ML24222A677
| ML24222A677 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, FitzPatrick, LaSalle  |
| Issue date: | 08/09/2024 |
| From: | Para W Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24222A677 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 August 9, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License No. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Constellation
U.S. Nuclear Regulatory Commission Response to Request for Additional Information - TSTF-591 August 9, 2024 Page 2 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244
Subject:
Response to Request for Additional Information for Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and revise 10 CFR 50.69 License Condition
References:
- 1. Letter from David P. Helker, Constellation Energy Generation, LLC to the U.S. Nuclear Regulatory Commission, Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and revise 10 CFR 50.69 License Condition, dated April 12, 2024 (ADAMS Accession No. ML24103A204).
- 2. Email from Scott Wall, U.S. Nuclear Regulatory Commission to Stephen Flickinger, Constellation Energy Generation, LLC, RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591 (EPID No. L-2024-LLA-0046), dated July 12, 2024 (ADAMS Accession No. ML24197A016).
By letter dated April 12, 2024, Constellation Energy Generation, LLC (CEG) submitted an application for amendment to the Technical Specifications (TS) for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, James A. Fitzpatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 and 2, Peach Bottom Atomic Power Station, Units 2 and 3, and R.E. Ginna Nuclear Power Plant.
CEG requested adoption of TSTF-591-A, "Revise Risk Informed Completion Time (RICT) Program" Revision 0, which is an approved change to the Standard Technical Specifications (STS), into the above licensees TS. TSTF-591-A revises the TS Section 5.5 Programs and Manuals, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT. Additionally, CEG is requesting the removal of certain stations Facility Operating License condition sections associated with the implementation of the 10 CFR 50.69 and Risk-Informed Completion Time programs. By email dated July 12, 2024, the U.S. Nuclear Regulatory Commission (NRC) notified CEG that additional information is needed to complete the review of the License Amendment Request (Reference 2). CEGs response to the NRCs Request for Additional Information is provided in Attachments 1 and 2.
U.S. Nuclear Regulatory Commission Response to Request for Additional Information - TSTF-591 August 9, 2024 Page 3 CEG has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in Reference 1. The information in this response does not impact the conclusion that the proposed license amendments do not involve a significant hazards consideration. The information also does not impact the conclusion that there is no need for an environmental assessment to be prepared in support of the proposed amendments.
There are no regulatory commitments contained in this response.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b), CEG is notifying the Commonwealth of Pennsylvania of this response to request for additional information by transmitting a copy of this letter to the designated State Official.
If you have any questions regarding this submittal, then please contact Steve Flickinger at 267-533-5302.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 9th day of August 2024.
Respectfully, Wendi Para Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments 1.
Response to Request for Additional Information 2a.
Markup of Technical Specifications Pages, James A. FitzPatrick Nuclear Power Plant 2b.
Markup of Technical Specifications Pages, Nine Mile Point Nuclear Station, Unit 2
U.S. Nuclear Regulatory Commission Response to Request for Additional Information - TSTF-591 August 9, 2024 Page 4 cc:
(w/ Attachments)
Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection, PA Department of Environmental Protection S. Seaman, State of Maryland A. L. Peterson, NYSERDA
U.S. Nuclear Regulatory Commission Response to Request for Additional Information - TSTF-591 August 9, 2024 Page 6 Director of Organizational Performance and Regulatory - R. E. Ginna Nuclear Power Plant Regulatory Assurance Manager - Braidwood Station Regulatory Assurance Manager - Byron Station Regulatory Assurance Manager - Calvert Cliffs Nuclear Power Plant Regulatory Assurance Manager - Clinton Power Station Regulatory Assurance Manager - James A. FitzPatrick Nuclear Power Plant Regulatory Assurance Manager - LaSalle County Station Regulatory Assurance Manager - Limerick Generating Station Regulatory Assurance Manager - Nine Mile Point Nuclear Station Regulatory Assurance Manager - Peach Bottom Atomic Power Station Regulatory Assurance Manager - R. E. Ginna Nuclear Power Plant
ATTACHMENT 1 Response to Request for Additional Information License Amendment Request Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, James A. FitzPatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 and 2, Peach Bottom Atomic Power Station, Units 2 and 3, and R.E. Ginna Nuclear Power Plant.
Docket Nos.
