ML21099A087

Notification of NRC Design Bases Assurance Inspection (Programs) and Initial Request for Information: Inspection Report 05000440/2021012

ML21099A087
Person / Time
Site:	Perry
Issue date:	04/08/2021
From:	Santiago E NRC/RGN-III/DRS/EB2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2021012
Download: ML21099A087 (9)

See also: IR 05000440/2021012

Text

April 8, 2021

Mr. Rod Penfield

Site Vice President

Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant

10 Center Road,

Perry, OH 44081

SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC DESIGN BASES

ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR

INFORMATION: INSPECTION REPORT 05000440/2021012

Dear Mr. Penfield:

On June 28, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline Design

Bases Assurance Inspection (Programs) at Fermi Power Plant, Unit 2. This inspection will be

performed in accordance with NRC Baseline Inspection Procedure 71111.21N, Design Bases

Assurance Inspection (Programs), Attachment 2, Design-Basis Capability of Power-Operated

Valves Under 10 CFR 50.55a Requirements.

This inspection will evaluate the reliability, functional capability, and design basis of

risk-important power-operated valves (POVs) as required by 10 CFR 50.55a and applicable

10 CFR Part 50, Appendix A and Appendix B, requirements. In conducting this inspection, the

team will select risk-important POVs used to prevent and mitigate the consequences of a design

basis accident.

The inspection will include two weeks of onsite inspection. The inspection team will consist of

three NRC inspectors. The current inspection schedule is as follows:

Preparation week: June 21 - 25, 2021

Onsite weeks: June 28, 2021 - July 2, 2021, and July 12 - 16, 2021

Experience with previous baseline engineering 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 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 May 10, 2021.

By May 14, 2021, the lead inspector will communicate the initial selected

R. Penfield

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samples and any additional information needed to support the in-office preparation

activities.

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 no later than June 14, 2021. During the 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 June 28,

2021. It is also requested that corrective action documents and answers to questions

developed during the inspection be provided to the lead inspector as the documents are

generated.

In addition, the enclosure includes information and requests addressing inspection logistics.

The lead inspector for this inspection is Elba Sanchez Santiago. We understand that our

licensing contact for this inspection is Sean Fahnestock of your organization. If there are any

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

inspector at 630-829-9520 or via e-mail at Elba.SanchezSantiago@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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Elba Sanchez Santiago, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-440

License No. NPF-58

Enclosure:

Design Bases Assurance Inspection

(Programs) Document Request

cc: Distribution via LISTSERV

R. Penfield

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Letter to Rod Penfield from Elba Sanchez Santiago dated April 8, 2021.

SUBJECT: PERRY NUCLEAR POWER PLANT - NOTIFICATION OF NRC DESIGN BASES

ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR

INFORMATION: INSPECTION REPORT 05000440/2021012

DISTRIBUTION:

Jessie Quichocho

Mark Haire

RidsNrrPMPerry Resource

RidsNrrDorlLpl3

RidsNrrDroIrib Resource

John Giessner

Kenneth OBrien

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML21099A087

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

OFFICE

RIII

NAME

ESanchez

Santiago:mb

via e-mail

DATE

04/08/2021

OFFICIAL RECORD COPY

Enclosure

DESIGN BASES ASSURANCE INSPECTION - POV PROGRAM

REQUEST FOR INFORMATION

I.

ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number:

05000440/2021012

Onsite Inspection Dates:

June 28, 2021 - July 2, 2021 and July 12 - 16, 2021

Inspection Procedure:

IP 71111.21N, Design Bases Assurance Inspection

(Programs), Attachment 2, Design-Basis Capability of

Power-Operated Valves Under 10 CFR 50.55a Requirements

Lead Inspector:

Elba Sanchez Santiago, Senior Reactor Inspector, RIII/DRS

630-829-9520

Elba.SanchezSantiago@nrc.gov

Teammate Inspectors:

Robert Daley, Senior Reactor Inspector, RIII/DRS

Kevin Barclay, Reactor Inspector, RIII/DRS

II. LOGISTICS

Email the following inspection logistics to the lead inspector by June 14, 2021, 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; and

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

meetings).

