ML24102A284
| ML24102A284 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/07/2024 |
| From: | James Drake Plant Licensing Branch IV |
| To: | Entergy Operations |
| Drake, J | |
| References | |
| EPID L-2023-LLA-0037, EPID L-2023-LLA-0038 | |
| Download: ML24102A284 (1) | |
Text
May 7, 2024 Vice President, Operations Entergy Operations, Inc.
River Bend Station 5485 US Highway 61 St. Francisville, LA 70775
SUBJECT:
RIVER BEND STATION, UNIT 1 -
SUMMARY
OF REGULATORY AUDIT 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 Vice President,
Operations:
By letters RBG-48142 and RBG-48143, dated February 27, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML23058A215 and ML23058A217, respectively), as supplemented by letter dated January 12, 2024 (ML24016A248), Entergy Operations, Inc. (Entergy, 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 conducted a virtual regulatory audit from June 8, 2023, through December 8, 2023, to support its review of the LAR. During the regulatory audit, the NRC staff reviewed documents and held discussions with the Entergy staff and its representatives. The regulatory audit summary is enclosed with this letter.
If you have any questions, please contact me at 301-415-8378 or via email at Jason.Drake@nrc.gov.
Sincerely, Jason J. Drake, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-458
Enclosure:
Regulatory Audit Summary cc: Listserv
/RA/
Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT
SUMMARY
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), as supplemented by letter dated January 12, 2024 (ML24016A248), 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, dated July 2, 2018 (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).
Information that the U.S. Nuclear Regulatory Commission (NRC) staff relies upon to make the safety determination must be submitted on the docket. However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) 50.71, Maintenance of records, making of reports, and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the NRC staff better understand the licensees submitted information. To support its review of the LAR, the NRC staff issued a regulatory audit plan on October 6, 2023 (ML23278A240). The purpose of the audit is to review the documentation related to the subject of its application (e.g.,
calculations and reports) that were not submitted on the River Bend docket, to acquire additional understanding about the amendment request, and to determine whether additional information is needed to be docketed to complete the NRC staffs safety evaluation.
2.0 AUDIT ACTIVITIES The NRC audit team consisted of NRC staff and NRC contract support from the Pacific Northwest National Laboratory (PNNL). Attachment 1 of this audit summary lists the individuals that took part in or attended the audit. The virtual regulatory audit was conducted from June 8, 2023, through December 8, 2023. Throughout the audit period, the NRC audit team used an internet-based portal provided by the licensee to review primarily non-docketed information related to the application. On September 22, 2023, the NRC staff submitted audit questions to the licensee (ML24102A244). On October 11 and October 12, 2023, formal, virtual audit meetings were held with the licensee to facilitate technical discussions of the audit questions according to the audit plan.
Technical discussions were focused on the following major areas: probabilistic risk assessment, external hazards, fire protection, TSs, electrical engineering, and instrumentation and controls.
Non-docketed information provided by the licensee in response to audit questions and the formal meetings is listed in attachment 2 of this audit summary. At the conclusion of the meetings, Entergy committed to issuing a supplement to the application to provide documentation on the docket of certain audit discussion points. Although the formal audit meetings ended on October 12, 2023, NRC staff interactions with the licensee continued until December 8, 2023. In lieu of an exit meeting, the NRCs licensing project managers December 13, 2023, discussion with the licensee regarding the supplement completed the regulatory audit related activities.
3.0 RESULTS OF THE AUDIT By letter dated January 12, 2024 (ML24016A248), the licensee supplemented its application to address certain items discussed during the audit. The NRC staff subsequently reviewed the licensees supplement and determined that no additional information was needed for the staff to complete its review of the LAR.
Attachments:
- 1. List of Participants
- 2. List of Documents Available for Staff Review During the Audit
List of Participants U.S. Nuclear Regulatory Commission (NRC) Audit Team Name, Organization Jason Drake, Plant Licensing Branch 4 (LPL4)
Jennifer Dixon-Herrity, LPL4 Samson Lee, LPL4 Alexander Schwab, Probabilistic Risk Assessment (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 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 Nathan Barrett, PNNL Garill Coles, PNNL Entergy Operations, Inc. (Entergy) Audit Team Name, Organization Ryan Doerr, Entergy Titus Folds, Entergy Phil Couture, Entergy Howard Mahan, Entergy Randy Crawford, Entergy Paul Sicard, Entergy Sarah Ollenburger, Entergy Shailendra Shrivastava, Entergy Gregory Norris, Entergy Firat Alemdar, Entergy Richard Meister, Entergy Stephen Zelesnik, Entergy Marie Schmehl, Enercon Sami Syed, Enercon Hunter Young, Jensen Hughes
List of Documents Available for Staff Review During the Audit Entergy Operations, Inc. (Entergy, the licensee) provided supporting documentation (e.g.,
analyses, calculations, reports, drawings, and procedures) on the River Bend Station, Unit 1 (River Bend) document portal during the audit period. Below is a listing of the documents provided on the portal for the U.S. Nuclear Regulatory Commission (NRC) audit teams review during the audit.
1 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 kilovolt and 480 volt standby bus.
- b. Each Class 1E direct current 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 and concurrent loss of offsite power (LOOP) and loss-of-coolant accident (LOCA)
- b. LCO 3.8.9, Condition C and 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 and PRA success criteria for the applicable TS Conditions for LAR table E1-1, River Bend TS 3.8 (Electrical Power Systems).
- by email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DRA/APLA/BC*
NRR/DRA/APLC/BC*
NAME JDrake PBlechman RPascarelli SVasavada DATE 4/12/2024 4/15/2024 4/19/2024 4/18/2024 OFFICE NRR/DSS/STSB/BC(A)*
NRR/DEX/EEEB/BC*
NRR/DEX/EICB/BC(A)*
NRR/DORL/LPL4/BC*
NAME SMehta WMorton FSacko JRankin DATE 4/19/2024 4/25/2024 4/18/2024 5/6/2024 OFFICE NRR/DORL/LPL4/PM*
NAME JDrake DATE 5/7/2024