ML23278A240
| ML23278A240 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/06/2023 |
| From: | James Drake Plant Licensing Branch IV |
| To: | Entergy Operations |
| Drake, J | |
| References | |
| EPID L-2023-LLA-0037, EPID L-2023-LLA-0038 | |
| Download: ML23278A240 (9) | |
Text
October 6, 2023 Vice President, Operations Entergy Operations, Inc.
River Bend Station 5485 US Highway 61 St. Francisville, LA 70775
SUBJECT:
RIVER BEND STATION, UNIT 1 - REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUESTS TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT RISK-INFORMED COMPLETION TIMES AND IMPLEMENT THE PROVISIONS OF 10 CFR 50.69 (EPID L-2023-LLA-0037 AND EPID L-2023-LLA-0038)
Dear Sir or Madam:
By letters RBG-48142 and RBG-48143, dated February 27, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML23058A215 and ML23058A217, respectively), Entergy Operations, Inc. (the licensee) submitted license amendment requests (LARs) to amend the license for River Bend Station, Unit 1, Renewed Facility Operating License No. NPF-47. The proposed LARs would adopt Technical Specifications Task Force (TSTF)
Traveler TSTF-505, Provide Risk-Informed Extended Completion Times, RITSTF [Risk-Informed TSTF] Initiative 4b, to permit the use of risk-informed technical specification completion times for certain actions required when limiting conditions for operation are not met, and to allow for the implementation of 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 reviewed the licensees LARs in parallel and determined that a regulatory audit would assist in the timely completion of both reviews. The NRC staff will conduct a regulatory audit to support its reviews in accordance with the enclosed audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information.
The NRC staff will conduct the audit to increase its understanding of the LARs and identify information that will require docketing to support the NRC staffs regulatory findings. The NRC staff will conduct the audit virtually from as soon as a portal can be established through December 31, 2023.
If you have any questions, please contact me at 301-415-8378 or via email at Jason.Drake@nrc.gov.
Sincerely,
/RA/
Jason J. Drake, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-458
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF LICENSE AMENDMENT REQUESTS TO TO ADOPT RISK-INFORMED COMPLETION TIMES AND RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS ENTERGY OPERATIONS, INC.
RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458
1.0 BACKGROUND
By letters RBG-48142 and RBG-48143, dated February 27, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML23058A215 and ML23058A217, respectively), Entergy Operations, Inc. (Entergy, the licensee) submitted license amendment requests (LARs) for River Bend Station, Unit 1 (River Bend). The first LAR would modify the River Bend 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 Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b (ML18183A493). These RICTs would apply to certain actions required when limiting conditions for operations are not met. The second LAR would allow for the implementation of 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 provisions of 10 CFR 50.69 allow adjustment of the scope of equipment subject to special treatment controls (e.g.,
quality assurance, testing, inspection, condition monitoring, assessment, and evaluation).
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, License Amendment Review Procedures, dated July 31, 2020 (ML19248C539).
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of information of primarily non-docketed information. 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 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 Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 31, 2019 (ML19226A274),
with exceptions noted within this audit plan.
The NRC staff will perform the audit to support its evaluation of whether the licensees LARs can be approved per 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit. The NRC staffs review will be informed by NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis, dated June 2007 (ML071700658). The audit will assist the NRC staff with understanding the licensees proposed program to implement RICTs for certain TSs.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The scope of the NRC staffs audit will focus on the following subjects:
Learn how the licensees proposed program implements TSTF-505 and conforms to NRC-endorsed guidance in Nuclear Energy Institute (NEI) report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification Guidelines, dated November 2006 (ML12286A322).
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 become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information, dated August 5, 2021 (ML21141A238).
The NRC staff will audit the PRA methods that the licensee would use to determine the risk impact from which the revised completion times would be obtained, including the licensees assessments of internal events (including internal flooding) and fire PRAs. The NRC will also audit the licensees quantification of risk from significant external events, whether the licensee uses PRA or bounding methods, and the licensees evaluation of defense-in-depth.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE 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 will provide the final audit items list as an enclosure to the audit summary report, which will be publicly available. The attachment to this audit plan includes the initial audit items list. Throughout the audit, the NRC staff may supplement this list with audit questions and audit-related requests so that the licensee can better prepare for audit discussions with NRC staff.
