ML23317A071

NRC Pre-Submittal Meeting on November 14th, 2023 - TSTF-591 and Selected 50.69 License Condition Updates (EPID L-2023-LLM-0098) (Slides)

ML23317A071
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	11/14/2023
From:	Constellation Energy Generation
To:	Scott Wall NRC/NRR/DORL/LPL3
Wall, SP
References
EPID L-2023-LLM-0098
Download: ML23317A071 (1)

Text

NRC Pre-Submittal Meeting TSTF-591 & Selected 50.69 License Condition Updates November 14th, 2023

Constellation Fleet Submittal

• Constellation is proposing a Fleet LAR submittal to adopt the recently NRC-approved TSTF-591 Revise Risk Informed Completion Time (RICT) Program. Constellation is seeking to:

- Align to Regulatory Guide 1.200, Revision 3 within the TS Section 5.5 RICT Program

- Establish at each site a RICT Upgrade Reporting Program

• Constellation is also proposing to update certain sites Facility Operating License conditions for the 10CFR 50.69 Program.

- Aligns those stations with current reference to RG 1.200 Revision 2 in their 50.69 FOL pages with the changes requested in TSTF-591 (e.g., going forward use of RG 1.200 Revision 3).

• This Pre-Submittal meeting is to propose the submittal strategy to accomplish both objectives and avoid conflicting information in certain sites TS pages 1

Fleet Submittal Structure

• Sites that will submit only for TSTF-591:

- Calvert Cliffs

- Clinton

- Ginna

- FitzPatrick

• Sites that will need to submit for TSTF-591 and submit to update their TS FOL Pages for 50.69

- Braidwood

- Byron

- LaSalle

- Limerick

- Nine Mile Point Unit 2

- Peach Bottom

• Sites that will not be a part of this Fleet submittal and will adopt TSTF-591 in another format or at a later time

- Dresden

- Quad Cities

- Nine Mile Point Unit 1 2

Affected Pages Per Unit

• Two or Three TS Pages per Unit will be revised.

• Blue Box is TSTF-591 and 50.69 FOL page update and Orange Box is just TSTF-591.

3

Submittal Proposal - Proposed Timing of 1Q2024.

• Constellation proposes one Fleet License Amendment Request for all sites seeking adoption of TSTF-591, and those updating their FOL 50.69 condition as well.

• Constellation intends to use the NRC approved TSTF-591 Model Application (ML23262B229).

- Those stations needing 50.69 alignment will be referenced in Section 2.2 Variations, seeking the additional FOL page change

- Constellation will ask for the LAR to be reviewed per the CLIIP process

• Benefits

- Managed under one document/EPID

- Ensures that Sites TS Section 5.5 and FOL pages are in alignment

- Maintains the continuity of one PRA model (i.e., same IE/IF and Fire models) to govern both 50.69 and RICT

- Due to the simplicity of changes with both TSTF-591 and the 50.69 update, the CLIIP process can still be used to process the change

• Constellation recognizes the potential for a >6month CLIIP approval process.

• Alternate submittal proposal

- Standalone TSTF-591 for all sites previously identified, requested via CLIIP

- Standalone 50.69 update LAR for those identified stations needing FOL 50.69 license condition update, requested via expedited review to align with TSTF-591 4

- Both documents submitted concurrently

Questions and Discussion