ML24116A000
| ML24116A000 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/02/2024 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Lies Q Indiana Michigan Power Co |
| Wall S | |
| References | |
| EPID L-2024-LLA-0025 | |
| Download: ML24116A000 (1) | |
Text
May 2, 2024
Q. Shane Lies Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 - REGULATORY AUDIT IN SUPPORT OF REVIEW OF THE APPLICATION TO ADOPT 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2024-LLA-0025)
Dear Q. Shane Lies:
By letter dated March 6, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24073A234), Indiana Mi chigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) for Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 (CNP). The proposed LAR would adopt Title 10 of the Code of Federal Regulations (10 CFR), section 50.69, Risk-informed categor ization and treatment of structures, systems and components for nuclear power reactors.
The U.S. Nuclear Regulatory Commission (NRC) staff has found 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 requires 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 approximately May 13, 2024, through September 20, 2024, with formal audit meetings to be scheduled during this period as needed. The detailed audit plan is enclosed with this letter.
Q. Shane Lies
If you have any questions, please contact me at (301) 415-2855 or by e-mail at Scott.Wall@nrc.gov.
Sincerely,
/RA/
Scott Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos. 50-315 and 50-316
Enclosure:
Audit Plan
cc: Listserv
REGULATORY AUDIT PLAN
BY THE OFFICE OF NUCLEAR REACTOR REGULATION
TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST
TO ADOPT THE REQUIREMENTS OF 10 CFR 50.69
INDIANA MICHIGAN POWER COMPANY
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2
DOCKET NOS. 50-315 AND 50-316
1.0 BACKGROUND
By letter dated March 6, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24073A234), Indiana Mi chigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) for Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 (CNP). The proposed LAR would adopt Title 10 of the Code of Federal Regulations (10 CFR), section 50.69, Risk-informed categorization and treatment of structures, systems and components [SCCs] for nuclear power reactors.
The staff from the Nuclear Regulatory Commissions (NRC) Office of Nuclear Reactor Regulation (NRR) has initiated its review of t he LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (ML19248C539).
2.0 REGULATORY AUDIT BASIS
A regulatory audit is a planned license, or regulation-related activity that includes the examination and evaluation of primarily 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 proced ures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits Revision 1, dated October 2019 (ML19226A274), with exceptions noted within this audit plan.
The NRC staff performs the audit to support its evaluation of whether the licensees LAR can be approved per 10 CFR, section 50.90, Application for amendment of license, construction permit, or early site permit. The NRC staffs review will be informed by NUREG-0800, 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 program for categorizing SSCs based on their risk significance.
Enclosure
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY
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 Nuclear Energy Institute (NEI) 00-04, Revision 0, SSC Categorization Guideline (ML052910035), as endorsed by Regulatory Guide 1.201, Revision 1, Guidelines for Categorizing Structures, Systems, and Com ponents in Nuclear Power Plants According to Their Safety Significance (ML061090627).
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the NRC staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Identify any information needed to enable the NRC 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 the licensee would use to categorize SSCs based on their risk significance. This will include the licensees assessments of internal events (including internal flooding), fire, seismic, PRAs, as well the treatment of uncertainties and evaluation of defense-in-depth. The NRC will also audi t 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 AUDIT
The NRC staff requests information and audit meeting(s) throughout the audit period. The NRC staff uses an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited. The NRC staff provi des the final audit items list as an enclosure to the audit summary report, which will be publicly available. The attachment to this audit plan includes the initial audit items list. Throughout the audit period, the NRC staff provides the licensee with audit questions and audit-related requests so that the licensee can better prepare for audit discussions with NRC staff. Any inform ation accessed through the licensees portal is not held or retained in any way by NRC staff. The NRC staff requests the licensee to have the requested audit information listed in the audit items list to be readily available and accessible for the NRC staffs review via a Web-based portal.
5.0 TEAM ASSIGNMENTS
The audit team will consist of t he following NRC staff from NRR.
Scott Wall, Plant Licensing Branch III (LPL3)
Adrienne Brown, PRA Licensing Branch A (APLA)
David Gennardo, APLA Michael Swim, PRA Licensing Branch C (APLC)
Sunwoo Park, APLC Rob Atienza, Containment and Plant Systems Branch (SCPB)
Brian Lee, SCPB Fred Forsaty, Nuclear Systems Performance Branch (SNSB)
Ming Li, Instrumentation and Controls Branch B (EICB)
Edmund Kleeh, Electrical Engineering Branch (EEEB)
Gurjendra Bedi, Mechanical Engineering and Inservice Testing Branch (EMIB)
Cory Parker, Vessels and Internals Branch (NVIB)
Stephen Cumblidge, Piping and Head Penetrations Branch (NPHP)
The NRC staff may request access for additi onal staff as the audit progresses.
