ML23149A001

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Audit Agenda TSTF-505 and 50.69 (E-mail Dated 5/29/2023) (EPIDs L-2022-LLA-0185 and L-2022-LLA-0186)
ML23149A001
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 05/29/2023
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: ML23149A001 (1)


Text

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

Bcc: Richard Guzman

Subject:

Nine Mile Point Nuclear Station, Unit 1 - TSTF-505 and 10 CFR 50.69 AUDIT AGENDA (EPIDs L-2022-LLA-0185, L-2022-LLA-0186)

Date: Monday, May 29, 2023 9:48:00 AM Attachments: Audit Agenda - NMP1 TSTF-505 and 50.69.pdf

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 developed a list of audit questions that were sent to you via email on April 28, 2023 (ML23118A388)

(deterministic questions) and on May 22, 2023 (ML23142A022) (PRA questions). The responses to the questions will be discussed during the audit meetings which are scheduled from Tuesday June 13, 2023, through Thursday, June 15, 2023. The proposed agenda for the audit is provided in the attached.

Please contact me if you have any questions.

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

REGULATORY AUDIT AGENDA LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-505 AND 10 CFR 50.69 NINE MILE POINT NUCLEAR STATION, UNIT 1 CONSTELLATION ENERGY GENERATION, LLC Day 1 - Tuesday, June 13, 2023 (9:00 am to 4:00 pm) *

  • Entrance meeting

- Opening comments by NRC and Constellation

- Introductions

- Audit logistics

  • Constellation TSTF-505 presentation: RTR model demonstration and RICT sample calculations
  • Discuss RTR model and calculation of RICT estimates for TSTF-505 LAR (APLA)

- RTR model (including use of surrogates, how seasonal variations are accounted, and model updating) (Questions 09, 13, and 14)

- PRA functional determination and RICT estimates

- Treatment of common cause failures for planned and emergent conditions

- Identification of risk-management actions

  • Discuss Key Principle 5, maintenance rule and monitoring for TSTF-505 LAR (APLA, Question 10)
  • Discuss PRA technical acceptability and uncertainties for TSTF-505 and 50.69 LARs (APLA)

- Credit for FLEX equipment and actions (Questions 06 and 22)

- RG 1.200, Revision 1, gap assessment (Questions 07 and 23)

- Open F&O disposition (Questions 08 and 24)

- Shared systems (Question 11)

- Digital I&C modeling (Question 12)

- Open phase condition (Question 15)

  • Summary of the day (3:30 pm)
  • NRC staff internal meeting (4:00 pm) 1

Day 2 - Wednesday, June 14, 2023 (9:00 am to 4:00 pm) *

  • Summary of previous day and review open items
  • Discuss PRA technical acceptability and uncertainties for TSTF-505 and 50.69 LARs (APLA, continued from Day 1)
  • Discuss TS Markups and License Condition for TSTF-505 LAR (STSB, Questions 03 and 04)
  • Discuss Operating Procedure N1-OP-19 for 50.69 LAR (EEEB, Question 05)
  • Summary of the day (3:30 pm) 1
  • NRC staff internal meeting (4:00 pm)

Day 3 - Thursday, June 15, 2023 (9:00 am to 4:00 pm) *

  • Summary of previous day and review open items
  • Discuss external hazards for TSTF-505 LAR (APLC, Questions 16 through 21)
  • Discuss external hazards for 50.69 LAR (APLC, Questions 25 through 28)
  • Follow-up on any remaining open action items
  • NRC staff internal meeting
  • Technical summary meeting with Constellations audit team
  • Formal exit meeting
  • Lunch will be tentatively scheduled from 12:00 pm - 1:00 pm 1 If the discussion points scheduled for Day 2 are completed early, external hazard discussions planned for Day 3 may be started.

2

Acronyms:

APLA NRC/NRR/PRA Licensing Branch A APLC NRC/NRR/PRA Licensing Branch C Constellation Constellation Energy Generation, LLC DORL NRR Division of Operating Reactor Licensing EEEB NRC/NRR/Electrical Engineering Branch EICB NRC/NRR/Instrumentation & Controls Branch F&O Facts and Observations FLEX Flexible Mitigation Strategies I&C Instrumentation and Control LAR License Amendment Request LCO Limiting Conditions for Operation NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PRA Probabilistic Risk Assessment RG Regulatory Guide RICT Risk-informed Completion Time RTR Real-time Risk STSB NRC/NRR/Technical Specifications Branch TS Technical Specifications TSTF-505 Technical Specifications Task Force Traveler 505, Provide Risk-Informed Extended Completion Times, RITSTF Initiative 4b 50.69 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 3