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| 1.8. Site (and corporate if applicable) procedures associated with implementation of the
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| POV programs required by 10 CFR 50.55a(b)(3)(ii) and/or ASME OM Code
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| Mandatory Appendix III.
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| 1.9. List of any valve removed from a POV program and basis for removal.
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| 1.10. List of corrective action documents related to the POV programs for the last
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| 5 years, including the document identifier and brief description. Provide a separate
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| list for each POV program.
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| 1.11. List of POVs in the Maintenance Rule (a)(1) category for the last 5 years. The list
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| should include a brief description of the surrounding circumstances.
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| 1.12. Current list of operator workarounds.
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| 1.13. List of open operability evaluations related to POVs.
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| 1.14. List of permanent plant modifications to POVs completed in the last 5 years. For
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| the purpose of this inspection, permanent plant modifications include permanent:
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| plant changes, design changes, set point changes, equivalency evaluations,
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| suitability analyses, and commercial grade dedications. The list should contain the
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| modification identifier, title, revision/date, the affected system, completion date, and
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| a brief modification description.
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| 1.15. Any self-assessment and/or audit of POV programs completed in the last 5 years.
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| 1.16. Updated Final Safety Analysis Report, Technical Specifications, Technical
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| Specifications Bases, and Technical Requirements Manual.
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| 1.17. The lead inspector will deliver forms to the licensee point of contact identified in the
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| letter for approximately 30 valves. Fill out the valve characteristics in the form
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| fields. It is possible that not all fields can be completed. For those fields that
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| cannot be filled, leave the fields blank.
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| 1.18. All emergency and abnormal operating procedures.
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| 3
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| 1.19. Current management and engineering organizational chart.
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| 2. Information Requested to Support Inspection Preparation Activities
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| The following information is requested by June 14, 2021, or sooner, to facilitate the final
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| inspection preparation.
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| 2.1. Preventive Maintenance (PM) Program document, implementing procedures, and
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| PM templates applicable to POVs.
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| 2.2. Title 10 CFR 50, Appendix J Program document and implementing procedures.
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| 2.3. Corrective Action Program procedures, including the operability/functionality
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| determination procedure.
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| 2.4. Quality Assurance Program document.
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| 2.5. Procedure for addressing issues captured in 10 CFR 21 notifications.
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| 2.6. Joint Owners Group (JOG) MOV program classification evaluation.
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| 2.7. For each selected POV, including its actuator (the response should be separated
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| by POV such as by creating a folder for each valve that includes the associated
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| documents):
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| 2.7.1. Procurement and design specifications, and Certificate of Conformance.
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| 2.7.2. Vendor documents addressing installation, operation, and maintenance.
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| 2.7.3. Piping and instrumentation drawings (PI&Ds) for the associated system.
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| 2.7.4. Electrical diagrams, including control logic diagrams.
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| 2.7.5. Valve and actuator component drawings.
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| 2.7.6. System description and/or training documents associated with the POV.
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| 2.7.7. Operations procedures that direct operators to control the valve, including
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| alarm response procedures.
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| 2.7.8. Applicable Maintenance Rule scoping document and the Maintenance
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| Rule performance criteria which would cause the system or component to
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| be moved from (a)(2) status to (a)(1) status. Also, documents (e.g.,
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| corrective action and work orders) associated with any instance the POV
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| was placed in (a)(1) status during the last 5 years.
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| 2.7.9. List of tests, including technical specification surveillances. The list
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| should identify the test periodicity and test procedure identifier.
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| 4
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| 2.7.10. Completed tests and surveillances performed during the last 5 years. For
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| those tests and surveillances performed at a periodicity of less than
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| 1 year or greater than 5 years, provide the latest three performed.
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| Include the associated acceptance criteria basis calculations.
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| 2.7.11. Completed preservice testing (PST).
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| 2.7.12. List of applicable PMs. The list should identify the PM periodicity and last
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| completion date, and briefly describe the PM.
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| 2.7.13. Completed PMs performed during the last 5 years, including any post
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| maintenance testing. For those PMs performed at a periodicity of less
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| than 1 year or greater than 5 years, provide the latest three performed.
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| 2.7.14. Corrective maintenance work orders performed on the POV during the
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| last 5 years, including any post maintenance testing.
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| 2.7.15. An all-inclusive list of calculation revisions in effect associated with the
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| POV. The list should include the document identifier, title, and revision
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| number.
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| 2.7.16. Calculations associated with the POV. Data files may be excluded.
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| Calculation examples include (as applicable):
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| * Minimum available and required voltage at transient and steady state;
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| * Thermal overload sizing evaluation;
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| * Critical setpoint calculations (e.g., limit switch settings);
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| * Required thrust/torque;
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| * Maximum allowed leakage;
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| * Maximum differential pressure;
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| * Ambient room temperature under normal and accident conditions;
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| * Environmental qualification (EQ) file;
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| * (For AOVs) Pneumatic supply sizing and setpoint calculations;
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| * System hydraulic calculations;
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| * Pressure locking/thermal binding evaluations; and
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| * Valve weak link/seismic weak link analysis.
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| 2.7.17. History of permanent modifications performed on the POV since
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| installation. Include modification identifier and brief modification
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| description.
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| 2.7.18. List of corrective action documents associated with the POV for the last
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| 5 years. The list should include the document identifier, brief description,
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| and status (e.g., open or completed).
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| 2.7.19. Open and closed operability evaluations originated during the last 5
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| years.
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| 5
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| 3. Additional Information to Be Provided Onsite
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| 3.1. During the in-office preparation activities, the team may identify additional
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| information needed to support the inspection. The lead inspector will provide a list
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| of the additional information needed during the week of June 21, 2021.
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| 3.2. Information requested to be provided throughout the inspection:
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| 3.2.1. Any corrective action documents generated as a result of the teams
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| questions during this inspection as the documents are generated.
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| 3.2.2. List of questions and/or document requests submitted by the team and
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| their status (e.g., open, closed) sorted by inspector. Provide to each
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| inspector daily 1.5 hours prior to the daily debrief. It is recommended to
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| provide the team leader with a master list sorted by inspector and each
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| inspector with a list containing only the items originated by that inspector.
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| 3.2.3. If available in hardcopy form, one complete set of P&IDs and simplified
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| drawings (e.g., training schematics). If any of these documents is not
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| available in hardcopy form, contact the lead inspector.
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| 6
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| }} | | }} |
