ML15289A526

Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies Related to Order EA-12-049

ML15289A526
Person / Time
Site:	Nine Mile Point
Issue date:	10/20/2015
From:	Paige J C Japan Lessons-Learned Division
To:	Korsnick M G Exelon Nuclear
Paige, Jason, NRR/JLD 415-5888
References
EA-12-049, TAC MF1130
Download: ML15289A526 (11)

Text

Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd Warrenville, IL 60555 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 20, 2015

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT 2 -PLAN FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES RELATED TO ORDER EA-12-049 (TAC NO. MF1130)

Dear Mr. Hanson On March 12,

2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, respectively).

The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML. 13066A 171 ), Exelon Generation, LLC, previously as Constellation Energy Nuclear Group, LLC (Exelon, the licensee) submitted its OIP for Nine Mile Point Nuclear Station, Units 1 and 2 (NMP). in response to Order EA-12-049.

By letter dated March 8, 2013 (ADAMS Accession No. ML 13074A056), Exelon submitted a complete revision of the OIP for NMP. By letters dated August 27, 2013, February 27, 2014, August 26, 2014, February 19, 2015, and August 28. 2015 (ADAMS Accession Nos. ML 13254A278, ML 14069A318, ML 14241 A380, ML 15062A036, and ML 15243A085, respectively), the licensee submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML 13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195).

This audit process led to the issuance of the NMP interim staff evaluation (ISE) and audjtreport (ADAMS Accession No. ML 13225A584) and continues with in-office and onsite of this audit B. Hanson By letter dated February 28, 2013 (ADAMS Accession No. ML 13066A 172), the licensee submitted its OIP for NMP in response to Order EA-12-051.

By letter dated June 5, 2013 (ADAMS Accession No. ML 13154A399), the NRC staff sent a request for additional information (RAI) to the licensee.

By letters dated July 5, 2013, August 27, 2013, February 24, 2014, August 26, 2014, February 19, 2015, and August 28, 2015 (ADAMS Accession Nos. ML 13197A220, ML 13254A279, ML 14069A180, ML 14241A016, ML 15062A035, and ML 15243A093, respectively), the licensee submitted its RAI responses and first five six-month updates to the OIP. The NRC staff's review to date led to the issuance of the NMP ISE and RAI dated November 15, 2013 (ADAMS Accession No. ML 13281A205).

By letter dated March 26, 2014 (ADAMS Accession No. ML 14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above. The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and other audit questions.

Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

The audit's onsite portion will occur prior to declarations of compliance for the first unit at each site. This document outlines the on-site audit process that occurs after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office audit communications with staff while proceeding towards compliance with the orders. The staff conducted an onsite audit at NMP from November 3-7, 2014, in accordance with the audit plan dated October 8, 2014 (ADAMS Accession No. ML 14274A288).

Due to the different strategies and technologies between the units, the staff focused its review on Unit 1, since its compliance date is prior to Unit 2. By letter dated April 28, 2015 (ADAMS Accession No. ML 15110A026), the staff issued an audit report for the November 3-7, 2014, onsite audit. The staff plans to conduct an onsite audit of the Unit 2 strategies in accordance with the enclosed audit plan from November 16-20, 2015.

B. Hanson If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.

Docket No.: 50-410

Enclosure:

Audit plan cc w/encl: Distribution via Listserv Mr. Peter Orphanos, Site Vice President Nine Mile Point Nuclear Station 348 Lake Road Lycoming, NY 13126 ly, son Paige, Proje t Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Audit Plan Nine Mile Point Nuclear Station, Unit 2 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML 12054A736 and ML 12054A679, respectively).

Order EA-12-049 directs licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order EA-12-051 requires, in part, that all operating reactor sites have a reliable means of remotely monitoring wide-range SFP levels to support effective prioritization of event mitigation and recovery actions in the event of a BDBEE. The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML 13066A 171 ), Exelon Generation, LLC, previously as Constellation Energy Nuclear Group, LLC (Exelon, the licensee) submitted its OIP for Nine Mile Point Nuclear Station, Units 1 and 2 (NMP), in response to Order EA-12-049.

By letter dated March 8, 2013 (ADAMS Accession No. ML 13074A056), Exelon submitted a complete revision of the 01 P for NMP. By letters dated August 27, 2013, February 27, 2014, August 26, 2014, February 19, 2015, and August 28, 2015 (ADAMS Accession Nos. ML 13254A278, ML 14069A318, ML 14241A380, ML 15062A036, and ML 15243A085, respectively), the licensee submitted its first five six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML 13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195).