STN 50-456 and STN 50-457, STN 50-454 and STN 50-455, 50-317 and 50-318, 50-461, 50-333, 50-373 and 50-374, 50-352 and 50-353, 50-220 and 50-410, 50-277 and 50-278, and 50-244
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response By letter dated April 12, 2024, Constellation Energy Generation, LLC (CEG) submitted an application for amendment to the Technical Specifications (TS) for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, James A. Fitzpatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 and 2, Peach Bottom Atomic Power Station, Units 2 and 3, and R.E. Ginna Nuclear Power Plant.
CEG requested adoption of TSTF-591-A, "Revise Risk Informed Completion Time (RICT)
Program" Revision 0, which is an approved change to the Standard Technical Specifications (STS), into the above licensees TS. TSTF-591-A revises the TS Section 5.5 Programs and Manuals, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT. Additionally, CEG is requesting the removal of certain stations Facility Operating License condition sections associated with the implementation of the 10 CFR 50.69 and Risk-Informed Completion Time programs. By email dated July 12, 2024, the U.S. Nuclear Regulatory Commission (NRC) notified CEG that additional information is needed to complete the review of the License Amendment Request (LAR) (Reference 2).
Requests for Additional Information (RAI):
RAI 1 - In Section 2.2, Variations, of the LAR, CEG included proposed changes to specific FOLs for the CEG fleet that would remove license conditions associated with the implementation of TSTF-505, 10 CFR 50.69 and instance of RG 1.200, Revision 2 for the 10 CFR 50.69 program. CEG proposes to remove the license condition that serves the same purpose as Paragraph e in TSTF-505 because the implementation conditions are no longer relevant.
License Conditions are subject to oversight and inspection. Removal of the license conditions in the subject LAR would therefore need to be validated and verified to assure PRA configuration control is maintained and there is no adverse impact on the decision rendered by the NRC staff for the issued amendment the license condition(s) supported.
The licensee asserted these implementation conditions have been implemented, are no longer relevant, and do not affect the applicability of TSTF-591. While these implementation conditions may not affect the applicability of TSTF-591, they go beyond the adoption of the traveler.
TSTF-591 was developed to be processed and reviewed as a CLIIP. The NRC staff acknowledges the proposed changes in this subject LAR that variated from the TSTF-591 are not major, however, they are not administrative in nature because they do required review to support validation and verification beyond the standard process for review of CLIIPs.
Per TSTF-591, it states in the model application that the licensee describes the differences between the license condition and the TSTF-505, Revision 2, Paragraph e and why they do not affect the applicability of TSTF-591. Please provide the information to justify how the implementation conditions are no longer relevant.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response
Response
The following table provides justification as to why the implementation conditions in the Facility Operating Licenses for Braidwood Station Units 1 and 2, Byron Station Units 1 and 2, LaSalle County Station Units 1 and 2, Nine Mile Point Nuclear Station Unit 2, Peach Bottom Atomic Power Station Units 2 and 3, and R.E. Ginna Power Plant are no longer relevant.
Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
Braidwood
- Station, Units 1 and 2 Adoption of 10 CFR 50.69 The licensee will complete the updated implementation items listed in Attachment 1 of Exelon letter to NRC dated September 13, 2018, prior to implementation of 10 CFR 50.69. All issues identified in the attachment will be addressed and any associated changes will be made, focused scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA Risk Management Document BB-MISC-055, Revision 0, provides documentation of completion of the implementation items described in the 10 CFR 50.69 License Amendment Request.
Item 3.a The internal events and fire PRA models were updated to model heating, ventilation and air conditioning (HVAC) dependency for High Energy Line Break (HELB) scenarios.
Item 3.b The FPRA models for Byron and Braidwood were updated to incorporate failures required to account for instances where breaker coordination could not be confirmed.
Item 3.c A Fire PRA sensitivity that removes the CCDP and CLERP scaling factor adjustments used for crediting alternate shutdown given abandonment of the MCR was performed during the BB Service Water System categorization. This sensitivity was in addition to the sensitivities required by NEI 00-04 None of the identified items is a PRA Upgrade so a Focused Scope Peer Review was not required. Each item was dispositioned in Attachment 6 of the original LAR application (ML17244A093) and their completion is documented in CEG Risk Management notebook BB-MISC-055.
Note that an F&O Closure Review has not been completed for these items.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the 10 CFR 50.69 categorization process.
Table 5-3 as per the implementation item. The Fire PRA was subsequently updated to eliminate the scaling factor adjustment.
Item 3.d Identification of all wall mounted panel configurations with four or more switches was completed and resulting changes to the Byron and Braidwood FPRA models to incorporate the impact of these panels were made.
Item 3.e The Byron and Braidwood FPRA models includes a new sump clogging value consistent with the WCAP-16362-NP guidance.
