ML21200A047

Audit Plan and Setup of Online Reference Portal for LAR to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors (EPID L-2021-LLA-0105,-0106)

ML21200A047
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/19/2021
From:	Thomas Wengert Plant Licensing Branch IV
To:	Entergy Operations
Wengert T
References
EPID L-2021-LLA-0105, EPID L-2021-LLA-0106
Download: ML21200A047 (7)

Text

July 19, 2021 ANO Site Vice President Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - AUDIT PLAN AND SETUP OF ONLINE REFERENCE PORTAL FOR LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2021-LLA-0105 AND EPID L-2021-LLA-0106)

Dear Sir or Madam:

By applications dated May 26, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML21147A234 and ML21147A264), Entergy Operations Inc.

(Entergy, the licensee), requested that the U.S. Nuclear Regulatory Commission (NRC) modify the licensing basis for Arkansas Nuclear One, Unit 1 (ANO-1), and Arkansas Nuclear One, Unit 2 (ANO-2), respectively. The proposed amendments would modify the ANO-1 and ANO-2 licensing basis by the addition of a license condition that would allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.

To improve the efficiency of the NRC staff reviews, the licensees representatives and the NRC staff have discussed the use of an audit using an online reference portal that would allow the NRC staff and contractors limited read-only access to the basis documents and other reference materials cited in the applications. The NRC staff plans to initially conduct a desk audit to review the documentation provided on the portal. The online reference portal would allow the NRC staff to audit basis documents to determine whether the information included in the documents is necessary to reach a safety conclusion on the application. Documents identified as necessary for analysis of the application will be identified by the NRC staff. The licensee will be formally requested to submit those documents on the NRC docket. Use of the online reference portal is acceptable as long as the following conditions are met:

The online reference portal will be password-protected and passwords will be assigned to those directly involved in the review on a need-to-know basis; The online reference portal will be sufficiently secure to prevent staff from printing, saving, or downloading any documents; and

Conditions of use of the online reference portal will be displayed on the login screen and will require concurrence by each user.

The NRC staff would like to request that the portal be populated with the documents listed in the enclosure to this letter. This is the initial list identified by the NRC staff. The NRC staff may request additional documents during the review, which will be transmitted to you via email. This will help with the preparation for a virtual audit. Please provide the NRC staff with access to the portal and send me the information needed for access, such as username and password, as soon as possible. The conditions associated with the online reference portal must be maintained throughout the duration of the review process. Please provide written confirmation that Entergy agrees to the terms and conditions set forth in this letter.

If you have any questions, please contact me at (301) 415-4037 or by e-mail at Thomas.Wengert@nrc.gov.

Sincerely,

/RA/

Thomas J. Wengert, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368

Enclosure:

Audit Plan cc: Listserv

REMOTE AUDIT PLAN REGARDING RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 DOCKET NOS. 50-313 AND 50-368

1.0 BACKGROUND

By applications dated May 26, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML21147A234 and ML21147A264), Entergy Operations Inc.

(Entergy, the licensee), requested that the U.S. Nuclear Regulatory Commission (NRC) modify the licensing basis for Arkansas Nuclear One, Unit 1 (ANO-1), and Arkansas Nuclear One, Unit 2 (ANO-2), respectively. The proposed amendments would modify the ANO-1 and ANO-2 licensing basis by the addition of a license condition that would allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors. The proposed changes are based on the Nuclear Energy Institute (NEI) 00-04, 10 CFR 50.69 SSC Categorization Guideline, Revision 0, dated July 2005 (ADAMS Accession No. ML052910035).

2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review of the license amendment request (LAR) and to gain insights of the licensees processes and procedures.

Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.

The basis of this remote audit is the licensees LARs for ANO-1 and ANO-2, and the Standard Review Plan Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance (ADAMS Accession No. ML071700658).

The remote audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274). An audit was determined to be the most efficient approach toward a timely resolution of issues associated with this LAR review, since the staff will have an opportunity to minimize the potential for multiple rounds of requests for additional information (RAIs) and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination.

