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{{#Wiki_filter:1/22/07               COMPONENT DESIGN BASES INSPECTION (CDBI)
{{#Wiki_filter:1/22/07
                                          INSPECTION PLAN
COMPONENT DESIGN BASES INSPECTION (CDBI)
                                  KEWAUNEE POWER STATION
INSPECTION PLAN
                (INSPECTION REPORT NUMBER 05000305/2007006(DRS) )
KEWAUNEE POWER STATION  
(INSPECTION REPORT NUMBER 05000305/2007006(DRS) )
Inspection Objectives
Inspection Objectives
This inspection fulfills the baseline inspection program requirements for biennial Inspection
This inspection fulfills the baseline inspection program requirements for biennial Inspection
Procedure (IP) 71111.21. The inspections objective is to verify that design bases have been
Procedure (IP) 71111.21. The inspections objective is to verify that design bases have been
correctly implemented for the selected risk significant components and that operating
correctly implemented for the selected risk significant components and that operating
procedures and operator actions are consistent with design and licensing bases. This is to
procedures and operator actions are consistent with design and licensing bases. This is to
ensure that selected components are capable of performing their intended safety functions.
ensure that selected components are capable of performing their intended safety functions.
This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity
This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity
cornerstones for which there are no indicators to measure performance.
cornerstones for which there are no indicators to measure performance.
Inspection Dates:       January 29, 2007, through March 2, 2007
Inspection Dates:
Exit:                   March 2, 2007
January 29, 2007, through March 2, 2007
Exit:
March 2, 2007
Applicable Inspection Procedures
Applicable Inspection Procedures
IP 71111.21   "Component Design Bases Inspection , dated June 22, 2006
IP 71111.21
IP 71152       Identification and Resolution of Problems (reference)
"Component Design Bases Inspection , dated June 22, 2006
              Prepared By:          /RA/                                 01/18/2007
IP 71152
                                Lead Inspector                             Date
Identification and Resolution of Problems (reference)
                                Zelig Falevits
Prepared By:          /RA/                  
              Approved By:             /RA/                               01/18/2007
01/18/2007
                                DRS Branch Chief                           Date
Lead Inspector
                                Ann Marie Stone
Date
              Reviewed By:         /RA/                                   01/18/2007
Zelig Falevits
                                DRP Branch Chief                           Date
Approved By:           /RA/                
                                Pat Louden
01/18/2007
DRS Branch Chief
Date
Ann Marie Stone
Reviewed By:       /RA/                    
01/18/2007
DRP Branch Chief
Date
Pat Louden


                              INSPECTION PLAN DETAILS
-2-
I. INSPECTION TEAM:
INSPECTION PLAN DETAILS
    Z. Falevits, Senior Engineering Inspector, Lead, x9717, zxf
I.
    C. Brown, Senior Engineering Inspector, x9605, ceb1
INSPECTION TEAM:
    R. Langstaff, Senior Engineering Inspector, x9747, ral4
Z. Falevits, Senior Engineering Inspector, Lead, x9717, zxf
    A. Dahbur, Engineering Inspector, x9810, akd
C. Brown, Senior Engineering Inspector, x9605, ceb1
    S. Burgess, Senior Reactor Analyst, x9752, sdb2
R. Langstaff, Senior Engineering Inspector, x9747, ral4
    M. Yeminy, Mechanical Consultant, 305-238-4732
A. Dahbur, Engineering Inspector, x9810, akd
    G. Skinner, Electrical Consultant, 412-963-9889
S. Burgess, Senior Reactor Analyst, x9752, sdb2
    F. Tran, Engineering Inspector, Observer, x9623, fpt
M. Yeminy, Mechanical Consultant, 305-238-4732
II Detailed Inspection Schedule
G. Skinner, Electrical Consultant, 412-963-9889
    Lead Inspector Preparation: January 8, 2007
F. Tran, Engineering Inspector, Observer, x9623, fpt
    Prep. at Region III Offices:   January 22-26, 2007
II
    Inspection Onsite Weeks:     January 29 to February 2, 2007
Detailed Inspection Schedule
                                  February 12-16, 2007
Lead Inspector Preparation: January 8, 2007
                                  February 26 to March 2, 2007
Prep. at Region III Offices:  
    In-office Weeks:             February 5 to 9, 2007
January 22-26, 2007
                                  February 19 to 23, 2007
Inspection Onsite Weeks:
    Entrance Meeting:             January 30 at 9:00 a.m.
January 29 to February 2, 2007
    Exit Meeting:                 March 2, at 9:00 a.m.
February 12-16, 2007
    Preparation of Inspection Report:
February 26 to March 2, 2007
    *       Inputs Due: March 9, 2007 COB
In-office Weeks:
    *       Draft Completed: March 30, 2007
February 5 to 9, 2007
    *       Management Review and Approval Completed (target): April 6, 2007
February 19 to 23, 2007
    Inspection Report Must Be Issued Before April 16, 2007
Entrance Meeting:
III Lead Inspector Preparation Activities
January 30 at 9:00 a.m.
    Review licensee material received based on information request letter, Review PRA
Exit Meeting:
    information with the SRAs, select 30 high risk components, and provide the team a copy
March 2, at 9:00 a.m.
    of the inspection plan.
Preparation of Inspection Report:
    Information Requests
*
                                            -2-
Inputs Due: March 9, 2007 COB
*
Draft Completed: March 30, 2007  
*
Management Review and Approval Completed (target): April 6, 2007  
Inspection Report Must Be Issued Before April 16, 2007
III
Lead Inspector Preparation Activities
Review licensee material received based on information request letter, Review PRA
information with the SRAs, select 30 high risk components, and provide the team a copy
of the inspection plan.
Information Requests


  As part of the inspection preparation, the lead inspector contacted the licensee,
-3-
  informed them of the scope of the inspection, and requested that the necessary
As part of the inspection preparation, the lead inspector contacted the licensee,
  information be provided to the inspection team. The information request letter was sent
informed them of the scope of the inspection, and requested that the necessary
  to the license on November 6, 2006.
information be provided to the inspection team. The information request letter was sent
  Distribution of Collected Information
to the license on November 6, 2006.
  On Monday, January 22, 2007, or sooner, the lead inspector will distribute information
Distribution of Collected Information
  provided by the licensee, for the 30 components selected by the SRA and the lead
On Monday, January 22, 2007, or sooner, the lead inspector will distribute information
  inspector. The majority of the information will be provided electronically. This
provided by the licensee, for the 30 components selected by the SRA and the lead
  information will be reviewed by the team members in order to reduce the selected items
inspector. The majority of the information will be provided electronically. This
  to about 15-20 high risk/low margin (HR/LM) components and to divide up the
information will be reviewed by the team members in order to reduce the selected items
  components to be reviewed by the team during the onsite inspection weeks. In addition,
to about 15-20 high risk/low margin (HR/LM) components and to divide up the
  other items required by the procedure will be selected.
components to be reviewed by the team during the onsite inspection weeks. In addition,
IV Team Preparation Activities
other items required by the procedure will be selected.
  In-office Prep Week to select final 15-20 components and other items based on high
IV
  risk significance and the least available margin. (January 22-26, 2007)
Team Preparation Activities
  We will have a team meeting on Monday, January 22nd, at 2:00 pm to discuss inspection
In-office Prep Week to select final 15-20 components and other items based on high
  logistics and plan. Team members will use this preparation week to review the design
risk significance and the least available margin. (January 22-26, 2007)
  related material the licensee provided for the 30 selected components to determine low
We will have a team meeting on Monday, January 22nd, at 2:00 pm to discuss inspection
  margin components and to narrow the selection to the final 15-20 HR/LM components to
logistics and plan. Team members will use this preparation week to review the design
  be inspected during the onsite inspection weeks. In addition, HR/LM operator actions,
related material the licensee provided for the 30 selected components to determine low
  operating experience, and related modifications and condition reports will be selected
margin components and to narrow the selection to the final 15-20 HR/LM components to
  during this week. The specific team assignments will be determined during this
be inspected during the onsite inspection weeks. In addition, HR/LM operator actions,
  preparation week. A second team meeting will be held on Thursday, January 25, at
operating experience, and related modifications and condition reports will be selected
  10:00 am to discuss specific team assignments, final selection of (15-20) components
during this week. The specific team assignments will be determined during this
  and other inspection items. In addition, the lead inspector will combine the list of
preparation week. A second team meeting will be held on Thursday, January 25, at
  additional team member requested information to be submitted to the licensee so that
10:00 am to discuss specific team assignments, final selection of (15-20) components
  the information will be ready for review during the first onsite inspection week.
and other inspection items. In addition, the lead inspector will combine the list of
  The inspectors should review the latest revised inspection procedure to familiarize
additional team member requested information to be submitted to the licensee so that
  themselves with the process for selection of components, operator actions, and
the information will be ready for review during the first onsite inspection week.  
  operating experience; and conduct of the inspection. Latest completed CDBI inspection
The inspectors should review the latest revised inspection procedure to familiarize
  reports, should be reviewed. In particular, review the following RIII issued CDBI
themselves with the process for selection of components, operator actions, and
  inspection reports: Quad Cities 254/265/2006003(DRS) and Duane Arnold IR #
operating experience; and conduct of the inspection. Latest completed CDBI inspection
  331/2006007(DRS) (Follow latest report format to write your input; including the list of
reports, should be reviewed. In particular, review the following RIII issued CDBI
  documents). Also, please review the Kewaunee CDBI pilot IR #305/2005002(DRS) for
inspection reports: Quad Cities 254/265/2006003(DRS) and Duane Arnold IR #
  attributes and components inspected and be mind full of what was looked at during the
331/2006007(DRS) (Follow latest report format to write your input; including the list of
  pilot inspection to ensure that we do not review the same attributes/documents during
documents). Also, please review the Kewaunee CDBI pilot IR #305/2005002(DRS) for
  this inspection, as much as possible. Also, the inspection procedure and the Matrix
attributes and components inspected and be mind full of what was looked at during the
  provided by the lead inspector identifies a number of component design review
pilot inspection to ensure that we do not review the same attributes/documents during
  attributes and considerations that can be used in support of the inspection to verify
this inspection, as much as possible. Also, the inspection procedure and the Matrix
  certain system or component attributes. Since most of the material may be electronic,
provided by the lead inspector identifies a number of component design review
  inspectors should bring a laptop computer to the site for their use in preparation for the
attributes and considerations that can be used in support of the inspection to verify
                                            -3-
certain system or component attributes. Since most of the material may be electronic,
inspectors should bring a laptop computer to the site for their use in preparation for the


