ML24163A325

Aging Management Regulatory Audit Plan

ML24163A325
Person / Time
Site:	Clinton
Issue date:	06/28/2024
From:	Lauren Gibson NRC/NRR/DNRL/NLRP
To:	Wilson C Constellation Energy Generation
Shared Package
ML24163A323	List: ML24163A324 ML24163A325
References
Download: ML24163A325 (10)

Text

June 28, 2024 Christopher D. Wilson Director, License Renewal Constellation Energy Generation, LLC 200 Energy Way, KSA-3E Kennett Square, PA 19348

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1 - AGING MANAGEMENT AUDIT PLAN REGARDING THE LICENSE RENEWAL APPLICATION REVIEW

Dear Christopher D. Wilson:

By letter dated February 14, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24045A024), Constellation Energy Generation, LLC (CEG or the applicant) submitted an application for license renewal of Facility Operating License No. NPF-62 for Clinton Power Station (Clinton or CPS), Unit 1, to the U.S. Nuclear Regulatory Commission (NRC or staff). The applicant submitted the application pursuant to Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for license renewal.

The NRC plans to conduct an Aging Management Audit from August 12, 2024 -

October 15, 2024, in accordance with the enclosed regulatory audit plan. The Aging Management Audit will be conducted at NRC Headquarters and the CPS site, as appropriate.

If you have any questions, please contact Chris Tyree at 301-415-3754 or by email at christopher.tyree@nrc.gov.

Sincerely,

/RA/

Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-461

Enclosure:

Aging Management Audit Plan cc: w/encl.: ListServ

ML24163A323 (Pkg)

ML24163A324 (Letter)

ML24163A325 (Audit Plan)

• via email NRR-106 OFFICE PM/NLRP/DNRL LA/NLIB/DNRL NAME CTyree*

KBratcher*

DATE 06/11/2024 06/12/2024 OFFICE BC/NLRP/DNRL NAME LGibson*

DATE 06/ 28 /2024

Enclosure Audit Plan Clinton Power Station, Unit 1 License Renewal Application Aging Management Regulatory Audit August 12, 2024 - October 15, 2024 Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Audit Plan Clinton Power Station, Unit 1 License Renewal Application Aging Management Regulatory Audit

1.

Background

By letter dated February 14,2024, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24045A024), Constellation Energy Generation, LLC (CEG or the applicant) submitted an application for license renewal of Facility Operating License Nos. NPF-62 for Clinton Power Station (CPS), Unit No. 1, to the U.S. Nuclear Regulatory Commission (NRC or staff).

In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, NRC staff will perform an aging management regulatory audit to gain a better understanding of (1) the applicants methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR), and (2) the applicants aging management programs (AMPs), AMR items, time-limited aging analyses (TLAAs), and associated bases and documentation as applicable.

2.

Regulatory Audit Bases License renewal (LR) requirements are specified in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Guidance is provided in NUREG-1800, Revision 2, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated December 2010, and NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL) Report, dated December 2010.

3.

Regulatory Audit Scope of Review Operating Experience Review The scope of this license renewal regulatory audit of CPS is the staffs independent review of plant specific operating experience (OE). The review is performed to identify pertinent examples of age-related degradation, as documented in the applicants corrective action program (CAP) database. The results of the audit will be used to support the staffs further review of AMPs, TLAAs and aging management review line items to provide a basis for the staffs conclusions on the ability of the applicants proposed AMP and TLAAs to manage the effects of aging in the period of extended operation.

The staff will use risk insights to focus the breadth and depth of its review of plant specific operating experience. However, the staffs review is not limited to risk-significant systems and components because 10 CFR Part 54 is a deterministic rule. The staff must conclude that there is reasonable assurance that activities will continue to be conducted in accordance with the current licensing basis and the effects of aging will be managed during the period of extended operation for all structures and components within the scope of 10 CFR Part 54.

