ML20295A495
| ML20295A495 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/27/2020 |
| From: | Joel Wiebe NRC/NRR/DORL/LPL3 |
| To: | Nicely K Exelon Generation Co |
| References | |
| Download: ML20295A495 (7) | |
Text
From:
Wiebe, Joel Sent:
Thursday, August 27, 2020 1:39 PM To:
Nicely, Ken M.:(GenCo-Nuc) (ken.nicely@exeloncorp.com)
Subject:
NRC Preliminary Audit Plan for Clinton TSTF-505 and 5j0.69 Submittals Attachments:
EPID-L-2020-LLA-0097 - Clinton TSTF-505 and 50.69 Audit Plan.docx
Hearing Identifier:
NRR_DRMA Email Number:
849 Mail Envelope Properties (BLAPR09MB6674C976D07EEFD02C21899F8B550)
Subject:
NRC Preliminary Audit Plan for Clinton TSTF-505 and 5j0.69 Submittals Sent Date:
8/27/2020 1:39:17 PM Received Date:
8/27/2020 1:39:00 PM From:
Wiebe, Joel Created By:
Joel.Wiebe@nrc.gov Recipients:
"Nicely, Ken M.:(GenCo-Nuc) (ken.nicely@exeloncorp.com)" <ken.nicely@exeloncorp.com>
Tracking Status: None Post Office:
BLAPR09MB6674.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 0
8/27/2020 1:39:00 PM EPID-L-2020-LLA-0097 - Clinton TSTF-505 and 50.69 Audit Plan.docx 57438 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Audit Plan by the Office of Nuclear Reactor Regulation To Support the Review of a License Amendment Request To Adopt TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times Risk-Informed Technical Specifications Task Force Initiative 4b Clinton Nuclear Generating Plant Docket No. 50--461 1.0
Background
By letters dated April 30, 2020, Exelon Generating Company, LLC (hereafter, Exelon) submitted license amendment requests for the Clinton Nuclear Generating Plant (References 1 and 2). The proposed amendment would modify the plants licensing basis to allow implementation of a traveler prepared by the Technical Specification Task Force (TSTF), specifically TSTF-505, Revision 2, Provide Risk-informed Extended Completion TimesRITSTF Initiative 4b (TSTF-505, Reference 3). The staff of the Office of Nuclear Reactor Regulation (NRR) in the U.S. Nuclear Regulatory Commission (NRC) has initiated a review of the submittal in accordance with NRR Office Instruction LIC-101, "License Amendment Review Procedures" (Reference 5).
The NRC staff has determined that a regulatory audit of the license amendment request (LAR) should be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits (Reference 6). This will enable the staff to gain a better understanding of the licensee's proposed program to implement risk-informed completion times for certain technical specifications.
2.0 Audit Bases A regulatory audit is a planned, license-or regulation-related activity that includes the examination and evaluation of information that is not on the docket. The basis for the review is the licensees LAR for Clinton and the NRCs Standard Review Plan Section 19.2 (Reference 7). The staff has determined an audit will be the most efficient path to a timely resolution of issues associated with this LAR review. It is intended to avoid unnecessary burden on the licensee by preventing the generation of requests for additional information (RAIs) when that information is not needed to make a safety determination. Furthermore, interaction to clarify what information is needed should avoid RAI responses that fall short of the staffs needs. In this way, followup requests should be minimized.
3.0 Objectives The LARs are to adopt 10 CFR 50.69 and TSTF-505, allowing certain technical specifications to incorporate a risk-informed completion time (RICT). These are the objectives of the audit:
Learn how the licensee's proposed program implements TSTF-505 and conforms to NRC-endorsed guidance from the Nuclear Energy Institute (NEI). Specifically, the program will be evaluated against NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification Guidelines (Reference 8).
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the staff's understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Evaluate the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Learn whether the proposed configurations challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform them. All configurations allowable under the proposed technical specifications should be considered.
Identify supplemental information the licensee might choose to submit to help the staff reach a licensing or regulatory decision. Identify questions that may become RAls.
4.0 Scope and Necessary Information The audit will be conducted remotely: a virtual audit over several weeks using Internet access as described in Section 7.0 with several days scheduled for presentation, questions, and discussion.