Item 8.c The Byron and Braidwood Fire PRAs retains a 1 E-06 joint HEP floor value and justification is included in the Fire PRA documentation for specific HEP combinations for which a value of less than 1 E-05 is used.
Item 11 The additional failure contribution of the Westinghouse RCP Shutdown Seal Bypass failure mode was added to the Byron and Braidwood Internal Events and Fire PRA models, consistent with the limitations and conditions in the NRC safety evaluation for PWROG-140001-P, Revision 1 (ADAMS Accession Number ML17200A116).
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
Byron
- Station, Units 1 and 2 Adoption of 10 CFR 50.69 The licensee will complete the updated implementation items listed in Attachment 1 of Exelon letter to NRC dated September 13, 2018, prior to implementation of 10 CFR 50.69. All issues identified in the attachment will be addressed and any associated changes will be made, focused scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA Risk Management Document BB-MISC-055, Revision 0, provides documentation of completion of the implementation items described in the 10 CFR 50.69 License Amendment Request.
See the above discussion for Braidwood as the resolutions apply to Byron as well.
See the above discussion for Braidwood, as it applies to Byron as well.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) of record prior to implementation of the 10 CFR 50.69 categorization process.
LaSalle County
- Station, Units 1 and 2
Adoption of 10 CFR 50.69 The licensee will complete the implementation items listed in Table APLA01.2 in Attachment 1 of EGC letter to NRC dated October 29, 2020, prior to implementation of 10 CFR 50.69 program. All issues identified will be addressed and any associated changes will be made, focusedscope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA Standard (ASME/ANSRASa2009, Three implementation items are discussed in of EGC letter to NRC dated October 29, 2020 and their resolutions are discussed below.
Item #1: Main Turbine High Water Level Trip Channels Risk Management Document LS-PRA-013, Revision 10, provides documentation of completion of the implementation item described in the 10 CFR 50.69 License Amendment Request.
The PRA Model of Record (MOR) was updated during the 2020 PRA update to include modeling for the main turbine high water level trip channels.
Appendix A of LS-PRA-013, Revision 10 summarizes the model changes performed for the 2020 PRA update. This implementation item was resolved in model change revision LS220A-030
("Created gate LVL8-TRIP-FAIL (LEVEL 8 TRIP CHANNEL FAIL)").
Item #2: Fire F&O 4-17 None of the identified items are PRA Upgrades so a Focused Scope Peer Review was not required. Each item was dispositioned for the application in of the original LAR application (ML20031E699) and their completion is documented in CEG RICT PARAGON Model Basis Document LS-CRM-37.
Note that an F&O Closure Review has not been completed for these items.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) as endorsed by RG1.200, Revision2),
and any findings will be resolved and reflected in the PRA of record prior to implementation of the 10 CFR 50.69 categorization process.
Risk Management Document LS-PRA-021.07, Revision 4, provides documentation of completion of the implementation item described in the 10 CFR 50.69 License Amendment Request.
Fire Finding F&O 4-17 involves reviewing plant-specific data to derive plant-specific automatic detection and suppression system failure probabilities. Appendix G of LS-PRA-021.07.02 documents the review of plant-specific detection and suppression data and the plant-specific failure probabilities are calculated in Section 3.8 of LS-PRA-021.07.02. The plant-specific failure probabilities were incorporated into the 2020 Fire PRA model.
Item #3: Fire F&O 6-11 Risk Management Document LS-MISC-047, Revision 0, provides documentation of completion of the implementation item described in the 10 CFR 50.69 License Amendment Request.
Fire Finding F&O 6-11 involves reviewing the Fire Safe Shutdown (Appendix R) circuit analysis to confirm that the circuit analysis methodology conforms to the NEI 00-01 guidance.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
A sampling of the Appendix R circuit analysis was performed to identify potential gaps in the existing circuit analysis. Identified gaps were resolved by performing detailed circuit analysis and incorporating the updated circuit analysis into the 2020 Fire PRA model.
LaSalle County
- Station, Units 1 and 2
Adoption of TSTF-505, Rev. 2 The licensee will complete the implementation item listed in Attachment 5 of Exelon letter to the NRC dated January 31, 2020, prior to implementation of the RICT Program. All issues identified in the attachment will be addressed and any associated changes will be made, focusedscope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS Three implementation items are discussed in of EGC letter to NRC dated October 29, 2020 and their resolutions are discussed below.
