ML24143A185

– Regulatory Audit in Support of LAR to Adopt TSTF-505, Rev. 2, TSTF-439, Rev. 2, and TSTF-591, Rev. 0

ML24143A185
Person / Time
Site:	Fermi
Issue date:	05/29/2024
From:	Shilpa Arora Plant Licensing Branch III
To:	Domingos C DTE Electric Company
Arora S
References
EPID L-2024-LLA-0034
Download: ML24143A185 (1)

Text

May 29, 2024

Christopher Domingos Site Vice President DTE Electric Company 600 N Dixie Highway Newport, MI 48166

SUBJECT:

FERMI POWER PLANT, UNIT 2 - REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B, TSTF-439, REVISION 2, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO, AND TSTF-591, REVISION 0, "REVISE RISK INFORMED COMPLETION TIME (RICT) PR OGRAM" (EPID L-2024-LLA-0034)

Dear Christopher Domingos:

By letter dated March 21, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24081A326), DTE Electr ic Company (the licensee) submitted a license amendment request (LAR) to amend the license for Fermi Power Plant, Unit 2, Operating License No. NPF-43. The proposed LAR would adopt Technical Specifications Task Force Traveler 505, Revision 2, Provide Risk-informed Extended Completion Times - RITSTF Initiative 4b (TSTF-505), TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, and TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program."

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 approximately June 17, 2024, through October 31, 2024, with formal audit meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.

C. Domingos

If you have any questions, please contact me by telephone at 301-415-1421 or by email to Surinder.Arora@nrc.gov.

Sincerely,

/RA/

Surinder Arora, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-341

Enclosures:

1. Audit Plan

2. Audit Requests

cc: Listserv

REGULATORY AUDIT PLAN

BY THE OFFICE OF NUCLEAR REACTOR REGULATION

TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST

TO ADOPT TSTF-505, REVISION 2, TSTF-439, REVISION 2, AND TSTF-591, REVISION 0

DTE ELECTRIC COMPANY

FERMI POWER PLANT, UNIT 2

DOCKET NO. 50-341

1.0 BACKGROUND

By letter dated March 21, 2024 [1], DTE Electric Company (the licensee) submitted a license amendment request (LAR) to amend the license for Fermi Power Plant, Unit 2 (Fermi 2). The proposed LAR would modify the Fermi 2 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 [2]. The proposed LAR would also adopt TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO [limiting condition for operation] [3], and TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT)

Program [4].

The staff from the U.S. Nuclear Regulatory Commissions (NRCs) Office of Nuclear Reactor Regulation(NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures [5].

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 relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR LIC-111, R egulatory Audits [6], with exceptions noted within this audit plan.

Enclosure 1

The NRC staff will perform the audit to support its evaluation of whether the licensees request can be approved per Title 10 of the Code of Federal Regulations (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 Licens ing Basis [7]. The audit will assist the NRC staff with understanding the licensees proposed program for implementing RICTs for certain TSs.

3.0 SCOPE

The audit team will view the documentation and calculations that provide the technical support for the LAR. 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 [8].

Understand how the licensees proposed program conforms to TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, and TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program.

Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the 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 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 [9].

The NRC staff will audit the PRA methods that the licensee would use to 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 also 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 two weeks of the date of this audit pl an. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within one 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:

Name E-mail Review Area (Organization)

Surinder Arora (1) Surinder.Arora@nrc.gov Plant Licensing Branch LPL 3 (LPL3)

Alexander Schwab(2) Alexander.Schwab@nrc.gov PRA Licensing Branch A (APLA)

Todd Hilsmeier Todd.Hilsmeier@nrc.gov Daniel Ju Daniel.Ju@nrc.gov Charles Moulton Charles.Moulton@nrc.gov PRA Licensing Branch B (APLB)

Jay Robinson(3) Jay.Robinson@nrc.gov Keith Tetter Keith.Tetter@nrc.gov PRA Licensing Branch C (APLC)

Sunwoo Park Sunwoo.Park@nrc.gov Edmund Kleeh Edmund.Kleeh@nrc.gov Electrical Engineering Branch Vijay Goel Vijay.Goel@nrc.gov (EEEB)

Norbert Carte Norbert.Carte@nrc.gov Instrumentation and Controls Ming Li Ming.Li@nrc.gov Branch (EICB)

Gurjendra Bedi Gurjendra.Bedi@nrc.gov Mechanical Engineering and Inservice Testing Branch (EMIB)

Derek Scully Derek.Scully@nrc.gov Containment and Plant Systems Rob Atienza Rob.Atienza@nrc.gov Branch (SCPB)

Fred Forsaty Fred.Forsaty@nrc.gov Nuclear Systems Performance Branch (SNSB)

Khadijah West Khadijah.West@nrc.gov Technical Specifications Branch Robert Elliott Robert.Elliott@nrc.gov (STSB)

To Be Determined (TBD) (4) TBD Pacific Northwest National TBD (4) TBD 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 within 2 weeks of the date of this audit plan (approximately June 17, 2024).

