ML23319A334
| ML23319A334 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/20/2023 |
| From: | Robert Kuntz Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation |
| Kuntz R | |
| References | |
| EPID L 2023 LLA 0084, EPID L 2023 LLA 0085 TSTF 505, CFR 50.69 | |
| Download: ML23319A334 (1) | |
Text
November 20, 2023
Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 -
REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED 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-0084 AND EPID L-2023-LLA-0085)
Dear Mr. Rhoades:
By letters dated June 8, 2023, Constellation E nergy Generation, LLC (the licensee) submitted license amendment requests (LARs) to amend the licenses for Quad Cities Nuclear Power Station, Units 1 and 2, Renewed Facility Operating License Nos. DPR-29 and DPR-30, respectively. The proposed LARs would adopt Technical Specifications Task Force (TSTF)Traveler TSTF-505, Revision 2, Provide Risk-informed Extended Completion Times, RITSTF [Risk-informed Technical Specifications Task Force] Initiative 4b and adopt the provisions of 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 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 using a licensee-established electronic portal available to NRC staff from the date of this letter through March 31, 2024, with formal audit meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.
D. Rhoades
If you have any questions, please contact me by telephone at 301-415-3733 or by email to Robert.Kuntz@nrc.gov.
Sincerely,
/RA/
Robert Kuntz, Senior Project Manager Plant Licensing Branch LPL3 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos. 50-254 and 50-265
Enclosures:
- 1. Audit Plan
- 2. Audit Requests and Audit Questions
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 - TSTF-505
AND 10 CFR 50.69 RISK-INFORMED CATEGORIZATION OF SSCs
CONSTELLATION ENERGY, LLC
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2
DOCKET NOS. 50-254 AND 50-265
1.0 BACKGROUND
By letters dated June 8, 2023 (Constellation Energy Generation, LLC (the licensee) submitted license amendment requests (LARs) for Quad Cities Nuclear Power Station (Quad Cities),
Units 1 and 2. The proposed LARs (Agencywide Documents and Access Management System (ADAMS) Accession No. ML23159A249 and ML23159A 253) requested to modify the Quad Cities technical specifications (TSs) to permit the use of risk-informed completion times (RICTs) in accordance with Technical Specifications Task Force (TSTF)-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (ML18183A493). and proposed 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 Structures, Systems and Components for Nuclear Power Reactors.
The staff from the U.S. Nuclear Regulatory Commissions (NRCs) 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 (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. 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
Enclosure 1
relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR LIC-111, Regulatory Audits (ML19226A274), with exceptions noted within this audit plan.
The NRC staff will perform the audit to support its evaluation of whether the licensees requests can be approved per 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit. The staffs review will be informed by Standard Review Plan, section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis (ML071700658). The audit will assist the NRC staff with understanding the licensees proposed programs for implementing RICTs for certain TSs and categorizing structures systems and components (SSCs) based on their risk significance. Further, due to the overlaps in technical matter and personnel reviewing the two LARs, the NRC staff determined that a combined audit would permit the most efficient use of resources for the NRC and the licensee.
3.0 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 (ML122860402).
Understand how the licensees proposed pr ogram conforms to NRC-endorsed guidance in NEI 00-04, Revision 0, SSC Categorization Guideline (ML052910035), 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 (ML061090627).
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LARs and confirm the 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 staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for these applications.
