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{{#Wiki_filter:From: | {{#Wiki_filter:From: Kimberly Green Sent: Tuesday, June 11, 2024 9:36 AM To: Hughes, Shawna Marie; Baron, Jesse Shawn Cc: Wells, Russell Douglas | ||
==Subject:== | ==Subject:== | ||
Audit Plan Related to Review of the Sequoyah Nuclear Plant, Units 1 and 2, and | Audit Plan Related to Review of the Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, LAR to Revise Technical Specification Table 3.3.2-1 Function 5 (EPID L-2023-LLA-0175) | ||
Attachments: | Attachments: Audit Plan for SQN and WBN LAR re TS Table 3.3.2-1 Function 5.docx | ||
==Dear Shawna Hughes and Jesse Baron:== | ==Dear Shawna Hughes and Jesse Baron:== | ||
By application dated December 18, 2023 (Agencywi de Documents Access and Management System Accession No. ML23352A298), Tennessee Valley Authority submitted a license amendment request (LAR) to amend Facility Operating License Nos. DPR -77, DPR-79, NPF-90, and NPF-96 for Sequoyah Nuclear Plant (Sequoyah), Units 1 and 2, and Watts Nuclear Plant (Watts Bar), Units 1 and 2, respectively. The proposed amendments would revise Sequoyah, Units 1 and 2, and Watts Bar, Units 1 and 2, Technical Specification (TS) Table 3.3.2-1, Engineered Safety Feature Actuation Sy stem Instrumentation, by adding a note for Functions 5a and 5b to state that the turbine trip function is not required when all turbine stop valves or all governor valves are incapable of opening. The LAR also proposes other changes to Watts Bar, Units 1 and 2, TS Table 3.3.2-1 notes f and h, respectively, to be consistent with the corresponding notes in Sequoyah, Units 1 and 2, TS Table 3.3.2 -1 and Westinghouse Standard Technical Specifications (i.e., NUREG -1431, Revision 5). | |||
By application dated December 18, 2023 (Agencywi | |||
The U.S. Nuclear Regulatory Commission staff is reviewing the proposed changes and has determined that a regulatory audit will aid it its review of the LAR. | The U.S. Nuclear Regulatory Commission staff is reviewing the proposed changes and has determined that a regulatory audit will aid it its review of the LAR. | ||
| Line 38: | Line 37: | ||
Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627 | Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627 | ||
Hearing Identifier: | Hearing Identifier: NRR_DRMA Email Number: 2532 | ||
Mail Envelope Properties | Mail Envelope Properties (MW4PR09MB9156852FCABA2E40D0E271A48FC72) | ||
==Subject:== | ==Subject:== | ||
Audit Plan Related to Review of the Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and | Audit Plan Related to Review of the Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, LAR to Revise Technical Specification Table 3.3.2-1 Function 5 (EPID L-2023-LLA-0175) | ||
Sent Date: | Sent Date: 6/11/2024 9:35:40 AM Received Date: 6/11/2024 9:35:00 AM From: Kimberly Green | ||
Created By: | Created By: Kimberly.Green@nrc.gov | ||
Recipients: | Recipients: | ||
| Line 54: | Line 53: | ||
Tracking Status: None | Tracking Status: None | ||
Post Office: | Post Office: MW4PR09MB9156.namprd09.prod.outlook.com | ||
Files | Files Size Date & Time MESSAGE 1598 6/11/2024 9:35:00 AM Audit Plan for SQN and WBN LAR re TS Table 3.3.2-1 Function 5.docx 34111 | ||
Options Priority: | Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: | ||
REGULATORY AUDIT PLAN | REGULATORY AUDIT PLAN | ||
| Line 78: | Line 77: | ||
DOCKET NOS. 50-327, 50-328, 50-390, AND 50-391 | DOCKET NOS. 50-327, 50-328, 50-390, AND 50-391 | ||
==1.0 | ==1.0 BACKGROUND== | ||
By application dated December 18, 2023 (Agencywide Documents Access and Management System Accession No. ML23352A298), pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) to amend Fac ility Operating License Nos. DPR-77, DPR-79, NPF-90, and NPF-96 for Sequoyah Nuclear Plant (Sequoyah), Units 1 and 2, and Watts Nuclear Plant (Watts Bar), Units 1 and 2, respectively. The proposed amendments would revise Sequoyah, Units 1 and 2, and Watts Bar, Units 1 and 2, Technical Specification (TS) | |||
By application dated December 18, 2023 (Agencywide Documents Access and Management System Accession No. ML23352A298), pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) to amend Fac | |||
Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, by addition a note for Functions 5a and 5b to state that the turbine trip function is not required when all turbine stop valves or all governor valves are incapable of opening. The LAR also proposes other changes to Watts Bar, Units 1 and 2, TS Table 3.3.2-1 notes f and h, respectively, to be consistent with the corresponding notes in Sequoyah, Units 1 and 2, TS Table 3.3.2-1 and Westinghouse Standard Technical Specifications (i.e., NUREG-1431, Revision 5). | Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, by addition a note for Functions 5a and 5b to state that the turbine trip function is not required when all turbine stop valves or all governor valves are incapable of opening. The LAR also proposes other changes to Watts Bar, Units 1 and 2, TS Table 3.3.2-1 notes f and h, respectively, to be consistent with the corresponding notes in Sequoyah, Units 1 and 2, TS Table 3.3.2-1 and Westinghouse Standard Technical Specifications (i.e., NUREG-1431, Revision 5). | ||
The Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit of the supporting information for the LAR should be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274). | The Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit of the supporting information for the LAR should be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274). | ||
2.0 | 2.0 REGULATORY AUDIT BASIS | ||
A regulatory audit is a planned license- or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with 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 TVAs processes and procedures. Information identified during the audit that the NRC staff relies upon to make the safety determination must be submitted on the docket. | A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with 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 TVAs processes and procedures. Information identified during the audit that the NRC staff relies upon to make the safety determination must be submitted on the docket. | ||
Attachment | Attachment | ||
3.0 | 3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY | ||
NRC staffs objectives of the audit are the following: | NRC staffs objectives of the audit are the following: | ||
| Line 98: | Line 96: | ||
* Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238). | * Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238). | ||
4.0 | 4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT | ||
The NRC staff requests information or documents related to the following areas: | The NRC staff requests information or documents related to the following areas: | ||
Item # | Item # Audit Item 1 Current logic (e.g., diagrams) for turbine trip signal related to the closing of the turbine stop valves and turbine governor valves 2 Information (e.g., logic diagrams) related to the turbine trip signal that is generated from the safety-related reactor trip signal 3 Information (e.g., logic diagrams) related to the reactor trip signal as it relates the turbine trip signal and turbine stop valve indication signal | ||
4 | 4 Any analyses or evaluations that considered anticipated operational occurrence(s) | ||
5 | 5 Any analyses or evaluations that considered false turbine stop valve indication (valve indication is OPEN but valve is closed) but the reactor does not trip 6 Any analyses or evaluations that considered false turbine stop valve indication (valve indication is CLOSED but valve is open) and the reactor trips but turbine stop valves and governor valves are left open 7 Description of any proposed design changes needed to support the requested TS change (e.g., changes to logic) and continued compliance with relevant general design criteria. | ||
8 | 8 Plant component ID listing for all turbine-related stop, throttle, governor, and control valves 9 Component description, including function, for reheat stop valves and interceptor valves 10 Information related to plant operations during Mode 1 with % RATED THERMAL POWER > 5% but < 50% (P-9 interlock) with all throttle valves, control valves, reheat stop valves, and interceptor valves in the CLOSED position 11 Information related to plant operations during Mode 1 with % RATED THERMAL POWER > 5 % and the P-14 interlock engaged (i.e., 2/3 steam generator water level above setpoint on one or more steam generators) | ||
Additional information needs identified during the audit will be communicated to the designated point of contact. | Additional information needs identified during the audit will be communicated to the designated point of contact. | ||
| Line 113: | Line 111: | ||
The NRC will document the final audit items list as an enclosure to the audit report, which will be publicly available. | The NRC will document the final audit items list as an enclosure to the audit report, which will be publicly available. | ||
5.0 | 5.0 TEAM ASSIGNMENTS | ||
The audit team will consist of the following NRC staff: | The audit team will consist of the following NRC staff: | ||
Team Member | Team Member Division Area of Responsibility | ||
Kimberly Green | Kimberly Green NRR/DORL/LPLII-2 Project Manager Kimberly.Green@nrc.gov David Nold NRR/DSS/SCPB Technical Review - | ||
David.Nold@nrc.gov | David.Nold@nrc.gov systems | ||
Ahsan Sallman | Ahsan Sallman NRR/DSS/SNSB Technical Review - | ||
Ahsan.Sallman@nrc.gov | Ahsan.Sallman@nrc.gov systems | ||
Hang Vu | Hang Vu NRR/DEX/EICB Technical Review - | ||
Hang.Vu@nrc.gov | Hang.Vu@nrc.gov instrumentation Tarico.Sweat NRR/DSS/STSB Technical Review - | ||
Tarico.Sweat@nrc.gov | Tarico.Sweat@nrc.gov technical specifications | ||
Key TVA personnel knowledgeable in the areas of interest should be made available | Key TVA personnel knowledgeable in the areas of interest should be made available for interactions, on a mutually agreeable schedule, to respond to any questions from the NRC staff. | ||
