IR 05000352/2024011

Information Request to Support Post-Approval Site Inspection for License Renewal; Inspection Report 05000352/2024011

ML24031A010
Person / Time
Site:	Limerick
Issue date:	01/31/2024
From:	Mel Gray NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2024011
Download: ML24031A010 (1)

Text

January 31, 2024

SUBJECT:

LIMERICK GENERATING STATION, UNIT 1 - INFORMATION REQUEST TO SUPPORT POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL; INSPECTION REPORT 05000352/2024011

Dear David Rhoades:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC) Region I staff will conduct a license renewal post-approval inspection at your Limerick Generating Station, Unit 1. Kevin Mangan, a Senior Reactor Inspector from the NRCs Region I office, will lead the inspection team. The inspection will be conducted in accordance with Inspection Procedure 71003, Post-Approval Site Inspection for License Renewal, dated August 11, 2023, (ADAMS Accession No. ML22245A071). This inspection is described as a Phase 2 license renewal inspection in the referenced inspection procedure and is conducted three months to one year prior to the plant entering its period of extended operation.

The inspection will assess the adequacy of the planned and/or completed activities and programs described in the regulatory commitments and license conditions added as part of your renewed license. This inspection will also evaluate the need for additional follow-up inspections (Phase 3) under Inspection Procedure 71003 or as part of the Reactor Oversight Program. Finally, an inspector has completed a license renewal inspection - Phase 1 (IR 05000352/2022002), in April 2022, performed to observe implementation of aging management programs and activities that are only accessible during a scheduled plant outage.

This onsite Phase 2 inspection is scheduled for the weeks of June 10 and June 24, 2024.

In order to minimize the impact on the site and to ensure a productive inspection for both parties, we have enclosed a request for information needed for the inspection. It is important that 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 two groups: * The first group lists information necessary for our initial inspection scoping and in-office preparation activities. During the in-office preparation activities, the team will identify as much as possible the information and activities to be reviewed during the inspection.

This information should be provided to the lead inspector by March 22, 2024.

• The second group includes the additional information required for the team to review the selected activities. This information should be provided to the team by May 31, 2024, or made available upon arrival onsite, as appropriate.

If there are any questions about the inspection or the information requested in the enclosure, please do not hesitate to contact the lead inspector at 610-337-5234 or via email at Kevin.Mangan@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.

This letter and its enclosure will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Digitally signed by Melvin Melvin K. K. Gray Date: 2024.01.31 Gray 11:41:52 -05'00'

Mel Gray Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000352 License No. NPF-39 Enclosure:

Information Request Post-Approval Site Inspection for License Renewal - Phase 2 cc w/ encl: Distribution via LISTSERV

ML24031A010 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DORS RI/DORS NAME KMangan MGray DATE 1/30/2024 1/30/2024

Information Request Post-Approval Site Inspection for License Renewal - Phase II Inspection Report: 05000352/2024011 Onsite Inspection Dates: June 10, through June 14, and June 24, through June 28, 2024 Inspection Procedure: Inspection Procedure 71003, Post-Approval Site Inspection for License Renewal Lead Inspector: Kevin Mangan, Senior Reactor Inspector 610-337-5234, Kevin.Mangan@nrc.gov Information Request Prior to the On-site Inspection Weeks I. General Information for Inspection Preparation The following information is requested by March 22, 2024, or sooner, to facilitate inspection preparation. This section of the request identifies general information that will help the inspectors to understand the applicable administrative procedures and overall completion status of license renewal activities. As such, the information requested herein is not aimed to a particular regulatory commitment, license condition, aging management program (AMP), or time-limited aging analysis (TLAA).

Contact the lead inspector as soon as possible if you have any questions regarding this information request. Please provide the information electronically in pdf files, Excel, or other searchable formats, preferably on some portable electronic media or web access site. The files should contain descriptive names, be indexed, and hyperlinked to facilitate ease of use. Information in lists should contain enough information to be easily understood by someone who has knowledge of light water reactor technology.

(1) Sections of the quality assurance program manual applicable to license renewal activities. Include any QA program changes made to implement license renewal commitments.

(2) Copies of the following procedures:

• Correction Action Program

• Operating Experience

• Regulatory Commitment Change Process (3) Updated Final Safety Analysis Report (UFSAR) supplement for license renewal submitted with the license renewal application (LRA), including the latest version of the UFSAR supplement submitted to the NRC per 10 CFR 50.71.