6.0 LOGISTICS
To support the review schedule communicated to the licensee when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and a Web-based portal or other virtual meeting space created by the licensee. NRC information requests and communica tions with licensee staff is coordinated through the NRCs licensing project manager.
A desktop audit will take place between Ma y 13, 2024, and September 20, 2024. The NRCs licensing project manager informs the licensee of the entrance and exit meeting dates when they are established. The NRC intends to set up audit meeting(s) (e.g., a single, multi-day, audit meeting; periodic audit meetings throughout the audit period) on mutually agreeable dates and times (to be determined) to discuss informati on 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.
The NRC staff requests the licensee to have the information referenced in section 4.0 of this audit plan available and accessible for the NRC sta ffs review via an internet-based portal within 2 weeks of the date of this audit plan. The NRC st aff 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 licensee of the new requests. The NRCs licensing project manager informs the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the NRC licensing project manager when an audit item is added to its portal by sending an e-mail to the NRC licensing project manager.
7.0 SPECIAL REQUESTS
The NRC requests access to requested documents and information through a Web-based portal that allows the NRC staff to access document s over the Internet. The following conditions associated with the online portal must be main tained while the NRC staff have access to the online portal:
The online portal will be password protected. A separate password will be assigned to each member of the NRC staff taking part in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password and/or other Web-based portal access information should be provided directly to members of the NRC staff as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES
The NRC staff will develop any RAIs, as needed, via NRR Office Instruction LIC-115 and issue such RAIs separately from audit-related co rrespondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.
Initial Audit Items List
Item # Audit Item 1 Reports cited in Enclosure 2 of the LAR to adopt 10 CFR 50.69 for 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) for the Internal Event and Internal Flooding PRA, Fire PRA, and Seismic PRA. Please include focused-scope peer reviews and F&O closure documentation associated with PRA upgrades and new methods, if applicable.
2 For the internal events, internal flooding, fire, and seismic PRAs, 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)
- b. Identification of key assumptions and sources of uncertainty for this LAR
- c. Parametric uncertainty and state-of-knowledge correlation evaluation 3 PRA notebooks for the modeling of FLEX equipment and FLEX human error probabilities credited in the PRAs.
4 PRA notebooks associated with open items for the Full Power Internal Events PRA, Fire PRA, and Seismic PRA identified in Attachment 3 of Enclosure 2 of the LAR.
5 Fire PRA notebooks containing the results of the fire PRA, including risk importance measures.
6 Seismic PRA notebooks containing the results of the seismic PRA, including risk importance measures.
7 Reports cited in Attachment 4 of Enclosure 2 of the LAR for External Hazards Screening.
8 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled, and scheduled PRA updates).
9 If available, 10 CFR 50.69 SSC Categorization program procedures (e.g., categorization review and adjustment process, decision criteria for Independent Decision-Making Panel (IDP)). (The licensee may choose (optional) to provide draft procedures if final procedures are not available.)
10 Other documentation that the licensee determines to be responsive to the staff's information requests.
Attachment
ML24116A000 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRA/APLA/BC NRR/DRA/APLC/BC NAME Swall SRohrer RPascarelli (ABrown for) SVasavada DATE 04/24/2024 04/25/2024 04/25/2024 04/25/2024 OFFICE NRR/DEX/EICB/BC NRR/DEX/EEEB/BC NRR/DEX/EMIB/BC NRR/DSS/SNSB/BC NAME FSacko WMorton SBailey PSahd DATE 04/25/2024 04/25/2024 04/25/2024 04/30/2024 OFFICE NRR/DSS/SCPB/BC NRR/DNRL/NPHP/BC NRR/DNRL/NVIB/BC NRR/DORL/LPL3/BC NAME BWittick (MValentin for) MMitchell ABuford JWhited DATE 04/25/2024 04/30/2024 04/30/2024 05/01/2024 OFFICE NRR/DORL/LPL3/PM NAME SWall DATE 05/02/2024