ML23118A388

Regulatory Audit Questions TSTF-505 and 50.69 (E-mail Dated 4/28/2023) (EPIDs L-2022-LLA-0185 and L-2022-LLA-0186)

ML23118A388
Person / Time
Site:	Nine Mile Point
Issue date:	04/28/2023
From:	Richard Guzman NRC/NRR/DORL/LPL1
To:	Reynolds R Constellation Energy Generation
References
EPID L-2022-LLA-0185, EPID L-2022-LLA-0186
Download: ML23118A388 (1)

Text

From: Richard Guzman To: Reynolds, Ronnie J:(Constellation Nuclear)

Subject:

Nine Mile Point Unit 1 - TSTF-505 and 10 CFR 50.69 Audit Questions (EPIDs L-2022-LLA-0185, L-2022-LLA-0186)

Date: Friday, April 28, 2023 10:58:58 AM Hello Ron, By letters dated December 15, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22349A108 and ML22349A521), Constellation Energy Generation, LLC (CEG, the licensee) submitted two license amendment requests (LARs) for Nine Mile Point Nuclear Station, Unit 1 (NMP1). The proposed amendments would modify license DPR-63 and the Technical Specifications (TSs) to adopt Technical Specifications Task Force (TSTF) Traveler 505 (TSTF-505), Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b, and 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.

On January 31, 2023, the NRC staff issued an audit plan (ML23025A386) that conveyed intent to conduct a regulatory audit to support its review of the subject licensing actions.

Based on the commonalities between the LARs and subsequent overlap in technical content and review personnel, the staff is conducting a combined audit that addresses both LARs. In the audit plan, the NRC staff requested an electronic portal setup and provided a list of documents to be added to the online portal. The audit plan also indicated that the NRC may request information and audit meetings/interviews throughout the audit period.

The NRC staff has performed an initial review of the list of documents and is developing a list of audit questions.

The first set of audit questions are provided below. Please post the response(s) for the questions to the online portal as the response is completed (but no later than one week before the date of the audit meeting). The dates and times for the audit discussions have not been set; however, the staff is targeting June 2023 to conduct the meetings via MS Team teleconference call. The proposed agenda for the audit discussions will also be provided on a later date. Please contact me at any time prior if a clarification discussion is needed. We look forward to discussing these questions and CEGs responses during the virtual audit meeting.

Thank you, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov

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AUDIT QUESTIONS LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2 AND LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS CONSTELLATION ENERGY GENERATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT 1 DOCKET NO. 50-220 By letters dated December 15, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML22349A108 and ML22349A521), Constellation Energy Generation, LLC (CEG, the licensee) submitted two license amendment requests (LARs) for Nine Mile Point Nuclear Station, Unit 1 (NMP1). The proposed amendments would modify license DPR-63 and the Technical Specifications (TSs) to adopt Technical Specifications Task Force (TSTF) Traveler 505 (TSTF-505), Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b, and 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. On January 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff issued an audit plan (ML23025A386) that conveyed intent to conduct a regulatory audit to support its review of the subject license amendments. Based on the commonalities between the LARs and subsequent overlap in technical content and review personnel, the NRC staff is conducting a combined audit that addresses both LARs.

The NRC staff has determined that the additional information is needed to support its review as shown in the following audit questions. The questions are ordered by number and identified by technical review branch/area and associated LAR (i.e., RICT for the TSTF-505 LAR and 50.69 for the LAR re: risk-informed categorization and treatment of SSCs).

Audit Question-01 (EEEB - RICT) - TS LCOs 3.6.3.b and 3.6.3.e.2 According to Table E1-1 of LAR Enclosure 1, corresponding to Technical Specification (TS) limiting condition for operation (LCO) 3.6.3.b (One required offsite circuit inoperable),

structures, systems and components (SSCs) covered by the TS LCO condition are listed as Lines 1/4. Elaborate on the meaning of Lines 1/4.

Also, in Table E1-1, provide complete information for all columns corresponding to TS LCO 3.6.3.e.2 (Two required offsite circuits inoperable).

Audit Question-02 (EEEB/STSB - RICT) - TS LCO 3.6.2i According to page 8 of LAR Attachment 4 (Cross-Reference of TSTF-505 and NMP1 TS) corresponding to the TSTF-505 TS Loss of Power (LOP) Instrumentation - one or more channels inoperable, the equivalent statement is in the NMP1 TS Table 3.6.2i, Note (1).

According to the comments column for TS 3.6.2.i, Note (1), No change to incorporate RICT program is proposed because TS 3.6.2i, Note (1) does not have an associated Completion Time, and is excluded. However, the change to TS 3.6.2i is discussed further in other parts of the LAR (e.g., page 21 of Attachment 5; page E1-15, page E1-19, page E1-21 of Enclosure 1).

Explain or resolve the above apparent discrepancy regarding TS 3.6.2i, Note (1).

Audit Question-03 (STSB - RICT) - TS Markups

a. Editorial: On TS page 54 of LAR Attachment 2 (Proposed Technical Specification Changes (Mark-Ups)), TS 3.1.4.c has the phrase insertion pointer in the wrong place.

b. On TS page 155 of LAR Attachment 2, the completion time for TS 3.3.6.c appears inconsistent with TSTF-505, Revision 2. The proposed change states, in part, the apparently malfunctioning vacuum breaker valve shall be exercised and pressure tested as specified in 3.3.6.b immediately and every 15 days thereafter or in accordance with the Risk Informed Completion Time Program until appropriate repairs have been completed. TSTF-505, Revision 2, Section 2.3, Scope, details the RICT program exclusion criteria for required actions and completion times.

Exclusions 7 and 16, do not allow periodically performed or immediate completions times. Please provide justification for this variation or revise all mentions of TS 3.3.6.c in the LAR.

c. On TS page 213 of LAR Attachment 2, TS Table 3.6.2.b Note (g) is included in the RICT program. However, it is not discussed in the LAR Attachment 4 cross reference table or the LAR Enclosure 1, Table E1-1 list of required actions to corresponding PRA functions. Please provide justification for this change or resolve the inconsistency where TS Table 3.6.2.b Note (g) is mentioned in the LAR.

Audit Question-04 (STSB - RICT) - License Condition What is the purpose of the proposed license condition in LAR Attachment 6? Is there an expectation that there will be probabilistic risk assessment related implementation items?

The proposed license condition is as follows:

Adoption of Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extension Completion Times - RITSTF Initiative 4b" CEG is approved to implement TSTF-505, Revision 2, modifying the Technical Specification requirements related to Completion Times (CT) for Required Actions to provide the option to calculate a longer, risk-informed CT (RICT). The methodology for using the new Risk-Informed Completion Time

Program is described in NEI 06-09-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)

Guidelines," Revision 0, which was approved by the NRC on May 17, 2007.

Audit Question-05 (EEEB - 50.69) - N1-OP-19, Revision 04200, Circulating Water System In NMP1 Operating Procedure N1-OP-19, Revision 04200, a NOTE in Sections F.3.0 and F.4.0 of Normal Operations states, in part:

Jogging E gate may result in tripping thermal overloads, which are located in hydraulic pump control cabinet.

Explain the consequences of thermal overloads tripping during normal operations due to jogging of E gate, or under overload condition. What is the present risk qualification of thermal overloads? Does it require any additional treatment?

Technical Review Branch/Review Area EEEB - Electrical Engineering STSB - Technical Specifications