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.constellationConstellation.com
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
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 remov al 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, 202 4, 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 becausethey 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed)
Braidwood Adoption of 10 CFR Risk Management Document BB-MISC-055, None of the identified items is a Station, 50.69 Revision 0, provides documentation of completion PRA Upgrade so a Focused Units 1 of the implementation items described in the 10 Scope Peer Review was not and 2 The licensee will CFR 50.69 License Amendment Request. required. Each item was complete the updated dispositioned in Attachment 6 of implementation items Item 3.a The internal events and fire PRA models the original LAR application listed in Attachment 1 of were updated to model heating, ventilation and air (ML17244A093) and their Exelon letter to NRC conditioning (HVAC) dependency for High Energy completion is documented in CEG dated September 13, Line Break (HELB) scenarios. Risk Management notebook BB-2018, prior to MISC-055.
implementation of 10 Item 3.b The FPRA models for Byron and CFR 50.69. All issues Braidwood were updated to incorporate failures Note that an F&O Closure Review identified in the required to account for instances where breaker has not been completed for these attachment will be coordination could not be confirmed. items.
addressed and any associated changes will Item 3.c A Fire PRA sensitivity that removes the be made, focused scope CCDP and CLERP scaling factor adjustments used peer reviews will be for crediting alternate shutdown given abandonment performed on changes of the MCR was performed during the BB Service that are PRA upgrades Water System categorization. This sensitivity was as defined in the PRA in addition to the sensitivities required by NEI 00-04
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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) standard (ASME/ANS Table 5-3 as per the implementation item. The Fire RA-Sa-2009, as PRA was subsequently updated to eliminate the endorsed by RG 1.200, scaling factor adjustment.
Revision 2), and any findings will be resolved Item 3.d Identification of all wall mounted panel and reflected in the PRA configurations with four or more switches was of record prior to completed and resulting changes to the Byron and implementation of the 10 Braidwood FPRA models to incorporate the impact CFR 50.69 of these panels were made.
categorization process.
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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed)
Byron Adoption of 10 CFR Risk Management Document BB-MISC-055, See the above discussion for Station, 50.69 Revision 0, provides documentation of completion Braidwood, as it applies to Byron Units 1 of the implementation items described in the 10 as well.
and 2 The licensee will CFR 50.69 License Amendment Request.
complete the updated implementation items See the above discussion for Braidwood as the listed in Attachment 1 of resolutions apply to Byron as well.
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 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) of record prior to implementation of the 10 CFR 50.69 categorization process.
LaSalle Adoption of 10 CFR Three implementation items are discussed in None of the identified items are County 50.69 Attachment 2 of EGC letter to NRC dated October PRA Upgrades so a Focused Station, 29, 2020 and their resolutions are discussed below. Scope Peer Review was not Units 1 and The licensee will required. Each item was 2 complete the Item #1: Main Turbine High Water Level Trip dispositioned for the application in implementation items Channels Attachment 3 of the original LAR listed in Table Risk Management Document LS-PRA-013, application (ML20031E699) and APLA-01.2 in Attachment Revision 10, provides documentation of completion their completion is documented in 1 of EGC letter to NRC of the implementation item described in the 10 CFR CEG RICT PARAGON Model dated October 29, 2020, 50.69 License Amendment Request. Basis Document LS-CRM-37.
prior to implementation of 10 CFR 50.69 The PRA Model of Record (MOR) was updated Note that an F&O Closure Review program. All issues during the 2020 PRA update to include modeling for has not been completed for these identified will be the main turbine high water level trip channels. items.
addressed and any Appendix A of LS-PRA-013, Revision 10 associated changes will summarizes the model changes performed for the be made, focused-scope 2020 PRA update. This implementation item was peer reviews will be resolved in model change revision LS220A-030 performed on changes ("Created gate LVL8-TRIP-FAIL (LEVEL 8 TRIP that are PRA upgrades CHANNEL FAIL)").
as defined in the PRA Standard Item #2: Fire F&O 4-17 (ASME/ANSRA-Sa-2009, 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) as endorsed by Risk Management Document LS-PRA-021.07, RG1.200, Revision2), Revision 4, provides documentation of completion and any findings will be of the implementation item described in the 10 CFR resolved and reflected in 50.69 License Amendment Request.
