ML22346A000

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Summary of November 3, 2022, Meeting with Constellation to Discuss Planned License Amendment Requests to Adopt TSTF-505 and 10 CFR 50.69
ML22346A000
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 12/14/2022
From: Richard Guzman
NRC/NRR/DORL/LPL1
To:
Constellation Energy Generation
References
EPID L-2022-LRM-0087
Download: ML22346A000 (1)


Text

1 December 14, 2022 LICENSEE:

Constellation Energy Generation, LLC FACILITY:

Nine Mile Point Nuclear Station, Unit 1

SUBJECT:

SUMMARY

OF NOVEMBER 3, 2022, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC TO DISCUSS PLANNED LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-505, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B, AND 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS, AT NINE MILE POINT NUCLEAR STATION, UNIT 1 (EPID L-2022-LRM-0087)

On November 3, 2022, an observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Constellation Energy Generation, LLC (CEG, the licensee) via Microsoft TEAMS meeting application. The purpose of the meeting was to discuss the licensees planned license amendment requests (LARs) to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-505, Provide Risk-Informed Extended Completion Times -

RITSTF [Risk-Informed TSTF] Initiative 4b, and Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69, Risk-informed categorization and treatment of structures, systems and components (SCC) for nuclear power reactors, at Nine Mile Point Nuclear Station, Unit 1 (NMP1).

The meeting notice and agenda, dated October 20, 2022, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22305A595. A list of attendees is provided as an enclosure to this meeting summary.

The licensee presented information (ML22301A013) regarding its planned license amendment requests (LARs). The licensees presentation included an overview of its planned LARs to adopt risk-informed completion times based on TSTF-505-A, Revision 2, and 10 CFR 50.69 risk-informed categorization of SSCs based on Nuclear Energy Institute 00-04.

The NRC staff queried the licensee throughout the presentation and discussed the following:

The NRC staff noted that one of the licensees listed plant-specific variances from TSTF-505 (on slide 4 of the licensees presentation) was not applicable to the model required actions in NUREG-1433 and to confirm that all proposed variances in the LAR are appropriately applied to the correct NUREG. The licensee indicated that all proposed variations specific to NMP1 are still in final technical review and will be verified prior to submission of the application. The licensee also acknowledged that the high-pressure core spray system is applicable to NUREG-1434 and that the stated variation was in error (i.e., the high-pressure injection system is applicable to NMP1).

In reference to the licensees discussion on fire probabilistic risk assessment (PRA) model technical adequacy, the NRC staff suggested that the application include changes NMP1 made since completing its transition to the National Fire Protection Association (NFPA)

Standard 805, Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants. The licensee stated that the model has been peer reviewed to Regulatory Guide 1.200, Revision 2 and the facts and observation (F&O) closure review has been performed. The licensee intends to discuss four open finding F&Os in their submittal.

The NRC staff inquired about the overall steps involved in the licensees proposed seismic penalty method and emphasized the use of plant-specific information in supporting the licensees method. The staff asked whether the penalty factor is a configuration-specific penalty or a general seismic penalty. The licensee explained that the penalty is the same penalty factor applied for other applicable CEG plant applications. Regarding external hazards, extreme wind or tornado/missiles, the licensee explained that they intend to submit a high winds safe shutdown equipment list for the 10 CFR 50.69 application. The licensee also noted that while its screening review for this hazard is still being finalized, the preliminary approach is to apply the progressive screening (PS3) criterion (design basis event mean frequency of less than 1E-5/year and the mean conditional core damage probability is less than 0.1).

The NRC staff inquired about the licensees external hazards screening process for seismic risk and requested that the licensee confirm in their application that while NMP1 may satisfy the EPRI Tier 1 plant criteria, the licensee should confirm in their application that seismic risk is low relative to total risk. The licensee explained that they have looked at relative risk for seismic for NMP1 (similar to the approach they took for Nine Mile Point Nuclear Station, Unit 2) and confirmed that core damage frequency is very low. The licensee indicated that large early release frequency is also low and similar to the results of Clinton Power Station.

Specifically, the licensee explained that the seismic relative risk contribution was comparable to that used for the 10 CFR 50.69 LAR for Clinton, which was recently reviewed and approved by the NRC staff (ML21090A193).

The NRC staff inquired about the licensees FLEX (diverse and flexible mitigation strategies) equipment whether it was credited and requested if credited, to provide description in the LAR. The licensee explained that they do have modeled FLEX components (e.g., portable pumps, portable diesel generators and battery chargers) and intend to provide a detailed explanation of it impacts and of how each is credited in their application.

The staff also asked if the licensee credits other fire PRA methods that may have not been fully updated over the years. The licensee explained that they have included the latest heat release rates and ignition frequencies from the applicable NUREG in their latest fire PRA update.

The licensee stated that it will submit separate applications for TSTF-505 and 10 CFR 50.69.

The licensee expects to submit both LARs by the end of December 2022 and will request approval within 1 year.

Members of the public were not in attendance. No regulatory decisions or commitments were made at the meeting. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-1030, or by email at Richard.Guzman@nrc.gov.

/RA/

Richard V. Guzman, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220

Enclosure:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES NOVEMBER 3, 2022, MEETING BETWEEN THE NUCLEAR REGULATORY COMMISSION AND CONSTELLATION ENERGY GENERATION, LLC REGARDING PLANNED LICENSE AMENDMENT REQUEST TO ADOPT TSTF-505, RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4b AND 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS, FOR FOR NINE MILE POINT NUCLEAR ONE, UNIT 1 ATTENDEES AFFILIATION/ORGANIZATION Brian Wittick U.S. Nuclear Regulatory Commission (NRC)

Rich Guzman NRC Mihaela Biro NRC Jonathan Evans NRC Alexander Schwab NRC Jeff Circle NRC Jigar Patel NRC Jay Robinson NRC Wesley Wu NRC Henry Wagage NRC Andrea Russell NRC Khadijah West NRC Chris Jackson NRC Fred Forsaty NRC Gurjendra Bedi NRC Robert Hsu NRC Steve Wyman NRC Adakou Foli NRC Vijay Goel NRC Hang Vu NRC Ming Li NRC Bob Davis NRC Karen Sida NRC

ATTENDEES AFFILIATION/ORGANIZATION Bart Fu NRC John Tsao NRC Dan Widrevitz NRC Carol Moyer NRC Kamishan Martin NRC Jeff Stone Constellation Energy Generation, LLC (Constellation)

Suzanne Loyd Constellation Ron Reynolds Constellation Jeremy Aiello Constellation Brandon Schultz Constellation Denise Wolniak Constellation Dan Morley Constellation Don Vanover Jensen Hughes (Contractor to Constellation)

Jeff Schappaugh Jensen Hughes Bob Kirchner Jensen Hughes Arfa Butt Jensen Hughes Rob Michel Jensen Hughes Chris Pupek Jensen Hughes Chris Seip Jensen Hughes Leo Shanley Jensen Hughes Ed Parsley Jensen Hughes David Passehl Jensen Hughes Kevin Huynh Jensen Hughes

Meeting Summary: ML22346A000 Meeting Notice: ML22305A595 Meeting Presentation: ML22301A013

  • by email OFFICE NRR/DORL/LPL1/PM*

NRR/DORL/LPL1/LA*

NRR/DRA/APLA/BC*

NAME RGuzman KEntz RPascarelli DATE 12/9/2022 12/12/2022 12/12/2022 OFFICE NRR/DORL/LPL1/BC*

NRR/DORL/LPL1/PM*

NAME HGonzalez RGuzman DATE 12/14/2022 12/14/2022