Identify any information needed to enable the 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 (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 INFORMATION AND OTHER MATERIAL 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 via a web-based electronic portal 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 licen see of the new requests. The NRC staff requests the licensee to notify the review team when an audit item is added to its 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 Review Area Name E-mail RICT 50. (Organization) 69 Robert Kuntz (1) Robert.Kuntz @nrc.gov X X Plant Licensing Branch III April Pulvirenti (2) April.Pulvirenti@nrc.gov X PRA Licensing Branch A Jeff Circle Jeff.Circle@nrc.gov X X (APLA)
Jigar Patel Jigar.Patel@nrc.gov X Charles Moulton Charles.Moulton@nrc.gov X Jay Robinson Jay.Robinson@nrc.gov X PRA Licensing Branch B Thinh Dinh (3) Thinh.Dinh@nrc.gov X X (APLB)
Naeem Iqbal Naeem.Iqbal@nrc.gov X Alissa Neuhausen Alissa.Neuhausen@nrc.gov X X PRA Licensing Branch C Stacey Rosenburg Stacey.Rosenburg@nrc.gov X X (APLC)
Keith Tetter Keith.Tetter@nrc.gov X X Vijay K Goel Vijay.Goel@nrc.gov X Electrical Engineering Edmund Kleeh Edmund.Kleeh@nrc.gov X X Branch (EEEB)
Norbert Carte Norbert.Carte@nrc.gov X Instrumentation and Controls Branch (EICB)
Ming Li Ming.Li@nrc.gov X
Table 1: NRC Audit Team Composition LAR Review Area Name E-mail RICT 50. (Organization) 69 Mechanical Engineering Michael Breach Michael.Breach@nrc.gov X and Inservice Testing Branch (EMIB)
Gurjendra Bedi Gurjendra.Bedi@nrc.gov X Dan Widrevitz Dan.Widrevitz@nrc.gov X Vessels and Internals Branch (NVIB)
Stephen Cumblidge Stephen.Cumblidge@nrc.gov X Piping and Head Penetrations (NPHP)
Gordon Curran Gordon.Curran@nrc.gov X Containment and Plant Nageswara Systems Branch (SCPB)
Karipineni Nageswara.Karipineni@nrc.gov X Diana Woodyatt Diana.Woodyatt@nrc.gov X X Nuclear Systems Jo Ambrosini Josephine.Ambrosini@nrc.gov X X Performance Branch (SNSB)
Khadijah West Khadijah.West@nrc.gov X Technical Specifications Branch (STSB)
Steve Short (4) Steve.Short@pnnl.gov X X Pacific Northwest National Mark Wilk (4) Mark.Wilk@pnnl.gov X X Laboratory (PNNL)
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, virtually. The audit will begin from the date of this letter and last through March 31, 2024.
The NRCs licensing project manager will inform t he licensee of the entrance and exit meeting dates when they are established. 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.
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
The NRC staff will develop any RAIs, as needed, in accordance with 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.
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 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 (OPC) in electrical switchyards and the open phase isolation system (OPIS).
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 Reports and procedures cited in Enclosure 4 of the LAR to adopt TSTF-505 and Attachment 4 of the LAR to adopt 10 CFR 50.69 related to the external flooding analysis, including revised analysis and updated strategies for Local Intense Precipitation and Probable Maximum Flooding. Specific reports include:
QDC0000-S-2089, "Evaluation of Flood Boundary Structures for Local Intense Precipitation," Revision 2, dated January 29, 2018 QCOA 0010-22, "Local Intense Precipitation Response Procedure," Revision 11 QCOA 0010-16 "Flood Emergency Procedure," Revision 29 QCNPS Quad Cities Nuclear Power Station, "Probabilistic Flood Hazard Assessment Report for the Mississippi River," dated December 7, 2021 EC 636912, "Update to Station External Flood Response in Support of Risk,"
dated June 10, 2022 EC 636914, "Update to LIP Barriers to Assist the Station External Flood,"
dated June 3, 2022 9 Reports cited in Enclosure 4 of the LAR to adopt TSTF-505 for the seismic penalty calculation and Attachment 4 of the LAR to adopt 10 CFR 50.69 for the EPRI seismic alternative Tier 1 methodology, including:
- Exelon Generation Company, LLC Report No. SL-012196, Seismic Hazard and Screening Report - Quad Cities Units 1 and 2, dated March 20214.
10 Reports and procedures cited in Enclosure 4 of the LAR to adopt TSTF-505 and Attachment 4 of the LAR to adopt 10 CFR 50.69 related to extreme winds, including:
QC-MISC-048, "Quad Cities Nuclear Power Station Tornado Missile Risk Assessment," Revision 0, dated May 2023.
Enclosure 2
ITEM AUDIT REQUEST 11 Reports, procedures, and inspections cited in Enclosure 4 of the LAR to adopt TSTF-505 and Attachment 4 of the LAR to adopt 10 CFR 50.69 related to screening of other external hazards, including external hazard assessments, hot and cold weather, toxic gas/chemical release, and lock and dam failure.
12 Documentation supporting the example risk-informed completion times (RICT) calculations presented in LAR Enclosure 1, table E1-2.
13 Documentation supporting the developm ent of the real-time risk tool and benchmarking it against the PRA.
14 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
15 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.