inspection. Also, if possible, bring a memory stick for efficient information transfer of
-4-
inspection. Also, if possible, bring a memory stick for efficient information transfer of
findings and exit notes between team members and the lead inspector.
findings and exit notes between team members and the lead inspector.
A component inspection Matrix will be developed to identify component attributes to be
A component inspection Matrix will be developed to identify component attributes to be
inspected and team member assignments.
inspected and team member assignments.  
Component Selection
Component Selection
The sample selection of 15-20 components should be based on risk significance and the
The sample selection of 15-20 components should be based on risk significance and the
least available margin. The team will initially select more than the minimum required to
least available margin. The team will initially select more than the minimum required to
ensure the minimum number of samples are met. If it is determined that either the team
ensure the minimum number of samples are met. If it is determined that either the team
does not have the time or resources to complete all of the selected components, they
does not have the time or resources to complete all of the selected components, they
will not be included as part of the number of completed samples. Design margin is
will not be included as part of the number of completed samples. Design margin is
typically defined as the difference between the actual (or predicted) and required
typically defined as the difference between the actual (or predicted) and required
performance of a system, component, or operator action (see IP for more details). The
performance of a system, component, or operator action (see IP for more details). The
procedure states that the following attributes should be considered in evaluating
procedure states that the following attributes should be considered in evaluating
component margin, analytical (design) margin, operations margin, maintenance margin
component margin, analytical (design) margin, operations margin, maintenance margin
and complexity margin. Margin includes, corrective action insights, maintenance
and complexity margin.   Margin includes, corrective action insights, maintenance
history, design changes, complex design schemes, and maintenance rule insights.
history, design changes, complex design schemes, and maintenance rule insights.  
Low margin can be a function of the original design, caused by design modifications,
Low margin can be a function of the original design, caused by design modifications,
power uprates, or can be due to degraded material conditions. Inspection samples
power uprates, or can be due to degraded material conditions. Inspection samples
(safety or non-safety risk significant components) should be identified at the major
(safety or non-safety risk significant components) should be identified at the major
component (e.g. pump, motor operated valve, batteries, etc.) or procedural step level to
component (e.g. pump, motor operated valve, batteries, etc.) or procedural step level to
assist in inspection planning. Included within the sample selected should be passive
assist in inspection planning. Included within the sample selected should be passive
components such as sump screens, strainers, piping, cables, etc., whose failure could
components such as sump screens, strainers, piping, cables, etc., whose failure could
impact system functionality, component design function that involves a lot of operation
impact system functionality, component design function that involves a lot of operation
and human actions, availability/reliability issues, and components design attributes
and human actions, availability/reliability issues, and components design attributes
which are not fully demonstrated through testing. To the extent practical, the sample
which are not fully demonstrated through testing. To the extent practical, the sample
should include a diverse range of equipment. The team in their selection of samples
should include a diverse range of equipment. The team in their selection of samples
should attempt to limit the number of systems involved (i.e. select pump, valve, strainer,
should attempt to limit the number of systems involved (i.e. select pump, valve, strainer,
etc, in same system, if possible), which will limit the amount of preparation time required
etc, in same system, if possible), which will limit the amount of preparation time required
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inspection.
inspection.
In order to identify low margin areas, the inspectors should review detailed calculations
In order to identify low margin areas, the inspectors should review detailed calculations
associated with the identified risk-significant components to identify areas of low margin.
associated with the identified risk-significant components to identify areas of low margin.  
In this case, the inspector should identify calculations showing little margin between
In this case, the inspector should identify calculations showing little margin between
predicted results and calculation and/or regulatory acceptance criteria.
predicted results and calculation and/or regulatory acceptance criteria.  
In addition, the margin review should include corrective action program insights and
In addition, the margin review should include corrective action program insights and
repetitive maintenance summaries associated with the identified risk-significant
repetitive maintenance summaries associated with the identified risk-significant
components as poor performing components may be indicative of inadequate design.
components as poor performing components may be indicative of inadequate design.  
Component review should also include evaluation of the impact of plant modifications or
Component review should also include evaluation of the impact of plant modifications or
licensing basis changes on available margin. In particular, licensing changes that can
licensing basis changes on available margin. In particular, licensing changes that can
reduce safety analysis margins, such as extended power uprates, should be considered.
reduce safety analysis margins, such as extended power uprates, should be considered.
                                          -4-


-5-
The SRA and SRI will participate and provide information to be used for selecting the
The SRA and SRI will participate and provide information to be used for selecting the
samples for review.
samples for review.
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The operations inspector should review the list of risk significant operator actions
The operations inspector should review the list of risk significant operator actions
provided by the licensee, and with insights provided by the SRA the resident inspector,
provided by the licensee, and with insights provided by the SRA the resident inspector,
and the team leader select 3-5 for review during the inspection. A review of operating
and the team leader select 3-5 for review during the inspection. A review of operating
procedures, and operator task analysis validation studies should be performed to
procedures, and operator task analysis validation studies should be performed to
identify critical operator actions with little margin between the time required and the time
identify critical operator actions with little margin between the time required and the time
available to complete an action. Based on the operator actions selected, the inspector
available to complete an action. Based on the operator actions selected, the inspector
should request from the licensee the procedures necessary to conduct the operations.
should request from the licensee the procedures necessary to conduct the operations.
Select high risk operator actions that have no job performance measure (JPM).
Select high risk operator actions that have no job performance measure (JPM).  
Operating Experience Selection
Operating Experience Selection
Based on the components selected, the regional inspectors will review the list of
Based on the components selected, the regional inspectors will review the list of
operating experience provided by the licensee and identify selected operating
operating experience provided by the licensee and identify selected operating
experience issues, either component specific, common cause, or generic issues that the
experience issues, either component specific, common cause, or generic issues that the
team may want to evaluate. Other operating experience that the inspectors are aware
team may want to evaluate. Other operating experience that the inspectors are aware
of that may be relevant to the components selected can also be selected for review. In
of that may be relevant to the components selected can also be selected for review. In
addition, the team should identify for review one or two generic or common cause issues
addition, the team should identify for review one or two generic or common cause issues
that are not related to the selected samples. Some of the operating experience selected
that are not related to the selected samples. Some of the operating experience selected
should cover initiating events and barrier integrity cornerstones. Based on those issues
should cover initiating events and barrier integrity cornerstones. Based on those issues
identified, the team will narrow down the samples to 4-6, which will be divided between
identified, the team will narrow down the samples to 4-6, which will be divided between
team members, as appropriate.
team members, as appropriate.  
Additional Prep Activities
Additional Prep Activities
Once it is determined which components, operator actions, and operating experience
Once it is determined which components, operator actions, and operating experience
samples will be reviewed, they will be assigned to individual inspectors. Once this
samples will be reviewed, they will be assigned to individual inspectors. Once this
designation has been accomplished, the inspectors should obtain sufficient familiarity
designation has been accomplished, the inspectors should obtain sufficient familiarity
with the chosen components, operator actions, and operating experience samples and
with the chosen components, operator actions, and operating experience samples and
their associated systems to understand the design and safety requirement for the
their associated systems to understand the design and safety requirement for the
samples selected and their associated system. The inspectors should also review the
samples selected and their associated system. The inspectors should also review the
flow paths (mechanical) and control logic circuitry (electrical) for the selected
flow paths (mechanical) and control logic circuitry (electrical) for the selected
components to verify if other components in those flow paths or control logic could
components to verify if other components in those flow paths or control logic could
potentially affect their function. For each component or inspection area assigned, the
potentially affect their function. For each component or inspection area assigned, the
inspector needs to develop a list of attributes (see IP 71111.21, section 02.02, Appendix
inspector needs to develop a list of attributes (see IP 71111.21, section 02.02, Appendix
1 and Appendix 2 for examples) that will be reviewed during the inspection. The
1 and Appendix 2 for examples) that will be reviewed during the inspection. The
inspectors review should also identify potential areas where the interface between
inspectors review should also identify potential areas where the interface between
engineering and operations procedures can be reviewed by the operations inspector to
engineering and operations procedures can be reviewed by the operations inspector to
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components to determine whether any are either complex, reduced margin, required for
components to determine whether any are either complex, reduced margin, required for
power uprate, etc., such that the modification should be considered for review during the
power uprate, etc., such that the modification should be considered for review during the
inspection. Although the inspection procedure does not identify a specific number of
inspection. Although the inspection procedure does not identify a specific number of
                                            -5-