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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 searchable formats, if possible.

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.

Important Note: For the purpose of this inspection, POVs are valves with power actuators.

Examples include motor-operated valves (MOVs), air-operated valves (AOVs),

hydraulic-operated valves (HOVs), solenoid-operated valves (SOVs), and

pyrotechnic-operated valves (e.g., squib valves).

1. Information Requested for Initial Inspection Scoping Activities

The following information is requested by May 10, 2021, or sooner, to facilitate the initial

sample selection.

1.1. List of systems, system numbers/designators, and corresponding system names.

1.2. Probabilistic safety analysis (PSA) system notebooks and latest PSA summary

document. Also, identify the top ten risk significant functions per the PSA.

1.3. List of POVs from your site-specific PSA sorted by Risk-Achievement Worth

(RAW). Include values for Birnbaum Importance, Risk-Reduction Worth, and

Fussell-Veseley (as applicable). The list should include (a) component

identification number; (b) applicable plant system; (c) ASME Boiler and Pressure

Vessel Code (BPV Code) Class; (d) safety-related or nonsafety-related

classification; (e) valve type, size, and manufacturer; and (f) actuator type, size,

and manufacturer. If the NRC has granted a license amendment to categorize

structures, systems, and component in accordance with 10 CFR 50.69, please

provide the Risk Informed Safety Category of the component.

1.4. All corrective action documents, evaluations, and NRC correspondence, including

any associated NRC requests for additional information (RAIs) and Safety

Evaluation Report(s), generated in response to the NRC communications listed

below. Also, any NRC inspection reports that were conducted to close out the

sites associated responses.

1.4.1. Generic Letter (GL) 89-10;

1.4.2. GL 96-05;

1.4.3. GL 95-07;

1.4.4.Bulletin 85-03;

1.4.5. Regulatory Issue Summary (RIS) 2000-03; and

1.4.6. GL 88-14.

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1.5. NRC Safety Evaluation Report(s) associated with the In-Service Testing (IST)

Program and relief and alternative requests submitted in accordance with

10 CFR 50.55a for POVs. Identify the edition of the ASME Operation and

Maintenance of Nuclear Power Plants (OM Code) that is the Code of record for the

current 10-year IST Program interval, as well as any self-imposed standards

related to the IST Program elements applicable to POVs.

1.6. IST Program documents, including implementing procedures, IST plan, and the

document that identifies the in-scope valves and the associated IST Program

requirements for each valve (e.g., IST valve table identifying category,

active/passive function).

1.7. Any NRC correspondence regarding the stations POV programs other than the

IST Program, including any associated NRC RAIs and any NRC Safety Evaluation

Report(s). Identify any self-imposed standards related to these programs.

1.8. Site (and corporate if applicable) procedures associated with implementation of the

POV programs required by 10 CFR 50.55a(b)(3)(ii) and/or ASME OM Code

Mandatory Appendix III.

1.9. List of any valve removed from a POV program and basis for removal.

1.10. List of corrective action documents related to the POV programs for the last

5 years, including the document identifier and brief description. Provide a separate

list for each POV program.

1.11. List of POVs in the Maintenance Rule (a)(1) category for the last 5 years. The list

should include a brief description of the surrounding circumstances.

1.12. Current list of operator workarounds.

1.13. List of open operability evaluations related to POVs.

1.14. List of permanent plant modifications to POVs completed in the last 5 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

modification identifier, title, revision/date, the affected system, completion date, and

a brief modification description.

1.15. Any self-assessment and/or audit of POV programs completed in the last 5 years.

1.16. Updated Final Safety Analysis Report, Technical Specifications, Technical

Specifications Bases, and Technical Requirements Manual.

1.17. The lead inspector will deliver forms to the licensee point of contact identified in the

letter for approximately 30 valves. Fill out the valve characteristics in the form

fields. It is possible that not all fields can be completed. For those fields that

cannot be filled, leave the fields blank.