Scoping and Screening Review The purpose of the scoping and screening review is to evaluate the applicants scoping and screening methodology used to identify SSCs within the scope of license renewal and subject to AMR, and the results of the implementation of the methodology. The review is performed by evaluating the scoping and screening process and results, as documented in the license renewal application (LRA), implementing procedures, reports, and drawings, such that the NRC staff:

Obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an AMR; and Has sufficient docketed information to allow the NRC staff to reach a conclusion on the adequacy of the scoping and screening methodology results, as documented in the LRA.

AMP, AMR, and TLAA Review The scope of the AMP, AMR, and TLAA review is to: (a) examine the applicants AMPs, AMR items, and TLAAs; (b) verify the applicants claims of consistency with the corresponding GALL Report AMPs, and AMR items; and (c) assess the adequacy of the TLAAs. Enhancements and exceptions will be evaluated on a case-by-case basis with the results documented in the safety evaluation (SE).

The NRC staff will audit Program Elements 1 - 10 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and OE) of the AMPs against the elements of the associated AMP described in the GALL Report. In addition, the NRC staff will verify that the conditions at the plant are bounded by the conditions for which the GALL Report program was evaluated.

The NRC staff will also examine the applicants program bases documents and related references for AMPs, AMR items, and TLAAs, and interview applicant representatives to obtain additional clarification.

The NRC staff will use risk insights to inform the prioritization of its review of documentation associated with AMPs, AMR items, and TLAAs and to focus the breadth and depth of its review of plant specific operating procedures and OE. However, the NRC staffs review is not limited to risk-significant systems and components because 10 CFR Part 54 is a deterministic rule and the NRC staff must conclude that there is reasonable assurance that activities will continue to be conducted in accordance with the current licensing basis and the effects of aging will be managed during the period of extended operation for all structures and components within the scope of 10 CFR Part 54.

The NRC staff has reviewed the list of risk-significant systems and components provided by the applicant to inform the establishment of priorities for the performance of the scoping and screening review.

4.

Audit Activities Throughout the Aging Management Audit technical staff will conduct a technical review of the LRA, as supplemented and revised, the AMP basis documents, license renewal drawings, and other CPS supporting documents, as appropriate and requested, on the applicants electronic portal (ePortal). The project team requires continued CPS document review capability via the ePortal throughout the audit process. Document requests for upload to the ePortal shall be made as needed via the NRC safety project manager to the appropriate applicant licensing manager.

The Aging Management Audit will consist of four parts that will be scheduled and coordinated between the NRC staff and the applicant. Each audit part allows the applicant to provide context on the ePortals contents and configuration, the methods used to develop the LRA, the corresponding results, and any areas unique to the CPS LRA. The staff will have the opportunity to have discipline-specific discussions with the applicant to discuss the approaches used for evaluation and development of AMPs, TLAAs, AMR items, with the consideration of OE. In addition, the staff may identify specific technical areas where the staff would benefit from a presentation or discussion to provide additional context to support the staffs review. The staff is to review the information needed to perform the safety review and use the information, to the extent possible, to begin developing draft input for the SE, resulting in an SE with open items.

At the conclusion of the staffs technical review, the staff will identify any areas requiring inclusion in appropriate formal audit parts outlined below. The four Aging Management Audit parts include:

Part 1: In-Office Operating Experience Audit The staff will review:

(1) Applicants Process to Identify OE Used in Development of AMPs. The staff requests that the applicant provides a presentation on the process used to identify and evaluate the pertinent OE that was used to inform the development of the AMPs as discussed in the LRA and basis documentation.

(2) Use of OE Contained in AMP Report-Out Documents. The staff requests that the applicant discuss how the OE contained in the AMP report-out documents (e.g., reports of inspections, assessments, AMP effectiveness reviews) is in alignment with information contained in the CAP database and how the process described in (1) along with the use of the report-out information would include any pertinent OE otherwise contained in the CAP database. The applicant should demonstrate that OE identified by the process or included in the report-out documents is bounding of OE that should be considered for developing the LRA. Additionally, the applicant should provide examples of the report-out documents and corresponding corrective action reports.