  modifications that need to be reviewed, the team will select approximately 4-6
-6-
  modifications for review (one per inspector). These modifications will be selected by the
modifications that need to be reviewed, the team will select approximately 4-6
  team from those identified by individual team members. Note that a modification/50.59
modifications for review (one per inspector). These modifications will be selected by the
  inspection was performed by the NRC in November 2006 which looked at modifications
team from those identified by individual team members. Note that a modification/50.59
  completed in the last 2 years. Make sure we do not select the same modifications for
inspection was performed by the NRC in November 2006 which looked at modifications
  review during this inspection.
completed in the last 2 years. Make sure we do not select the same modifications for
  Requests for Additional Information
review during this inspection.
  During the course of the inspection, team members should request their licensee
Requests for Additional Information
  contact to provide any specific information and/or documents they want to have readily
During the course of the inspection, team members should request their licensee
  available when they return to the site. This might include any specific modification
contact to provide any specific information and/or documents they want to have readily
  packages, calculations, drawings, condition reports, procedures, and scheduling
available when they return to the site. This might include any specific modification
  interviews or walkdowns, etc. Licensee computers may be available in the conference
packages, calculations, drawings, condition reports, procedures, and scheduling
  room with access to mainly calculations, condition reports and procedures.
interviews or walkdowns, etc. Licensee computers may be available in the conference
V Onsite Inspection Activities
room with access to mainly calculations, condition reports and procedures.
  Plant Walkdowns
V
  The inspectors are expected to walkdown their assigned components and their
Onsite Inspection Activities
  associated systems by discipline groups (electrical, mechanical, operations). The intent
Plant Walkdowns
  of the component/system walkdowns is for the inspectors to obtain basic familiarity with
The inspectors are expected to walkdown their assigned components and their
  the systems, material condition of equipment, where components are located, etc. in
associated systems by discipline groups (electrical, mechanical, operations). The intent
  order to accomplish inspection objectives. During the walkdowns, the inspectors are
of the component/system walkdowns is for the inspectors to obtain basic familiarity with
  also asked to be aware of general plant material conditions. Any abnormal or
the systems, material condition of equipment, where components are located, etc. in
  questionable conditions should be brought to the lead inspector to discuss with the
order to accomplish inspection objectives. During the walkdowns, the inspectors are
  resident staff and the licensee.
also asked to be aware of general plant material conditions. Any abnormal or
  Inspection
questionable conditions should be brought to the lead inspector to discuss with the
  Successful completion of the CDBI inspection procedure requires a full understanding of
resident staff and the licensee.
  how the components and their associated system operates, and is supposed to operate.
Inspection
  Inspection of some broad-based attributes, such as those described in the inspection
Successful completion of the CDBI inspection procedure requires a full understanding of
  procedure, cannot be accomplished by a single inspector working independently of the
how the components and their associated system operates, and is supposed to operate.  
  rest of the team. However, to avoid duplication of work, each individual will be assigned
Inspection of some broad-based attributes, such as those described in the inspection
  primary responsibility for the attributes being inspected. For example, if a mechanical
procedure, cannot be accomplished by a single inspector working independently of the
  inspector is assigned to review a motor-operated valve, they may need an electrical
rest of the team.   However, to avoid duplication of work, each individual will be assigned
  inspector to review the degraded voltage calculation. The team lead will facilitate these
primary responsibility for the attributes being inspected. For example, if a mechanical
  types of reviews and will attempt to assign them at the start of the inspection to equalize
inspector is assigned to review a motor-operated valve, they may need an electrical
  the work load between inspectors.
inspector to review the degraded voltage calculation. The team lead will facilitate these
  Inspectors should plan their workload so that all major areas are preliminarily reviewed
types of reviews and will attempt to assign them at the start of the inspection to equalize
  prior to the end of the first two onsite weeks of the inspection. Most of the last onsite
the work load between inspectors.
  week should primarily be spent reviewing responses to questions previously asked,
Inspectors should plan their workload so that all major areas are preliminarily reviewed
  resolving issues, and developing any findings. This does not mean that new inspection
prior to the end of the first two onsite weeks of the inspection. Most of the last onsite
  can't be done; just that doing so leaves little time to develop issues before the end of the
week should primarily be spent reviewing responses to questions previously asked,
  inspection.
resolving issues, and developing any findings. This does not mean that new inspection
                                            -6-
can't be done; just that doing so leaves little time to develop issues before the end of the
inspection.


  Inspection Objectives (IP 71111.21, Sections 02.02a thru e)
-7-
  For the inspection attributes and inspection activities identified during the prep week,
Inspection Objectives (IP 71111.21, Sections 02.02a thru e)
  conduct a detailed design review of the selected components calculations,
For the inspection attributes and inspection activities identified during the prep week,
  surveillances, and other associated system documentation to confirm each of the
conduct a detailed design review of the selected components calculations,
  specified attributes for your assigned areas (02.02a). Perform plant walkdowns of
surveillances, and other associated system documentation to confirm each of the
  selected components to verify as-built condition is consistent to design requirements
specified attributes for your assigned areas (02.02a). Perform plant walkdowns of
  and inspect component for material condition; and review components corrective action
selected components to verify as-built condition is consistent to design requirements
  and maintenance history that could affect the components to function (02.02b). The
and inspect component for material condition; and review components corrective action
  operations inspector should verify performance of risk significant operator actions, along
and maintenance history that could affect the components to function (02.02b). The
  with a walk-through of a sample operations procedures for the selected components
operations inspector should verify performance of risk significant operator actions, along
  (02.02c). Review permanent plant modifications to ensure design bases, licensing
with a walk-through of a sample operations procedures for the selected components
  bases, and performance capability have not been degraded (02.02d). Review the
(02.02c). Review permanent plant modifications to ensure design bases, licensing
  licensees evaluation and disposition of selected operating experience to ensure it has
bases, and performance capability have not been degraded (02.02d). Review the
  been adequately addressed (02.02e).
licensees evaluation and disposition of selected operating experience to ensure it has
  Identification and Resolution of Problems
been adequately addressed (02.02e).  
  Identifying Design Issues - threshold and corrective action program.
Identification and Resolution of Problems
  Sample of Problems - verify appropriateness of corrective actions.
Identifying Design Issues - threshold and corrective action program.
  In-office Inspection
Sample of Problems - verify appropriateness of corrective actions.
  Inspectors should be aware of the direct inspection hour limits for this inspection. The
In-office Inspection
  number of hours used during the in-office weeks should be carefully monitored as to not
Inspectors should be aware of the direct inspection hour limits for this inspection. The
  exceed the total hours allotted for this inspection. The lead inspector will track both the
number of hours used during the in-office weeks should be carefully monitored as to not
  preparation and direct inspection hours used for each inspector, including contractors.
exceed the total hours allotted for this inspection. The lead inspector will track both the
  This information should be provided to the lead inspector every Monday, on a weekly
preparation and direct inspection hours used for each inspector, including contractors.  
  basis, via e-mail. If significant issues arise that require use of more hours, the lead
This information should be provided to the lead inspector every Monday, on a weekly
  inspector and branch chief should be informed prior to expending the resources.
basis, via e-mail. If significant issues arise that require use of more hours, the lead
VI Issues and Findings
inspector and branch chief should be informed prior to expending the resources.  
  Any issues arising from the inspection are to be preliminarily evaluated using MC 0612,
VI
  MC 0609 and the Kewaunee specific Phase 2 worksheets prior to more than 4 hours
Issues and Findings
  inspection time being spent on them. The lead inspector will have copies of the
Any issues arising from the inspection are to be preliminarily evaluated using MC 0612,
  worksheets available on site. Doing a preliminary evaluation will ensure that inspection
MC 0609 and the Kewaunee specific Phase 2 worksheets prior to more than 4 hours
  effort is focused on risk significant activities and will provide direction for areas needing
inspection time being spent on them. The lead inspector will have copies of the
  exploration in order to confirm a finding.
worksheets available on site. Doing a preliminary evaluation will ensure that inspection
  Unless an issue can be shown to be greater than minor, additional inspection time (over
effort is focused on risk significant activities and will provide direction for areas needing
  the 4 hours) should not be spent. If an issue appears greater than minor, then sufficient
exploration in order to confirm a finding.
  questions need to be asked of the licensee to enable the inspectors to confirm any
Unless an issue can be shown to be greater than minor, additional inspection time (over
  assumptions and complete the Phase 1 and 2 worksheets. Green findings will be
the 4 hours) should not be spent. If an issue appears greater than minor, then sufficient
  documented in the inspection report. Findings that appear to be "other than green" or a
questions need to be asked of the licensee to enable the inspectors to confirm any
  potential operability issue shall be immediately brought to the lead inspector's attention
assumptions and complete the Phase 1 and 2 worksheets. Green findings will be
  so that it can be discussed with the licensee and the senior reactor analyst. If a color
documented in the inspection report. Findings that appear to be "other than green" or a
                                              -7-
potential operability issue shall be immediately brought to the lead inspector's attention
so that it can be discussed with the licensee and the senior reactor analyst. If a color


