ML19290E548

Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000331/2020010

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:

Jessie Quichocho

RidsNrrDorlLpl3

RidsNrrPMDuaneArnold Resource

RidsNrrDirsIrib Resource

Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

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

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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

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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

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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.