ML20302A460

Request for Information for an NRC Triennial Baseline Deisgn Bases Assurance Inspection (Team): Inspection Report 05000237/2021010; 05000249/202101

ML20302A460
Person / Time
Site:	Dresden
Issue date:	10/28/2020
From:	Jorge Corujo-Sandin NRC/RGN-III/DRS/EB2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2021010
Download: ML20302A460 (9)

See also: IR 05000237/2021010

Text

October 28, 2020

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Co., LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR

INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES

ASSURANCE INSPECTION (TEAM): INSPECTION REPORT 05000237/2021010;

05000249/2021010

Dear Mr. Hanson:

On January 11, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin a triennial baseline

Design Bases Assurance Inspection (Team) at Dresden Nuclear Power Station. This inspection will

be performed in accordance with NRC Baseline Inspection Procedure 71111.21M.

The Design Bases Assurance Inspection focuses on the design, maintenance, and operation of risk

significant components with low margin, or associated with an accident scenario, or a specific

system. The inspection also monitors the implementation of modifications to structures, systems,

and components as modifications to one system may also affect the design bases and functioning of

interfacing systems as well as introduce the potential for common cause failures. The components

and modifications to be reviewed during this baseline inspection will be identified as part of the

preparation for the inspection and finalized during the in-office preparation week that occurs prior to

the first onsite inspection week. In addition, operating experience issues, associated with the

component samples, will also be selected for review. The inspection team may request scenarios to

be performed on the simulator. This request would require support from your simulator staff to

validate scenarios, simulator time, and a crew to perform the actions which would most likely occur

during the second onsite week. The team will work closely with your staff early on during the

inspection process to ensure this activity can be accomplished with minimal impact.

The inspection will include 2 weeks onsite. The inspection team will consist of six NRC inspectors

who will focus on engineering/maintenance/operations of the selected components and

modifications. The current inspection schedule is as follows:

Preparation week:

January 4 - 8, 2021

Onsite weeks:

January 11 - 15, 2021; and January 25 - 29, 2021

Experience with previous baseline design/modification inspections of similar depth and length has

shown that this type of inspection is extremely resource intensive, both for the NRC inspectors and

the licensee staff. In order to minimize the inspection impact on the site and to ensure a productive

inspection for both parties, we have enclosed a request for information needed for the inspection.

B. Hanson

-2-

It is important that all of these documents are up-to-date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of the

inspection. Insofar as possible, this information should be provided electronically to the lead

inspector. The information request has been divided into four groups:

The first group lists information necessary for our initial inspection scoping activities. This

information should be provided to the lead inspector no later than November 13, 2020.

The lead inspector will communicate the initial selected set of samples no later than

December 2, 2021.

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

preparation activities. This set of documents should be provided to the lead inspector no

later than December 29, 2020. During the in-office preparation activities, the team may

identify additional information needed to support the inspection.

The third group includes the additional information above as well as plant specific reference

material. This information should be available to the team onsite on January 11, 2021.

The last group includes supporting information to be provided throughout the inspection.

Specifically, corrective action documents and questions developed during the inspection

are requested to be provided as the documents are generated.

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

The lead inspector for this inspection is Mr. J. Corujo-Sandin. We understand that our licensing

contact for this inspection is Mr. D. Walker of your organization. If there are any questions about the

inspection or the material requested in the enclosure, please contact the lead inspector at

630-829-9741 or via e-mail at Jorge.Corujo-Sandin@nrc.gov.

This letter does not contain new or amended information collection requirements subject to the

Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number 3150-0011.

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for

information or an information collection requirement unless the requesting document displays a

currently valid Office of Management and Budget Control Number.

B. Hanson

-3-

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance

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

Sincerely,

/RA/

Jorge Corujo-Sandin, Senior Reactor Engineer

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-237 and 50-249

License Nos. DPR-19 and DPR-25

Enclosure:

Design Bases Assurance Inspection

Document Request

cc: Distribution via LISTSERV

B. Hanson

-4-

Letter to Bryan C. Hanson from Jorge Corujo-Sandin dated October 28, 2020.

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR

INFORMATION FOR AN NRC TRIENNIAL BASELINE DESIGN BASES

ASSURANCE INSPECTION (TEAM): INSPECTION REPORT 05000237/2021010;

05000249/2021010

DISTRIBUTION:

Jessie Quichocho

Richard Skokowski

RidsNrrDorlLpl3

RidsNrrPMDresden Resource

RidsNrrDroIrib Resource

John Giessner

Kenneth OBrien

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML20302A460

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

OFFICE

RIII

NAME

JCorujo-Sandin:mb

via e-mail

DATE

10/28/2020

OFFICIAL RECORD COPY

Enclosure

DESIGN BASES ASSURANCE INSPECTION (TEAMS)

REQUEST FOR INFORMATION

I. ADMINISTRATIVE INSPECTION INFORMATION

Inspection Report Number:

05000237/2021010; 05000249/2021010

Onsite Inspection Dates:

January 11-15, 2021; and January 25-29, 2021

Inspection Procedure:

IP 71111.21M, Design Bases Assurance Inspection (Team)

Lead Inspector:

Jorge Corujo-Sandin, Senior Reactor Inspector, DRS

630-829-9741

Jorge.Corujo-Sandin@nrc.gov

Teammates:

Jamie Benjamin, Senior Reactor Inspector, RIII/DRS

Robert Daley, Senior Reactor Inspector, RIII/DRS

Mel Holmberg, Senior Reactor Inspector, RIII/DRS

Joon Park, Reactor Inspector, RIII/DRS

Kevin Barclay, Reactor Inspector, RIII/DRS

II. LOGISTICS

Email the following inspection logistics to the lead inspector by December 11, 2020, or sooner:

1. Entrance meeting time and location.

2. Current management and engineering organizational chart.

3. Response team contact information (names and phone numbers) and team roles (e.g.,

management sponsor, lead, inspector counterpart).

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

meetings).

Due to the ongoing COVID-19 situation, additional logistics related with inspector presence on-site

will be coordinated closer to the actual start of the inspection. Reach out to the Team Lead for

questions or comments.

III. INFORMATION REQUEST

Contact the lead inspector as soon as possible if you have any questions regarding this

information request. Provide the information electronically in pdf files, Excel, or other searchable

formats, preferably via an electronic sharing service (CERTREC, ShareFile, Box, etc.). If you do

not have access to any of these services or similar, we can provide you access to Box, which

can be used to upload/download and share documents. The files should contain descriptive

names and be indexed and hyperlinked to facilitate ease of use. Information in lists should

contain enough information to be easily understood by someone who has knowledge of light water

reactor technology.

2

1. Information Requested for Selection of Components/Modifications

The following information is requested by November 13, 2020, or sooner, to facilitate the initial

sample selection.

1.1. Risk-ranking of top 250 components from your site-specific probabilistic safety

analysis (PSA) sorted by Risk-Achievement Worth (RAW). Include values for

Birnbaum Importance, Risk-Reduction Worth, and Fussell-Veseley (as applicable).

Provide any basic event mapping used to develop the ranking of components.

1.2. Risk-ranking of top 100 containment-related components (i.e. Large Early Release

Frequency (LERF)) from your site-specific PSA sorted by RAW. See examples in

Inspection Manual Chapter 0609, Appendix H, Table 4.1, Containment-Related

SSCs Considered for LERF Implications. Provide any basic event mapping used to

develop the ranking of components.

1.3. Provide a list of the top 200 cut-sets from your PSA. Provide the descriptions of the

basic events in the list of cut-sets.

1.4. Provide a list of the top 100 cut-sets for each initiator modeled in the PSA that

contributes more than 5 percent to the baseline plant core damage frequency.

1.5. Copies of PSA system notebooks, Human Error Reliability Analysis Notebook, and

latest PSA summary document.

1.6. If you have an External Events or Fire PSA Model, provide the information requested

in Items 1 and 2 for external events and fire. Provide narrative description of each

coded event (including fire, flood zone description).

1.7. Provide copies of the emergency operating procedures and abnormal operating

procedures.

1.8. Electronic copy of the site Individual Plant Examination of External Events, if

available.

1.9. Provide the in-service testing program (IST) document identifying the in-scope valves

and pumps, and the associated IST program requirements for each component (e.g.,

IST valve table identifying category, active/passive function).

1.10. List of high-risk Maintenance Rule systems/components based on engineering or

expert panel judgment (i.e., those systems/components not identified high risk in the

PSA).

1.11. Structures, systems, and components (SSCs) in the Maintenance Rule (a)(1)

category for the last 3 years.

1.12. A list of operating experience evaluations for the last 3 years.

1.13. Information of any common cause failure of components experienced in the last

5 years at your facility.

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1.14. List of Root Cause Evaluations associated with component failures or design issues

initiated/completed in the last 5 years.

1.15. List of open operability evaluations.

1.16. List of permanent plant modifications to SSCs that are field work complete. For the

purpose of this inspection, permanent plant modifications include permanent:

1.16.1 Plant changes, design changes, set point changes, completed in the last 5 years;

1.16.2 Equivalency evaluations, suitability analyses, and commercial grade dedications

completed in the last 3 years;

1.16.3 Procedure changes for Emergency Operating Procedures (EOPs), Abnormal

Operating Procedures (AOPs), surveillances, and test procedures in the last

3 years; and

1.16.4 Calculation changes that have been issued for use in the last 3 years.

Note: Items 1.16.1. through 1.16.4. should be provided as separate, individual lists and

each list should contain the number of each document, title, revision/date, and the affected

system.

1.17. List of all time critical and/or risk significant operator actions. Identify those actions

that do not have job performance measures.

1.18. Copies of procedures addressing the following: modifications, design changes, set

point changes, equivalency evaluations or suitability analyses, commercial grade

dedications, and post-modification testing.