the PRA of record prior to implementation of the Fire Finding F&O 4-17 involves reviewing plant-10 CFR 50.69 specific data to derive plant-specific automatic categorization process. 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant 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 Adoption of TSTF-505, Three implementation items are discussed in None of the identified items are County Rev. 2 Attachment 2 of EGC letter to NRC dated October PRA Upgrades so a Focused Station, 29, 2020 and their resolutions are discussed below. Scope Peer Review was not Units 1 and The licensee will required. Each item was 2 complete the Item #1: Main Turbine High Water Level Trip dispositioned for the application in implementation item Channels Attachment 3 of the original LAR listed in Attachment 5 of Risk Management Document LS-PRA-013, application (ML20031E699) and Exelon letter to the NRC Revision 10, provides documentation of completion their completion is documented in dated January 31, 2020, of the implementation item described in the 10 CFR CEG RICT PARAGON Model prior to implementation 50.69 License Amendment Request. Basis Document LS-CRM-37.
of the RICT Program. All issues identified in the The PRA Model of Record (MOR) was updated Note that an F&O Closure Review attachment will be during the 2020 PRA update to include modeling for has not been completed for these addressed and any the main turbine high water level trip channels. items.
associated changes will Appendix A of LS-PRA-013, Revision 10 be made, focused-scope summarizes the model changes performed for the peer reviews will be 2020 PRA update. This implementation item was performed on changes resolved in model change revision LS220A-030 that are PRA upgrades ("Created gate LVL8-TRIP-FAIL (LEVEL 8 TRIP as defined in the PRA CHANNEL FAIL)").
standard (ASME/ANS 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed)
RA-Sa-2009, as Item #2: Fire F&O 4-17 endorsed by RG 1.200, Risk Management Document LS-PRA-021.07, Revision 2), and any Revision 4, provides documentation of completion findings will be resolved of the implementation item described in the 10 CFR and reflected in the PRA 50.69 License Amendment Request.
of record prior to implementation of the Fire Finding F&O 4-17 involves reviewing plant-RICT Program. 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant 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 Adoption of 10 CFR Risk Management Document N2-PRA-013 PRA None of the identified items is a Point 50.69 Summary Revision 3 provides documentation of PRA Upgrade so a Focused Nuclear completion of the implementation items described in Scope Peer Review is not Station, Constellation Energy the 10 CFR 50.69 License Amendment Request. required. All Fact and Unit 2 Generation, LLC will Observations have been complete the items listed Six implementation items are discussed in implemented and were closed as in Attachment 7 of Attachment 7: described in F&O Closure Review Exelon letter to NRC Report 032405-RPT-01.
dated December 26, Item i. refers to Mechanical Vacuum Pump Isolation 2019, prior to Instrumentation not modeled. The model was implementation of 10 updated to include these SSCs and the PRA CFR 50.69. All issues Success Criteria matches the Design Success identified in the Criteria.
attachment will be addressed and any Item ii refers to modeling of suppression chamber-associated changes will to-drywell vacuum breakers. The model was be made, focused-scope updated to include failure-to-open and the PRA peer reviews will be Success Criteria matches the Design Success performed on changes Criteria.
that are PRA upgrades 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) as defined in the PRA Item iii refers to updating the model such that the standard (ASME/ANS PRA Success Criteria matches the Design Success RA-Sa-2009, as Criteria when UHS temperature is > 82°F. The endorsed by RG 1.200, model was updated and the PRA Success Criteria Revision 2), and any matches the Design Success Criteria.
findings will be resolved and reflected in the PRA Item iv refers to modeling of intake deicer heaters.
of record prior to The model was updated to explicitly include the implementation of the 10 deicer heaters.
CFR 50.69 categorization process. 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 Adoption of TSTF-505, Risk Management Document N2-PRA-013 PRA See the above 50.69 discussion Point Revision 2 Summary Revision 3 provides documentation of for Nine Mile Point 2 it applies to Nuclear completion of all but one of the implementation the TSTF-505 application as well.
Station, Constellation Energy items described in the TSTF-505 License Unit 2 Generation, LLC will Amendment Request. The final implementation complete the item is documented in the Level 2 Notebook implementation items Revision 2.
listed in Attachment 6 of 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed)
Exelon Letter to the NRC See the above discussion for Nine Mile 2. The dated October 31, 2019, same implementation items are provided in prior to implementation Attachment 6 of the original TSTF-505 LAR of the RICT Program. All (ML19304B653).
