ML24318A943

– Notification of Conduct of Phase II Inspection of Title 10 of the Code of Federal Regulations 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactor

ML24318A943
Person / Time
Site:	Limerick
Issue date:	11/13/2024
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
Download: ML24318A943 (1)

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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE RD, SUITE 102 KING OF PRUSSIA, PENNSYLVANIA 19406-1415 November 13, 2024 David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Office (CNO)

Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - NOTIFICATION OF CONDUCT OF PHASE II INSPECTION OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS, AND COMPONENTS FOR NUCLEAR POWER REACTORS

Dear David Rhoades:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff will conduct Phase II of the Title 10 of the Code of Federal Regulations (10 CFR) 50.69 program inspection at Limerick Generating Station, Units 1 and 2, in March 2025. The inspection team will be composed of personnel from the Region I Office and led by Len Cline. The inspection will be conducted in accordance with Inspection Procedure 37060. It will focus on review of your feedback and adjustment process and any changes to the risk-informed categorization and treatment process following the approval of an alternate seismic approach for risk categorization on May 17, 2023 (ADAMS Accession No. ML23089A124). The inspection is being performed because at least two refueling outages have occurred since completion of initial system categorization for at least five systems after approval of the 10 CFR 50.69 license amendments for Units 1 and 2 on July 31, 2018 (ADAMS Accession No. ML18165A162).

The schedule for the inspection is as follows:

Information Gathering Trip Week of February 3, 2025 On-Site Inspection:

Week of March 16, 2025 An initial list of the documents that the team will review during the conduct of the inspection are listed in the Enclosure. The team leader will contact you with any additional specific document requests prior to the start of the inspection. Your cooperation and support during this inspection will be appreciated.

If you have questions concerning this inspection, or the inspection team's information request or logistical needs, please contact Len Cline, Team Leader at (610) 337-5373, or via email at leonard.cline@nrc.gov.

D. Rhoades 2

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, under Control Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

10 CFR 50.69 Program Supporting Documentation cc: Distribution via ListServ Glenn T.

Dentel Digitally signed by Glenn T. Dentel Date: 2024.11.13 11:46:54 -05'00'

ML24318A943 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DORS RI/DORS NAME LCline GDentel DATE 11/12/2024 11/13/2024

Enclosure 10 CFR 50.69 Program Supporting Documentation If you have any questions regarding this information request, please contact Len Cline, as soon as possible, at (610) 337-5373 or via email at leonard.cline@nrc.gov. Electronic format is the preferred media, except where specifically noted. If electronic media is made available via an internet based remote document management system, then the remote document access must allow inspectors to download, save, and print the documents in the NRC's Regional office.

Additionally, word-searchable documents are preferred, if available. Paper records (hard copy) are acceptable. At the end of the inspection, the documents in the team's possession will not be retained.

This document request is based on typical documents that a generic plant might have. As such, this generic document request is not meant to imply that any specific plant is required to have all the listed documents. It is recognized that some documents listed below may not be available for your plant. In addition, the document titles listed below are based on typical industry document names; your plant specific document titles may vary.

Information Requested by December 31, 2024

1. Licensing bases documents:

a. Limerick 10 CFR 50.69 License Amendment Request (LAR).

b. Responses to Requests for Additional Information regarding the Limerick 10 CFR 50.69 LAR.

c. U.S. NRC Safety Evaluation Report and approval of 10 CFR 50.69 LAR.

d. Updated Final Safety Analysis changes associated with the implementation of 10 CFR 50.69 at Limerick.

e. NEI 00-04.

f. Units 1 and 2 Facility Operating License.

2. Copy (latest revision) of 10 CFR 50.69 program procedures.

3. 10 CFR 50.69 categorization documents (Word portion only) for all systems which have completed system categorization.

4. Probabilistic Risk Assessment (PRA) system notebooks for systems that have completed system categorization.

5. Most recent revisions of the following PRA notebooks: Summary (LG-PRA-013) and Quantification (LG-PRA-014).

6. List of structures, systems, and components (SSCs), broken down by system, that have alternate treatment plans that are implemented or planned to be implemented. Only include systems that have been reviewed at Integrated Decision-Making Panel (IDP) meetings to date.

7. List of Risk-Informed Safety Class (RISC)-1, RISC-2, and RISC-3 component failures (issue report designator and title will be acceptable) since implementing the program requirements on associated systems. If applicable, provide any performance indicators

2 utilized to monitor performance of RISC-1, RISC-2, and RISC-3 SSCs consistent with categorization process assumptions and in the PRA model.

8. Administrative procedures utilized to implement alternative treatment of regulatory requirements under 10 CFR 50.69 (example: changes to In-service Testing Program procedures, Maintenance Rule Program procedures, Reportability Manual, etc.).

9. Meeting Minutes for all IDP meetings since completion of the Phase I 50.69 inspection (February 27, 2020).

10. List of Corporate and Limerick issue reports (designator and title) associated with the implementation of the 10 CFR 50.69 process at Limerick. Do not include issue reports only associated with the submittal and approval of the 10 CFR 50.69 license amendment.

11. Audits and self-assessments of the Limerick/Corporate 10 CFR 50.69 Program since Phase I 50.69 inspection (February 27, 2020).

12. List of all changes or upgrades made to the PRA model of record utilized for 10 CFR 50.69 Program since the Phase I 50.69 inspection (February 27, 2020).

13. Pending changes to the PRA model of record (Updating Requirement Evaluations) -

please include a brief description of each change.

14. Provide program requirements that implement the requirement for feedback and process adjustments per 10 CFR 50.69(e). If applicable, provide a summary of any updates/changes to the categorization or treatment processes as a result of 50.69(e) reviews, changes to the plant, operational practices, operating experience, or as a result of the performance issues associated with RISC-1, 2, or 3 SSCs.

15. List of any modifications that were field installed on categorized systems since the Phase I 50.69 inspection (February 27, 2020).

16. Licensee event reports associated with any reportable events per 10 CFR 50.69 (g) since Phase I 50.69 inspection (February 27, 2020).

17. PRA model information (e.g., Excel spreadsheet) providing a listing of all basic events with all available importance measures (e.g., Birnbaum, F-V, Risk Achievement Worth and Risk Reduction Worth) and an associated list of cutsets. This information shall be taken from the PRA model of record used in the 10 CFR 50.69 categorization process.

18. System drawings identifying the RISC category of passive system components for systems that have completed the categorization process since completion of the Phase I 50.69 inspection (February 27, 2020).

19. If a seismic PRA was not used for passive risk categorization, please provide the Safe Shutdown Equipment List (used for Seismic Margins Analysis).

20. The plants Individual Plant Examination of External Events.