    cannot be determined by the end of the inspection, the issue will be described as an
-8-
    "unresolved item," pending final determination of the appropriate risk significance.
cannot be determined by the end of the inspection, the issue will be described as an
    Enforcement action will be handled in accordance with the Enforcement Policy.
"unresolved item," pending final determination of the appropriate risk significance.  
VII Documentation
Enforcement action will be handled in accordance with the Enforcement Policy.
    Inspection Questions
VII
    Detailed design inspections normally result in a number of questions being raised.
Documentation
    These questions are to be given to the licensee verbally  or, if written, the licensee
Inspection Questions
    must copy the information and the inspector must retain the written document. No
Detailed design inspections normally result in a number of questions being raised.  
    written information is to be provided to the licensee.
These questions are to be given to the licensee verbally  or, if written, the licensee
    Questions should not be "stored up" to the end of the day, but given to the licensee
must copy the information and the inspector must retain the written document. No
    reasonably soon after being generated. As part of the daily interfaces with the licensee,
written information is to be provided to the licensee.
    the lead inspector will go over the status of outstanding questions. Therefore, the team
Questions should not be "stored up" to the end of the day, but given to the licensee
    members need to keep the lead inspector apprized of any concerns regarding the
reasonably soon after being generated. As part of the daily interfaces with the licensee,
    timeliness or quality of responses to questions.
the lead inspector will go over the status of outstanding questions. Therefore, the team
    Lack of response to questions will not be accepted as a reason for any delay in
members need to keep the lead inspector apprized of any concerns regarding the
    providing an input unless the licensee did not respond in a reasonable time frame
timeliness or quality of responses to questions.
    (usually 24 hours), the lead inspector has been informed of the delay and has discussed
Lack of response to questions will not be accepted as a reason for any delay in
    it with the licensee prior to the exit, and the issue is one that has been determined to be
providing an input unless the licensee did not respond in a reasonable time frame
    potentially "greater than minor." Any document requests generated on the day of the
(usually 24 hours), the lead inspector has been informed of the delay and has discussed
    debrief or afterwards must be approved by the lead inspector, must pertain to areas
it with the licensee prior to the exit, and the issue is one that has been determined to be
    already inspected and must be only for the purpose of finalizing a finding or ensuring an
potentially "greater than minor." Any document requests generated on the day of the
    accurate document list entry.
debrief or afterwards must be approved by the lead inspector, must pertain to areas
    Report Preparation
already inspected and must be only for the purpose of finalizing a finding or ensuring an
    The report will be prepared in accordance with the guidance in MC 0612, MC 0620,
accurate document list entry.
    Region III model inspection report, and regional procedure 1220. It's recognized that
Report Preparation
    RP 1220 does not strictly apply; however, it provides the best guidance available for
The report will be prepared in accordance with the guidance in MC 0612, MC 0620,
    formatting of the report and document lists. Input will primarily consist of a list of the
Region III model inspection report, and regional procedure 1220. It's recognized that
    documents reviewed, unless a finding meets the guidance for documentation. Issues
RP 1220 does not strictly apply; however, it provides the best guidance available for
    which an inspector considers as meeting the criteria for inclusion in the report shall be
formatting of the report and document lists. Input will primarily consist of a list of the
    discussed with the lead inspector prior to preparing an input. Finding input shall consist
documents reviewed, unless a finding meets the guidance for documentation. Issues
    of both the detailed write-up for the body of the inspection report and the associated
which an inspector considers as meeting the criteria for inclusion in the report shall be
    paragraphs for the summary of finding section of the inspection report. Also, make sure
discussed with the lead inspector prior to preparing an input. Finding input shall consist
    you evaluate each finding for cross cutting aspects, discuss the cross cutting aspect
of both the detailed write-up for the body of the inspection report and the associated
    with the team lead and during team meetings and document it in the report input. Inputs
paragraphs for the summary of finding section of the inspection report. Also, make sure
    are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the
you evaluate each finding for cross cutting aspects, discuss the cross cutting aspect
    exit.
with the team lead and during team meetings and document it in the report input. Inputs
    In keeping with the requirements of MC 0620 (see latest revision changes), only those
are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the
    documents which were reviewed as part of meeting an inspection attribute are to be
exit.
    included. The document list does not include procedures reviewed as part of
In keeping with the requirements of MC 0620 (see latest revision changes), only those
                                              -8-
documents which were reviewed as part of meeting an inspection attribute are to be
included. The document list does not include procedures reviewed as part of


    preparation for the inspection. Corrective action documents generated as a result of the
-9-
    inspector's questions shall be called out separately from corrective action documents
preparation for the inspection. Corrective action documents generated as a result of the
    that were in the licensee's system prior to the inspection. It is strongly recommended
inspector's questions shall be called out separately from corrective action documents
    that inspectors keep a list of documents up-to-date to ensure that no documents are
that were in the licensee's system prior to the inspection. It is strongly recommended
    missed.
that inspectors keep a list of documents up-to-date to ensure that no documents are
XIII HRMS Information
missed.
    Overall Time Management
XIII
    The baseline inspection hours primarily encompasses only those hours spent starting
HRMS Information
    with the first on-site inspection week and prior to the exit meeting. Time spent during
Overall Time Management
    the three in-office preparation weeks are to be charged to prep. They do not include
The baseline inspection hours primarily encompasses only those hours spent starting
    time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-
with the first on-site inspection week and prior to the exit meeting. Time spent during
    mail, or keeping track of hours to correctly credit them. However, they do include time
the three in-office preparation weeks are to be charged to prep. They do not include
    spent in team meetings and in preparing for team meetings. Between 10 to 15% of the
time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-
    baseline hours are to be spent in evaluating problem identification and resolution efforts.
mail, or keeping track of hours to correctly credit them. However, they do include time
    Baseline Inspection (BI) Charges
spent in team meetings and in preparing for team meetings. Between 10 to 15% of the
    The hours given for the this procedure is as follows:
baseline hours are to be spent in evaluating problem identification and resolution efforts.
      Procedure                       Nominal               Minimum             Maximum
Baseline Inspection (BI) Charges
      71111.21                           347                   408                 470
The hours given for the this procedure is as follows:
    As a result, each inspector should be able to charge approximately 102 hours over the
Procedure
    3-week inspection period (4 x 102 = 408 +/- 15%). Contractors are allotted
Nominal
    approximately 272 hours of direct inspection effort (136 each).
Minimum
    Preparation Charges
Maximum
    The lead inspector has estimated that each inspector should charge approximately 60
71111.21
    hours (60 X 4 = 240) to BIP for this inspection over the three weeks preparation period.
347
    If an inspector is unable to prepare due to other work demands, please discuss this with
408
    the lead inspector (who will then work with management to ensure proper inspection
470
    preparation occurs.)
As a result, each inspector should be able to charge approximately 102 hours over the
    Documentation Charges
3-week inspection period (4 x 102 = 408 +/- 15%). Contractors are allotted
    During the inspection, any time spent documenting items which have been reviewed is
approximately 272 hours of direct inspection effort (136 each).
    to be charged to BID. Also, the time spent on the exit meeting is to be charged to BID.
Preparation Charges
    If the inspector has no findings, documentation time should be about 6-8 hours.
The lead inspector has estimated that each inspector should charge approximately 60
    Documentation of findings should take about 20 hours, or more, depending on their
hours (60 X 4 = 240) to BIP for this inspection over the three weeks preparation period.  
    complexity. Please note that this does not change the time period over which the input
If an inspector is unable to prepare due to other work demands, please discuss this with
    is due: It still will be five working days following the exit.
the lead inspector (who will then work with management to ensure proper inspection
                                                -9-
preparation occurs.)  
Documentation Charges
During the inspection, any time spent documenting items which have been reviewed is
to be charged to BID. Also, the time spent on the exit meeting is to be charged to BID.  
If the inspector has no findings, documentation time should be about 6-8 hours.  
Documentation of findings should take about 20 hours, or more, depending on their
complexity. Please note that this does not change the time period over which the input
is due: It still will be five working days following the exit.


  Checking E-mail and Other Such Activities
-10-
  For planning purposes, the lead inspector has assumed that each inspector will spend a
Checking E-mail and Other Such Activities
  maximum of 2 hours during each on-site week of the inspection, maximum of 6 hours,
For planning purposes, the lead inspector has assumed that each inspector will spend a
  checking e-mail, HRMS, or doing other activities not directly related to the inspection.
maximum of 2 hours during each on-site week of the inspection, maximum of 6 hours,
  This time, if used, should be charged to general administration.
checking e-mail, HRMS, or doing other activities not directly related to the inspection.  
  Travel Charges
This time, if used, should be charged to general administration.  
  All travel time is to be charged in HRMS to an IPE code of "AT", including travel during
Travel Charges
  non-regular hours (see below). For planning purposes, a total of approximately 21
All travel time is to be charged in HRMS to an IPE code of "AT", including travel during
  hours is allotted to each inspector for travel to site and back during this inspection (7 per
non-regular hours (see below). For planning purposes, a total of approximately 21
  week).
hours is allotted to each inspector for travel to site and back during this inspection (7 per
  Overtime
week).
  Overtime for each regional inspector should be minimal and normally not to exceed 4
Overtime
  hours per onsite week. The overtime is to only be requested and used to meet the
Overtime for each regional inspector should be minimal and normally not to exceed 4
  inspection requirements or if an issue comes up at the end of the day that requires
hours per onsite week. The overtime is to only be requested and used to meet the
  prompt resolution. Inspectors need to inform the team leader if overtime will be used.
inspection requirements or if an issue comes up at the end of the day that requires
  Overtime must be claimed in HRMS if used. Any overtime spent traveling (although
prompt resolution. Inspectors need to inform the team leader if overtime will be used.  
  there shouldn't be any) also must be claimed in HRMS using the overtime code of
Overtime must be claimed in HRMS if used. Any overtime spent traveling (although
  "CPETV".
there shouldn't be any) also must be claimed in HRMS using the overtime code of
IX Interface and Coordination Meetings
"CPETV".
  Entrance Meeting:
IX
  The team will conduct the entrance meeting on Monday, January 30, 2007, tentatively
Interface and Coordination Meetings
  scheduled for 9:00 a.m. Team members are expected to arrive onsite to attend the
Entrance Meeting:
  entrance meeting. A field walkdown will be conducted after the team entrance meeting.
The team will conduct the entrance meeting on Monday, January 30, 2007, tentatively
  Licensee Debriefings
scheduled for 9:00 a.m. Team members are expected to arrive onsite to attend the
  Daily debriefings with the licensee will start Tuesday, January 30th at approx. 9:30 am.
entrance meeting. A field walkdown will be conducted after the team entrance meeting.
  These daily meetings will normally be between the lead inspector and the licensee, with
Licensee Debriefings
  team member attendance only on an as-needed basis.
Daily debriefings with the licensee will start Tuesday, January 30th at approx. 9:30 am.  
  Routine Interactions
These daily meetings will normally be between the lead inspector and the licensee, with
  Throughout the inspection, team members are expected to have routine interactions
team member attendance only on an as-needed basis.  
  with licensee employees. It is expected that these interactions will be professional in
Routine Interactions
  nature and will normally be conducted without the lead inspector present. Inspectors
Throughout the inspection, team members are expected to have routine interactions
  should keep track of any questions or requests for further information arising from these
with licensee employees. It is expected that these interactions will be professional in
  meetings.
nature and will normally be conducted without the lead inspector present. Inspectors
                                            -10-
should keep track of any questions or requests for further information arising from these
meetings.  