6.0 | 6.0 LOGISTICS | ||
To support the review schedule communicated to TVA when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams and an internet-based portal made available by TVA. | To support the review schedule communicated to TVA when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams and an internet-based portal made available by TVA. | ||
| Line 141: | Line 139: | ||
Username, password, and other portal access information should be provided directly to members of the NRC audit team. The NRC licensing project manager will provide TVA with names and contact information of the NRC staff participating in the audit (section 5.0 above). All other communications should be coordinated through the NRC project manager. | Username, password, and other portal access information should be provided directly to members of the NRC audit team. The NRC licensing project manager will provide TVA with names and contact information of the NRC staff participating in the audit (section 5.0 above). All other communications should be coordinated through the NRC project manager. | ||
NRC information requests and communications with TVA staff will | NRC information requests and communications with TVA staff will be coordinated through the NRCs licensing project manager. | ||
The virtual audit will commence after the internet-based portal is set up and the documentation addressing the items in section 4.0 of this audit plan is made available to the NRC staff. The audit will be conducted during a specified time that is mutually agreeable to the NRC staff and TVA. The NRC project manager will coordinate with the NRC staff and | The virtual audit will commence after the internet-based portal is set up and the documentation addressing the items in section 4.0 of this audit plan is made available to the NRC staff. The audit will be conducted during a specified time that is mutually agreeable to the NRC staff and TVA. The NRC project manager will coordinate with the NRC staff and TVA for any teleconferences needed while the NRC staff is reviewing the documentation. The NRC project manager will inform TVA of the entrance and exit call dates when they are established. The NRCs project manager will inform TVA via routine communications when the NRC staff no longer needs access to the portal. | ||
7.0 | 7.0 DELIVERABLES | ||
The NRC staff will issue an audit summary report within 90 days of the audit exit call. The staff may request additional information needed to complete the review of the LAR but will issue any such RAIs separately from audit-related correspondence in accordance with NRR Office Instruction LIC-115, Processing Requests for Additional Information.}} | The NRC staff will issue an audit summary report within 90 days of the audit exit call. The staff may request additional information needed to complete the review of the LAR but will issue any such RAIs separately from audit-related correspondence in accordance with NRR Office Instruction LIC-115, Processing Requests for Additional Information.}} | ||
Latest revision as of 13:02, 4 October 2024
| ML24177A141 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah, Watts Bar  |
| Issue date: | 06/11/2024 |
| From: | Kimberly Green Plant Licensing Branch II |
| To: | Baron J, Hughes S Tennessee Valley Authority |
| References | |
| L-2023-LLA-0175 | |
| Download: ML24177A141 (6) | |
Text
From: Kimberly Green Sent: Tuesday, June 11, 2024 9:36 AM To: Hughes, Shawna Marie; Baron, Jesse Shawn Cc: Wells, Russell Douglas
Subject:
Audit Plan Related to Review of the Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, LAR to Revise Technical Specification Table 3.3.2-1 Function 5 (EPID L-2023-LLA-0175)
Attachments: Audit Plan for SQN and WBN LAR re TS Table 3.3.2-1 Function 5.docx
Dear Shawna Hughes and Jesse Baron:
By application dated December 18, 2023 (Agencywi de Documents Access and Management System Accession No. ML23352A298), Tennessee Valley Authority submitted a license amendment request (LAR) to amend Facility Operating License Nos. DPR -77, DPR-79, NPF-90, and NPF-96 for Sequoyah Nuclear Plant (Sequoyah), Units 1 and 2, and Watts Nuclear Plant (Watts Bar), Units 1 and 2, respectively. The proposed amendments would revise Sequoyah, Units 1 and 2, and Watts Bar, Units 1 and 2, Technical Specification (TS) Table 3.3.2-1, Engineered Safety Feature Actuation Sy stem Instrumentation, by adding a note for Functions 5a and 5b to state that the turbine trip function is not required when all turbine stop valves or all governor valves are incapable of opening. The LAR also proposes other changes to Watts Bar, Units 1 and 2, TS Table 3.3.2-1 notes f and h, respectively, to be consistent with the corresponding notes in Sequoyah, Units 1 and 2, TS Table 3.3.2 -1 and Westinghouse Standard Technical Specifications (i.e., NUREG -1431, Revision 5).
