ML23275A171

October 16, 2023, Licensee Pre-submittal Meeting Slides - License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505-A, Revision 2 for Wolf Creek Generating Station

ML23275A171
Person / Time
Site:	Wolf Creek
Issue date:	10/16/2023
From:	Evergy, Wolf Creek
To:	Samson Lee NRC/NRR/DORL/LPL4
Lee S, 301-415-3168
References
EPID L-2023-LRM-0076
Download: ML23275A171 (1)

Text

Pre-Submittal Meeting License Amendment Request to Revise Wolf Creek Generating Station Technical Specifications to Adopt Risk Informed Completion Times TSTF-505-A, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b DATE: October 16th, 2023 Internal Use Only

AGENDA

• Scope of License Amendment Request (LAR)

• Variations from TSTF-505-A

• Other LAR Changes

• Probabilistic Risk Assessment (PRA) Model Technical Adequacy

• Configuration Risk Management (CRM)

Program

• LAR Schedule

• Summary

• Questions/Comments?

2 Internal Use Only

Scope of License Amendment Request

• License Amendment Request (LAR) is based on TSTF-505-A, Revision 2, and NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines

• Risk Informed Completion Times (RICTs) apply to 50 TS Required Actions (RAs) at Wolf Creek Generating Station (WCGS)

- Applicable in Modes 1 and 2

- No loss of function consistent with template

• New TS 5.5 program called the Risk Informed Completion Time Program

• LAR informed by approved precedent and those currently under review

• Includes adoption of TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO 3

Internal Use Only

Variations from TSTF-505 Several types of administrative variations are taken

• RAs with different numbering and slightly different wording with same intent

• TSTF-505 RAs that WCGS TS do not have

• Instrumentation RAs invoked for different Functions or wording that a RICT applies to

• RICTs not applied since Additional Justifications werent met (e.g., not having a Shutdown PRA), or loss of function could not be confirmed

• Corrections to obvious minor traveler errors and administrative formatting changes

• Various plant-specific differences that are still bounded by related TSTF-505 changes 4

Internal Use Only

Variations from TSTF-505 (continued)

Seven technical variations are being taken

• WCGS TS 3.3.2 Required Action I which requires comparison with Standard Technical Specifications (STS) TS 3.3.2 Condition J meets the criteria for RICT

• WCGS TS 3.3.2 Required Action N does not have a corresponding STS TS, but meets the criteria for RICT

• WCGS TS 3.3.2 Required Action Q does not have a corresponding STS TS, but meets the criteria for RICT

• WCGS TS 3.7.2 Required Action A does not have a corresponding STS TS, but meets the criteria for RICT

• WCGS TS 3.7.2 Required Action B does not have a corresponding STS TS, but meets the criteria for RICT

• WCGS TS 3.7.2 Required Action C does not have a corresponding STS TS, but meets the criteria for RICT

• WCGS TS 3.8.1 Required Action C.1, C.2, C.3, and C.4 do not have a corresponding STS TS, but meets the criteria for RICT 5

Internal Use Only

Deviations from TSTF-505

• Maintenance Rule (MR) Program

• MR program outlined in TSTF-505 follows guidance defined in NUMARC 93-01

• Wolf Creek MR program follows guidance defined in NEI 18-10 (MR 2.0)

• Deviation is noted in LAR enclosure 6

Internal Use Only

Other LAR Changes TSTF-439 is included

• Traveler is cited as prerequisite for applying RICT to RAs with second Completion Times

• Technical justification is incorporated as a different stand-alone section of the LAR

• Affects 10 RAs and Completion Times allowing RICT application

• Six Administrative variations of inconsequential nature

• One Technical Variation for a RA with a second Completion Time not covered by the traveler, but meet the intent for a second Completion Time deletion

• Consistent approach proposed by Callaway Plant and Browns Ferry Nuclear Plants 7

Internal Use Only

Other LAR Changes (continued)

Changes for Consistency With ITS Writers Guide

• Three opportunistic changes are made on TS pages impacted by TSTF-505 changes that promote consistency with the ITS Writers Guide Editorial Corrections

• Three opportunistic changes are made on TS pages impacted by TSTF-505 changes that make certain editorial corrections 8

Internal Use Only

PRA Model Technical Adequacy The PRA models supporting this submittal have been assessed against the ASME/ANS PRA Standard (RA-Sa-2009 and Part 5 Code Case) and RG 1.200, Revision 2, consistent with NRC RIS 2007-06.