Any information accessed through the licensees portal will not be held or retained in any way by NRC staff. The NRC staff will use the audit items list to support the periodic audit meetings with the licensee, which the staff will schedule, as needed. The NRC staff requests that the licensee have the requested audit information listed in the audit items list be readily available and accessible for the staffs review via a web-based portal.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR, including contractors:
Jason Drake, Plant Licensing Branch 4 (LPL4)
Samson Lee, LPL4 Alexander Schwab, PRA Licensing Branch A (APLA)
Mihaela Biro, APLA Thinh Dinh, PRA Licensing Branch B (APLB)
Charles Moulton, APLB Sunwoo Park, PRA Licensing Branch C (APLC)
De Wu, APLC Edmund Kleeh, Electrical Engineering Branch (EEEB)
Vijay K. Goel, EEEB Ming Li, Instrumentation and Controls Branch (EICB)
Norbert Carte, EICB Gurjendra Bedi, Mechanical Engineering and Inservice Testing Branch (EMIB)
Angelo Stubbs, Containment and Plant Systems Branch (SCPB)
Derek Scully, SCPB Fred Forsaty, Nuclear Systems Performance Branch (SNSB)
Khadijah West, Technical Specifications Branch (STSB)
Andrea Russell, STSB Karen Sida, Piping and Head Penetrations Branch (NPHP)
Varoujan Kalikian, NPHP Dan Widrevitz, Vessels and Internals Branch (NVIB)
Mark Wilk, Pacific Northwest National Laboratory (PNNL)
Steve Short, PNNL 6.0 LOGISTICS To support the schedule established when the NRC staff accepted the LARs for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and any web-based portals or meeting spaces created by the licensee. NRC information requests and communications with licensee staff will be coordinated through the NRCs licensing project manager.
The audit will occur as soon as a portal can be established through December 31, 2023. The NRC staffs official entrance meeting with the licensee will likely be in October 2023. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC staff intends to establish meetings as necessary on mutually agreeable dates and times (to be determined) to discuss information needs and questions arising from the staffs review of the audited items.
The NRC staff requests the licensee to have the information referenced in section 4.0 of this audit plan available and accessible for the NRC staffs review via an internet-based portal as soon as possible after issuance 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 requests. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the review team when an audit item is added to its portal by sending an email to the NRC licensing project manager.
7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a web-based portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected, and a separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password information should be provided directly to members of the NRC staff and contractors. The NRC licensing project manager will provide the licensee names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, in accordance with NRR Office Instruction LIC-115 and will issue such RAIs separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LARs.
Attachment:
Audit Items List
Attachment AUDIT ITEMS LIST ITEM #
AUDIT REQUEST 1
Near-term: Presentation of an overview of the risk-informed completion time (RICT) program procedures, including those for determining risk management actions, a demonstration of the process for calculating RICTs (including use of the configuration risk management program tool), and a demonstration of how to use the licensees web-based portal.
2 Results of the fire probabilistic risk analysis (PRA) 3 Reports of full-scope and focused-scope peer reviews (and facts and observations (F&Os) closure reviews) and any self-assessment performed for the internal events, internal flooding, and fire PRAs cited in the license amendment requests (LARs) 4 Closure reports on F&Os from these assessments 5
- a. For the internal events, internal flooding, and fire PRAs, plant-specific documentation (e.g., uncertainty notebooks) related to: The review of the PRA model assumptions and sources of uncertainty
- b. Identification of key assumptions and sources of uncertainty for the application 6
PRA notebooks for the modeling of Diverse and Flexible Mitigation Capability (FLEX) equipment and FLEX human error probabilities credited in the PRA 7
Documentation supporting the example RICT calculations 8
Any draft or final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation (LCOs))
9 Plant and PRA configuration control procedures 10 Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA 11 Relevant design documentation (e.g., single line diagrams of the electrical power distribution systems and piping and instrumentation diagrams) 12 All primary fire PRA notebooks 13 Other documentation that the licensee determines to be responsive to the NRC staff's information requests 14 Load list for each safety-related bus 15 Plant procedures related to the risk management action for the electrical power systems, if available 16 Single line diagrams for following:
- a. Each 4.16 kV (kilovolt) and 480 V (volt) standby bus.
- b. Each Class 1E direct current (DC) division or a comprehensive single line.
- c. Each Class 1E inverter division or a comprehensive single line.
17 Electrical lineups for following:
- a. LCO 3.8.9, Condition A & concurrent loss of offsite power (LOOP) & loss-of-coolant accident (LOCA)
- b. LCO 3.8.9, Condition C & concurrent LOOP & LOCA 18 High-level discussion of the fault tree(s) and/or event tree(s) for electrical sources associated with Technical Specification (TS) LCOs 3.8.1, Condition D; and 3.8.4, Condition B.
19 Discussion of the reasons for any differences between Design Success Criteria (DSC) and PRA Success Criteria for the applicable TS Conditions for LAR table E1-1, River Bend TS 3.8 (Electrical Power Systems).
- concurrence via email OFFICE NRR/DORL/LPL4/PM*
NRR/DORL/LPL4/LA*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME JDrake PBlechman JDixon-Herrity (TWengert for)
JDrake DATE 10/5/2023 10/6/2023 10/6/2023 10/6/2023