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| {{#Wiki_filter:March 30, 2021 | | {{#Wiki_filter: |
| Mr. Joel P. Gebbie
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| Senior VP and Chief Nuclear Officer
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| Indiana Michigan Power Company
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| Nuclear Generation Group
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| One Cook Place
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| Bridgman, MI 49106
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| SUBJECT: DONALD C. COOK NUCLEAR PLANT - NOTIFICATION OF NRC DESIGN
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| BASES ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR
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| INFORMATION: INSPECTION REPORT 05000315/2021011; 05000316/2021011
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| Dear Mr. Gebbie:
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| On August 9, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
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| Design Bases Assurance Inspection (Programs) at Donald C. Cook Nuclear Plant. This
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| inspection will be performed in accordance with NRC Baseline Inspection Procedure
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| 71111.21N, Design Bases Assurance Inspection (Programs), Attachment 2, Design-Basis
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| Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements.
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| This inspection will evaluate the reliability, functional capability, and design basis of
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| risk-important power-operated valves (POVs) as required by 10 CFR 50.55a and applicable
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| 10 CFR Part 50, Appendix A and Appendix B, requirements. In conducting this inspection, the
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| team will select risk-important POVs used to prevent and mitigate the consequences of a design
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| basis accident.
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| The inspection will include two weeks of onsite inspection. The inspection team will consist of
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| three NRC inspectors. The current inspection schedule is as follows:
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| * Preparation week: August 2 - 6, 2021
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| * Onsite weeks: August 9 - 13, 2021, and August 23 - 27, 2021
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| Experience with previous baseline engineering inspections of similar depth and length has
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| shown this type of inspection is extremely resource intensive, both for the NRC inspectors and
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| the licensee staff. In order to minimize the inspection impact on the site and to ensure a
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| productive inspection for both parties, we have enclosed a request for information needed for
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| the inspection. It is important that all of these documents are up-to-date and complete in order
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| to minimize the number of additional documents requested during the preparation and/or the
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| onsite portions of the inspection. Insofar as possible, this information should be provided
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| electronically to the lead inspector. The information request has been divided into four groups:
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| J. Gebbie -2-
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| * The first group lists information necessary for our initial risk-informed scoping activities.
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| This information should be provided to the lead inspector no later than April 16, 2021.
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| * The second group lists information necessary for our initial inspection scoping activities.
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| This information should be provided to the lead inspector no later than June 4, 2021. By
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| June 28, 2021, the lead inspector will communicate the initial selected samples and any
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| additional information needed to support the in-office preparation activities.
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| * The third group of documents requested are those items needed to support our in-office
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| preparation activities. This set of documents should be provided to the lead inspector no
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| later than July 23, 2021. During the preparation activities, the team may identify
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| additional information needed to support the inspection.
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| * The fourth group includes the additional information above as well as plant-specific
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| reference material. This information should be available to the team onsite on
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| August 9, 2021. It is also requested that corrective action documents and answers to
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| questions developed during the inspection be provided to the lead inspector as the
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| documents are generated.
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| In addition, the enclosure includes information and requests addressing inspection logistics.
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| These items are requested be provided to the lead inspector by July 16, 2021.
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| The lead inspector for this inspection is Jorge Corujo-Sandin. We understand that our licensing
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| contact for this inspection is Mr. M. Ellet of your organization. If there are any questions about
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| the inspection or the material requested in the enclosure, contact the lead inspector at
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| 630-829-9741 or via e-mail at Jorge.Corujo-Sandin@nrc.gov.
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| This letter does not contain new or amended information collection requirements subject to
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| the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
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| requirements were approved by the Office of Management and Budget, Control
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| Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
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| respond to, a request for information or an information collection requirement unless the
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| requesting document displays a currently valid Office of Management and Budget Control
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| Number.
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| J. Gebbie -3-
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| This letter and its enclosure will be made available for public inspection and copying at
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| http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in
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| accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
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| Sincerely,
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| /RA/
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| Jorge Corujo-Sandin, Senior Reactor Inspector
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| Engineering Branch 2
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| Division of Reactor Safety
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| Docket Nos. 50-315 and 50-316
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| License Nos. DPR-58 and DPR-74
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| Enclosure:
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| Design Bases Assurance Inspection
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| (Programs)Document Request
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| cc: Distribution via LISTSERV
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| J. Gebbie -4-
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| Letter to Joel P. Gebbie from Jorge Corujo-Sandin dated March 30, 2021.