  Team Meetings at RIII Office
-11-
  Team meetings during the in-office prep week will be held on Monday, January 22nd, at
Team Meetings at RIII Office
  2:00 p.m. and on Thursday, January 25th, at 10:00 am. The intent of these meetings is
Team meetings during the in-office prep week will be held on Monday, January 22nd, at
  to discuss the selection of components, operator actions, and operating experience that
2:00 p.m. and on Thursday, January 25th, at 10:00 am. The intent of these meetings is
  will be reviewed during the inspection, the following week. Final selection of
to discuss the selection of components, operator actions, and operating experience that
  components, operator actions, operating experience, and modifications should occur
will be reviewed during the inspection, the following week. Final selection of
  during this in-office prep week.
components, operator actions, operating experience, and modifications should occur
  Team meetings will also be held during the last two in-office weeks on Tuesdays at
during this in-office prep week.
  10:00 a.m. in the DRS conference room. Contractors will be tied into the meeting via
Team meetings will also be held during the last two in-office weeks on Tuesdays at
  teleconference, as appropriate due to inspection hour considerations.
10:00 a.m. in the DRS conference room. Contractors will be tied into the meeting via
  Team Meetings Onsite
teleconference, as appropriate due to inspection hour considerations.
  Team meetings during the onsite inspection weeks will be held starting Tuesday,
Team Meetings Onsite
  January 30th, at 3:00 p.m. The meetings should last approximately 45 minutes. The
Team meetings during the onsite inspection weeks will be held starting Tuesday,
  intent is to allow each inspector, including the lead inspector, to briefly discuss the day's
January 30th, at 3:00 p.m. The meetings should last approximately 45 minutes. The
  activities/issues, status of inspection activities, and any administrative or logistics items.
intent is to allow each inspector, including the lead inspector, to briefly discuss the day's
  An extensive team meeting will be held on Wednesday , February 28th to discuss the
activities/issues, status of inspection activities, and any administrative or logistics items.  
  team's findings and determine what issues will be presented at the exit. This meeting
  will probably begin at 2:00 p.m. and will probably run longer than normal team meetings.
An extensive team meeting will be held on Wednesday , February 28th to discuss the
  Final De-brief
team's findings and determine what issues will be presented at the exit. This meeting
  The final de-brief with the licensee will be held on Thursday, March 1st around 2:00 p.m.
will probably begin at 2:00 p.m. and will probably run longer than normal team meetings.
  Inspectors should be ready to discuss in detail the areas they inspected, observations,
Final De-brief
  and any potential violations/findings.
The final de-brief with the licensee will be held on Thursday, March 1st around 2:00 p.m.  
  Exit Meeting
Inspectors should be ready to discuss in detail the areas they inspected, observations,
  The team will conduct the exit meeting on Friday, March 2nd tentatively scheduled for
and any potential violations/findings.
  9:00 a.m. Team members are expected to attend the final exit meeting and to be
Exit Meeting
  prepared to present any of their findings to the licensee.
The team will conduct the exit meeting on Friday, March 2nd tentatively scheduled for
X Logistics
9:00 a.m. Team members are expected to attend the final exit meeting and to be
  Travel
prepared to present any of their findings to the licensee.
  Kewaunee is approximately 220 miles from the RIII office. The lead inspector has
X
  allotted approximately 4.0 hours of driving travel time each way. There is no need for
Logistics
  Sunday travel. Additionally, the lead inspector requests that everyone use good
Travel
  judgement in all travel arrangements. If severe weather conditions arise, it is expected
Kewaunee is approximately 220 miles from the RIII office. The lead inspector has
  that inspectors will take sensible precautions during traveling.
allotted approximately 4.0 hours of driving travel time each way. There is no need for
  The following hotel is in the area around Kewaunee. Per diem is (60/39/99).
Sunday travel. Additionally, the lead inspector requests that everyone use good
                                          -11-
judgement in all travel arrangements. If severe weather conditions arise, it is expected
that inspectors will take sensible precautions during traveling.
The following hotel is in the area around Kewaunee. Per diem is (60/39/99).


Hotel                                   Telephone
-12-
Hotel
Telephone
Country Inn Suites, Green Bay, WI (Phone # 920-336-6600)
Country Inn Suites, Green Bay, WI (Phone # 920-336-6600)
Residence Inn, Green Bay, WI (Phone # 920-435-2222)
Residence Inn, Green Bay, WI (Phone # 920-435-2222)
Inspection Location
Inspection Location
The inspection team will be located in room ATF-107 (1st week) and Administration
The inspection team will be located in room ATF-107 (1st week) and Administration
Line 444: Line 482:
Hours of Work
Hours of Work
Inspectors are expected to generally adhere to their normal working hours, as much as
Inspectors are expected to generally adhere to their normal working hours, as much as
possible. Significant changes should be coordinated with the lead inspector but will be
possible. Significant changes should be coordinated with the lead inspector but will be
accommodated if possible. However, compressed days off should be changed to a non-
accommodated if possible. However, compressed days off should be changed to a non-
onsite week. Inspectors desiring to work overtime on their compressed days off need to
onsite week. Inspectors desiring to work overtime on their compressed days off need to
individually coordinate this with their branch chief prior to the inspection.
individually coordinate this with their branch chief prior to the inspection.  
Work at Home
Work at Home
It is acceptable to the lead inspector for inspectors to have work-at-home for the in-
It is acceptable to the lead inspector for inspectors to have work-at-home for the in-
between week, the documentation week, and for parts of the prep weeks. Team
between week, the documentation week, and for parts of the prep weeks. Team
meetings will occur during these weeks and it is expected that inspectors working at
meetings will occur during these weeks and it is expected that inspectors working at
home will be available via teleconference for these meetings. If you desire to do work-
home will be available via teleconference for these meetings. If you desire to do work-
at-home, please note that work-at-home must be approved by the appropriate branch
at-home, please note that work-at-home must be approved by the appropriate branch
chief.
chief.
                                          -12-


                                                                                      Attachment A
Attachment A
                                    DESIGN REVIEW QUESTIONS
DESIGN REVIEW QUESTIONS
-13-
During the design review, inspectors should consider the following questions:
During the design review, inspectors should consider the following questions:
Valves
Valves
1.     Are the permissive interlocks appropriate?
1.
2.     Will the valve function at the pressures that will exist during transient/accident
Are the permissive interlocks appropriate?
        conditions?
2.
3.     Will the control and indication power supply be adequate for system function?
Will the valve function at the pressures that will exist during transient/accident
4.     Is the control logic consistent with the system functional requirements?
conditions?
5.     What manual actions are required to back up and/or correct a degraded function?
3.
Will the control and indication power supply be adequate for system function?
4.
Is the control logic consistent with the system functional requirements?
5.
What manual actions are required to back up and/or correct a degraded function?
Pumps
Pumps
1.     Is the pump capable of supplying required flow at required pressures under
1.
        transient/accident conditions?
Is the pump capable of supplying required flow at required pressures under
2.     Is adequate net positive suction head (NPSH) available under all operating conditions?
transient/accident conditions?
3.     Is the permissive interlock and control logic appropriate for the system function?
2.
4.     Is the pump control adequately designed for automatic operation?
Is adequate net positive suction head (NPSH) available under all operating conditions?
5.     When manual actions are required, do the operating procedures appropriately describe
3.
        necessary operator actions?
Is the permissive interlock and control logic appropriate for the system function?
6.     What manual actions are required to back up and /or correct a degraded function?
4.
7.     Has the motive power required for the pump during transient/accident conditions been
Is the pump control adequately designed for automatic operation?
        correctly estimated and included in the normal and emergency power supplies?
5.
8.     Do vendor data and specifications support sustaining operations at low flow rates?
When manual actions are required, do the operating procedures appropriately describe
9.     Is the design and quality of bearing and seal cooling systems acceptable?
necessary operator actions?
6.
What manual actions are required to back up and /or correct a degraded function?
7.
Has the motive power required for the pump during transient/accident conditions been
correctly estimated and included in the normal and emergency power supplies?
8.
Do vendor data and specifications support sustaining operations at low flow rates?
9.
Is the design and quality of bearing and seal cooling systems acceptable?
Instrumentation
Instrumentation
1.     Are the required plant parameters used as inputs to the initiation and control system?
1.
2.     If operator intervention is required in certain scenarios, have appropriate alarms and
Are the required plant parameters used as inputs to the initiation and control system?
        indications been provided?
2.
3.     Are the range, accuracy, and setpoint of instrumentation adequate?
If operator intervention is required in certain scenarios, have appropriate alarms and
4.     Are the specified surveillance and calibrations of such instrumentation acceptable?
indications been provided?
3.
Are the range, accuracy, and setpoint of instrumentation adequate?
4.
Are the specified surveillance and calibrations of such instrumentation acceptable?
Circuit Breakers and Fuses
Circuit Breakers and Fuses
1.     Is the breaker control logic adequate to fulfill the functional requirements?
1.
2.     Is the short circuit rating in accordance with the short circuit duty?
Is the breaker control logic adequate to fulfill the functional requirements?
3.     Are the breakers and fuses properly rated for the load current capability?
2.
4.     Are breakers and fuses properly rated for DC operation?
Is the short circuit rating in accordance with the short circuit duty?
3.
Are the breakers and fuses properly rated for the load current capability?
4.
Are breakers and fuses properly rated for DC operation?
Cables
Cables
1.     Are cables rated to handle full load at the environments temperature expected?
1.
2.     Are cables properly rated for short circuit capability?
Are cables rated to handle full load at the environments temperature expected?
                                                -13-
2.
Are cables properly rated for short circuit capability?