Enclosure

3.0 PURPOSE AND SCOPE The purpose of the remote audit is to gain a more detailed understanding of the licensees process to implement risk-informed categorization and treatment of structures, systems and components (SSCs), as proposed in the LAR. The NRC staff will review internal events and fire probabilistic risk assessment (FPRA) and the risk informed approach implementing 10 CFR 50.69.

The areas of focus for the regulatory audit are the information contained in the licensees submittal, the enclosed audit information needs, and all associated and relevant supporting documentations (e.g., methodology, process information, calculations, etc.). The relevant supporting documents are identified below.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY REMOTE AUDIT The following documentation should be available to the audit team:

1. Internal Events/Internal Flooding PRA and FPRA model self-assessment and full peer review reports.

2. Focused-Scope peer review reports for Internal Flooding, large early release frequency (LERF), and FPRA.

3. Close-out of Facts and Observations using Appendix X reports.

4. Available 10 CFR 50.69 SSC Categorization program procedures (i.e., Categorization review and adjustment process, decision criteria for Independent Decision-Making Panel (IDP), etc.).

5. Plant specific documentation related to PRA model assumptions and sources of uncertainty for the internal events, internal flooding, and the FPRA.

6. Seismic screening notebook using the Electric Power Research Institute Report 3002017583 methodology, if available.

7. PRA notebooks for the modeling of FLEX equipment and FLEX human error probabilities.

8. Any procedural changes made to the fire protection program after issuance of the National Fire Protection Association-805 safety evaluation.

5.0 AUDIT TEAM The members of the audit team are anticipated to be:

Thomas Wengert, Project Manager, NRC (Thomas.Wengert@nrc.gov)

Jeff Circle, APLA1 ,NRC (Jeff.Circle@nrc.gov)

April Pulvirenti, APLA, NRC (April.Pulvirenti@nrc.gov)

Jigar Patel, APLA, NRC (Jigar.Patel@nrc.gov)

De Wu, APLC2, NRC (De.Wu@nrc.gov)

Sunwoo Park, APLC, NRC (Sunwoo.Park@nrc.gov)

David Heeszel, EXHB3, NRC (David.Heeszel@nrc.gov)

Kevin Quinlan, EXHB, NRC (Kevin.Quinlan@nrc.gov)

Mark Wilk, Contractor, PNNL4 (Mark.Wilk@pnnl.gov) 6.0 LOGISTICS After the electronic portal is set up and the documentation is made available to the NRC staff, a virtual audit will be scheduled and conducted remotely. The virtual audit will be conducted via Microsoft Teams or a compatible platform to be agreed upon. Prior to the audit, the NRC staff and contractors will review the portal information and develop audit questions. An entrance briefing will be held at the beginning of the audit and an exit briefing will be held at the end of the audit. The NRC project manager will coordinate with the licensee the audit dates and any identified changes to the schedule and logistics.

7.0 SPECIAL REQUESTS The NRC staff would like access to the documents listed above in Section IV through an online portal that allows the NRC staff and contractors to access documents remotely from July 23, 2021. NRC staff and contractors access to the online portal should be terminated by March 18, 2022.

The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff and contractors have access to the online portal:

The online portal will be password-protected, and separate passwords will be assigned to the NRC staff and contractors who are participating in the audit.

The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information on the online portal.

Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.

User name and password information should be provided directly to the NRC staff and contractors. The NRC project manager will provide Entergy with the names and contact 1

Probabilistic Risk Assessment Licensing Branch A 2

Probabilistic Risk Assessment Licensing Branch C 3

External Hazards Branch 4

Pacific Northwest National Laboratory

information of the NRC staff and contractors who will be participating in the audit. All other communications should be coordinated with 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 site audit. If the NRC staff identifies information during the remote audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee after the completion of the site audit.

ML21200A047 *by e-mail OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DRA/APLA/BC*

NAME TWengert PBlechman (SRohrer for) RPascarelli DATE 7/19/2021 7/19/2021 7/19/2021 OFFICE NRR/DRA/APLC/BC* NRR/DORL/LPL4/BC* NRR/DORL/LPL4-2/PM*

NAME SRosenberg JDixon-Herrity TWengert DATE 7/19/2021 7/19/2021 7/19/2021