The U.S. Nuclear Regulatory Commission staff is reviewing the proposed changes and has determined that a regulatory audit will aid it its review of the LAR.
Attached, please find an audit plan containing the basis, scope, information needs, audit team members, logistics, and deliverable for this audit.
If you have any questions, please let me know.
Sincerely,
Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627
Hearing Identifier: NRR_DRMA Email Number: 2532
Mail Envelope Properties (MW4PR09MB9156852FCABA2E40D0E271A48FC72)
Subject:
Audit Plan Related to Review of the Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, LAR to Revise Technical Specification Table 3.3.2-1 Function 5 (EPID L-2023-LLA-0175)
Sent Date: 6/11/2024 9:35:40 AM Received Date: 6/11/2024 9:35:00 AM From: Kimberly Green
Created By: Kimberly.Green@nrc.gov
Recipients:
"Wells, Russell Douglas" <rdwells0@tva.gov>
Tracking Status: None "Hughes, Shawna Marie" <smhughes@tva.gov>
Tracking Status: None "Baron, Jesse Shawn" <jsbaron@tva.gov>
Tracking Status: None
Post Office: MW4PR09MB9156.namprd09.prod.outlook.com
Files Size Date & Time MESSAGE 1598 6/11/2024 9:35:00 AM Audit Plan for SQN and WBN LAR re TS Table 3.3.2-1 Function 5.docx 34111
Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
REGULATORY AUDIT PLAN
BY THE OFFICE OF NUCLEAR REACTOR REGULATION
TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST
TO REVISE TECHNICAL SPECIFICATION TABLE 3.3.2-1 RELATED TO
FUNCTIONS 5A AND 5B
TENNESSEE VALLEY AUTHORITY
SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2
WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2
DOCKET NOS. 50-327, 50-328, 50-390, AND 50-391
1.0 BACKGROUND
By application dated December 18, 2023 (Agencywide Documents Access and Management System Accession No. ML23352A298), pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) to amend Fac ility Operating License Nos. DPR-77, DPR-79, NPF-90, and NPF-96 for Sequoyah Nuclear Plant (Sequoyah), Units 1 and 2, and Watts Nuclear Plant (Watts Bar), Units 1 and 2, respectively. The proposed amendments would revise Sequoyah, Units 1 and 2, and Watts Bar, Units 1 and 2, Technical Specification (TS)
Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, by addition a note for Functions 5a and 5b to state that the turbine trip function is not required when all turbine stop valves or all governor valves are incapable of opening. The LAR also proposes other changes to Watts Bar, Units 1 and 2, TS Table 3.3.2-1 notes f and h, respectively, to be consistent with the corresponding notes in Sequoyah, Units 1 and 2, TS Table 3.3.2-1 and Westinghouse Standard Technical Specifications (i.e., NUREG-1431, Revision 5).
The Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit of the supporting information for the LAR should be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274).
2.0 REGULATORY AUDIT BASIS
A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with 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 TVAs processes and procedures. Information identified during the audit that the NRC staff relies upon to make the safety determination must be submitted on the docket.
Attachment
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY
NRC staffs objectives of the audit are the following:
- Confirm the NRC staffs understanding of the LAR.