Item #1: Main Turbine High Water Level Trip Channels Risk Management Document LS-PRA-013, Revision 10, provides documentation of completion of the implementation item described in the 10 CFR 50.69 License Amendment Request.
The PRA Model of Record (MOR) was updated during the 2020 PRA update to include modeling for the main turbine high water level trip channels.
Appendix A of LS-PRA-013, Revision 10 summarizes the model changes performed for the 2020 PRA update. This implementation item was resolved in model change revision LS220A-030
("Created gate LVL8-TRIP-FAIL (LEVEL 8 TRIP CHANNEL FAIL)").
None of the identified items are PRA Upgrades so a Focused Scope Peer Review was not required. Each item was dispositioned for the application in of the original LAR application (ML20031E699) and their completion is documented in CEG RICT PARAGON Model Basis Document LS-CRM-37.
Note that an F&O Closure Review has not been completed for these items.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
RASa2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the RICT Program.
Item #2: Fire F&O 4-17 Risk Management Document LS-PRA-021.07, Revision 4, provides documentation of completion of the implementation item described in the 10 CFR 50.69 License Amendment Request.
Fire Finding F&O 4-17 involves reviewing plant-specific data to derive plant-specific automatic detection and suppression system failure probabilities. Appendix G of LS-PRA-021.07.02 documents the review of plant-specific detection and suppression data and the plant-specific failure probabilities are calculated in Section 3.8 of LS-PRA-021.07.02. The plant-specific failure probabilities were incorporated into the 2020 Fire PRA model.
Item #3: Fire F&O 6-11 Risk Management Document LS-MISC-047, Revision 0, provides documentation of completion of the implementation item described in the 10 CFR 50.69 License Amendment Request.
Fire Finding F&O 6-11 involves reviewing the Fire Safe Shutdown (Appendix R) circuit analysis to confirm that the circuit analysis methodology conforms to the NEI 00-01 guidance.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
A sampling of the Appendix R circuit analysis was performed to identify potential gaps in the existing circuit analysis. Identified gaps were resolved by performing detailed circuit analysis and incorporating the updated circuit analysis into the 2020 Fire PRA model.
Nine Mile Point Nuclear
- Station, Unit 2 Adoption of 10 CFR 50.69 Constellation Energy Generation, LLC will complete the items listed in Attachment 7 of Exelon letter to NRC dated December 26, 2019, prior to implementation of 10 CFR 50.69. All issues identified in the attachment will be addressed and any associated changes will be made, focused-scope peer reviews will be performed on changes that are PRA upgrades Risk Management Document N2-PRA-013 PRA Summary Revision 3 provides documentation of completion of the implementation items described in the 10 CFR 50.69 License Amendment Request.
Six implementation items are discussed in :
Item i. refers to Mechanical Vacuum Pump Isolation Instrumentation not modeled. The model was updated to include these SSCs and the PRA Success Criteria matches the Design Success Criteria.
Item ii refers to modeling of suppression chamber-to-drywell vacuum breakers. The model was updated to include failure-to-open and the PRA Success Criteria matches the Design Success Criteria.
None of the identified items is a PRA Upgrade so a Focused Scope Peer Review is not required. All Fact and Observations have been implemented and were closed as described in F&O Closure Review Report 032405-RPT-01.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the 10 CFR 50.69 categorization process.
Item iii refers to updating the model such that the PRA Success Criteria matches the Design Success Criteria when UHS temperature is > 82°F. The model was updated and the PRA Success Criteria matches the Design Success Criteria.
Item iv refers to modeling of intake deicer heaters.
The model was updated to explicitly include the deicer heaters.
Item v refers to the updating the internal flood model to incorporate new pipe rupture frequencies using the pipe length approach per the latest revision of EPRI TR-1013141. The internal flood model was updated accordingly.
Item vi refers to addressing all open F&O issues in Report 032405-RPT-01 (also shown in Attachment 3 of ML19360A145). These issues were closed.
Nine Mile Point Nuclear
- Station, Unit 2 Adoption of TSTF-505, Revision 2 Constellation Energy Generation, LLC will complete the implementation items listed in Attachment 6 of Risk Management Document N2-PRA-013 PRA Summary Revision 3 provides documentation of completion of all but one of the implementation items described in the TSTF-505 License Amendment Request. The final implementation item is documented in the Level 2 Notebook Revision 2.
See the above 50.69 discussion for Nine Mile Point 2 it applies to the TSTF-505 application as well.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
Exelon Letter to the NRC dated October 31, 2019, prior to implementation of the RICT Program. All issues identified in the attachment will be addressed and any associated changes will be made, focused-scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to the implementation of the RICT Program.