All Facts and Observations (F&O) closure reviews were performed in accordance with the process documented in Appendix X to NEI 05-04, NEI 07-12, NEI 12-13, and NEI 17-07 as accepted by the NRC (ML17079A427), as well as the requirements published in the ASME/ANS PRA Standard (RA-Sa-2009).

9 Internal Use Only

PRA Model Technical Adequacy

• Internal Events and Internal Flood PRA

• Full scope peer review against ASME/ANS RA-Sa-2009 performed in June 2019

• Two F&O closure reviews performed in accordance with Appendix X to NEI 05-04 and NEI 17-

07. The latest F&O closure occurred in August 2023.

• No open Finding F&Os*

• Internal Fire PRA

• The Fire PRA was prepared using the methodology defined in NUREG/CR-6850, Fire PRA Methodology for Nuclear Power Facilities

• Peer review against ASME/ANS RA-Sa-2009 performed in November 2021

• Peer review included all applicable elements except for technical element SF. Focus scope peer review for SF technical element is scheduled for October 2023.

• A single F&O closure review was performed in accordance with Appendix E to NEI 17-07 in August 2022

• No open Finding F&Os**

10

• F&O Closure report is not finalized yet. Statement made from draft report.

• • Technical element SF is not yet peer reviewed. All potential findings from this peer review will be discussed in Enclosure 2 of LAR.

Internal Use Only

PRA Model Technical Adequacy

• Seismic Hazard

• Penalty factor utilized for RICT application

• High Winds Hazard

• Penalty factor utilized for RICT application

• Other External Hazards

• External Hazards screening assessment was reviewed against the technical elements in Section 6 of the ASME/ANS PRA standard in September 2015

• A single F&O closure review was performed in accordance with Appendix E to NEI 17-07 in August 2023*

11 *F&O Closure report is not finalized yet. Any potentially open Findings will be discussed in Enclosure 2 of LAR.

Internal Use Only

PRA Model Uncertainties and Assumptions

• WCGS followed the process defined in NUREG-1855, EPRI 1016737, and EPRI 1026511

• Assessment of potential sources of uncertainty key to the RICT application and provided disposition/treatment of uncertainty for the application

• Identification of plant-specific sources and generic sources for all Hazards per EPRI 1016737

• Identification of Internal Fire PRA plant-specific sources and generic sources per Appendices of EPRI 1026511

• Consideration of both parameter and completeness uncertainties 12 Internal Use Only

CRM Program

• A Real-Time Risk Model (CRM Model) similar to existing Maintenance Rule a(4) quantitative Configuration Risk Management Program

• Incorporates Internal Events, Internal Flooding, and Fire into a One-Top Multi-Hazard Model

• Uses EPRI Phoenix Risk Monitor Software to develop quantitative results

• Incorporates RICT Calculation Based on CDF and LERF with maximum 30-day backstop

• Maintenance Rule (MR) Program

• Current MR program at WCGS follow guidance defined in NEI 18-10 (MR 2.0) 13 Internal Use Only

LAR Schedule Projected submittal in November 2023 with requested approval within one year

• Submittal timing supports a TSTF-505 audit after completion of the Spring 2024 Refueling Outage

• A 180-day implementation period is proposed WCNOC plans to submit a 10 CFR 50.69 LAR during the NRC review of the TSTF-505 LAR

• It is expected that there will be efficiencies gained by synergies with these concurrent reviews of the PRA 14 Internal Use Only

Summary

• TSTF-505 LAR is scheduled to be submitted in November 2023 with approval requested in one year

• LAR is consistent with TSTF-505 Model Application

• RICT process will follow NEI 06-09-A

• PRA is technically acceptable for the RICT Application 15 Internal Use Only

Questions/Comments?

16 Internal Use Only