ML18082B323

Request for Information for an NRC Design Bases Assurance Inspection (Program): Implementation of the Environmental Qualification Program Inspection Report 05000440/2018010 (DRS-A.Dunlop)

ML18082B323
Person / Time
Site:	Perry
Issue date:	03/22/2018
From:	Dunlop A NRC/RGN-III/DRS/EB2
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
IR 2018010
Download: ML18082B323 (7)

See also: IR 05000440/2018010

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, ILLINOIS 60532-4352

March 22, 2018

Mr. David B. Hamilton

Site Vice President

FirstEnergy Nuclear Operating Company

Perry Nuclear Power Plant

Reg Affairs-A210

10 Center Road, P.O. Box 97

Perry, OH 44081-0097

SUBJECT: PERRY NUCLEAR POWER PLANTREQUEST FOR INFORMATION FOR AN

NRC DESIGN BASES ASSURANCE INSPECTION (PROGRAM):

IMPLEMENTATION OF THE ENVIRONMENTAL QUALIFICATION PROGRAM

INSPECTION REPORT 05000440/2018010

Dear Mr. Hamilton:

On June 25, 2018, the U. S. Nuclear Regulatory Commission (NRC) will begin a Triennial

Baseline Design Bases Assurance Inspection (Program) at Perry Nuclear Power Plant.

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 (EQ) Program to verify you are maintaining the qualified

status of equipment during the life of the plant. The EQ components to be reviewed during this

baseline inspection will be identified during the in-office preparation week that occurs prior to the

onsite inspection week.

The inspection will include a bagman trip to support selection of components and 2 weeks of

onsite inspection. The inspection team will consist of three NRC inspectors. The current

inspection schedule is as follows:

Bagman trip onsite week: May 30, 2018, through June 1, 2018;

Preparation week: June 18-22, 2018; and

Onsite inspection weeks: June 25-29, 2018, and July 9-13, 2018.

Experience with previous baseline design 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.

D. Hamilton

-2-

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 April 24, 2018.

Prior to the bagman trip on May 4, 2018, the lead inspector will communicate the initial

selected set of approximately 12 EQ components.

The second group of documents requested is those items needed to support the

bagman trip. This set of documents should be available to the lead inspector onsite on

May 30, 2018.

The third group of documents requested is those items needed to support our in-office

preparation activities for the selected set of 6-9 EQ components. This set of

documents should be provided to the lead inspector at the Regional Office no later

than June 14, 2018. 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

June 25, 2018. 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 Mr. Andrew Dunlop. We understand that our licensing

contact for this inspection is Mr. Anthony Kledzik of your organization. If there are any

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

lead inspector at 630-829-9726 or via e-mail at Andrew.Dunlop@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. Hamilton

-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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Andrew Dunlop, Senior Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-440

License No. NPF-58

Enclosure:

Design Bases Assurance Inspection

EQ Program Document Request

cc: Distribution via LISTSERV

D. Hamilton

-4-

Letter to David B. Hamilton from Andrew Dunlop dated March 22, 2018

SUBJECT: PERRY NUCLEAR POWER PLANTREQUEST FOR INFORMATION FOR AN

NRC DESIGN BASES ASSURANCE INSPECTION (PROGRAM):

IMPLEMENTATION OF THE ENVIRONMENTAL QUALIFICATION PROGRAM

INSPECTION REPORT 05000440/2018010

DISTRIBUTION:

Jeremy Bowen

RidsNrrPMPerry Resource

RidsNrrDorlLpl3

RidsNrrDirsIrib Resource

Steven West

Darrell Roberts

Richard Skokowski

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number ML: 18082B323

OFFICE

RIII

RIII

RIII

RIII

NAME

ADunlop:cl

DATE

03/22/18

OFFICIAL RECORD COPY

DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM DOCUMENT REQUEST

Enclosure

Inspection Report: 05000440/2018010

Bagman Dates:

May 30, 2018, through June 1, 2018

Inspection Dates:

June 25-29, 2018, and July 9-13, 2018

Inspection Procedure:

IP 71111.21N, Design Bases Assurance Inspection (Program),

Attachment 1, Environmental Qualification (EQ) under

10 CFR 50.49 Programs, Processes, and Procedures

Lead Inspector:

Andrew Dunlop, Senior Reactor Engineer, DRS

630-829-9726

Andrew.Dunlop@nrc.gov

I.

Information Requested Prior to the Onsite Information Gathering/Bagman Week

The following information is requested by April 24, 2018, or sooner, to facilitate

inspection preparation. If you have any questions regarding this information, please call

the team leader 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 250 components required to meet environmental

qualifications (EQ) from your site specific probabilistic safety analysis (PSA)

sorted by Fussell Vesely Importance.

2.

PSA listing of top 10 risk significant systems.

3.

NRC Safety Evaluation Report(s) associated with EQ.

4.

Electronic copies of Updated Final Safety Analysis Report, Technical

Specifications, and Technical Specifications Bases. Specifically identify which

Updated Final Safety Analysis Report sections address EQ (including seismic).

5.

Identify the various EQ standards (including year, edition, or revision) that the

station is committed to.

6.

Site (and corporate if applicable) procedures associated with the Title 10 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.

7.

Copy of EQ Design Basis Document, if applicable.

DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM DOCUMENT REQUEST

2

8.

Copy of any open licensing commitments related to EQ, if applicable.

9.

Equipment Qualification Master List (EQML). 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, and plant location.

10.

List of any installed equipment removed from the EQML and basis for removal.

11.

List of EQ solenoid valves that are normally continuously energized.

12.

List or drawings of plant areas that are subjected to EQ, identifying design

(limiting) temperature, both normal and accident, high energy line break,

radiation levels, etc. that the associated equipment will have to be qualified to

meet EQ. If unit has obtained a power uprate (greater than 5 percent) provide

same information pre-update (earliest available if multiple uprates).

13.

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.

14.

List of Corrective Action Documents related to the EQ program or EQ of specific

components for the last 5 years.

15.

Current management and engineering organizational chart.

II.

Information Requested (for the approximate 9-12 selected components) to be

Available by the Bagman Trip on May 30, 2018.

1.

EQ summary report for each component/subcomponent.

2.

Qualification Maintenance Requirement Sheet or equivalent.

3.

List of corrective action documents associated with each of the selected

components for the last 5 years.

4.

Photos of any component in containment or high radiation areas, if available.

III.

Information Requested (for the approximate 6-9 selected components) to be

Available by June 14, 2018, (will be reviewed by the team in the Regional office

during the week of June 18-22, 2018).

This information should be separated for each selected component, especially if

provided electronically (e.g., folder with component name that includes EQ files,

Qualification Test Reports, calculations, corrective action documents, maintenance

history, etc.).

1.

EQ file, including associated Qualification Test Reports.

2.

Vendor manual (electronic copy or availability of hard copy during inspection).

DESIGN BASES ASSURANCE INSPECTION EQ PROGRAM DOCUMENT REQUEST

3

3.

Preventive maintenance template.

4.

Last performed work order (WO) for each associated EQ preventive

maintenance.

5.

List of corrective maintenance WOs for the last 10 years. Include WO number,

date performed, and brief one line description.

6.

If repair work (e.g., a motor rewind) was performed under a purchase order,

provide copy of the purchase order.

7.

Thermal life calculation.

8.

Any self-assessments of the EQ program in the last 3 years.

IV.

Additional Information to be Provided on June 25, 2018 Onsite

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 18-22, 2018.

V.

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).

If you have questions regarding the information requested, please contact the lead inspector.