(3) Staffs Review of Age-Related OE Contained in the CAP Database. Following the applicants presentations on the process to identify and evaluate OE as well as the information included in the report-out documents, the staff should determine if there are any specific areas of OE that have not been sufficiently addressed or if there is a need to sample the information discussed by the applicant to verify the applicants results. If the staff identifies such a need, the staff will have an opportunity to perform an independent review of age-related OE contained in the CAP database, as necessary, to provide

reasonable assurance that the applicant has adequately identified and evaluated pertinent OE in the development of the LRA in Part 2 of the Aging Management Audit.

Part 2: On-Site Scoping and Screening Audit The applicant presents on references, tools, procedures and reports, and approach to scoping and screening methodology developed and applied to meet the requirements of 10 CFR 54.4(a) and 10 CFR 54.21. The presentation includes technical references used for scoping and screening - updated final safety analysis report, equipment database, Maintenance Rule information, program tools used for LRA development (database),

implementing procedures, guidance documents and reports, and the plant structural layout.

The staff, with the assistance of the applicant, will conduct a detailed review of scoping and screening methodology for mechanical, electrical, and structural systems and components. As applicable, the review will include implementing procedures; source information; electronic databases; definition of safety-related; design bases events consideration; identification of SSCs within scope; identification of intended functions; scoping/screening boundaries; license renewal drawings; identification of structural systems and components subject to AMR; exceptions taken to Nuclear Energy Institute 95-10, Appendix F, and scoping and screening reports. The review may also include discussions of commodities, consumables, insulation, overhead handling systems, abandoned equipment, and staged equipment, as applicable.

As necessary, the staff will conduct walkdowns of structural systems and components within the scope of license renewal in accordance with 10 CFR 54.4(a). The walkdown includes a review of areas, rooms or structures containing a combination of structural systems and components within the scope of license renewal.

Part 3: On-Site Audit The purpose of the On-Site Audit is to make visual observations of areas, equipment conditions, and configurations, and will be performed by an integrated review team. The On-Site Audit will target specific areas, equipment, and systems, and the staff shall provide the applicant with the audit scope prior to the On-Site Audit to ensure access and to verify that licensee support is available.

Part 4: In-Office Breakout Sessions During the In-Office Breakout Sessions, the NRC staff will have the opportunity to discuss various basis documents, license renewal drawings, references, condition/corrective action reports, and to obtain additional clarification related to the LRA safety review with the applicant.

The NRC staff will hold breakout sessions, via electronic means, of communication with NRC staff and CPS subject matter experts to discuss various basis documents, references, condition/corrective action reports, and interview CPS representatives to obtain additional clarification related to the LR review. Breakout sessions for various technical review areas will occur at predesignated time slots during the audit, with preassigned NRC staff and CPS representatives. NRC staff will provide discussion topics and technical requests and questions to the NRC safety project manager, who will

then relay the information to the CPS licensing manager. Any information requests transmitted to the applicant will be included in the audit report. All breakout sessions will be coordinated via the NRC safety project manager and the CPS licensing manager.

Each of the four parts of the Aging Management Audit will provide the staff the opportunity to have technical discussions with the applicant to gain clarity and information regarding the LRA.

The audit is coordinated to support the development of the reviewers reasonable assurance for the safety finding to be documented in the SE. The staff may require additional information from the applicant for some technical areas, while finding that information on the ePortal is sufficient for other technical areas. Accordingly, some technical areas may not require inclusion in Part 3:

On-Site Audit. The License Renewal Projects Branch (NLRP) safety project manager will coordinate all communications with the applicant. The staff requests for communication with the applicant will require approval of their respective technical branch chief and the NLRP branch chief.

5.

Information and Other Material Necessary for the Regulatory Audit Throughout the Aging Management Audit, the staff will review the LRA, as supplemented and revised, the AMP basis documents and other applicant supporting documents as appropriate and requested, which have been uploaded to the ePortal.

