ML23094A183
| ML23094A183 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 04/18/2023 |
| From: | Klos L NRC/NRR/DORL/LPL2-1 |
| To: | Treadway R Duke Energy Carolinas |
| References | |
| EPID L-2023-LLA-0021, EPID L-2023-LLA-0022 | |
| Download: ML23094A183 (1) | |
Text
April 18, 2023 Mr. Ryan Treadway Director - Nuclear Fleet Licensing Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078
SUBJECT:
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 - REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-505, REVISION 2, 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, (EPID L-2023-LLA-0021 AND EPID L-2023-LLA-0022)
Dear Mr. Treadway:
By letters dated February 16 and 17, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23047A465 and ML23048A022), respectively, Duke Energy Carolinas, LLC (the licensee, Duke Energy) submitted license amendment requests (LARs) to amend the licenses for McGuire Nuclear Station, Units 1 and 2, Renewed Facility Operating License Nos. NPF-9 and NPF-17, respectively. The proposed LARs would adopt Technical Specifications Task Force Traveler 505, Revision 2, Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b (TSTF-505) and adopt 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 U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the SNCs non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit in person and virtually via Teams using a licensee-established electronic portal available to NRC staff from approximately during a two-week period between May 1, 2023, through October 23, 2023, with formal audit meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.
R. Treadway If you have any questions, please contact me by telephone at 301-415-5136 or by email to John.Klos@nrc.gov.
Sincerely,
/RA/
L. John Klos, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370
Enclosures:
- 1. Audit Plan
- 2. Audit Requests cc: Listserv
ML23094A183 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DRA/APLA/BC NAME JKlos KGoldstein RPascarelli DATE 4/10/2023 4/18/2023 4/11/2023 OFFICE NRR/DRA/APLC/BC NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME SVasavada MMarkley JKlos DATE 4/10/2023 4/18/2023 4/18/2023 REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUESTS TO ADOPT RISK INFORMED COMPLETION TIMES - TSTF-505 AND 10 CFR 50.69 RISK-INFORMED CATEGORIZATION OF SSCs DUKE ENERGY CAROLINAS, LLC MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370
1.0 BACKGROUND
By letters dated February 16 (Reference 1) and February 17, 2023 (Reference 2), Duke Energy Carolinas, LLC (Duke Energy) submitted license amendment requests (LARs) for McGuire Nuclear Station, Units 1 and 2 (McGuire). Reference 1 would modify the McGuire Technical Specifications (TSs) to permit the use of Risk-Informed Completion Times (RICTs) in accordance with Technical Specifications Task Force (TSTF)-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (Reference 3).
Reference 2 proposes the addition of a license condition that allows implementation of the provisions in 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 staff from the Nuclear Regulatory Commissions (NRCs) Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (Reference 4).
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license, or regulation-related activity that includes the examination and evaluation of Duke Energys non-docketed information that provides the technical basis for the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and Enclosure 1
gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR LIC-111, Regulatory Audits, with exceptions noted within this audit plan (Reference 5).
The NRC staff will perform the audit to support its evaluation of whether the licensees requests can be approved per 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit. The staffs review will be informed by Standard Review Plan Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis (Reference 6). The audit will assist the NRC staff with understanding the licensees proposed programs for implementing RICTs for certain TSs and categorizing structures systems and components (SSCs) based on their risk significance. Further, due to the overlaps in technical matter and personnel reviewing the two LARs, the NRC staff determined that a combined audit would permit the most efficient use of resources for the NRC and Duke Energy.
3.0 SCOPE The audit team will view the documentation and calculations that provide the technical support for the LARs. The scope of the NRC staffs audit will focus on the following subjects:
Understand how the licensees proposed program conforms to NRC-endorsed guidance in the Nuclear Energy Institute (NEI) report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification Guidelines (Reference 7).
Understand how the licensees proposed program conforms to NRC-endorsed guidance in NEI 00-04, Revision 0, SSC Categorization Guideline (Reference 8), as endorsed by Regulatory Guide 1.201, Revision 1, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance (Reference 9).
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LARs and confirm the staffs understanding of the LARs.
Gain a better understanding of plant design features and their implications for the LARs.
Identify any information needed to enable the staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for these applications.
Identify any information needed to enable the staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (Reference 10).
The NRC staff will audit the PRA methods that the licensee would use to: (1) categorize SSCs based on their risk significance, and (2) determine the risk impact from which the revised
completion times for TSTF-505 would be obtained. This will include the licensees assessment of internal events (including internal flooding) and fire as well as the treatment of uncertainties and evaluation of defense in depth. The NRC will also audit the licensees quantification of risk from significant external events, whether the licensee uses PRA or bounding methods. In addition, the audit team will discuss these topics with Duke Energys subject matter experts.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will request information and interviews throughout the audit period. The NRC staff will use an audit items list to identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested interviews and meetings.
The NRC staff requests the licensee to have the information referenced in the attachment of this audit plan available and accessible for the NRC staffs review via a web-based electronic portal within two weeks of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within one week of the date of the NRCs notification to the licensee of the new requests. The NRC staff requests the licensee to notify the review team when an audit item is added to its electronic portal by sending an email to the NRC licensing project manager.
The staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff.
5.0 AUDIT TEAM The following table identifies the NRC audit team members, including contractors, and their respective focus areas:
Table 1: NRC Audit Team Composition LAR Name E-mail Review Area (Organization)
RICT 50.69 Plant Licensing Branch LPL II-1 John Klos (1) John.Klos@nrc.gov X X (LPL2-1)
Todd Hilsmeier (2) (3) Todd.Hilsmeier@nrc.gov X Malcolm Patterson (2) Malcolm.Patterson@nrc.gov X PRA Licensing Branch A (APLA)
Adrienne Brown Adrienne.Driver@nrc.gov X X De (Wesley) Wu De.Wu@nrc.gov X X PRA Licensing Branch C (APLC)
Keith Tetter (3) Keith.Tetter@nrc.gov X X Hari Kodali Hari.Kodali@nrc.gov X Electrical Engineering Branch Stephen Wyman Stephen.Wyman@nrc.gov X (EEEB)
Edmund Kleeh Edmund.Kleeh@nrc.gov X Instrumentation and Controls Norbert Carte Norbert.Carte@nrc.gov X X Branch (EICB)
Mechanical Engineering and Gurjendra Bedi Gurjendra.Bedi@nrc.gov X X Inservice Testing Branch (EMIB)
Vessels and Internals Branch Dan Widrevitz Dan.Widrevitz@nrc.gov X (NVIB)
Piping and Head Penetrations Stephen Cumblidge Stephen.Cumblidge@nrc.gov X (NPHP)
Brian Lee Brian.Lee@nrc.gov X X Containment and Plant Systems
Table 1: NRC Audit Team Composition LAR Name E-mail Review Area (Organization)
RICT 50.69 Branch (SCPB)
Nuclear Systems Performance Christopher Jackson Christopher.Jackson@nrc.gov X X Branch (SNSB)
Technical Specifications Branch Andrea Russell Andrea.Russell@nrc.gov X (STSB)
Steve Short (4) Steve.Short@pnnl.gov X X Pacific Northwest National Mark Wilk (4) Mark.Wilk@pnnl.gov X X Laboratory (PNNL)
Notes:
(1) NRR Division of Operating Reactor Licensing Project Manager (2) Technical Lead (3) Contracting Officer Representative (4) NRC Contractor 6.0 LOGISTICS The audit will be conducted using a secure, online electronic portal, established by the licensee to present supporting documentation and calculations and by interviews with Duke Energys subject matter experts, both in person and virtually. The audit will begin within two weeks of the date of this audit plan (approximately May 1, 2023) and last through October 23, 2023. The NRC will establish a schedule of audit meetings (e.g., a single, multi-day audit meeting and periodic audit meetings throughout the audit period) on mutually agreeable dates and times to discuss information needs and questions arising from the NRCs review of the audited items.
The NRCs licensing project manager will inform the licensee of audit meeting dates when they are established, including the date of an audit kick-off meeting.
A desktop audit will take place between approximately May 1, 2023 and October 23, 2023. The NRCs entrance meeting to the desktop audit will be on approximately May 15, 2023. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC project manager will coordinate with the licensee to set dates and times to discuss information needs and questions arising from the NRCs review of the audited items. The NRC staff may change and/or add audit dates and times when deemed necessary. Audit meeting agenda and questions will be sent in advance of the audit meeting.
The NRC staff intends to conduct an in-person audit meeting with Duke Energys staff in Charlotte, NC in the late June 2023 timeframe to discuss items addressing external hazards PRA. The in-person audit will include an entrance and an exit meeting.
7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff and contractors on the audit team have access to the online portal:
The online electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The online web-based electronic portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information from the web portal.
Conditions of use of the online electronic portal will be displayed on the login screen and will require acknowledgment by each user.
Duke Energy should provide username and password information directly to the NRC staff and contractors on the audit team, listed above. The NRC project manager will provide Duke Energy the names and contact information of the NRC staff and contractors who are added to the audit team. All other communications should be coordinated with the NRC project manager. The NRCs project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the electronic portal.
No data accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, in accordance with NRR LIC-115 (Reference 10) and issue such RAIs separate from audit-related correspondence. The NRC staff will issue an audit summary report within approximately 90 days after the end of the audit and prior to completing its safety evaluation of the LAR.
9.0 References 1 Pigott, Edward R., Duke Energy Carolinas, LLC, McGuire Nuclear Station, Units 1 and 2 -
letter to U.S. Nuclear Regulatory Commission (NRC), License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF-Initiative 4b, Serial RA-18-0190 February 16, 2023 (ML23047A465).
2 Pigott, Edward R., Duke Energy Carolinas, LLC, McGuire Nuclear Station, Units 1 and 2 -
letter to U.S. Nuclear Regulatory Commission (NRC), Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, Serial: RA-18-0090 February 17, 2023 (ML23048A022).