- Gain a better understanding of the logic for the turbine valve signals and associated turbine trips and reactor trips and their implications for the LAR.
- Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT
The NRC staff requests information or documents related to the following areas:
Item # Audit Item 1 Current logic (e.g., diagrams) for turbine trip signal related to the closing of the turbine stop valves and turbine governor valves 2 Information (e.g., logic diagrams) related to the turbine trip signal that is generated from the safety-related reactor trip signal 3 Information (e.g., logic diagrams) related to the reactor trip signal as it relates the turbine trip signal and turbine stop valve indication signal
4 Any analyses or evaluations that considered anticipated operational occurrence(s)
5 Any analyses or evaluations that considered false turbine stop valve indication (valve indication is OPEN but valve is closed) but the reactor does not trip 6 Any analyses or evaluations that considered false turbine stop valve indication (valve indication is CLOSED but valve is open) and the reactor trips but turbine stop valves and governor valves are left open 7 Description of any proposed design changes needed to support the requested TS change (e.g., changes to logic) and continued compliance with relevant general design criteria.
8 Plant component ID listing for all turbine-related stop, throttle, governor, and control valves 9 Component description, including function, for reheat stop valves and interceptor valves 10 Information related to plant operations during Mode 1 with % RATED THERMAL POWER > 5% but < 50% (P-9 interlock) with all throttle valves, control valves, reheat stop valves, and interceptor valves in the CLOSED position 11 Information related to plant operations during Mode 1 with % RATED THERMAL POWER > 5 % and the P-14 interlock engaged (i.e., 2/3 steam generator water level above setpoint on one or more steam generators)
Additional information needs identified during the audit will be communicated to the designated point of contact.
The NRC will document the final audit items list as an enclosure to the audit report, which will be publicly available.
5.0 TEAM ASSIGNMENTS
The audit team will consist of the following NRC staff:
Team Member Division Area of Responsibility
Kimberly Green NRR/DORL/LPLII-2 Project Manager Kimberly.Green@nrc.gov David Nold NRR/DSS/SCPB Technical Review -
David.Nold@nrc.gov systems
Ahsan Sallman NRR/DSS/SNSB Technical Review -
Ahsan.Sallman@nrc.gov systems
Hang Vu NRR/DEX/EICB Technical Review -
Hang.Vu@nrc.gov instrumentation Tarico.Sweat NRR/DSS/STSB Technical Review -
Tarico.Sweat@nrc.gov technical specifications
Key TVA personnel knowledgeable in the areas of interest should be made available for interactions, on a mutually agreeable schedule, to respond to any questions from the NRC staff.
6.0 LOGISTICS
To support the review schedule communicated to TVA when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams and an internet-based portal made available by TVA.
The internet-based portal should be populated with the documents requested in section 4.0 of this audit plan. The following conditions associated with the portal must be maintained while the NRC staff have access to the portal:
- The portal will be password-protected. A separate password will be assigned to each member of the NRC staff participating in the audit.
- The portal should prevent the NRC staff from printing, saving, downloading, or collecting any information directly from the online portal.
- Conditions of use of the portal will be displayed on the login screen and will require acknowledgment by each user.
Username, password, and other portal access information should be provided directly to members of the NRC audit team. The NRC licensing project manager will provide TVA with names and contact information of the NRC staff participating in the audit (section 5.0 above). All other communications should be coordinated through the NRC project manager.
NRC information requests and communications with TVA staff will be coordinated through the NRCs licensing project manager.
The virtual audit will commence after the internet-based portal is set up and the documentation addressing the items in section 4.0 of this audit plan is made available to the NRC staff. The audit will be conducted during a specified time that is mutually agreeable to the NRC staff and TVA. The NRC project manager will coordinate with the NRC staff and TVA for any teleconferences needed while the NRC staff is reviewing the documentation. The NRC project manager will inform TVA of the entrance and exit call dates when they are established. The NRCs project manager will inform TVA via routine communications when the NRC staff no longer needs access to the portal.
7.0 DELIVERABLES
The NRC staff will issue an audit summary report within 90 days of the audit exit call. The staff may request additional information needed to complete the review of the LAR but will issue any such RAIs separately from audit-related correspondence in accordance with NRR Office Instruction LIC-115, Processing Requests for Additional Information.