This audit process led to the issuance of the NMP interim staff evaluation (ISE) and audit report (ADAMS Accession No. ML 13225A584) and continues with in-office and onsite portions of this audit. By letter dated February 28, 2013 (ADAMS Accession No. ML 13066A 172), the licensee submitted its OIP for NMP in response to Order EA-12-051.

By letter dated June 5, 2013 (ADAMS Accession No. ML 13154A399), the NRC staff sent a request for additional information (RAI) to the licensee.

By letters dated July 5, 2013, August 27, 2013, February 24, 2014, August 26, 2014, February 19, 2015, and August 28, 2015 (ADAMS Accession Nos. ML 13197A220, ML 13254A279, ML 14069A180, ML 14241A016, ML 15062A035, and ML 15243A093, respectively), the licensee submitted its RAI responses and first five six-month updates to the OIP. The NRC staff's review to date led to the issuance of the NMP ISE and RAI dated November 15, 2013 (ADAMS Accession No. ML 13281A205).

By letter dated March 26, 2014 (ADAMS Accession No. ML 14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above. Enclosure The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions.

Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

The audit's onsite portion will occur prior to declarations of compliance for the first unit at each site. This document outlines the onsite audit process that occurs after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs), and continue in-office audit communications with staff while proceeding towards compliance with the orders. Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML 12242A378), as endorsed, by NRC interim staff guidance (ISG) JLD-ISG-2012-01 "Compliance with Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"' (ADAMS Accession No. ML 12229A174) as providing one acceptable means of meeting the order requirements.

For Order EA-12-051, the staff will make a safety determination regarding order compliance using the NEI guidance document NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML 12240A307), as endorsed, with exceptions and clarifications, by NRC ISG JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation'" (ADAMS Accession No. ML 12221A339) as providing one acceptable means of meeting the order requirements.

Should the licensee propose an alternative strategy or other method deviating from the guidance, additional staff review will be required to evaluate if the alternative strategy complies with the applicable order. AUDIT SCOPE As discussed, onsite audits will be performed per NRR Office Instruction LIC-111, "Regulatory Audits," to support the development of safety evaluations.

Site-specific OIPs and OPDs/FIPs rely on equipment and procedures that apply to all units at a site, therefore, audits will be planned to support the "first unit at each site." On-site audits for subsequent units at a site will be on an as-needed basis. The purpose of the audits is to obtain and review information responsive to the NMP, Unit 2 OIP, as supplemented, open and confirmatory items from the mitigation strategies ISE, and to observe and gain a better understanding of the basis for the site's overall programs to ensure the licensee is on the correct path for compliance with the Mitigation Strategies order. These may include, but are not limited to:

• Onsite review and discussion for the basis and approach for detailed analysis and calculations (Orders EA-12-049);

• Walk-throughs of strategies and laydown of equipment to assess feasibility, timing, and effectiveness of a given mitigating strategy or integration of several strategies (Order EA-12-049);

• Storage, protection, access, and deployment feasibility and practicality for onsite portable equipment (Order EA-12-049);

and

• Evaluation of staging, access, and deployment of offsite resources to include equipment provided by the Strategic Alliance for FLEX Emergency Response (SAFER) from the National SAFER Response Centers (NSRCs) provided (Order EA-12-049).

NRC AUDIT TEAM Title Team Member Team Lead/Project ManaQer Jason PaiQe Technical Support Michael Levine Technical Support Matthew McConnell Technical Support Brett Titus Technical Support Laura Okruhlik LOGISTICS The audit will be conducted onsite at NMP on November 16-20, 2015. Entrance and exit briefings will be held with the licensee at the beginning and end of the audit, respectively, as well as daily briefings of team activities.

Additional details will be addressed over the phone. A more detailed schedule is provided below. A private conference room is requested for NRC audit team use with access to audit documentation upon arrival and as needed. DELIVERABLES An audit report/summary will be issued to the licensee within 90 days from the end of the audit. INFORMATION NEEDS

• Materials/documentation provided in responses to open or confirmatory items in the ISE;

• OPD/FIP (current version), operator procedures, FLEX Support Guidelines (FSGs), operator training plans, NSRC (SAFER) NMP Response Plan; and

• Materials/documentation for staff audit questions and/or licensee OIP identified open items, as stated in Part 2 below To provide supplemental input to the ongoing audit of documents submitted to the NRC and made available via e-portal, the onsite audit will have three components:

1) a review of the overall mitigating strategies for the site, including, if needed, walk-throughs of strategies and equipment laydown of select portions;

2) a review of material relating to open or confirmatory items from the ISE, staff audit questions, and licensee open items; and 3) additional specific issues requested by NRC technical reviewers related to preparation of a safety evaluation.

