JAFP-24-0009, Response to Request for Additional Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis

Response to Request for Additional Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis

ML24059A130
Person / Time
Site:	FitzPatrick
Issue date:	02/28/2024
From:	David Gudger Constellation Energy Company
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
JAFP-24-0009
Download: ML24059A130 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 JAFP-24-0009 February 28, 2024 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Response to Request for Additional Information for License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis

References:

1.

Letter from D. Gudger (Constellation Energy Generation, LLC) to U.S.

Nuclear Regulatory Commission, "License Amendment Request to Update the Technical Specification Bases to Change the Fuel Handling Accident Analysis," JAFP-23-0040, dated August 3, 2023

2.

Email from James Kim (Project Manager, U.S. Nuclear Regulatory Commission) to A. Hasanat (Constellation Energy Generation, LLC),

"FitzPatrick - Final HFE RAI regarding Amendment to Update the Fuel Handling Accident Analysis (EPID: L-2023-LLA-0109)," ML24033A054, dated February 1, 2024 By letter dated August 3, 2023 (Reference 1), Constellation Energy Generation, LLC (CEG) requested to change the James A. FitzPatrick Nuclear Power Plant (JAF) Technical Specifications (TS) Bases to change the Fuel Handling Accident Analysis (FHA) due to new Refuel Bridge Mast NF-400 to NF-500 and definition for Recently Irradiated Fuel.

On February 1, 2024 (Reference 2), the U.S. Nuclear Regulatory Commission (NRC) determined that additional information was necessary to complete the review of the amendment.

to this letter contains the NRCs request for additional information immediately followed by CEGs response.

The proposed change in Reference 1 has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Fuel Handling Accident Analysis Docket No. 50-333 February 28, 2024 Page 2 This letter contains no new regulatory commitments.

Should you have any questions concerning this submittal, please contact Abul Hasanat Abul.Hasanat@Constellation.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2024.

Respectfully, David T. Gudger Senior Manager - Licensing & Regulatory Affairs Constellation Energy Generation, LLC

Response to Request for Additional Information cc:

USNRC Region I, Regional Administrator w/attachment USNRC Senior Resident Inspector, JAF USNRC Project Manager, JAF A. L. Peterson, NYSERDA B. Frymire, NYSPSC C. Powers, NYSPSC

ATTACHMENT 1 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Response to Request for Additional Information

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Page 1 of 4 Fuel Handling Accident Analysis Docket No. 50-333 By letter dated August 3, 2023 (ML23215A012, JAFP-23-0040), Constellation Energy Generation, LLC (CEG) submitted a license amendment request (LAR) to update the Technical Specification Bases to change the fuel handling accident analysis.

Additional information was requested on February 1, 2024 (ML24033A054) by 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.

Response to RAI HFE #1:

The operator manual action is initiated by both symptom based and event based criteria associated with a refueling accident. Technical Specification required instrumentation will remain operable for Control Room Ventilation instrumentation. Redundant to this, continuous communication between the refueling bridge and the control room is established per OSP-66.001, Management of Refueling Activities, during all fuel transfer operations. The fundamental initiating condition is based on the dropped fuel bundle event.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Page 2 of 4 Fuel Handling Accident Analysis Docket No. 50-333 AOP-44, Dropped Fuel Assembly, directs the isolation of control room ventilation. These actions involve performing a single switch manipulation in the backpanels of the main control room, verifying that the appropriate isolation dampers have closed and that the emergency ventilation fans have started using Regulatory Guide (RG) 1.97 indication available at the control room panel. To prevent loss of function on a single failure of the supply isolation damper, a redundant isolation bypass damper is then manually positioned closed.

Access to this damper involves exiting the control room and traversing the same level of the Admin Building elevation, a Seismic Class II structure, to the Admin Building Fan room, up a twelve-foot ladder, and to the bypass damper. Success criteria is conservatively assumed to be achieved upon closure of this manual bypass damper. Performing these actions as directed by abnormal operation procedures is an evaluated task in non-licensed operator training. JAF Technical Specifications require one non-licensed operator during modes 4 and 5, when this time critical action would be required. Emergency and administrative staffing requirements would add significant margin in staffing during modes 4 and 5.