The staff may request additional applicant documents to be added to the ePortal during the course of the audit. The staff requests for ePortal additions shall be made, as needed, to the safety project manager, who will provide the requests to the applicant.

All documents used as the basis for the staffs review will be documented in the audit report.

6.

Team Members Team Member Branch/Division Chris Tyree License Renewal Projects Branch (NLRP)/Division of New and Renewed Licenses (DNRL)

Lauren Gibson NLRP/DNRL John Wise DNRL Steven Bloom Corrosion and Steam Generator Branch (NCSG)/DNRL Andrew Johnson NCSG/DNRL Brian Allik NCSG/DNRL Gregory Makar NCSG/DNRL Joel Jenkins NCSG/DNRL Leslie Terry NCSG/DNRL Lydiana Alvarado Guilloty NCSG/DNRL Matthew Yoder NCSG/DNRL Miranda Ross NCSG/DNRL Paul Klein NCSG/DNRL Reena Boruk NCSG/DNRL Tony Gardner NCSG/DNRL James Gavula NCSG/DNRL Matthew Mitchell Piping and Head Penetrations Branch (NPHP)/DNRL

Ali Rezai NPHP/DNRL Bart Fu NPHP/DNRL Varoujan Kalikian NPHP/DNRL Seung Min NPHP/DNRL Karen Sida NPHP/DNRL Angela Buford Vessels and Internals Branch (NVIB)/DNRL Emma Haywood NVIB/DNRL James Medoff NVIB/DNRL Steven Levitus NVIB/DNRL Eric Palmer NVIB/DNRL On Yee NVIB/DNRL Wendell Morton Electrical Engineering Branch (EEEB)/Division of Engineering and External Hazards (DEX)

Adakou Foli EEEB/DEX Jason Paige Long Term Operations and Modernization Branch (ELTB)/DEX Liliana Ramadan ELTB/DEX Matthew McConnell ELTB/DEX Jorge Cintron-Rivera ELTB/DEX Kenn Miller ELTB/DEX Brian Correll ELTB/DEX Ian Tseng Structural, Civil, Geotech Engineering Branch (ESEB)/DEX George Wang ESEB/DEX George Thomas ESEB/DEX Shao Lai ESEB/DEX Dan Hoang ESEB/DEX Lucas Mackey PNNL Pete Sakalaukus PNNL Shiattin Makor PRA Licensing B (APLB)/Division of Risk Assessment (DRA)

Naeem Iqbal APLB/DRA Daniel Ju APLB/DRA Milton Valentin Containment and Plant Systems (SCPB)/Division of Safety Systems (DSS)

Angelo Stubbs SCPB/DSS Nicholas Soliz SCPB/DSS Gordon Curran SCPB/DSS Nageswara Karipineni SCPB/DSS Rob Atienza SCPB/DSS Phillip Sahd Nuclear Systems Performance Branch (SNSB)/DSS Charles Peabody SNSB/DSS Santosh Bhatt SNSB/DSS Fred Forsaty SNSB/DSS

7.

Logistics The Aging Management Audit will be conducted primarily via electronic means. Entrance and exit briefings will be held at the beginning and end of each audit.

On-Site Audits will be done at CPS and portions of the audit shall be done with electronic means, as needed, to allow NRC staff to participate remotely. The audits schedules, which were coordinated with the NRC staff and the applicant are follows:

In-Office Operating Experience Audit: August 12, 2024 - August 23, 2024 On-Site Scoping and Screening Audit: September 3, 2024 - September 6, 2024 On-Site Audit: TBD In-Office Breakout Sessions: September 23, 2024 - October 15, 2024 These dates may be adjusted if necessary. If so, the NRC staff and the applicant will coordinate on the revised schedule.

8.

Special Requests The NRC staff requests the applicant to make available the LRA program basis documentation and drawings, and other documents as requested.

9.

Deliverables An audit report should be issued to the applicant within 90 days from the end of the Aging Management Audit.