ML23226A100
| ML23226A100 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/18/2023 |
| From: | Siva Lingam Plant Licensing Branch IV |
| To: | Entergy Operations |
| Lingam S, 301-415-1564 | |
| References | |
| EPID L-2023-LLA-0080, EPID L-2023-LLA-0081 | |
| Download: ML23226A100 (1) | |
Text
August 18, 2023
Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-505, REVISION 2, PROVIDE RISK-INFORMED 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-0081 AND EPID L-2023-LLA-0080)
Dear Sir or Madam:
By letters dated June 6, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML23158A043 and ML23158A044), respectively, Entergy Operations, Inc. (the licensee) submitted license amendment requests (LARs) to amend the license for Grand Gulf Nuclear Station, Unit 1, Renewed Facility Operating License No. NPF-29. The proposed LARs would adopt Technical Specifications Task Force (TSTF) Traveler (TSTF)-505, Revision 2, Provide Risk-Informed Completion Times, RITSTF [Risk-Informed TSTF]
Initiative 4b (TSTF-505) and the provisions of Title 10 of the Code of Federal Regulations 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 licensees 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 virtually v ia Teams (and in person if warranted) from December 4-6, 2023, using the already established licensees electronic portal (Certrec) available to the NRC staff until January 15, 2024, with periodic meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.
If you have any questions, please contact me at 301-415-1564 or via email at Siva.Lingam@nrc.gov.
Sincerely,
/RA/
Siva P. Lingam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket No. 50-416
Enclosure:
Regulatory Audit Plan
cc: Listserv
REGULATORY AUDIT PLAN
BY THE OFFICE OF NUCLEAR REACTOR REGULATION
TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUESTS
TO ADOPT RISK INFORMED COMPLETION TIMES
AND RISK-INFORMED CATEGORIZATION AND TREATMENT OF
STRUCTURES, SYSTEMS AND COMPONENTS
ENTERGY OPERATIONS, INC.
GRAND GULF NUCLEAR STATION, UNIT 1
DOCKET NO. 50-416
1.0 BACKGROUND
By letters dated June 6, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML23158A043 and ML23158A044, respectively), Entergy Operations, Inc. (the licensee) submitted license amendment requests (LARs) for Grand Gulf Nuclear Station, Unit 1 (Grand Gulf). The first LAR would modify the Grand Gulf technical specifications (TSs) to permit the use of risk-informed completion times (RICTs) in accordance with Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk Informed Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b (TSTF-505) (ML18183A493).
The second LAR 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 struct ures, systems and components for nuclear power reactors.
The U.S. Nuclear Regulatory Commission (NRC) staff from the Office of Nuclear Reactor Regulation(NRR) has initiated its review of the LARs in accordance with NRR Office Instruction LIC-101, Revision 6, License Amendment Review Procedures, dated July 31, 2020 (ML19248C539).
2.0 REGULATORY AUDIT BASES
A regulatory audit is a planned license, or regulation-related activity that includes the examination and evaluation of the licensees non-docketed information that provides the technical basis for the LAR. The NRC staff has proposed to conduct a regulatory audit from December 4-6, 2023, to enhance technical understanding of the submitted documentation, with periodic meetings to be scheduled during this period, as needed, before the audit and after the audit prior to finalizing a request for additional information (RAI). This audit will help the NRC staff better understand the supporting documentation and analysis results through both review and interaction with the licensees technical ex perts to help focus on the NRC staffs RAI, where
Enclosure
docketed information is needed to complete the review. The proposed audit will be held in accordance with NRR Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274).
The NRC staff would like the licensee to make ava ilable the appropriate technical experts with detailed knowledge of the Grand Gulf licensing basis and the submitted LARs, supporting methodology, and supporting documents used in the development of the LARs.
The licensee is requested to have the presentations and documents related to the areas of focus listed. The documentation should be provided by presentations, documents, and calculation details as necessary.
The deliberations during the audit, along with the original contents of the LAR as well as any supplemental information, will be used to generate RAIs in order to complete the comprehensive review of the LARs.
3.0 REGULATORY AUDIT 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 pr ogram 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, dated October 2012 (Package: ML122860402).
Understand how the licensees proposed pr ogram conforms to NRC-endorsed guidance in NEI 00-04, Revision 0, 10 CFR 50.69 SSC Categorization Guideline, dated July 2005 (ML052900163), 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, dated May 2006 (ML061090627).
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LARs and confirm the NRC 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 NRC staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for these applications.
Identify any information needed to enable the NRC 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 becom e formal RAIs per NRR Office Instruction LIC-115, Revision 1, Processing Requests for Additional Information, dated August 5, 2021 (ML21141A238).
The NRC staff will audit the PRA methods that th e 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 al so 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 the licensees subject matter experts.
4.0 SUPPORTING INFORMATION NECESSARY FOR THE REGULATORY AUDIT
The NRC staff will request information and interv iews 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 in Certrec within 2 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 1 week of the date of the NRCs notification to the licensee of the new reques ts. The NRC staff requests the licensee to notify the review team when an audit item is added to it s electronic portal by sending an email to the NRC licensing project manager.