See the above discussion for Nine Mile 2. The same implementation items are provided in of the original TSTF-505 LAR (ML19304B653).
Peach Bottom Atomic Power
- Station, Adoption of 10 CFR 50.69 The licensee will complete the Risk Management Document PB-MISC-045, Revision 0, provides documentation of completion of the implementation items described in the 10 CFR 50.69 License Amendment Request except for item 12. Risk Management Document PB-MISC-Items 1 and 7 were considered PRA Model Upgrades and were reviewed and dispositioned with a Focused Scope Peer Review as documented in PB-MISC-045.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed)
Units 2 and 3
implementation items listed in Attachment 2 of Exelons letter to the NRC dated June 6, 2018, prior to implementation of 10 CFR 50.69. All issues identified in the attachment will be addressed and any associated changes will be made, focusedscope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RASa2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the 10 CFR 50.69 categorization process.
027 Rev 5 provides documentation of completion of implementation item 12.
Thirteen implementation items are discussed in :
Item 1 The HRA pre-initiators in the internal events PRA model were updated to meet Capability Category II of the ASME/ANS RA-Sa-2009 as endorsed by RG 1.200, Revision 2. A focused-scope peer review was be conducted of the pre-initiator analysis, and any resulting F&Os were resolved, as indicated in response to RAI 03.a contained in Exelon letter dated May 7, 2018.
Item 2 The transient floor area ratios (FARs) in the fire PRA were adjusted to consider the treatment of obstructed floor space to provide a more accurate distribution of transient ignition frequency, as indicated in response to RAI 03.b contained in Exelon letter dated May 7, 2018.
Item 3 Risk significant fire PRA scenarios for ignition sources capable of being modeled with a two-point fire modeling approach were updated to include the two-point fire modeling approach, as Items 2, 3, 4, 6 and 8 were not a PRA Upgrade so a Focused Scope Peer Review was not required. Each was resolved by an F&O Closure Review as documented in PB-MISC-045.
Items 9, 10, 11 and 12 were not a PRA Upgrade so a Focused Scope Peer Review was not required. These items (except item 12) were directly implemented in the model as documented in PB-MISC-045.
Because these model modifications were not the result of a Peer Review, a F&O Closure review was not applicable.
For Item 12, High Winds and Tornado Missile hazards were screened for 50.69 based on the evaluation provided in PB-MISC-027, Rev. 5.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) indicated in response to RAI 03.c contained in Exelon letter dated May 7, 2018.
Item 4 A review was conducted of potentially vulnerable fire wrap configurations to identify which are subject to mechanical damage. The fire PRA was updated to ensure that fire wrap configurations are not credited in fire scenarios that could subject it to mechanical damage, as indicated in response to RAI 03.d contained in Exelon letter dated May 7, 2018.
Item 5 The categorization process includes the fire PRA sensitivity studies from NEI 00-04Table 5-3 which includes the sensitivity study to remove all credit for manual suppression. Another fire PRA sensitivity study is be performed as part of the categorization process that assumes credit for immediate manual suppression, as indicated in response to RAI 04.a contained in Exelon letter dated Mav 7, 2018.
Item 6 Sources of uncertainty associated with implementation of FLASHCAT in the fire PRA introduced through use of generic parameters from NUREG-7010 Vol. 1 and weighted averages of parameters for cables located within the physical Note: For item 12, the amendments are 321 and 324 for Peach Bottom Units 2 and 3; respectively.
Items 5 and 13 are 50.69 program implementation items that have been captured in Constellation's 50.69 programmatic procedures to perform the additional sensitivity that assumes credit for immediate manual suppression (Item 5). In addition, ASME Class 1 components shall be categorized HSS including any supports that are within the boundary of the categorized system and cannot be changed by the IDP.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) analysis units in which the scenarios implementing the FLASHCAT model were located were removed by basing values for these parameters (mass per unit length and plastic mass fraction) on the scenario specific set of cables that are located within the cable trays analyzed using the FLASHCAT model, as indicated in response to RAI 04.a and RAI 04.d contained in Exelon letter dated May 7, 2018.
Item 7 The NUREG-1921 methodology was applied in identifying undesired operator actions and will be used to incorporate any identified actions into the fire PRA. A focused-scope peer review of the application of this methodology was performed, and any new F&Os resulting from the focused scope review were resolved, as indicated in response to RAI 05.a contained in Exelon letter dated May 7, 2018.