The areas of focus for the regulatory audit are (a) the information contained in the LAR, (b) documentation needs identified in this section of the audit plan, (c) an overview presentation on the program procedures including those for determining risk management actions, (d) demonstration of the process for calculating RICT (including use of the configuration risk management program tool).
The team will review the PRA methods used to determine the risk impact from which the revised completion times are obtained. Assessments include the internal events and fire PRAs. The quantification of risk from significant external events will also be evaluated, whether PRA or bounding methods are used.
The team will discuss questions prepared in advance of the audit. The team may also develop new questions arising from those discussions, from the review of documents, and from evaluation of methods used by the licensee.
All relevant supporting documentations should also be made available to the audit team (e.g.,
methodology, process information, and calculations), including the following documentation:
- 1. closure reports on facts and observations (F&O) from the independent assessments conducted on the internal events, internal flooding, and fire PRAs
- 2. any draft or final RICT program procedures (e.g., for risk management actions and recording limiting conditions for operation)
- 3. for the internal events, internal flooding, and fire PRAs, plant-specific documentation related to the review of the PRA model assumptions and sources of uncertainty identification of key assumptions and sources of uncertainty for the application
- 5. other documentation that Exelon determines to be responsive to the staffs information requests 5.0 Logistics The audit will be conducted from September 14, 2020 to September 17, 2020 through remote online access (electronic portal, ePortal, electronic reading room) established by Exelon. A session for presentations, review of audit questions, and discussion will be scheduled using a mutually acceptable platform. This session is expected to last three days, but it will be extended if necessary. NRC staff and contractors access to the online portal should be continued until the audit report has been completed.
6.0 Team and Review Assignments The audit will be conducted by the following NRC staff and contractors from Pacific Northwest National Laboratory (PNNL). Other NRC staff may participate by conference call.
Joel Wiebe, Project Manager Jonathan Evans, Technical Reviewer, Team Leader Adrienne Brown, Technical Reviewer Robert Vettori, Technical Reviewer Keith Tetter, Technical Reviewer Alissa Neuhausen, Technical Reviewer Hanry Wagage, Technical Reviewer Vijay Goel, Technical Reviewer Derek Scully, Technical Reviewer Khadijah West, Technical Reviewer Norbert Carte, Technical Reviewer Joseph Ashcraft, Technical Reviewer Mark Wilk, Technical Reviewer (PNNL)
Garill A. Coles, Technical Reviewer (PNNL)
Steve M. Short, Technical Reviewer (PNNL) 7.0 Special Requests The NRC requests access to the documents listed in Section 4 through an online portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
User name and password information should be provided directly to members of the NRC staff and contractors. The NRC project manager will provide EXELON the names and contact information of the NRC staff and contractors who will be participating in the audit.
All other communications should be coordinated through the NRC project manager.
8.0 Deliverables An audit summary, which may be public, will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee.
9.0 References
- 1. Letter from Patrick R. Simpson to the U.S. Nuclear Regulatory Commission, License Amendment Request: Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, dated April 30, 2020, (Accession No. ML20121A178 in the Agencywide Documents Access and Management System (ADAMS))
- 2. Letter from Patrick R. Simpson to the U.S. Nuclear Regulatory Commission, Application to Adopt 10 CFR 50.69, "Risk-informed categorization and treatment of structures, systems, and components for nuclear power reactors", dated April 30, 2020, (ADAMS Accession No. ML20121A241)
- 3. Letter from U.S. Nuclear Regulatory Commission to Technical Specifications Task Force, Final Revised Model Safety Evaluation of Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 48, dated November 21, 2018 (ADAMS Package Accession No. ML18269A041).
- 4. Nuclear Energy Institute, NEI 00-04, Revision 0, 10 CFR 50.69 SSC Categorization, dated July 2005 (ADAMS Accession No. ML052910035
- 5. U.S. Nuclear Regulatory Commission, NRR Office Instruction LIC-101, Revision 5, License Amendment Review Procedures, dated January 9, 2017 (ADAMS Accession No. ML16061A451).
- 6. U.S. Nuclear Regulatory Commission, NRR Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274).
- 7. U.S. Nuclear Regulatory Commission, Standard Review Plan (NUREG-0800)
Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific changes to the Licensing Basis: General Guidance, June 2007 (ADAMS Accession No. ML071700658).
- 8. NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification Guidelines, dated November 2006 (ADAMS Accession No. ML12286A322).