The NRC 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 TSTF-50.69 Review Area (Organization) 505 Siva Lingam(1) Siva.Lingam@nrc.gov X X Plant Licensing Branch LPL4 Ching Ng(2) Ching.Ng@nrc.gov X Todd Hilsmeier(2) Todd.Hilsmeier@nrc.gov X PRA Licensing Branch A De (Wesley) Wu De.Wu@nrc.gov X X Jigar Patel Jigar.Patel@nrc.gov X X Thinh Dinh Thinh.Dinh@nrc.gov X PRA Licensing Branch B Jay Robinson(3) Jay.Robinson@nrc.gov X Sunwoo Park Sunwoo.Park@nrc.gov X X PRA Licensing Branch C Hari Kodali Hari.Kodali@nrc.gov X X Electrical Engineering Branch Khoi Nguyen Khoi.Nguyen@nrc.gov X Maurin Scheetz Maurin.Scheetz@nrc.gov X Operator Licensing and Human Factors Branch Jack Zhao Jack.Zhao@nrc.gov X Instrumentation and Controls Branch
Table 1: NRC Audit Team Composition LAR Name E-mail TSTF-50.69 Review Area (Organization) 505 Gurjendra Bedi Gurjendra.Bedi@nrc.gov X Mechanical Engineering and Michael Breach Michael.Breach@nrc.gov X Inservice Testing Branch
Dan Widrevitz Dan.Widrevitz@nrc.gov X Vessels and Internals Branch
Gordan Curran Gordan.Curran@nrc.gov X Containment and Plant David Nold David.Nold@nrc.gov X Systems Branch Fred Forsaty Fred.Forsaty@nrc.gov X X Nuclear Systems Performance Branch Andrea Russell Andrea.Russell@nrc.gov X Technical Specifications Branch Steve Short(4) Steve.Short@pnnl.gov X Pacific Northwest National To be Laboratory determined(4) To be determined X 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 the licensees subject matter experts, both in person and virtually. After issuance of this audit plan, periodic meetings may be scheduled as needed until January 15, 2024.
A desktop audit will take place until January 15, 2024. 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 licensee should also provide any other documentation that may aid discussion on the specific topics of interest.
The audit will start at 8:00 a.m. (Eastern Time (ET)) on Monday, December 4, 2023, and conclude on Wednesday, December 6, 2023, at 4:30 p.m. (ET) approximately.
Please note that the following proposed schedule that is subject to change:
December 4, 2023
8:00 a.m. Entrance Meeting - Introductions, Audit Activities, Goals, and Logistics 8:15 a.m. Licensee and NRC Staff to Discuss Technical Topics
12:00 p.m. Lunch 1:00 p.m. Continue Discussion of Related Topics 3:30 p.m. NRC Audit Team Caucus 4:00 p.m. NRC/Licensee Interim Meeting 4:30 p.m. Audit Team Daily Closeout
December 5, 2023
8:00 a.m. Entrance Meeting - Introductions, Audit Activities, Goals, and Logistics 8:15 a.m. Licensee and NRC Staff to Discuss Technical Topics 12:00 p.m. Lunch 1:00 p.m. Continue Discussion of Related Topics 3:30 p.m. NRC Audit Team Caucus 4:00 p.m. NRC/Licensee Interim Meeting 4:30 p.m. Audit Team Daily Closeout
December 6, 2023
8:00 a.m. Continue Discussion of Related Topics (and any items leftover from previous day) 12:00 p.m. Lunch 1:00 p.m. Continue Discussion of Related Topics 4:30 p.m. Audit Exit
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 passwor d-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.
The licensee 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 the licensee 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
At the conclusion of the audit, the NRC staff will provide a summary of audit results for each of the topics defined in the audit scope. The NRC staff will develop any RAIs, as needed, in accordance with NRR LIC-115 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 evaluations of the LARs.
List of Audit Request Items
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 No.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 PRA notebooks for the modeling of diverse and flexible coping strategies (FLEX) equipment and FLEX human error probabilities credited in the PRAs.
4 PRA notebooks for the modeling of digital control systems, including basis for the representative failure probabilities.
5 If modeled, PRA notebooks associated with the modeling of open phase condition in electrical switchyards and the open phase isolation system.
6 Documentation of how shared or cross-tied systems are modeled in the PRA.
7 Fire PRA notebooks containing the results of the fire PRA, including risk importance measures.
8 Provide documentation of Fire PRA peer reviews. Identity and discuss any F&Os that were not resolved and their path forward.
9 Engineering Report GGNS-CS-23-00001, Grand Gulf Seismic High Confidence Low Probability of Failure (HCLPF) Determination, Revision 000, dated April 2023.
Tornado Missile Risk Evaluator analysis report.
Plant operational procedures related to external hazards, such as high wind and flooding.
10 Documentation supporting the example RICT calculations presented in LAR enclosure 1, table E1-2.
11 Documentation supporting the developm ent of the real-time risk tool and benchmarking it against the PRA.
12 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
ITEM AUDIT REQUEST 13 If available, final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation). [The licensee may choose (optional) to provide draft RICT program procedures if final procedures are not available.]
14 Readable one-line diagrams for alternating current (AC) and direct current (DC) power distribution systems, information on diesel generators and associated supporting systems (i.e. buses and loads), load list, and list of any loads shared between AC distribution systems and DC distribution systems 15 Other documentation that the licensee determines to be responsive to the NRC staffs information requests.
ML23226A100 *by mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DRA/APLA/BC*
NAME SLingam PBlechman RPascarelli DATE 8/14/23 8/15/2023 8/18/23 OFFICE NRR/DRA/APLB/BC* NRR/DRA/APLC/BC* NRR/DORL/LPL4/BC NAME JWhitman (JRobinson for) SVasavada JDixon-Herrity DATE 8/18/23 8/18/23 8/18/23 OFFICE NRR/DORL/LPL4/PM NAME SLingam DATE 8/18/23