Item 8 The fire PRA model was updated to address breaker coordination in non-safety related power supplies credited in the model by assuming failure of the power supply, including accounting for opening of the power supply upstream breaker that may occur due to the potential lack of coordination between it and the downstream breaker associated
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) with the damaged power cable, when the power cable within the circuits of concern are identified to be damaged by fire scenarios, or additional analysis will be performed to determine that circuits are coordinated, as indicated in response to RAI 05.b contained in Exelon letter dated May 7, 2018.
Item 9 The PRA model was updated to account for the requirement for two EDG cooling fans during periods when the outdoor temperatures at Peach Bottom are above the design temperature of 80° F, as indicated in response to RAI 08.a contained in Exelon letter dated May 7, 2018.
Item 10 The pipe rupture frequencies were updated in the internal flooding PRA to the most recent EPRI pipe rupture frequencies, as indicated in Exelon's letter dated August 30, 2017.
Item 11 Credit for core melt arrest in-vessel at high reactor pressure vessel (RPV) pressure conditions were removed from the internal events PRA model, as indicated in Exelon's letter dated August 30, 2017.
Item 12 Exelon completed necessary actions (e.g.,
analyses, modifications, etc.) to screen tornado
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) missile hazards in accordance with the original license amendment request submittal dated August 30, 2017. This hazard screening will be completed prior to implementation of License Amendment XXX involving adoption of 10 CFR 50.69.
Item 13 All ASME Code Class 1 SSCs with a pressure retaining function, as well as supports, will be designated high safety-significant (HSS) for passive categorization which will result in HSS for its risk-informed safety classification, and cannot be changed by the IDP (RAI 15).
Peach Bottom Atomic Power
- Station, Units 2 and 3
Adoption of TSTF-505, Revision 2 Constellation Energy Generation, LLC will complete the implementation items listed in Attachment 6 of Exelon letter to the NRC dated May 29, 2020, prior to implementation of the RICT Program. All issues identified in the attachment will be addressed and any Risk Management Document PB-ASM-22 Revision 0 provides documentation of completion of the implementation items described in the TSTF-505 License Amendment Request.
Three implementation items are discussed in :
Item 1 refers to Failure of the reactor building-to-suppression chamber vacuum breakers to open was not modeled in the PRA. Prior to implementation, logic was added to the PRA to model the impact of these reactor building-to-suppression chamber vacuum breakers failing to open.
Each item was not a PRA Upgrade so a Focused Scope Peer Review was not required.
These items were directly implemented in the model as documented in PB-ASM-22.
Because these model modifications were not the result of a Peer Review, a F&O Closure review was not applicable.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) associated changes will be made, focusedscope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RASa2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the RICT Program.
Item 2 refers to Failure of the suppression chamber-to-drywell vacuum breakers to open was currently modeled in the PRA Prior to implementation, logic was added to the PRA to model the impact of these vacuum breakers failing to open. Enclosure 9, Table E9-3, Task #2 Component Selection Item 3 refers to the Standby Liquid Control (SLC) out of service cases may not represent the true delta risk without having the appropriate cable data for that system. The SLC cable data was obtained and the Fire PRA model was updated to account for the SLC cabling and potential random Anticipated Transient Without Scram (ATWS) scenarios.
R.E. Ginna Nuclear Power Plant Adoption of TSTF-505, Revision 2 Constellation Energy Generation, LLC will complete the implementation items listed in Attachment 6 of Exelon Letter to the NRC dated May 20, 2021, prior to implementation of the RICT Program. All These items address 5 implementation items addressing additional tornado protection margin:
Item 1 is SAFW Generator Radiator Exhaust:
Replace 19W4 1/4x 2 Bar Grating with 19W4 1/4x 4Bar Grating The bar grating was replaced under C93804738 Item 2 is B Emergency Diesel Generator Room Air Intake: Replace 19W4 1/4x 2 Bar Grating with 19W4 1/4x 4Bar Grating Not applicable for Ginna since these were not PRA modeling commitments. Evidence of their completion is provided in the previous column.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response Table 1: Implementation Conditions Plant License Condition Justification that License Condition is No Longer Relevant PRA Model Upgrade (Y/N),
Focused-Scope Peer Review Results and F&O Closure Review Results (if needed) issues identified in the attachment will be addressed and any associated changes will be made, focused-scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to the implementation of the RICT Program.
The bar grating was replaced under C93804741 and C93803310 Item 3 is B EDG Roof Vents: Increase anchorage capacity by expanding baseplate, increasing the size/embedment depth of anchors.