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.
Peach Adoption of 10 CFR Risk Management Document PB-MISC-045, Items 1 and 7 were considered Bottom 50.69 Revision 0, provides documentation of completion PRA Model Upgrades and were Atomic of the implementation items described in the 10 reviewed and dispositioned with a Power The licensee will CFR 50.69 License Amendment Request except for Focused Scope Peer Review as Station, complete the item 12. Risk Management Document PB-MISC-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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed)
Units 2 and implementation items 027 Rev 5 provides documentation of completion of 3 listed in Attachment 2 of implementation item 12. Items 2, 3, 4, 6 and 8 were not a Exelons letter to the PRA Upgrade so a Focused NRC dated June 6, Thirteen implementation items are discussed in Scope Peer Review was not 2018, prior to Attachment 2: required. Each was resolved by implementation of 10 an F&O Closure Review as CFR 50.69. All issues Item 1 The HRA pre-initiators in the internal events documented in PB-MISC-045.
identified in the PRA model were updated to meet Capability attachment will be Category II of the ASME/ANS RA-Sa-2009 as Items 9, 10, 11 and 12 were not a addressed and any endorsed by RG 1.200, Revision 2. A focused-PRA Upgrade so a Focused associated changes will scope peer review was be conducted of the pre-Scope Peer Review was not be made, focused-scope initiator analysis, and any resulting F&Os were required. These items (except peer reviews will be resolved, as indicated in response to RAI 03.a item 12) were directly performed on changes contained in Exelon letter dated May 7, 2018. implemented in the model as that are PRA upgrades documented in PB-MISC-045.
as defined in the PRA Item 2 The transient floor area ratios (FARs) in the Because these model standard (ASME/ANS fire PRA were adjusted to consider the treatment of modifications were not the result RA-Sa-2009, as obstructed floor space to provide a more accurate of a Peer Review, a F&O Closure endorsed by RG 1.200, distribution of transient ignition frequency, as review was not applicable.
Revision 2), and any indicated in response to RAI 03.b contained in findings will be resolved Exelon letter dated May 7, 2018. For Item 12, High Winds and and reflected in the PRA Tornado Missile hazards were of record prior to Item 3 Risk significant fire PRA scenarios for screened for 50.69 based on the implementation of the 10 ignition sources capable of being modeled with a evaluation provided in PB-MISC-CFR 50.69 two-point fire modeling approach were updated to 027, Rev. 5.
categorization process. include the two-point fire modeling approach, as 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) indicated in response to RAI 03.c contained in Note: For item 12, the Exelon letter dated May 7, 2018. amendments are 321 and 324 for Peach Bottom Units 2 and 3; Item 4 A review was conducted of potentially respectively.
vulnerable fire wrap configurations to identify which are subject to mechanical damage. The fire PRA Items 5 and 13 are 50.69 program was updated to ensure that fire wrap configurations implementation items that have are not credited in fire scenarios that could subject it been captured in Constellation's to mechanical damage, as indicated in response to 50.69 programmatic procedures to RAI 03.d contained in Exelon letter dated May 7, perform the additional sensitivity 2018. that assumes credit for immediate manual suppression (Item 5). In Item 5 The categorization process includes the fire addition, ASME Class 1 PRA sensitivity studies from NEI 00- 04Table 5-3 components shall be categorized which includes the sensitivity study to remove all HSS including any supports that credit for manual suppression. Another fire PRA are within the boundary of the sensitivity study is be performed as part of the categorized system and cannot be categorization process that assumes credit for changed by the IDP.
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 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant 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 Adoption of TSTF-505, Risk Management Document PB-ASM-22 Revision Each item was not a PRA Bottom Revision 2 0 provides documentation of completion of the Upgrade so a Focused Scope Atomic implementation items described in the TSTF-505 Peer Review was not required.
Power Constellation Energy License Amendment Request. These items were directly Station, Generation, LLC will implemented in the model as Units 2 and complete the Three implementation items are discussed in documented in PB-ASM-22.
3 implementation items Attachment 6: Because these model listed in Attachment 6 of modifications were not the result Exelon letter to the NRC Item 1 refers to Failure of the reactor building-to-of a Peer Review, a F&O Closure dated May 29, 2020, suppression chamber vacuum breakers to open review was not applicable.
prior to implementation was not modeled in the PRA. Prior to of the RICT Program. All implementation, logic was added to the PRA to issues identified in the model the impact of these reactor building-to-attachment will be suppression chamber vacuum breakers failing to addressed and any open.