                                                                                    Attachment A
Attachment A
                                DESIGN REVIEW QUESTIONS
DESIGN REVIEW QUESTIONS
3.     Are cables properly rated for voltage requirements for the loads?
-14-
3.
Are cables properly rated for voltage requirements for the loads?
Electrical Loads
Electrical Loads
1.     Have electrical loads been analyzed to function properly under the expected lowest and
1.
        highest voltage conditions?
Have electrical loads been analyzed to function properly under the expected lowest and
2.     Have loads been analyzed for their inrush and full load currents?
highest voltage conditions?
3.     Have loads been analyzed for their electrical protection requirements?
2.
Have loads been analyzed for their inrush and full load currents?
3.
Have loads been analyzed for their electrical protection requirements?
As-built System
As-built System
1.     Are service water flow capacities sufficient with the minimum number of pumps available
1.
        under accident conditions?
Are service water flow capacities sufficient with the minimum number of pumps available
2.     Have modified equipment components falling under the scope of 10CFR 50.49 been
under accident conditions?
        thoroughly evaluated for environmental equipment qualifications considerations such as
2.
        temperature, radiation, and humidity?
Have modified equipment components falling under the scope of 10CFR 50.49 been
3.     Are the modifications to the system consistent with the original design and licensing
thoroughly evaluated for environmental equipment qualifications considerations such as
        bases?
temperature, radiation, and humidity?
                                                -14-
3.
Are the modifications to the system consistent with the original design and licensing
bases?
}}
}}

Latest revision as of 03:36, 15 January 2025

IR 05000305-07-006, Kewaunee Power, Inspection Plan
ML070310250
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 01/18/2007
From: Falevits Z, Louden P, Ann Marie Stone
Engineering Branch 3
To:
Nuclear Management Co
References
IR-07-006
Download: ML070310250 (14)


See also: IR 05000305/2007006

Text

1/22/07

COMPONENT DESIGN BASES INSPECTION (CDBI)

INSPECTION PLAN

KEWAUNEE POWER STATION

(INSPECTION REPORT NUMBER 05000305/2007006(DRS) )

Inspection Objectives

This inspection fulfills the baseline inspection program requirements for biennial Inspection

Procedure (IP) 71111.21. The inspections objective is to verify that design bases have been

correctly implemented for the selected risk significant components and that operating

procedures and operator actions are consistent with design and licensing bases. This is to

ensure that selected components are capable of performing their intended safety functions.

This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity

cornerstones for which there are no indicators to measure performance.

Inspection Dates:

January 29, 2007, through March 2, 2007

Exit:

March 2, 2007

Applicable Inspection Procedures

IP 71111.21

"Component Design Bases Inspection , dated June 22, 2006

IP 71152

Identification and Resolution of Problems (reference)

Prepared By: /RA/

01/18/2007

Lead Inspector

Date

Zelig Falevits

Approved By: /RA/

01/18/2007

DRS Branch Chief

Date

Ann Marie Stone

Reviewed By: /RA/

01/18/2007

DRP Branch Chief

Date

Pat Louden

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INSPECTION PLAN DETAILS

I.

INSPECTION TEAM:

Z. Falevits, Senior Engineering Inspector, Lead, x9717, zxf

C. Brown, Senior Engineering Inspector, x9605, ceb1

R. Langstaff, Senior Engineering Inspector, x9747, ral4

A. Dahbur, Engineering Inspector, x9810, akd

S. Burgess, Senior Reactor Analyst, x9752, sdb2

M. Yeminy, Mechanical Consultant, 305-238-4732

G. Skinner, Electrical Consultant, 412-963-9889

F. Tran, Engineering Inspector, Observer, x9623, fpt

II

Detailed Inspection Schedule

Lead Inspector Preparation: January 8, 2007

Prep. at Region III Offices:

January 22-26, 2007

Inspection Onsite Weeks:

January 29 to February 2, 2007

February 12-16, 2007

February 26 to March 2, 2007

In-office Weeks:

February 5 to 9, 2007

February 19 to 23, 2007

Entrance Meeting:

January 30 at 9:00 a.m.

Exit Meeting:

March 2, at 9:00 a.m.

Preparation of Inspection Report:

Inputs Due: March 9, 2007 COB

Draft Completed: March 30, 2007

Management Review and Approval Completed (target): April 6, 2007

Inspection Report Must Be Issued Before April 16, 2007

III

Lead Inspector Preparation Activities

Review licensee material received based on information request letter, Review PRA

information with the SRAs, select 30 high risk components, and provide the team a copy

of the inspection plan.

Information Requests

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As part of the inspection preparation, the lead inspector contacted the licensee,

informed them of the scope of the inspection, and requested that the necessary

information be provided to the inspection team. The information request letter was sent

to the license on November 6, 2006.

Distribution of Collected Information

On Monday, January 22, 2007, or sooner, the lead inspector will distribute information

provided by the licensee, for the 30 components selected by the SRA and the lead

inspector. The majority of the information will be provided electronically. This

information will be reviewed by the team members in order to reduce the selected items

to about 15-20 high risk/low margin (HR/LM) components and to divide up the

components to be reviewed by the team during the onsite inspection weeks. In addition,

other items required by the procedure will be selected.

IV

Team Preparation Activities

In-office Prep Week to select final 15-20 components and other items based on high

risk significance and the least available margin. (January 22-26, 2007)

We will have a team meeting on Monday, January 22nd, at 2:00 pm to discuss inspection

logistics and plan. Team members will use this preparation week to review the design

related material the licensee provided for the 30 selected components to determine low

margin components and to narrow the selection to the final 15-20 HR/LM components to

be inspected during the onsite inspection weeks. In addition, HR/LM operator actions,

operating experience, and related modifications and condition reports will be selected

during this week. The specific team assignments will be determined during this

preparation week. A second team meeting will be held on Thursday, January 25, at

10:00 am to discuss specific team assignments, final selection of (15-20) components

and other inspection items. In addition, the lead inspector will combine the list of

additional team member requested information to be submitted to the licensee so that

the information will be ready for review during the first onsite inspection week.

The inspectors should review the latest revised inspection procedure to familiarize

themselves with the process for selection of components, operator actions, and

operating experience; and conduct of the inspection. Latest completed CDBI inspection

reports, should be reviewed. In particular, review the following RIII issued CDBI

inspection reports: Quad Cities 254/265/2006003(DRS) and Duane Arnold IR #

331/2006007(DRS) (Follow latest report format to write your input; including the list of

documents). Also, please review the Kewaunee CDBI pilot IR #305/2005002(DRS) for

attributes and components inspected and be mind full of what was looked at during the

pilot inspection to ensure that we do not review the same attributes/documents during

this inspection, as much as possible. Also, the inspection procedure and the Matrix

provided by the lead inspector identifies a number of component design review

attributes and considerations that can be used in support of the inspection to verify

certain system or component attributes. Since most of the material may be electronic,

inspectors should bring a laptop computer to the site for their use in preparation for the

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inspection. Also, if possible, bring a memory stick for efficient information transfer of

findings and exit notes between team members and the lead inspector.

A component inspection Matrix will be developed to identify component attributes to be

inspected and team member assignments.

Component Selection

The sample selection of 15-20 components should be based on risk significance and the

least available margin. The team will initially select more than the minimum required to

ensure the minimum number of samples are met. If it is determined that either the team

does not have the time or resources to complete all of the selected components, they

will not be included as part of the number of completed samples. Design margin is

typically defined as the difference between the actual (or predicted) and required

performance of a system, component, or operator action (see IP for more details). The

procedure states that the following attributes should be considered in evaluating

component margin, analytical (design) margin, operations margin, maintenance margin

and complexity margin. Margin includes, corrective action insights, maintenance

history, design changes, complex design schemes, and maintenance rule insights.