Item 3 was repaired under ECP-20-000602-CN-004 Item 4 is KDG08 Exhaust: Additional gussets at outside face of piping and, re-pad on outside edge of elbow Gussets installed and re-pad performed under C93804738 Item 5 is KDG01B Exhaust: Perform field measurements to determine thickness of silencer (SDG01A) shell; upgrade as necessary.
Field measurements and upgrade was performed under C93804741 and C93803310.
Constellation License Amendment Request Adoption of TSTF-591-A Rev 0 and modifications to FOL Pages Request for Additional Information - Response RAI 2 - The NRC staff noted the following editorial issues in Attachment 2 of the LAR (mark-ups):
FitzPatrick For Insert 1, item a., the licensee has the phrase and means of assessing the hazard which is not in the TSTF-591 traveler. Provide justification or correct.
For Insert 2, first paragraph, the licensee has the phrase prior to using those methods instead of prior to the first use of those methods which is the approved language in the traveler. Provide justification or correct.
NMP1 For Insert 1, item g. the licensee states A report shall be submitted in accordance with Specification 5.6.9 before a newly developed method is used to calculate a RICT.
Insert 2 references Specification 6.6.8. Provide justification or correct.
Response
FitzPatrick:
For Insert 1, item e[a]., means of assessing the hazard has been deleted from the TS mark-ups. It is reflected in Attachment 2a of this response.
For Insert 2, the first paragraph, prior to using those methods has been revised to prior to the first use of those methods. It is reflected in Attachment 2a of this response.
NMP1:
For Insert 1, item g., the section number has been changed to 6.6.8. It is reflected in b of this response.
References:
- 1. Letter from David P. Helker, Constellation Energy Generation, LLC to the U.S. Nuclear Regulatory Commission, Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and revise 10 CFR 50.69 License Condition, dated April 12, 2024 (ADAMS Accession No. ML24103A204).
- 2. Email from Scott Wall, U.S. Nuclear Regulatory Commission to Stephen Flickinger, Constellation Energy Generation, LLC, RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-591 (EPID No. L-2024-LLA-0046),
dated July 12, 2024 (ADAMS Accession No. ML24197A016).
ATTACHMENT 2a Markup of Technical Specifications Pages James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 Revised Technical Specifications Page 5.5-16 5.6-3
Programs and Manuals 5.5 5.5 Programs and Manuals JAFNPP 5.5-16 Amendment 353 Risk Informed Completion Time Program (continued) d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support License Amendment No., or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
(continued) 5.5.16
'Insert 1 JAf NIPIP
!Ri§ik !tr1fo~medl Com[Qlietiotr1 Time IPmg~aim (icotr1titr11U1edl}
!Pm g1ra1 m § ai tr1 di Mai tr11U1 ai !§ 5J5 do fm eme~getr1t icotr1dlitiotr1§, if tlhie exll:etrit of icotr1dlitiotr1 evai!1U1aitiotr1 to~
itr1ope~ailblie §tmcilUl~e§, §)l'§tem§, m icompotr1etr1t§ (§§C§) i§ tr1ot icompil!;lite p~io~ to exiceedlitr1g tlhie Compietiotr1 Time, tlhie IR!CT §lhiaiii aiicico1U1 tr1t to~ tlhie itr1ic~eai§edl po§§iiblmty of icommotr1 taJIUl§e fairn 1tue (CCf } lbly eitlhier:
io NIUlme~iicaiiiy aJICICOIUltrititr1g fo~ tlhie itr1icmai§edi [PlO§§iiblmty of CCf itri tlhie IR!CT icai!ic1U1!aitiotr1; or
- t
!Ri§ik Mai tr1aigemetr1t AciiOtri§ (IRMM} trilOt aiireaidly icredlitedl itri tlhie IR!CT icai!t1U1!aitiotr1 §lhiaJ!! Ible impiemetr1tedl tlhiait §IUl[Pl[PlOrt ~edl1U1tr1dlai tr1t or dliverne §§C§ t lhiait peruorm tlhie f1U1tr1ictiotr1(§) of t lhie itr1opemlbiie
§§C§, ai tr1dl, if praiictiicailbiie, redl1U1ice t lhie f~eq1U1etr1icy of itr1itiaiti tr1g evetr1t§ t lhiait iclhiaii!etr1ge tlhie f 1U1tr1ictiotr1(§) peruormedl lbly tlhie itr1opemlbiie §§C§"
TIAie risi<1 assessme1111t approaolAies amJI metlAiodls slAiaii lbie aooeptalbiie to tlAio NRG" TIAie piamt PR/!\\ slAiaii lbie lbiasodl 81111 tlAio as lbilLliit, as opomtedl, m,1dl mai1111tai1111odl pia1111t; a1111dl rofieot tlAie opemti1111g D*[PJDl'ie1111oe at tlAie pia1111t, as speoifiedl i1111 Reg1L1iatmy GIL!idle 1"200, Rm.,iisio1111 2" MetlAiodls to assess tlAie risi<1 from e~e1111dli1111g tlAie Gompietio1111 Times mlLlst lbie PR/\\
metlAiodls IL!Sedl to SILl[PJ[PJ8R Uoe 1111se li>>ime1111dlme1111t N8o
, 01' otlAiel' metlAiodls itll[Pl[PJ1'8"1edl by tlAie NRG for ge1111erio !Lise; a1111dl a1111y 01Aia1111ge i1111 tlAie PRA metlAiodls to assess risi< tlAiat me 01L1tsidle tlAiese iEil[Pl[Pll'O'JiEili lbio1L1 1111dlmies req 1L1im prior NRG appm"lat
11nsert 2 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 5.6.6 CORE OPERATING LIMITS REPQRJ lCOLR) (continued)
- c.