Control room actions would be expected to be directly supervised by the control room supervisor, presenting an opportunity for validation of successful performance by another operator. These control room actions and indications are adequate to achieve the design basis isolation, however single failure proof manual closure of the bypass damper would be performed by an operator outside the control room in the manner described above.

It was concluded based on this review and the reduction in available time that while the existing action to isolate the control room is time validated at 6.5 minutes, it is prudent to streamline the Abnormal Operating Procedure (AOP) guidance to increase margin. This is being tracked as a required change prior to implementing the license amendment.

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.

Response to RAI HFE #2:

Consistent with the existing licensing basis, operators are required to manually isolate the control room upon a design basis refueling accident. The pre-existing time critical action to isolate the control room is an evaluated task in equipment operator training, screened in accordance with industry standard procedure NISP-TR-01, Systematic Approach to Training Process, as a low risk significance, a high frequency of routine performance and a low difficulty.

Control/Relay Room Ventilation System is trained to Equipment Operator Continuing Training every 3 years per the Long-Range Training Plan and was last taught in 2022. Any changes to the implementing procedures made to establish additional margin will be assessed for impact on existing training. No change in operator training is required at this time based on this reduction in the available time of completion.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Page 3 of 4 Fuel Handling Accident Analysis Docket No. 50-333 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.

Response to RAI HFE #3:

Please provide a description of the results of the timing validation of the new time critical operator action for verification of CREVAS manual actuation.

No new operator action has been created as a result of this amendment. The amendment revises the assumed time of completion for an existing licensing basis operator action to isolate the control room, which has previously been validated per OP-AA-102-106 at 6.5 minutes. While enhancements are planned to increase the margin to the required completion time, these actions are not required to bring the existing action into compliance with the 8 minute assumptions described in the LAR.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Page 4 of 4 Fuel Handling Accident Analysis Docket No. 50-333 Measures included to create realistic scenario conditions:

The Validation Team Leader directs the plant walkthrough by first providing the plant initial condition and then providing appropriate cues while the personnel walk through each procedure step. (e.g., that fan indication indicates red light on, green light off). The validation personnel use the procedures in accordance with the scenario and plant walkthrough or talk through actions they would take in response to each instruction step.

During the plant walkthrough, personnel performing the procedures describe the actions they are taking, identify the information sources used to take actions, identify the controls used to carry out actions expected system responses, how responses are verified, and the actions to be taken if responses did not occur.

Any issues identified with procedural completeness, technical accuracy, and usability:

There were no issues identified with procedure completeness, technical accuracy, and usability.

Any training program issues identified:

There were no 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:

The isolation of control room ventilation is currently time validated per OP-AA-102-106 as an established Operator Time Critical Action with a validated performance of 6.5 minutes.

Based on the risk significance of the task, adequate margin currently exists to the proposed required completion time of 8 minutes. Based on the significant reduction in the allowable time, prudent actions to streamline the implementing procedure are in progress to increase this margin (per RAI 1).

Whether any complicating factors that might be expected to affect the crews' ability to perform the credited operator actions were included:

No required complicating factors are included in the validation of this time critical action, however, for one of the periodic validations, an injected complicating factor of a damper failure to operate and the associated delays was encompassed, and the activity still successfully performed within 6.5 minutes.

How many complete crews of operators participated in the walkthrough scenarios:

For this amendment, the scope of the task required to meet the design basis assumptions was revisited and the time subsequently revalidated at between 4 and 5 minutes using two independent equipment operators per the guidance described above. With an allowable time (AT) of 8 minutes, the smallest amount of margin we were left with following isolation is 37.5%.

As a result of the greater than 20% margin, the Operator Response Time Program per OP-AA-102-106 did not require validating the action a third time.