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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) associated changes will be made, focused-scope Item 2 refers to Failure of the suppression chamber-peer reviews will be to-drywell vacuum breakers to open was currently performed on changes modeled in the PRA Prior to implementation, logic that are PRA upgrades was added to the PRA to model the impact of these as defined in the PRA vacuum breakers failing to open. Enclosure 9, Table standard (ASME/ANS E9-3, Task #2 Component Selection RA-Sa-2009, as endorsed by RG 1.200, Item 3 refers to the Standby Liquid Control (SLC)
Revision 2), and any out of service cases may not represent the true findings will be resolved delta risk without having the appropriate cable data and reflected in the PRA for that system. The SLC cable data was obtained of record prior to and the Fire PRA model was updated to account for implementation of the the SLC cabling and potential random Anticipated RICT Program. Transient Without Scram (ATWS) scenarios.
R.E. Ginna Adoption of TSTF-505, These items address 5 implementation items Not applicable for Ginna since Nuclear Revision 2 addressing additional tornado protection margin: these were not PRA modeling Power commitments. Evidence of their Plant Constellation Energy Item 1 is SAFW Generator Radiator Exhaust: completion is provided in the Generation, LLC will Replace 19W4 1/4x 2 Bar Grating with 19W4 1/4x previous column.
complete the 4Bar Grating implementation items listed in Attachment 6 of The bar grating was replaced under C93804738 Exelon Letter to the NRC dated May 20, 2021, Item 2 is B Emergency Diesel Generator Room Air prior to implementation Intake: Replace 19W4 1/4x 2 Bar Grating with of the RICT Program. All 19W4 1/4x 4Bar Grating 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
PRA Model Upgrade (Y/N),
Plant License Condition Justification that License Condition Focused-Scope Peer Review is No Longer Relevant Results and F&O Closure Review Results (if needed) issues identified in the attachment will be The bar grating was replaced under C93804741 addressed and any and C93803310 associated changes will be made, focused-scope Item 3 is B EDG Roof Vents: Increase anchorage peer reviews will be capacity performed on changes by expanding baseplate, increasing the that are PRA upgrades size/embedment depth of anchors.
as defined in the PRA standard (ASME/ANS Item 3 was repaired under ECP 000602-CN- 004 RA-Sa-2009, as endorsed by RG 1.200, Item 4 is KDG08 Exhaust: Additional gussets at Revision 2), and any outside face of piping and, re-pad on outside edge findings will be resolved of elbow and reflected in the PRA of record prior to the Gussets installed and re-pad performed under implementation of the C93804738 RICT Program.
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.
- 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 Attachment 2b 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 S pe cifications Pages James A. Fi tzPatrick N uclear P ower Plant Renewed Facility O perating Li cense N o. D PR-59 NRC Docket No. 50-3 33
Revised Technical Specifications Page 5.5-16 5.6-3
!Pm g1ra1 m § ai tr1 di Mai tr11U1 ai !§ Programs and Manuals 55J5.5
5.5 Programs and Manuals (continued)
5.5.16 R!R i§ik !tr1fo~medl Com[Qlieti o tr1 Time IPmg~ai m (icotr1ti tr11U1edl} isk Informed Completion Time Program (continued) ddo fm eme~getr1t.For emergent cico tr1dlitiotr1ondition§, if tlhie exll:etrit s, if the extent oof ico tr1 dlitiotr1 evai !1U1 aitiotr1 to ~ f condition evaluation for ii tr1 ope ~ailblie §t m cilUl~e§, §)l'§t em§, m icompotr1etr1t § (§§C§) i§ tr1 ot icompil!;lit e noperable structures, systems, or components (SSCs) is not complete pp~ io~ to exiceedlitr1g riortoexceedingtlhi e Compieti otr1 Time, tlhi e IR !CtheCompletionTime,theRICT §lhi ai ii aiicico1U1tr1 t to ~ Tshallaccountfortlhie the ii tr1 ic ~ncreeai§edl po§§iiblmty of icommotr1 taJIUl§e f airn 1tue (CC f } lbly e itlhie rased possibility of common cause failure (CCF) by either: :
