ML24033A054

NRR E-mail Capture - FitzPatrick - Final HFE RAI Regarding Amendment to Update the Fuel Handling Accident Analysis

ML24033A054
Person / Time
Site:	FitzPatrick
Issue date:	02/01/2024
From:	Edwards T NRC/NRR/DORL/LPL1
To:	Hasanat A Constellation Energy Generation, Exelon FitzPatrick
References
L-2023-LLA-0103
Download: ML24033A054 (5)

Text

From:

Theo Edwards Sent:

Thursday, February 1, 2024 4:30 PM To:

Hasanat, Abul M:(Constellation Nuclear)

Cc:

Hawes, Mark:(Constellation Nuclear); James Kim

Subject:

Final HFE RAI regarding FtizPatrick Amendment to Update the Fuel Handling Accident Analysis (EPID: L-2023-LLA-0109)

Attachments:

Fitzpatrick FHA analysis TS change RAIs-rev 1.docx

SUBJECT:

FitzPatrick - Final HFE RAI regarding Amendment to Update the Fuel Handling Accident Analysis (EPID: L-2023-LLA-0109)

Mr. Hasanat, By letter dated August 3, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession ML23215A012), Constellation Energy Generation, LLC (CEG) submitted an amendment to revise the James A. FitzPatrick Nuclear Plant fuel handling accident analysis and technical specification bases definition of recently irradiated fuel to account for changes to the analyses in support of the transition from the refuel bridge mast NF-400 (i.e., triangular mast) to the new NF-500 mast.

The NRC staff has determined that additional information is needed to complete its review of the amendment. On January 22, 2023, the NRC staff sent FitzPatrick the draft Request for Additional Information (RAI) from the Human Factors Engineering Branch (HFE). On February 1, 2024, the RAI clarification call was held between the NRC and FitzPatrick staff and the licensee agreed to provide the RAI responses by March 1, 2024. A publicly available version of this final RAI (attached) will be placed in the NRCs ADAMS.

Theo Edwards Project Manager NRR/DORL/LPL-1 U.S. Nuclear Regulatory Commission

Hearing Identifier:

NRR_DRMA Email Number:

2386 Mail Envelope Properties (SA1PR09MB115967C6E2A1A69986303E13E9F432)

Subject:

Final HFE RAI regarding FtizPatrick Amendment to Update the Fuel Handling Accident Analysis (EPID L-2023-LLA-0109)

Sent Date:

2/1/2024 4:30:18 PM Received Date:

2/1/2024 4:28:00 PM From:

Theo Edwards Created By:

Theo.Edwards@nrc.gov Recipients:

"Hawes, Mark:(Constellation Nuclear)" <Mark.Hawes@constellation.com>

Tracking Status: None "James Kim" <James.Kim@nrc.gov>

Tracking Status: None "Hasanat, Abul M:(Constellation Nuclear)" <Abul.Hasanat@constellation.com>

Tracking Status: None Post Office:

SA1PR09MB11596.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1282 2/1/2024 4:28:00 PM Fitzpatrick FHA analysis TS change RAIs-rev 1.docx 47774 Options Priority:

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OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING HUMAN FACTORS ENGINEERING DESCRIBED IN LICENSE AMENDMENT REQUEST TO UPDATE THE TECHNICAL SPECIFICATION BASES TO CHANGE THE FUEL HANDLING ACCIDENT ANALYSIS LICENSE AMENDMENT FOR JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NOS. 50-333 (ENTERPRISE PROJECT IDENTIFICATION NUMBER EPID: L-2023-LLA-0109 By letter dated August 3, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23215A012), Constellation Energy Generation, LLC (CEG) submitted to the U.S. Nuclear Regulatory Commission (NRC) a license amendment request (LAR) to update the Technical Specification Bases to change the fuel handling accident analysis.

Additional information is needed for the NRC staff to continue its review of this LAR.

The NRC staff is reviewing the LAR using the following regulations and guidance:

Title 10 of the Code of Federal Regulations (10 CFR), Part 50.67(b) states, in part, the following:

[a] licensee who seeks to revise its current accident source term in design basis radiological consequence analyses shall apply for a license amendment under § 50.90. The application shall contain an evaluation of the consequences of applicable design basis accidents previously analyzed in the safety analysis report.

In conducting reviews of the HFE aspects of licensing submittals for light water reactor facilities, the NRC staff apply the guidance of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR [Light-Water Reactor] Edition (the SRP). Chapter 18 of the SRP, Revision 3, Human Factors Engineering, provides guidance for the review of HFE considerations of plant modifications and important human actions.

For circumstances involving both changes resulting from plant modifications and the evaluation of important human actions, SRP Chapter 18 provides guidance regarding the use of NUREG-1764, Guidance for the Review of Changes to Human Actions, Revision 1. This document provides guidance for reviewing changes in human actions, such as those that are credited in nuclear power plant safety analyses.

RAI HFE #1

Background

NUREG-1764 section 4.2 provides criteria regarding the conduct of task analysis, including analyses regarding how personnel will both know when action is necessary and that it is performed correctly. However, the LAR does not provide any discussion of the results of any task analysis for the proposed change.

Question

Please provide a description of any task analysis conducted for operator actions affected by the proposed change, including whether the results of any such analysis concluded that operator tasks would remain unchanged.

RAI HFE #2

Background

NUREG-1764 section 4.3 provides criteria regarding modifications to operator training as it relates to operator task requirements. However, the LAR does not describe the operator training that will be conducted for the manual operator actions affected by the proposed change.

Question Please provide a description of the operator training that is conducted for the manual operator actions that are discussed in the LAR, as well as whether any modifications to the operator training program will occur in conjunction with the proposed change.

RAI HFE #3

Background

NUREG-1764 section 4.4 provides criteria regarding walkthrough activities conducted for human actions to determine that procedures are accurate and usable, that the training program appropriately addressed the changes, and that the human actions can be completed within the required time. In Section 3.0 of the LAR, CEG stated the following:

Implementation of these two proposed changes first required the FHA analysis to be redefined with three different cases Case 2 accounts for the scenario from 24 - 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> after reactor shutdown where SC is not operable, but CREVAS is operable. CREVAS action occurs by manual operator action as controlled by existing operator procedure AOP-44 Dropped Fuel Assembly. Crediting of CREVAS as early as 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor shutdown requires an 8-minute Time Critical Action (TCA) after initiation of the event to isolate control room ventilation.

The operator action is defined by the following criteria:

Procedure is entered when the control room operator in communication with the refuel floor reports a fuel handling accident.

Success criteria is achieved when the control room is isolated by manual switch in the control room and a supply isolation bypass damper is manually positioned closed to address single failure of inlet isolation valve.

This revision to the time critical operator action required time will be managed per guidance in OP-AA-102-106 Operator Response Time Program.

Question Please provide a description of the results of the timing validation of the new time critical operator action for verification of CREVAS manual actuation. As part of this, please include details regarding the following:

Measures included to create realistic scenario conditions;

Any issues identified with procedural completeness, technical accuracy, and usability; Any training program issues identified; Whether the credited operator actions could be completed within the allowed time and whether adequate margin exists between the time required and time allowed; Whether any complicating factors that might be expected to affect the crews' ability to perform the credited operator actions were included; and How many complete crews of operators participated in the walkthrough scenarios.