A desktop audit will take place between approximately June 17, 2024, and October 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 NRR LIC-115 [9] and issue such RAIs separate from audit-related corre spondence. 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 evaluation of the LAR.

9.0 REFERENCES

[1] Domingos, Christopher P., DTE Electric Company, Fermi Power Plant Unit 2 - letter to U.S.

Nuclear Regulatory Commission, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, Revise the Risk Informed Completion Time (RICT) Program, March 21, 2024 (Agencywide Documents A ccess and Management System (ADAMS)

Accession No. ML24081A326).

[2] Technical Specifications Task Force (TSTF) - A Joint Owners Group Activity, TSTF Comments on Draft Safety Evaluation for Traveler TSTF 505, Provide Risk-Informed Extended Completion Times, and Submittal of TSTF-505, Revision 2, July 2, 2018 (ADAMS Package Accession No. ML18183A493).

[3] Technical Specifications Task Force Traveler TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO," June 20, 2005 (ML051860296).

[4] Technical Specifications Task Force Traveler TSTF-591, Revise Risk-Informed Completion Time (RICT) Program, March 22, 2022 [letter] and September 21, 2023 [final safety evaluation]

(ML22081A224 and ML23262B230, respectively).

[5] U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-101, Revision 6, License Amendment Review Procedures, July 31, 2020 (ML19248C539).

[6] U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-111, Revision 1, Regulatory Audits, October 31, 2019 (ML19226A274).

[7] U.S. Nuclear Regulatory Commission, NUREG-0800 - Standard Review Plan: Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, June 2007 (ML071700658).

[8] Nuclear Energy Institute (NEI), NEI 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Techn ical Specifications (RMTS) Guidelines -

Industry Guidance Document, Octo ber 2012 (ADAMS Package Accession No. ML122860402).

9] U.S. Nuclear Regulatory Commmission, Office of Nuclear Reactor Regulation, LIC-115, Revision 1, Processing Requests for Additional Information, August 5, 2021 (ML21141A238).

AUDIT REQUESTS

[ITEM AUDIT REQUEST 1 Reports cited in Enclosure 2 of the LAR to adopt TSTF-505 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 #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 LAR.

b. Identification of key assumptions and sources of uncertainty for the TSTF-505 LAR.

c. Parametric uncertainty and state-of-knowledge correlation evaluation for the TSTF-505 LAR.

3 PRA notebooks for the modeling of digital control systems, including basis for the representative failure probabilities.

4 If modeled, PRA notebooks associated with the modeling of open phase condition (OPC) in electrical switchyards and the open phase isolation system (OPIS).

5 Documentation of how shared or cross-tied systems are modeled in the PRA.

6 Fire PRA notebooks containing the results of the fire PRA, including risk importance measures.

7 -Fermi 2 Nuclear Power Station; Other External Hazards Screening Report; EF2-PRA-023 Rev 1, Fermi 2 PRA; Approved 29 August 2016.

-Report EF2-PRA-014, "Level 2 Notebook," Revision 3.

-Report EF2-PRA-006, "Dependency Notebook," Rev. 2.

8 Documentation supporting the example risk-informed completion times (RICT) calculations presented in LAR Enclosure 1, Table E1-2.

9 Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA.

10 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).

11 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.]

12 Other documentation that the licensee determines to be responsive to the U.S.

Nuclear Regulatory Commission staffs information requests.

Enclosure 2

ML24143A185 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRA/APLA/BC NAME SArora SRohrer RPascarelli DATE 5/21/2024 5/23/2024 5/20/2024 OFFICE NRR/DRA/APLB/BC NRR/DRA/APLC/BC NRR/DORL/LPL3/BC NAME SMakor SVasavada JWhited DATE 5/28/2024 5/23/2024 5/28/2024 OFFICE NRR/DORL/LPL3/PM NAME SArora DATE 5/29/2024