(4) Post-approval evaluations or assessments performed to verify that in-scope structures, systems, or components (SSCs) were not excluded from the LRA and appropriate aging management has been considered in accordance with 10 CFR 54.37(b).

Enclosure

(5) List of plant modifications with a brief description of the modifications scope that were approved and/or implemented from the date the LRA was submitted to the date the renewed license was issued.

(6) Self-assessments that may have been performed after the renewed license was issued associated with the implementation of license renewal commitments, including AMPs and TLAAs.

(7) Gap analyses that may have been performed to assess the differences between the current AMPs and the recommendations in the latest revision of NUREG-1801, Generic Aging Lessons Learned (GALL), and subsequent NRC Interim Staff Guidance.

(8) Site-specific responses and/or evaluations for NRC communications associated with license renewal that were issued after the renewed license was granted.

(9) List of your license renewal commitments with a description of the overall completion status of action items associated with each commitment, including AMPs and TLAAs.

(10) Description of administrative controls that will be used to ensure that all activities due prior to (and during) the period of extended operation (PEO) will be satisfactorily completed as described in the license renewal documents.

(11) Description of plans or processes that would be used during the PEO to continuously incorporate operating experience into license renewal activities.

(12) Internal/external self-assessment that may have been conducted and associated corrective action documents generated in preparation for this inspection.

(13) License renewal organizational chart and points of contact for this inspection, including the appropriate regulatory assurance, engineering, and license renewal staff.

II. Information Requested to Be Available by May 30, 2024 (Specific Requests for each License Renewal Commitment, including associated AMP and TLAA)

The following information should be separated for each regulatory commitment, especially if provided electronically (e.g., a folder for each commitment named after the commitment that includes the information requested below). The commitment should include the associated AMP and TLAAs. This section is focused on documentation demonstrating completion of each specific license renewal commitment.

(1) Program basis documents and administrative procedures describing key program attributes such as program objectives, scope, detection and monitoring methods, administrative controls, acceptance criteria, corrective actions, and scope expansion requirements.

(2) Implementing procedures for program activities (e.g., visual examination

Information Request Post-Approval Site Inspection for License Renewal - Phase II procedures, ultrasonic examination procedures, maintenance procedures, system walkdowns, etc).

(3) Updated license renewal scoping drawings showing the SSCs within the scope of the AMP.

(4) Applicable sections of the LRA and the NRCs safety evaluation report.

(5) Applicable Requests for Additional Information issued by NRCs technical reviewers during the review of the LRA and corresponding responses.

(6) Copy of or ready access to the key industry standards that will be followed during the PEO for the implementation of the program (e.g., American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Electric Power Research Institute Guidelines, Nuclear Energy Institute Guidelines, etc).

(7) Description of changes made to the license renewal commitment, including the associated technical and regulatory evaluations supporting the change.

(8) Description of activities completed to meet license conditions, license renewal commitments, and the UFSAR. For example, this should include completed Work Orders with associated inspection reports describing the work done and the results of the inspection.

(9) Description of instances where examination scope expansion was required based on the initial examination of an SSC for license renewal. Please describe the logic to select the scope expansion, and any resulting changes to the AMP.

(10) Description of instances where examination scope changes were required based on limitations encountered during the initial examination of an SSC for license renewal. Please describe the actions taken, and any resulting changes to the AMP.

(11) Description of pending activities due prior to the PEO, which are necessary to meet license conditions, license renewal commitments, and the activities described in the UFSAR. For example, this may include a list of pending Work Orders with a brief description of the work to be performed.

(12) Copy of any correspondence between the licensee and the NRC, after the license was issued, associated with regulatory issues affecting the license renewal commitment. For example, this may include notifications of commitment changes, or license amendment requests, affecting a license condition or a license renewal commitment.

(13) List of Corrective Action Program documents (e.g., Condition Reports)

associated with the implementation of the AMP. This includes unacceptable aging effects identified during the implementation of license renewal activities and programmatic deficiencies requiring resolution.

Information Request Post-Approval Site Inspection for License Renewal - Phase II (14) Copy of evaluations performed for applicable external/internal Operating Experience issues associated with license renewal. This request is limited to Operating Experience items issued after the renewed operating license was granted.

III. Information Requested to be Provided Throughout the Inspection (1) Access to any corrective action documents generated as a result of the teams questions or queries during this inspection.

(2) Access to the list of questions submitted by the team members and the status/resolution of the information requested (please provide daily during the inspection to each team member).

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