Low margin can be a function of the original design, caused by design modifications,

power uprates, or can be due to degraded material conditions. Inspection samples

(safety or non-safety risk significant components) should be identified at the major

component (e.g. pump, motor operated valve, batteries, etc.) or procedural step level to

assist in inspection planning. Included within the sample selected should be passive

components such as sump screens, strainers, piping, cables, etc., whose failure could

impact system functionality, component design function that involves a lot of operation

and human actions, availability/reliability issues, and components design attributes

which are not fully demonstrated through testing. To the extent practical, the sample

should include a diverse range of equipment. The team in their selection of samples

should attempt to limit the number of systems involved (i.e. select pump, valve, strainer,

etc, in same system, if possible), which will limit the amount of preparation time required

to understand design and system requirements necessary to conduct a successful

inspection.

In order to identify low margin areas, the inspectors should review detailed calculations

associated with the identified risk-significant components to identify areas of low margin.

In this case, the inspector should identify calculations showing little margin between

predicted results and calculation and/or regulatory acceptance criteria.

In addition, the margin review should include corrective action program insights and

repetitive maintenance summaries associated with the identified risk-significant

components as poor performing components may be indicative of inadequate design.

Component review should also include evaluation of the impact of plant modifications or

licensing basis changes on available margin. In particular, licensing changes that can

reduce safety analysis margins, such as extended power uprates, should be considered.

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The SRA and SRI will participate and provide information to be used for selecting the

samples for review.

Operator Action Selection

The operations inspector should review the list of risk significant operator actions

provided by the licensee, and with insights provided by the SRA the resident inspector,

and the team leader select 3-5 for review during the inspection. A review of operating

procedures, and operator task analysis validation studies should be performed to

identify critical operator actions with little margin between the time required and the time

available to complete an action. Based on the operator actions selected, the inspector

should request from the licensee the procedures necessary to conduct the operations.

Select high risk operator actions that have no job performance measure (JPM).

Operating Experience Selection

Based on the components selected, the regional inspectors will review the list of

operating experience provided by the licensee and identify selected operating

experience issues, either component specific, common cause, or generic issues that the

team may want to evaluate. Other operating experience that the inspectors are aware

of that may be relevant to the components selected can also be selected for review. In

addition, the team should identify for review one or two generic or common cause issues

that are not related to the selected samples. Some of the operating experience selected

should cover initiating events and barrier integrity cornerstones. Based on those issues

identified, the team will narrow down the samples to 4-6, which will be divided between

team members, as appropriate.

Additional Prep Activities

Once it is determined which components, operator actions, and operating experience

samples will be reviewed, they will be assigned to individual inspectors. Once this

designation has been accomplished, the inspectors should obtain sufficient familiarity

with the chosen components, operator actions, and operating experience samples and

their associated systems to understand the design and safety requirement for the

samples selected and their associated system. The inspectors should also review the

flow paths (mechanical) and control logic circuitry (electrical) for the selected

components to verify if other components in those flow paths or control logic could

potentially affect their function. For each component or inspection area assigned, the

inspector needs to develop a list of attributes (see IP 71111.21, section 02.02, Appendix

1 and Appendix 2 for examples) that will be reviewed during the inspection. The

inspectors review should also identify potential areas where the interface between

engineering and operations procedures can be reviewed by the operations inspector to

ensure design requirements are adequately implemented into procedures.

The inspectors should review the list of modifications performed on their assigned

components to determine whether any are either complex, reduced margin, required for

power uprate, etc., such that the modification should be considered for review during the

inspection. Although the inspection procedure does not identify a specific number of

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modifications that need to be reviewed, the team will select approximately 4-6

modifications for review (one per inspector). These modifications will be selected by the

team from those identified by individual team members. Note that a modification/50.59

inspection was performed by the NRC in November 2006 which looked at modifications

completed in the last 2 years. Make sure we do not select the same modifications for

review during this inspection.

Requests for Additional Information

During the course of the inspection, team members should request their licensee

contact to provide any specific information and/or documents they want to have readily

available when they return to the site. This might include any specific modification

packages, calculations, drawings, condition reports, procedures, and scheduling

interviews or walkdowns, etc. Licensee computers may be available in the conference

room with access to mainly calculations, condition reports and procedures.

V

Onsite Inspection Activities

Plant Walkdowns

The inspectors are expected to walkdown their assigned components and their

associated systems by discipline groups (electrical, mechanical, operations). The intent

of the component/system walkdowns is for the inspectors to obtain basic familiarity with

the systems, material condition of equipment, where components are located, etc. in

order to accomplish inspection objectives. During the walkdowns, the inspectors are

also asked to be aware of general plant material conditions. Any abnormal or

questionable conditions should be brought to the lead inspector to discuss with the

resident staff and the licensee.

Inspection

Successful completion of the CDBI inspection procedure requires a full understanding of

how the components and their associated system operates, and is supposed to operate.

Inspection of some broad-based attributes, such as those described in the inspection

procedure, cannot be accomplished by a single inspector working independently of the

rest of the team. However, to avoid duplication of work, each individual will be assigned

primary responsibility for the attributes being inspected. For example, if a mechanical

inspector is assigned to review a motor-operated valve, they may need an electrical

inspector to review the degraded voltage calculation. The team lead will facilitate these

types of reviews and will attempt to assign them at the start of the inspection to equalize

the work load between inspectors.

Inspectors should plan their workload so that all major areas are preliminarily reviewed

prior to the end of the first two onsite weeks of the inspection. Most of the last onsite

week should primarily be spent reviewing responses to questions previously asked,

resolving issues, and developing any findings. This does not mean that new inspection

can't be done; just that doing so leaves little time to develop issues before the end of the

inspection.

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Inspection Objectives (IP 71111.21, Sections 02.02a thru e)

For the inspection attributes and inspection activities identified during the prep week,

conduct a detailed design review of the selected components calculations,

surveillances, and other associated system documentation to confirm each of the

specified attributes for your assigned areas (02.02a). Perform plant walkdowns of

selected components to verify as-built condition is consistent to design requirements

and inspect component for material condition; and review components corrective action

and maintenance history that could affect the components to function (02.02b). The

operations inspector should verify performance of risk significant operator actions, along

with a walk-through of a sample operations procedures for the selected components

(02.02c). Review permanent plant modifications to ensure design bases, licensing

bases, and performance capability have not been degraded (02.02d). Review the

licensees evaluation and disposition of selected operating experience to ensure it has

been adequately addressed (02.02e).

Identification and Resolution of Problems

Identifying Design Issues - threshold and corrective action program.

Sample of Problems - verify appropriateness of corrective actions.

In-office Inspection

Inspectors should be aware of the direct inspection hour limits for this inspection. The

number of hours used during the in-office weeks should be carefully monitored as to not

exceed the total hours allotted for this inspection. The lead inspector will track both the

preparation and direct inspection hours used for each inspector, including contractors.

This information should be provided to the lead inspector every Monday, on a weekly

basis, via e-mail. If significant issues arise that require use of more hours, the lead

inspector and branch chief should be informed prior to expending the resources.

VI

Issues and Findings

Any issues arising from the inspection are to be preliminarily evaluated using MC 0612,

MC 0609 and the Kewaunee specific Phase 2 worksheets prior to more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

inspection time being spent on them. The lead inspector will have copies of the

worksheets available on site. Doing a preliminary evaluation will ensure that inspection

effort is focused on risk significant activities and will provide direction for areas needing

exploration in order to confirm a finding.

Unless an issue can be shown to be greater than minor, additional inspection time (over

the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) should not be spent. If an issue appears greater than minor, then sufficient

questions need to be asked of the licensee to enable the inspectors to confirm any

assumptions and complete the Phase 1 and 2 worksheets. Green findings will be

documented in the inspection report. Findings that appear to be "other than green" or a

potential operability issue shall be immediately brought to the lead inspector's attention

so that it can be discussed with the licensee and the senior reactor analyst. If a color

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cannot be determined by the end of the inspection, the issue will be described as an

"unresolved item," pending final determination of the appropriate risk significance.

Enforcement action will be handled in accordance with the Enforcement Policy.

VII

Documentation

Inspection Questions

Detailed design inspections normally result in a number of questions being raised.

These questions are to be given to the licensee verbally or, if written, the licensee

must copy the information and the inspector must retain the written document. No

written information is to be provided to the licensee.

Questions should not be "stored up" to the end of the day, but given to the licensee

reasonably soon after being generated. As part of the daily interfaces with the licensee,

the lead inspector will go over the status of outstanding questions. Therefore, the team

members need to keep the lead inspector apprized of any concerns regarding the

timeliness or quality of responses to questions.

Lack of response to questions will not be accepted as a reason for any delay in

providing an input unless the licensee did not respond in a reasonable time frame

(usually 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), the lead inspector has been informed of the delay and has discussed

it with the licensee prior to the exit, and the issue is one that has been determined to be

potentially "greater than minor." Any document requests generated on the day of the

debrief or afterwards must be approved by the lead inspector, must pertain to areas

already inspected and must be only for the purpose of finalizing a finding or ensuring an

accurate document list entry.

Report Preparation

The report will be prepared in accordance with the guidance in MC 0612, MC 0620,

Region III model inspection report, and regional procedure 1220. It's recognized that

RP 1220 does not strictly apply; however, it provides the best guidance available for

formatting of the report and document lists. Input will primarily consist of a list of the

documents reviewed, unless a finding meets the guidance for documentation. Issues

which an inspector considers as meeting the criteria for inclusion in the report shall be

discussed with the lead inspector prior to preparing an input. Finding input shall consist

of both the detailed write-up for the body of the inspection report and the associated

paragraphs for the summary of finding section of the inspection report. Also, make sure

you evaluate each finding for cross cutting aspects, discuss the cross cutting aspect

with the team lead and during team meetings and document it in the report input. Inputs

are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the

exit.