1io NIUl me~ iicai iiy.NumericallyaaJICICOIUltrit itr1 g ccountingfo~ fort lhie itr1 icmai§edi [PlO§§iibl mty of CC f itri theincreasedpossibilityofCCFin the RICT calculation; or tlhie IR !CT icai !ic1U1 !aitio tr1 ; o r 2:;t !Ri§ik Mai tr1 aigemetr1t Aci iO.Risk Management Actiontri § (IRMM} tril Os (RMAs) not ai ireaidly ic redlitedl i tri tlhie t already credited in the RICT calculation shall be implemented that support redundant IR !CT icai !t1U1 !aitiotr1 §lhi aJ! ! Ible imp iemetr1t edl tlhi ai t §IUl[Pl[PlOrt ~edl1U1tr1dlaitr1 t oo r dlive rn e §§C§ t lhi ait pe ruo rm tlhie f 1U1tr1ictir diverse SSCs that performthe functiootr1(§) of t lhi e i tr1 opemlbiie n(s) of the inoperable
§§C§, ai tr1dl, if prai ictiicailbiie, redl1U1ice t lhi e f ~SSCs, and, if practicable, reduce the freeq1U1etr1icy quency oof i tr1itiaiti tr1 g f initiating eeve tr1 t§ t lhi ait ic lhi ai i!e tr1 ge t lhie f 1U1tr1ictivents that challenge the functio tr1 (§) peruo rmedl lbly tlhie on(s) performed by the ii tr1 opemlbiie §§C§" noperable SSCs.
- e. TIAie risi<1 assessmeThe risk assessmen1111t approaolAies t approaches aamJI metlAiodls slAiaii lbie aooeptalbind methods shall be acceptablie to e to tlAio NRG" the NRC. TTIAie piamt PR/!\\ slAiaii lbie lbiasodl 81111 tlAio as lbilLliithe plant PRA shall be based on the as-built,, as as-oopomtedl, perated, m,1dl ma i1111 ta i1111odl pia1111t; a1111dl rofieot tlAie opemti1111g D*[PJDl'ie1111oe and maintained plant; and reflect the operating experience aat t lAie t the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to pia1111t, as speoifiedl i1111 Reg1L1 iatmy GIL! idle 1 "200, Rm.,iis io1111 2 " Met lAiodls to aassess ssess ttlAie ris i<1 from e~e1111dli1111g he risk from extending ttlAie Gompietio1111 Times mlLlst lbie PR/\\ he Completion Times must be PRA mmetlAiodls ethods uIL!Sedl to SILl[PJ[PJ8R Uoe 1111 se li>>ime1111dlme1111t sed to support License Amendment NN8 o, 01' otlAiel' o., or other mmetlAiodls ethods aitll[Pl[PJ1'8"1edl pproved bby tlAie NRG for ge1111erio y the NRC for generic u!Lise; a 1111dl a1111y 01Aia1111ge i1111 tlAie se; and any change in the PPRA metlAiodls RA methods tto assess risi< o assess risk tt lAiat me 01L1tsidle hat are outside ttlAiese iEil[Pl[Pll'O'JiEilhese approvali
'Insert 1 blbio1L1 1111dlmies req 1L1 im prio r NRG ap pm"lat oundaries require prior NRC approval.
JAFNPP 5.5-16 Amendment 353 JAf NIPIP Reporting Requirements 5.6
5.6 Reporting Requirements
5.6.5 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.
5.6.6 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:
11nsert 2 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.
JAFNPP 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 haz ard groups require prior NRC a pproval.
- 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 r eport describing newly deve loped methods and their i mplementation 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 S pe cifications Pages Nine Mile Point N uclear S tation, U nit 1 Renewed Facility O perating Li cense N o. N PF-63 NRC D ocket N o. 50- 220
Revised Technical Specifications Page 355c 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 areperformed at intervals sufficient to assure the associated Limiting Conditions forOperation are met.
- a. The Surveillance Frequency Control Program shall containa list of Frequencies of the Surveillance Requirements for which the Frequency iscontrolled by the program.
- b. Changes to the Frequencies listed in the Surveillance Frequency Controlled Program shall bemade 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 revisedRICT must be determined priorto 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:
- 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:
- 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-Inf ormed A ctivities."
- g. A report shall be submitted in accordance with Specification 6.6.8 before a newly developed method is us ed to calculate a RICT.