1.19. A list of corrective action documents (open and closed) in the last 3 years that

address permanent plant modifications issues, concerns, or processes. These

documents should also include the corrective action documents associated with the

modification implementation.

1.20. Electronic copies of Updated Final Safety Analysis Report, Technical Specifications,

Technical Specifications Bases, and Technical Requirements Manual.

1.21. Electronic copies of simplified plant drawings (if available). Note: these may be

uncontrolled documents such as big notes, training diagrams, etc.

2. Information Requested (for the approximate 7 selected components and 7

selected modifications) to be Available by December 29, 2020, (will be reviewed

by the team in the Regional office during the week of January 4, 2021).

This information should be separated for each selected component or modification, especially

if provided electronically (e.g., folder with component or modification name that includes

calculations, condition reports, maintenance history, etc.). Items 2.1-2.16 are associated with

the selected components and item 2.17 for the selected modifications.

2.1. List of condition reports (corrective action documents) associated with each of the

selected components for the last 6 years.

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2.2. The maintenance history (corrective, preventive, and elective) associated with each

of the selected components for the last 10 years. Identify frequency of preventive

maintenance activities.

2.3. Aging Management Program documents applicable to each selected component.

2.4. Copies of calculations associated with each of the selected components, excluding

data files. [Pipe stress calculations excluded from this request].

2.5. Provide an all-inclusive list of calculation revisions in effect associated with each of

the selected components. Include document number, title, and revision number.

2.6. Electronic copies of electrical drawings (ac and dc) and key diagrams.

2.7. Electronic copy of Piping and Instrumentation Drawings (P&IDs) (if available).

2.8. System Health Reports, System Descriptions, Design Basis Documents, and/or

Training Lesson Plans associated with each of the selected components.

2.9. A list of modifications, including equivalency evaluations and setpoint changes,

associated with each of the selected components. This list should include a

descriptive paragraph on the purpose of the modification. Please ensure this list only

includes design completed (not canceled) modifications.

2.10. Copies of operability evaluations (open/closed for last 3 years) associated with each

of the selected components and plans for restoring operability, if applicable.

2.11. Copies of selected operator work-around evaluations associated with each of the

selected components and plans for resolution, if applicable.

2.12. Copies of any open temporary modifications associated with each of the selected

components, if applicable.

2.13. Trend data on the selected electrical/mechanical components performance for last

3 years (For example, pumps performance including in-service testing, other vibration

monitoring, oil sample results, etc., for valves: stroke time and leak rate results,

diagnostic trend data, etc.).

2.14. Provide copies of the normal and alarm response procedures associated with the

selected components and selected scenarios.

2.15. Procedures addressing time critical and/or risk significant operator actions.

2.16. Completed tests and surveillances for each selected component performed during

the last 3 years. For those tests and surveillances performed at a periodicity of

greater than 3 years, provide the latest two performed. Include the associated

acceptance criteria basis calculations.

2.17. For each of the selected modifications, copies of associated documents such as

modification package, engineering changes, 50.59 screening or evaluation,

calculations, post-modification test packages, corrective action documents, design

drawings, preventive maintenance requirements and procedures, etc.

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

determination procedure.

2.19. Quality Assurance Program document/procedure.

2.20. A copy of any internal/external self-assessments and associated corrective action

documents generated in preparation for the inspection.

2.21. A copy of engineering/operations related audits completed in the last 2 years.

3. Additional Information to be Provided on January 11, 2021 Onsite (for final

selected components and modifications)

3.1. During the in-office preparation activities, the team will be making final selections and

may identify additional information needed to support the inspection.

3.2. Schedule of any testing/maintenance activities to be conducted on the selected

components during the two onsite inspection weeks.

4. Information Requested to be Provided Throughout the Inspection

4.1. Any corrective action documents generated as a result of the teams questions during

this inspection as the documents are generated.

4.2. List of questions and/or document requests submitted by the team and their status

(e.g., open, closed) sorted by inspector. Provide daily by 2:15 p.m. to each inspector.

It is recommended to provide the team leader with a master list sorted by inspector

and each inspector with a list containing only the items originated by that inspector.

4.3. If available in hardcopy form, one complete set of P&IDs and simplified drawings (e.g.,

training schematics). If any of these documents is not available in hardcopy form,

contact the lead inspector.

4.4. Please ensure that other supporting documents for the selected items have been

located and are readily retrievable as the inspection team will likely be requesting

these documents during the inspection. Examples of supporting documents are:

4.4.1

Individual Plant Examination/Probabilistic Risk Assessment report;

4.4.2

Procurement documents for components and modifications selected (verify

retrievable);

4.4.3

Plant procedures (normal, abnormal, emergency, surveillance, etc.);

4.4.4

Vendor manuals;

4.4.5

Historical revisions of the Final Safety Analysis Report; and

4.4.6

Copy of electrical drawings, key diagrams and isometrics (paper copies).

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