The core operating limits shall be determf ned such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits, and accident analysis llmlts) of the safety analysis are met.
- d.
The COLR, Including any mldcycle revisions or supplements, shall be provided upon Issuance for each reload cycle to the NRC.
PAM Report When a report Is required by Condition B or F of LCO 3.3.3.1, 'Post Accident Mon1tortn1 (PAM) Instrumentation,* a report shall be submitted within the following 14 days. The report shall outllne the preplanned alternate method of monitoring. the cause of the lnoperablllty, and the plans and schedule for restoring the Instrumentation channels of the Function to OPERABLE status.
5.6. 7 Reactor Coolant System (RCS PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)
- a.
RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic test1n1 as well as heatup and cooldown rates shall be established and documented In the PTLR for the following:
I) Umltlng Conditions for Operation Section 3.4.9 *Res Pressure and Temperature (P/T) Umlts" II) Surveillance Requirements Section 3.4.9 *Res Pressure and Temperature (P/T) Umlts"
- b.
The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, speclflcally those described In the following documents:
I) SIR-05-044-A, "Pressure-Temperature Umlts Report Methodology for Bolling Water Reactors" II) SIA Celcutatlon 0800846.301, *2* Instrument Nozzle Stress Analysis"
- c.
The PTLR shall be provided to the NRC upon Issuance for each reactor vessel fluence period and for any revision or supplement thereto.
5.6-3 Amendment 292
Insert 1:
- e. A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, and seismic hazards using penalty factors. Changes to these means of assessing the hazard groups require prior NRC approval.
f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."
- g. A report shall be submitted in accordance with Specification 5.6.8 before a newly developed method is used to calculate a RICT.
Insert 2:
5.6.8 Risk Informed Completion Time (RICT) Program Upgrade Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods and prior to the first use of those methods to calculate a RICT. The report shall include:
- a. The PRA models upgraded to include newly developed methods;
- b. A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review;"
c.
Any open findings from the peer-review of the implementation of the newly developed methods and how those findings were dispositioned; and
- d. All changes to key assumptions related to newly developed methods or their implementations.
ATTACHMENT 2b Markup of Technical Specifications Pages Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. NPF-63 NRC Docket No. 50-220 Revised Technical Specifications Page 355c
For Information Only 6.5.9 Surveillance Frequency Control Program This program provides controls for the Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.
a.
The Surveillance Frequency Control Program shall contain a list of Frequencies of the Surveillance Requirements for which the Frequency is controlled by the program.
b.
Changes to the Frequencies listed in the Surveillance Frequency Controlled Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequency, Revision 1.
c.
The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.
6.5.10 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines."
The program shall include the following:
a.
The RICT may not exceed 30 days; b.
A RICT may only be utilized in the Power Operating Condition; c.
When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.
1.
For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.
2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
AMENDMENT NO. 222, 250 355b
d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
e.
The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support License Amendment No. 250, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.
AMENDMENT NO. 250 355c Insert 1
Insert 1:
- e. A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, seismic hazards using penalty factors, and configuration-specific straight wind and tornado wind pressure / tornado missile hazards using penalty factors. Changes to these means of assessing the hazard groups require prior NRC approval.
f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."
- g. A report shall be submitted in accordance with Specification 6.6.8 before a newly developed method is used to calculate a RICT.