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| SUBJECT: DONALD C. COOK NUCLEAR PLANT - NOTIFICATION OF NRC DESIGN
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| BASES ASSURANCE INSPECTION (PROGRAMS) AND INITIAL REQUEST FOR
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| INFORMATION: INSPECTION REPORT 05000315/2021011; 05000316/2021011
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| DISTRIBUTION:
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| Brett Titus
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| Mark Haire
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| RidsNrrDorlLpl3
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| RidsNrrPMDCCook Resource
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| RidsNrrDroIrib Resource
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| John Giessner
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| Kenneth OBrien
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| Jamnes Cameron
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| Allan Barker
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| DRPIII
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| DRSIII
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| ADAMS Accession Number: ML21089A156
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| Publicly Available Non-Publicly Available Sensitive Non-Sensitive
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| OFFICE RIII RIII
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| NAME JHanna:mb JCorujo-Sandin
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| via e-mail via e-mail
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| DATE 03/30/2021 03/30/2021
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| OFFICIAL RECORD COPY
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| DESIGN BASES ASSURANCE INSPECTION - POV PROGRAM
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| REQUEST FOR INFORMATION
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| I. ADMINISTRATIVE INSPECTION INFORMATION
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| Inspection Report Number: 05000315/2021011; 05000316/2021011
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| Onsite Inspection Dates: August 9 - 13, 2021, and August 23 - 27, 2021
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| IP 71111.21N, Design Bases Assurance Inspection
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| Inspection Procedure: (Programs), Attachment 2, Design-Basis Capability of
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| Power-Operated Valves Under 10 CFR 50.55a Requirements
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| Jorge Corujo-Sandin, Senior Reactor Inspector, RIII/DRS
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| Lead Inspector: 630-829-9741
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| Jorge.Corujo-Sandin@nrc.gov
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| Kevin Barclay, Reactor Inspector, RIII/DRS
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| Teammate Inspectors:
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| Michael Jones, Reactor Inspector, RIII/DRS
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| II. LOGISTICS
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| Email the following inspection logistics to the lead inspector by July 16, 2021, or sooner:
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| 1. Inspection room name/number, directions from the main access facility, and phone number;
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| 2. Interview room name/number;
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| 3. Response team contact information (names and phone numbers) and team roles (e.g.,
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| management sponsor, lead, inspector counterpart);
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| 4. Any site access/badging actions needed for each inspector;
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| 5. Any dosimetry actions needed for each inspector;
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| 6. Entrance meeting time and location;
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| 7. Confirmation that the team will have access to a licensee computer with a nearby printer;
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| 8. Confirmation that the team will have Wi-Fi access;
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| 9. Cafeteria location and hours;
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| 10. Inspection response team normal working hours; and
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| 11. Any potential resource conflicts during the inspection (e.g., emergency drills and all-staff
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| meetings).
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| Enclosure
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| III. INFORMATION REQUEST
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| Contact the lead inspector as soon as possible if you have any questions regarding this
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| information request. Provide the information electronically in searchable formats, if possible.
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| The files should contain descriptive names, and be indexed and hyperlinked to facilitate ease of
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| use. Information in lists should contain enough information to be easily understood by
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| someone who has knowledge of light water reactor technology.
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| Important Note: For the purpose of this inspection, POVs are valves with power actuators.
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| Examples include motor-operated valves (MOVs), air-operated valves (AOVs),
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| hydraulic-operated valves (HOVs), solenoid-operated valves (SOVs), and pyrotechnic-operated
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| valves (e.g., squib valves).
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| 1. Information Requested to Support Risk Informed Selections
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| The following information is requested by April 16, 2021, or sooner, to facilitate the initial
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| sample selection.
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| 1.1. List of systems, system numbers/designators, and corresponding system names.
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| 1.2. Probabilistic safety analysis (PSA) system notebooks and latest PSA summary
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| document.
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| 1.3. List of POVs from your site-specific PSA sorted by Risk-Achievement Worth (RAW).