Each part is described in more detail below: Part 1 -Overall Mitigating Strategies and Program Review: During the onsite audit, please be prepared to conduct a tabletop discussion of the site's integrated mitigating strategies compliance program. This discussion should address the individual components of the plans, as well as the integrated implementation of the strategies including a timeline.

The licensee team presenting this should include necessary representatives from site management, engineering, training, and operations that were responsible for program development, and will be responsible for training and execution.

Following the tabletop discussion, please be prepared to conduct walk-throughs of procedures and demonstrations of equipment as deemed necessary by NRC audit team members. Include representatives from engineering and operations that will be responsible for training and execution.

At this time we expect, at a minimum, to walk-through the items below. Based on the tabletop presentations and audit activities, this list may change. WALK-THROUGH LIST: 1. Walk-through a sample of strategies that will be delineated by specific NRC technical staff audit team members. 2. Walk-through of portable (FLEX) diesel generator (DG) procedures, to include power supply pathways, areas where manual actions are required, and electrical isolation.

3. Walk-through of building access procedures, to include any unique access control devices. 4. Strategy walk-through of transfer routes from staging and storage areas to deployment locations for both onsite and offsite equipment.

5. Strategy walk-through for core cooling and reactor coolant system (RCS) inventory, to include portable pumping equipment, flow paths, and water storage locations and the related reactor systems analysis and calculations.

6. Walk-through of communications enhancements.

Part 2 -Specific Technical Review Items: During the visit, audit items will be addressed from the licensee's ISE open and confirmatory items; audit question list; licensee OIP, as supplemented, open items; and draft safety evaluation additional questions.

Please provide documents or demonstrations as needed to respond to each item.

Part 3 -Specific Topics for Discussion:

1. Draft of NMP's OPD/FIP 2. Training 3. Portable (FLEX) equipment maintenance and testing 4. NSRC (SAFER) Response Plan for NMP Proposed Schedule Onsite Day 1, Monday, November 16, 2015 1300 Check in at site: Badging Dosimetry and whole body count for RCA entrance 1430 Entrance meeting 1500 Licensee presentation of strategies 1630 Team lead daily debrief/next day planning with licensee Onsite Day 2, Tuesday, November 17, 2015 0830 NRC Audit Team Activities:

• Technical area break-out discussions between NRC and licensee staff in the areas of reactor systems, electrical, balance-of-plant/structures, and others

• Review documents relating to open or confirmatory items, codes, analyses, etc. 1230 Lunch 1330 Continue NRC Audit Team Activities:

• Technical area break-out discussions between NRC and licensee staff in the areas of reactor systems, electrical, balance-of-plant/structures, and others

• Review documents relating to open or confirmatory items, codes, analyses, etc. 1600 NRC Audit Team meeting 1630 Team lead daily debrief/next day planning with licensee Onsite Day 3, Wednesday, November 18, 2015 0830 Check in at site; meet with Senior Resident/Resident 0900 NRC Audit Team Activities:

• Review documents relating to open or confirmatory items, codes, analyses, etc.

• Mitigating Strategies walk-throughs with licensee 1200 Lunch 1300 Continue NRC Audit Team Activities 1600 NRC Audit Team meeting 1630 Team lead daily debrief/next day planning with licensee Onsite Day 4, Thursday, November 19, 2015 0830 Continue NRC Audit Team Activities 1200 Lunch 1300 Continue NRC Audit Team Activities 1600 NRC Audit Team meeting 1630 Team lead daily debrief/next day planning with licensee Onsite Day 5, Friday, November 20, 2015 0830 NRC Audit Team meeting 0900 NRG/Licensee pre-exit meeting 1000 NRG/Licensee exit meeting 1030 Audit closeout/departure B. Hanson If you have any questions, please contact me at 301-415-5888 or by e-mail at Jason.Paige@nrc.gov.

Docket No.: 50-410

Enclosure:

Audit plan cc w/encl: Distribution via Listserv Mr. Peter Orphanos, Site Vice President Nine Mile Point Nuclear Station 348 Lake Road Lycoming, NY 13126 DISTRIBUTION:

PUBLIC JOMBD R/F RidsNrrDorllpl 1-1 Resource RidsNrrPMNineMilePoint Resource RidsNrrLASLent Resource RidsAcrsAcnw_MailCTR Resource ADAMS Accession No. ML 15289A526 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NAME JPaige SLent DATE 10/20/2015 10/20/2015 Sincerely, IRA/ Jason Paige, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation RidsRgn1 MailCenter Resource JPaige, NRR/JLD JBowen, NRR/JLD *via email NRR/JLD/JOMB/BC NRR/JLD/JOMB/PM MHalter JPaige 10/20/2015 10/20/2015 OFFICIAL RECORD COPY