3 Technical Specifications Task Force (TSTF) - A Joint Owners Group Activity, TSTF Comments on Draft Safety Evaluation for Traveler TSTF 505, Provide Risk-Informed Extended Completion Times, and Submittal of TSTF-505, Revision 2., TSTF-18-07; PROJ0753 July 2, 2018 (ML18183A493).
4 U. S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-101, Revision 6 License Amendment Review Procedures, July 31, 2020 (ML19248C539).
5 U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-111, Revision 1 Regulatory Audits, October 31, 2019 (ML19226A274).
6 U. S. Nuclear Regulatory Commission (NRC), NUREG-0800 - Standard Review Plan:
[Section]19.2 Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, June 2007 (ML071700658).
7 Nuclear Energy Institute (NEI), NEI 06-09 (Revision 0)-A Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines -
Industry Guidance Document, November 2006 and May 17, 2007 (ML12286A322).
8 Nuclear Energy Institute (NEI); Risk Applications Task Force; NEI Option 2 Task Force, and
NEI Risk-Informed Regulation Working Group, NEI 00-04 (Rev. O) - 10 CFR 50.69 - SSC Caegorization Guideline, July 2005 (ML052910035).
9 U. S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research, Regulatory Guide 1.201 - Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to their Safety Significance, May 2006, Revision 1 (ML061090627).
10 U.S. Nuclear Regulatory Commmission, Office of Nuclear Reactor Regulation, LIC-115, Revision 1 Licensing Processes, August 5, 2021 (ML21141A238).
ATTACHMENT: AUDIT REQUESTS ITEM AUDIT REQUEST 1 Reports cited in Enclosure 2 of the LAR to adopt TSTF-505 and Section 3 of the LAR to adopt 10 CFR 50.69 from full-scope and focused-scope peer reviews, self- and gap assessments (including findings, observations, and dispositions), and closure reviews of facts and observations (F&Os).
2 For the PRAs identified under Item #1 above, plant-specific documentation (e.g.,
uncertainty notebooks) related to:
- a. The review of the PRA model assumptions and sources of uncertainty (generic and plant-specific assumptions/uncertainties) for the TSTF-505 and 50.69 LARs.
- c. Parametric uncertainty and state-of-knowledge correlation evaluation for the TSTF-505 and 50.69 LARs.
3 If modeled, PRA notebooks associated with the modeling of open phase condition (OPC) in electrical switchyards and the open phase isolation system (OPIS).
4 Documentation of how shared or cross-tied systems are modeled in the PRA.
5 Fire PRA notebooks containing the results of the fire PRA, including risk importance measures.
6 McGuire Nuclear Station, Severe Accident Analysis, McGuire PRA System Documentation; External Events Seismic Analysis, MCC-1535.00-00-0049, Revision 3, November 9, 2001.
ARES Corporation, Report No. 030319.13.05.01-001, Revision B, IPEEE Adequacy Review for Duke Energys McGuire Nuclear Station, April 2014.
Investigation of Seismic Probabilistic Risk Assessment (SPRA) Quantification to Simplify PRA Models Used to Assess Risk-Informed Completion Times, EPRI Configuration Risk Management Forum Research Task, EPRI, Palo Alto, CA: 2021, 3002020744.
Jung, S. (Duke Energy), Improved Seismic Penalty Approach for RICT, Electric Power Research Institute Configuration Risk Management Forum (CRMF)
Conference, Charlotte, NC, March 28, 2022.
McGuire Nuclear Station, Seismic Hazard Curve Sensitivity Study for the McGuire IPEEE, MCC-1535.00-00-0003, 1994.
MCC-1535.00-00-0178, McGuire Nuclear Station High Wind Probabilistic Risk Assessment, Revision 4, November 2022.
High Wind Loss of Offsite Power Durations and Recovery, EPRI, Palo Alto, CA: 2020, 3002018232.
Enclosure 2
ATTACHMENT: AUDIT REQUESTS ITEM AUDIT REQUEST 6 RP/0/A/5700/006, Natural Disasters, Revision 036.
RP/0/B/5700/027, Severe Weather Preparation, Revision 013.
Calculation MCC-1535.00-00-0252, MNS 50.69 and TSTF-505 LAR Support Calculation, Revision 1.
Calculation MCC-1211.00-00-0141, McGuire Nuclear Station Control Room Habitability Toxic Gas Review, Revision 4, July 2022.
7 Documentation supporting the example risk-informed completion times (RICT) calculations presented in LAR Enclosure 1, Table E1-2.
8 Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA.
9 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
If available, final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation). [The 10 licensee may choose (optional) to provide draft RICT program procedures if final procedures are not available.]
11 Other documentation that the licensee determines to be responsive to the U.S.
Nuclear Regulatory Commission staffs information requests.
12 Unit 1, Updated Final Safety Analysis Report (UFSAR), Single line diagrams -
Figure 8-3 Auxiliary Power Distribution system, Figure 8 -16 (3 pages) Main Station Buses, Figure 8-17 (3 pages) Station Main Buses, Figure 8-34 Single line diagram 125 V DC and 240/120 V AC Aux Power system.
These drawings are related to UFSAR, Chapter 8. These drawings or equivalent training drawings are required for review.