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| Include values for Birnbaum Importance, Risk-Reduction Worth, and Fussell-Veseley
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| (as applicable). The list should include (a) component identification number, including
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| noun name (i.e. descriptive name); (b) applicable plant system; (c) ASME Boiler and
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| Pressure Vessel Code (BPV Code) Class; (d) safety-related or nonsafety-related
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| classification; (e) valve type, size, and manufacturer; and (f) actuator type, size, and
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| manufacturer. If the NRC has granted a license amendment to categorize structures,
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| systems, and component in accordance with 10 CFR 50.69, please provide the Risk
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| Informed Safety Category of the component. (Please provide in Excel.)
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| 1.4. List of corrective action documents related to the POV programs for the last 5 years,
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| including the document identifier and brief description. Provide a separate list for each
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| POV program.
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| 1.5. List of POVs in the Maintenance Rule (a)(1) category for the last 5 years. The list
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| should include a brief description of the surrounding circumstances.
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| 2. Information Requested for Initial Inspection Scoping Activities
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| The following information is requested by June 4, 2021, or sooner, to facilitate the initial
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| sample selection.
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| 2.1. NRC Safety Evaluation Report(s) associated with the In-Service Testing (IST) Program
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| and relief and alternative requests submitted in accordance with 10 CFR 50.55a for
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| POVs. Identify the edition of the ASME Operation and Maintenance of Nuclear Power
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| Plants (OM Code) that is the Code of record for the current 10-year IST Program
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| interval, as well as any self-imposed standards related to the IST Program elements
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| applicable to POVs.
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| 2
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| 2.2. IST Program documents, including implementing procedures, IST plan, and the
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| document that identifies the in-scope valves and the associated IST Program
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| requirements for each valve (e.g., IST valve table identifying category, active/passive
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| function).
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| 2.3. Site (and corporate if applicable) procedures associated with implementation of the
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| POV programs required by 10 CFR 50.55a(b)(3)(ii) and/or ASME OM Code Mandatory
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| Appendix III.
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| 2.4. Joint Owners Group (JOG) MOV program classification evaluation.
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| 2.5. List of any valve removed from a POV program and basis for removal.
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| 2.6. Current list of operator workarounds.
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| 2.7. List of open operability evaluations related to POVs.
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| 2.8. List of permanent plant modifications to POVs completed in the last 5 years. For the
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| purpose of this inspection, permanent plant modifications include permanent: plant
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| changes, design changes, set point changes, equivalency evaluations, suitability
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| analyses, and commercial grade dedications. The list should contain the modification
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| identifier, title, revision/date, the affected system, completion date, and a brief
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| modification description.
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| 2.9. Any self-assessment and/or audit of POV programs completed in the last 5 years.
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| 2.10. Updated Final Safety Analysis Report (in one file), Technical Specifications, Technical
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| Specifications Bases, and Technical Requirements Manual.
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| 2.11. The lead inspector will deliver forms to the licensee point of contact identified in the
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| letter for approximately 30 valves. Fill out the valve characteristics in the form fields. It
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| is possible that not all fields can be completed. For those fields that cannot be filled,
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| leave the fields blank.
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| 2.12. Current management and engineering organizational chart.
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| 3. Information Requested to Support Inspection Preparation Activities
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| The following information is requested by July 23, 2021, or sooner, to facilitate the final
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| inspection preparation.
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| 3.1. All corrective action documents, evaluations, and NRC correspondence, including any
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| associated NRC requests for additional information (RAIs) and Safety Evaluation
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| Report(s), generated in response to the NRC communications listed below. Also, any
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| NRC inspection reports that were conducted to close out the sites associated
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| responses.
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| 3.1.1. Generic Letter (GL) 89-10;
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| 3.1.2. GL 96-05;
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| 3
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| 3.1.3. GL 95-07;
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| 3.1.4. Bulletin 85-03;
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| 3.1.5. Regulatory Issue Summary (RIS) 2000-03; and
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| 3.1.6. GL 88-14.
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| 3.2. Any NRC correspondence regarding the stations POV programs other than the IST
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| Program, including any associated NRC RAIs and any NRC Safety Evaluation
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| Report(s). Identify any self-imposed standards related to these programs.
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| 3.3. Preventive Maintenance (PM) Program document, implementing procedures, and PM
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| templates applicable to POVs.
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| 3.4. Title 10 CFR 50, Appendix J Program document and implementing procedures.
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| 3.5. Corrective Action Program procedures, including the operability/functionality
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| determination procedure.