1.18. All emergency and abnormal operating procedures.

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1.19. Current management and engineering organizational chart.

2. Information Requested to Support Inspection Preparation Activities

The following information is requested by June 14, 2021, or sooner, to facilitate the final

inspection preparation.

2.1. Preventive Maintenance (PM) Program document, implementing procedures, and

PM templates applicable to POVs.

2.2. Title 10 CFR 50, Appendix J Program document and implementing procedures.

2.3. Corrective Action Program procedures, including the operability/functionality

determination procedure.

2.4. Quality Assurance Program document.

2.5. Procedure for addressing issues captured in 10 CFR 21 notifications.

2.6. Joint Owners Group (JOG) MOV program classification evaluation.

2.7. For each selected POV, including its actuator (the response should be separated

by POV such as by creating a folder for each valve that includes the associated

documents):

2.7.1.

Procurement and design specifications, and Certificate of Conformance.

2.7.2.

Vendor documents addressing installation, operation, and maintenance.

2.7.3.

Piping and instrumentation drawings (PI&Ds) for the associated system.

2.7.4.

Electrical diagrams, including control logic diagrams.

2.7.5.

Valve and actuator component drawings.

2.7.6.

System description and/or training documents associated with the POV.

2.7.7.

Operations procedures that direct operators to control the valve, including

alarm response procedures.

2.7.8.

Applicable Maintenance Rule scoping document and the Maintenance

Rule performance criteria which would cause the system or component to

be moved from (a)(2) status to (a)(1) status. Also, documents (e.g.,

corrective action and work orders) associated with any instance the POV

was placed in (a)(1) status during the last 5 years.

2.7.9.

List of tests, including technical specification surveillances. The list

should identify the test periodicity and test procedure identifier.

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2.7.10. Completed tests and surveillances performed during the last 5 years. For

those tests and surveillances performed at a periodicity of less than

1 year or greater than 5 years, provide the latest three performed.

Include the associated acceptance criteria basis calculations.

2.7.11. Completed preservice testing (PST).

2.7.12. List of applicable PMs. The list should identify the PM periodicity and last

completion date, and briefly describe the PM.

2.7.13. Completed PMs performed during the last 5 years, including any post

maintenance testing. For those PMs performed at a periodicity of less

than 1 year or greater than 5 years, provide the latest three performed.

2.7.14. Corrective maintenance work orders performed on the POV during the

last 5 years, including any post maintenance testing.

2.7.15. An all-inclusive list of calculation revisions in effect associated with the

POV. The list should include the document identifier, title, and revision

number.

2.7.16. Calculations associated with the POV. Data files may be excluded.

Calculation examples include (as applicable):

Minimum available and required voltage at transient and steady state;

Thermal overload sizing evaluation;

Critical setpoint calculations (e.g., limit switch settings);

Required thrust/torque;

Maximum allowed leakage;

Maximum differential pressure;

Ambient room temperature under normal and accident conditions;

Environmental qualification (EQ) file;

(For AOVs) Pneumatic supply sizing and setpoint calculations;

System hydraulic calculations;

Pressure locking/thermal binding evaluations; and

Valve weak link/seismic weak link analysis.

2.7.17. History of permanent modifications performed on the POV since

installation. Include modification identifier and brief modification

description.

2.7.18. List of corrective action documents associated with the POV for the last

5 years. The list should include the document identifier, brief description,

and status (e.g., open or completed).

2.7.19. Open and closed operability evaluations originated during the last 5

years.

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3. Additional Information to Be Provided Onsite

3.1. 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 June 21, 2021.

3.2. Information requested to be provided throughout the inspection:

3.2.1.

Any corrective action documents generated as a result of the teams

questions during this inspection as the documents are generated.

3.2.2.

List of questions and/or document requests submitted by the team and

their status (e.g., open, closed) sorted by inspector. Provide to each

inspector daily 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> prior to the daily debrief. 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.

3.2.3.

If available in hardcopy form, one complete set of P&IDs and simplified

drawings (e.g., training schematics). If any of these documents is not

available in hardcopy form, contact the lead inspector.