16 EC 404409, "Integrated Review of Flex Actions IAW NEI Validation Process Fukushima," dated April 20, 2016 17 LN-FLEX.2, Licensed/Non-Licensed Operator Initial/Continual Training, FLEX Equipment, August 2019 18 EC 404409, "Integrated Review of FLEX Actions IAW NEI Validation Process Fukushima," dated February 1, 2016 19 QC-MISC-047, "Assessment of Key Assumptions and Sources of Uncertainty for the Quad Cities Nuclear Power Plant," Revision 0 20 QC-PRA-021.62, "Quad Cities Nuclear Power Plant Fire PRA Uncertainty and Sensitivity Analysis Notebook," Revision 2, dated November 2021 21 According to the TS 3.8.1 LCO [limiting condition for operation], Items c and d; the opposite units onsite Class 1E Electrical Distribution supports the following equipment required to Operable by: LCO 3.6.4.3, Standby Gas Treatment (SGT)
System, LCO 3.7.4, Control Room Emergency Ventilation (CREV) System (Unit 2 only), and LCO 3.7.5, Control Room Emergency Ventilation Air Conditioning (AC)
System" (Unit 2 only).
Provide relevant drawings and description showing/explaining the details of AC power feeds from the safety-related buses (fed by the one qualified offsite circuit or the opposite units diesel generator (DG)) to above stated shared equipment/systems, i.e., Standby Gas Tr eatment (SGT) System; Control Room Emergency Ventilation (CREV) System (Unit 2 only), and Control Room Emergency Ventilation Air Conditioning (AC) System" (Unit 2 only).
ITEM AUDIT REQUEST 22 According to the TS 3.8.4 LCO, Item c; the opposite units 125 VDC electrical power subsystem supports the following equipment required to Operable by: LCO 3.6.4.3, Standby Gas Treatment (SGT) System, LCO 3.7.4, Control Room Emergency Ventilation (CREV) System (Unit 2 only), and LCO 3.7.5, Control Room Emergency Ventilation Air Conditioning (AC) System" (Unit 2 only), and LCO 3.8.1, AC
[alternating current] Sources - Operating.
Provide relevant drawings and description showing/explaining the details of 125 VDC (volts of direct current) power feeds from the safety-related 125 VDC buses to above stated shared equipment/systems, i.e., Standby Gas Treatment (SGT)
System; Control Room Emergency Ventila tion (CREV) System (Unit 2 only), and Control Room Emergency Ventilation Air Conditioning (AC) System" (Unit 2 only) and LCO 3.8.1, AC Sources - Operating.
23 Provide main single-line diagrams showing the safety-related 250 VDC and 125 VDC systems for each unit.
24 Other documentation that the licensee determines to be responsive to the U.S.
Nuclear Regulatory Commission staffs information requests.
Audit Questions
STSB-1
In Attachment 2 of the LAR, the proposed change to add RICTs for Quad Cities TSs Required Action 3.3.5.1.F.2 (place channel in trip) is, in part:
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channel concurrent with HPCI
[high-pressure coolant injection] or reactor core isolation cooling (RCIC) inoperable OR
In accordance with the Risk-Informed Completion Time Program
The NRC staff recognizes that the licensees proposed change is consistent with the NUREG-1433 Standard Technical Specificatio ns General Electric BWR/4 Plants, Revision 4 (ML21272A358) TS markups in TSTF-505, Revision 2. However, it has been brought to staffs attention that some of the TSTF-505 markups contain errors, introducing potential for licensee actions to be less conservative than the original intent of the requirements. To modify completion times that include the phrase from discovery, the RICT shall start at discovery instead of the time the TS action statement is entered, or the normal time zero. The requirement is not clear when the RICT statement is separated from the from discovery statement.
To provide clarity, revise the placement of the proposed completion time for TS Required Action 3.3.5.1.F.2 between 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> and from discovery or discuss how the proposed change ensures that the time of entry for the condition as at from discovery is clear. Also, provide a similar change of discussion for proposed change for Required Action 3.3.5.1.G.2, which is formatted similarly.
STSB-2
In TSTF-505, Revision 2, TS Example 1.3-8 appears to contain a typographical error.
Assess whether the reference in the first paragraph to Condition C should be revised to Condition B.
STSB-3
Discuss why the following Required Actions have a proposed note that excludes loss of function (LOF) conditions for the RICT program when the associated LCO has a separate TS condition that addresses a LOF condition? (This question is seeking to understand, not necessarily to revise, the proposed TS.)