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| 3.6. Quality Assurance Program document.
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| 3.7. Procedure for addressing issues captured in 10 CFR 21 notifications.
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| 3.8. All emergency and abnormal operating procedures
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| 3.9. For each selected POV, including its actuator (the response should be separated by
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| POV such as by creating a folder for each valve that includes the associated
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| documents):
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| 3.9.1. Procurement and design specifications, and Certificate of Conformance.
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| 3.9.2. Vendor documents addressing installation, operation, and maintenance.
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| 3.9.3. Piping and instrumentation drawings (PI&Ds) for the associated system.
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| 3.9.4. Electrical diagrams, including control logic diagrams.
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| 3.9.5. Valve and actuator component drawings.
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| 3.9.6. System description and/or training documents associated with the POV.
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| 3.9.7. Operations procedures that direct operators to control the valve, including
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| alarm response procedures.
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| 3.9.8. Applicable Maintenance Rule scoping document and the Maintenance Rule
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| performance criteria which would cause the system or component to be
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| moved from (a)(2) status to (a)(1) status. Also, documents (e.g., corrective
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| action and work orders) associated with any instance the POV was placed in
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| (a)(1) status during the last 5 years.
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| 4
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| 3.9.9. List of tests, including technical specification surveillances. The list should
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| identify the test periodicity and test procedure identifier.
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| 3.9.10. Completed tests and surveillances performed during the last 5 years. For
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| those tests and surveillances performed at a periodicity of less than 1 year or
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| greater than 5 years, provide the latest three performed. Include the
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| associated acceptance criteria basis calculations.
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| 3.9.11. Completed preservice testing (PST).
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| 3.9.12. List of applicable PMs. The list should identify the PM periodicity and last
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| completion date, and briefly describe the PM.
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| 3.9.13. Completed PMs performed during the last 5 years, including any post
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| maintenance testing. For those PMs performed at a periodicity of less than
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| 1 year or greater than 5 years, provide the latest three performed.
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| 3.9.14. Corrective maintenance work orders performed on the POV during the last
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| 5 years, including any post maintenance testing.
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| 3.9.15. An all-inclusive list of calculation revisions in effect associated with the POV.
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| The list should include the document identifier, title, and revision number.
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| 3.9.16. Calculations associated with the POV. Data files may be excluded.
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| Calculation examples include (as applicable):
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| * Minimum available and required voltage at transient and steady state;
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| * Thermal overload sizing evaluation;
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| * Critical setpoint calculations (e.g., limit switch settings);
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| * Required thrust/torque;
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| * Maximum allowed leakage;
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| * Maximum differential pressure;
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| * Ambient room temperature under normal and accident conditions;
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| * Environmental qualification (EQ) file;
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| * (For AOVs) Pneumatic supply sizing and setpoint calculations;
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| * System hydraulic calculations;
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| * Pressure locking/thermal binding evaluations; and
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| * Valve weak link/seismic weak link analysis.
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| 3.9.17. History of permanent modifications performed on the POV since installation.
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| Include modification identifier and brief modification description.
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| 3.9.18. List of corrective action documents associated with the POV for the last
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| 5 years. The list should include the document identifier, brief description, and
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| status (e.g., open or completed).
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| 3.9.19. Open and closed operability evaluations originated during the last 5 years.
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| 5
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| 4. Additional Information to Be Provided Onsite
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| 4.1. During the in-office preparation activities, the team may identify additional information
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| needed to support the inspection. The lead inspector may provide a list of the
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| additional information needed during the week of August 2, 2021.
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| 4.2. Information requested to be provided throughout the inspection:
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| 4.2.1. Any corrective action documents generated as a result of the teams
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| questions during this inspection as the documents are generated.
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| 4.2.2. List of questions and/or document requests submitted by the team and their
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| status (e.g., open, closed) sorted by inspector. Provide to each inspector
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| daily 1.5 hours prior to the daily debrief. It is recommended to provide the
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| team leader with a master list sorted by inspector and each inspector with a
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| list containing only the items originated by that inspector.
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| 4.2.3. If available in hardcopy form, one complete set of P&IDs and simplified
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| drawings (e.g., training schematics). If any of these documents is not
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| available in hardcopy form, contact the lead inspector.
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| 6
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| }} | | }} |