In keeping with the requirements of MC 0620 (see latest revision changes), only those

documents which were reviewed as part of meeting an inspection attribute are to be

included. The document list does not include procedures reviewed as part of

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preparation for the inspection. Corrective action documents generated as a result of the

inspector's questions shall be called out separately from corrective action documents

that were in the licensee's system prior to the inspection. It is strongly recommended

that inspectors keep a list of documents up-to-date to ensure that no documents are

missed.

XIII

HRMS Information

Overall Time Management

The baseline inspection hours primarily encompasses only those hours spent starting

with the first on-site inspection week and prior to the exit meeting. Time spent during

the three in-office preparation weeks are to be charged to prep. They do not include

time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-

mail, or keeping track of hours to correctly credit them. However, they do include time

spent in team meetings and in preparing for team meetings. Between 10 to 15% of the

baseline hours are to be spent in evaluating problem identification and resolution efforts.

Baseline Inspection (BI) Charges

The hours given for the this procedure is as follows:

Procedure

Nominal

Minimum

Maximum

71111.21

347

408

470

As a result, each inspector should be able to charge approximately 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> over the

3-week inspection period (4 x 102 = 408 +/- 15%). Contractors are allotted

approximately 272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> of direct inspection effort (136 each).

Preparation Charges

The lead inspector has estimated that each inspector should charge approximately 60

hours (60 X 4 = 240) to BIP for this inspection over the three weeks preparation period.

If an inspector is unable to prepare due to other work demands, please discuss this with

the lead inspector (who will then work with management to ensure proper inspection

preparation occurs.)

Documentation Charges

During the inspection, any time spent documenting items which have been reviewed is

to be charged to BID. Also, the time spent on the exit meeting is to be charged to BID.

If the inspector has no findings, documentation time should be about 6-8 hours.

Documentation of findings should take about 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, or more, depending on their

complexity. Please note that this does not change the time period over which the input

is due: It still will be five working days following the exit.

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Checking E-mail and Other Such Activities

For planning purposes, the lead inspector has assumed that each inspector will spend a

maximum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> during each on-site week of the inspection, maximum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

checking e-mail, HRMS, or doing other activities not directly related to the inspection.

This time, if used, should be charged to general administration.

Travel Charges

All travel time is to be charged in HRMS to an IPE code of "AT", including travel during

non-regular hours (see below). For planning purposes, a total of approximately 21

hours is allotted to each inspector for travel to site and back during this inspection (7 per

week).

Overtime

Overtime for each regional inspector should be minimal and normally not to exceed 4

hours per onsite week. The overtime is to only be requested and used to meet the

inspection requirements or if an issue comes up at the end of the day that requires

prompt resolution. Inspectors need to inform the team leader if overtime will be used.

Overtime must be claimed in HRMS if used. Any overtime spent traveling (although

there shouldn't be any) also must be claimed in HRMS using the overtime code of

"CPETV".

IX

Interface and Coordination Meetings

Entrance Meeting:

The team will conduct the entrance meeting on Monday, January 30, 2007, tentatively

scheduled for 9:00 a.m. Team members are expected to arrive onsite to attend the

entrance meeting. A field walkdown will be conducted after the team entrance meeting.

Licensee Debriefings

Daily debriefings with the licensee will start Tuesday, January 30th at approx. 9:30 am.

These daily meetings will normally be between the lead inspector and the licensee, with

team member attendance only on an as-needed basis.

Routine Interactions

Throughout the inspection, team members are expected to have routine interactions

with licensee employees. It is expected that these interactions will be professional in

nature and will normally be conducted without the lead inspector present. Inspectors

should keep track of any questions or requests for further information arising from these

meetings.

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Team Meetings at RIII Office

Team meetings during the in-office prep week will be held on Monday, January 22nd, at

2:00 p.m. and on Thursday, January 25th, at 10:00 am. The intent of these meetings is

to discuss the selection of components, operator actions, and operating experience that

will be reviewed during the inspection, the following week. Final selection of

components, operator actions, operating experience, and modifications should occur

during this in-office prep week.

Team meetings will also be held during the last two in-office weeks on Tuesdays at

10:00 a.m. in the DRS conference room. Contractors will be tied into the meeting via

teleconference, as appropriate due to inspection hour considerations.

Team Meetings Onsite

Team meetings during the onsite inspection weeks will be held starting Tuesday,

January 30th, at 3:00 p.m. The meetings should last approximately 45 minutes. The

intent is to allow each inspector, including the lead inspector, to briefly discuss the day's

activities/issues, status of inspection activities, and any administrative or logistics items.

An extensive team meeting will be held on Wednesday , February 28th to discuss the

team's findings and determine what issues will be presented at the exit. This meeting

will probably begin at 2:00 p.m. and will probably run longer than normal team meetings.

Final De-brief

The final de-brief with the licensee will be held on Thursday, March 1st around 2:00 p.m.

Inspectors should be ready to discuss in detail the areas they inspected, observations,

and any potential violations/findings.

Exit Meeting

The team will conduct the exit meeting on Friday, March 2nd tentatively scheduled for

9:00 a.m. Team members are expected to attend the final exit meeting and to be

prepared to present any of their findings to the licensee.

X

Logistics

Travel

Kewaunee is approximately 220 miles from the RIII office. The lead inspector has

allotted approximately 4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of driving travel time each way. There is no need for

Sunday travel. Additionally, the lead inspector requests that everyone use good

judgement in all travel arrangements. If severe weather conditions arise, it is expected

that inspectors will take sensible precautions during traveling.

The following hotel is in the area around Kewaunee. Per diem is (60/39/99).

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Hotel

Telephone

Country Inn Suites, Green Bay, WI (Phone # 920-336-6600)

Residence Inn, Green Bay, WI (Phone # 920-435-2222)

Inspection Location

The inspection team will be located in room ATF-107 (1st week) and Administration

Assembly Room (2nd and 3rd weeks) rooms are inside the protected area. The telephone

extension in ATF-107 is Later and in the AAR is Later.

Hours of Work

Inspectors are expected to generally adhere to their normal working hours, as much as

possible. Significant changes should be coordinated with the lead inspector but will be

accommodated if possible. However, compressed days off should be changed to a non-

onsite week. Inspectors desiring to work overtime on their compressed days off need to

individually coordinate this with their branch chief prior to the inspection.

Work at Home

It is acceptable to the lead inspector for inspectors to have work-at-home for the in-

between week, the documentation week, and for parts of the prep weeks. Team

meetings will occur during these weeks and it is expected that inspectors working at

home will be available via teleconference for these meetings. If you desire to do work-

at-home, please note that work-at-home must be approved by the appropriate branch

chief.

Attachment A

DESIGN REVIEW QUESTIONS

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During the design review, inspectors should consider the following questions:

Valves

1.

Are the permissive interlocks appropriate?

2.

Will the valve function at the pressures that will exist during transient/accident

conditions?

3.

Will the control and indication power supply be adequate for system function?

4.

Is the control logic consistent with the system functional requirements?

5.

What manual actions are required to back up and/or correct a degraded function?

Pumps

1.

Is the pump capable of supplying required flow at required pressures under

transient/accident conditions?

2.

Is adequate net positive suction head (NPSH) available under all operating conditions?

3.

Is the permissive interlock and control logic appropriate for the system function?

4.

Is the pump control adequately designed for automatic operation?

5.

When manual actions are required, do the operating procedures appropriately describe

necessary operator actions?

6.

What manual actions are required to back up and /or correct a degraded function?

7.

Has the motive power required for the pump during transient/accident conditions been

correctly estimated and included in the normal and emergency power supplies?

8.

Do vendor data and specifications support sustaining operations at low flow rates?

9.

Is the design and quality of bearing and seal cooling systems acceptable?

Instrumentation

1.

Are the required plant parameters used as inputs to the initiation and control system?

2.

If operator intervention is required in certain scenarios, have appropriate alarms and

indications been provided?

3.

Are the range, accuracy, and setpoint of instrumentation adequate?

4.

Are the specified surveillance and calibrations of such instrumentation acceptable?

Circuit Breakers and Fuses

1.

Is the breaker control logic adequate to fulfill the functional requirements?

2.

Is the short circuit rating in accordance with the short circuit duty?

3.

Are the breakers and fuses properly rated for the load current capability?

4.

Are breakers and fuses properly rated for DC operation?

Cables

1.

Are cables rated to handle full load at the environments temperature expected?

2.

Are cables properly rated for short circuit capability?

Attachment A

DESIGN REVIEW QUESTIONS

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3.

Are cables properly rated for voltage requirements for the loads?

Electrical Loads

1.

Have electrical loads been analyzed to function properly under the expected lowest and

highest voltage conditions?

2.

Have loads been analyzed for their inrush and full load currents?

3.

Have loads been analyzed for their electrical protection requirements?

As-built System

1.

Are service water flow capacities sufficient with the minimum number of pumps available

under accident conditions?

2.

Have modified equipment components falling under the scope of 10CFR 50.49 been

thoroughly evaluated for environmental equipment qualifications considerations such as

temperature, radiation, and humidity?

3.

Are the modifications to the system consistent with the original design and licensing

bases?