- a. RA 3.3.2.2.A.1 (TS 3.3.2.2 Condition B addresses LOF)
- b. RA 3.3.4.1.A.1 and A.2 (TS 3.3.4.1 Conditions B and C address LOF)
- c. RA 3.3.6.1.A.1 (TS 3.3.6.1 Condition B addresses LOF)
STSB-4
For TS Required Action 3.8.4.B.2, the current completion time is [p]rior to exceeding 7 cumulative days per operating cycle of battery inoperability, on a per battery basis, as a result of maintenance or testing. The frontstop 7 cumulative days is not fixed like all described in TSTF-505, Revision 2; it is variable depending on how many days have been used during the operating cycle for an inoperable battery. Applying a RICT to this required action is also inconsistent with the guidance in NEI 06-09-A that does not mention variable frontstop completion times.
Remove this proposed change or provide justification for the following questions:
- a. How would the variable frontstop be evaluated to begin calculating a RICT?
- 1. Provide an example where more than 1 day but less than 7 days has been applied to an inoperable battery in the operating cycle.
- 2. Provide an example of what would happen when TS 3.8.4 Condition B is applicable and the 7-day threshold has already been exceeded (e.g., RICT was used one time and exited during the same operating cycle)?
- b. Are there ever emergent maintenance and testing scenarios that would apply to TS 3.8.4 Condition B? If so, would a RICT be applied after the 7-day threshold were exceeded and what frontstop value would be selected?
STSB-5
The proposed administrative controls for the RICT program in TS 5.5.15 paragraph e of of the LAR was based on the TS markups of TSTF-505, Revision 2, for Quad Cities, Units 1 and 2. The NRC staff recognizes that the model safety evaluation (SE) for TSTF-505, Revision 2, contains improved phrasing for the administrative controls for the RICT program in TS 5.5.15 paragraph e, namely the phrasing approved for use with this program instead of used to support this li cense amendment. In lieu of the original phrasing in TS 5.5.15 paragraph e, discuss whether the phrases methods used to support Amendment # xxx or, as discussed in the TSTF-505 model SE, methods approved for use with this program would provide more clarity for this paragraph.
EEEB-1
According to the Quad Cities Updated Final Safety Analysis Report, chapter 8, page 8.3-9, the plant has three emergency diesel generators (EDGs), one dedicated to each unit, and a common which is automatically connected to the unit in which loss of offsite power (LOOP) and loss-of-coolant accident (LOCA) occurs. Considering this arrangement, explain whether the plant (both units) can be safely shutdown in the following scenarios: LOOP for both units, a LOCA on a unit, and a single failure of EDG on another unit. If not, please explain the single-failure criteria as applied to the two units. This clarification will help understand/verify the Design Success Criteria considered in table E-1 of the LAR.
EEEB-2
According to LAR, table E1-1, corresponding to TS Condition 3.8.1.B One required DG inoperable, the design success criteria require Two of out of three DGs, whereas the PRA success criteria require One out of three DGs. Explain the reason for this difference.
EEEB-3
Explain the single-failure criteria considered for the safety-related 250 VDC and 125 VDC systems as applied to the two units.
EEEB-4
In the LAR, corresponding to TS Conditions 3.8.7.A, One or more AC electrical power distribution subsystems inoperable the proposed RICT program has a NOTE stating: Only applicable when a loss of function has not occurred. Explain why a similar NOTE is not proposed for the TS Condition 3.8.7.B, One or more DC [direct current] electrical power distribution subsystems inoperable and TS Condition 3.8.7.C, One or more required opposite unit AC or DC electrical power distribution subsystems inoperable.
EEEB-5
According to the LAR, table E1-1, corresponding to the TS Condition 3.8.1.C Two required offsite circuits inoperable, the design success criteria require Two required offsite circuits.
Explain how the design success criteria will be met with Two required offsite circuits inoperable.
EEEB-6
According to the LAR, table E1-1, the TS Condition 3.8.1.D states One required offsite circuit inoperable OR one required DG inoperable. Please confirm that the TS Condition 3.8.1.D in table E1-1 was meant to state One required offsite circuit inoperable AND one required DG inoperable. Also, according to the table E1-1, for the design success require Two required sources. Explain the two required sources.
ML23319A334 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME RKuntz SRohrer JWhited (SWall for) RKuntz DATE 11/15/23 11/16/23 11/20/23 11/20/23