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{{#Wiki_filter:From: | {{#Wiki_filter:From: | ||
Cc: | Marshall, Michael To: | ||
[Licensee] Ron Reynolds (Exelon) | |||
Cc: | |||
Danna, James | |||
==Subject:== | ==Subject:== | ||
NINE MILE POINT NUCLEAR STATION, UNIT 2 - WITHDRAWAL AND REPLACEMENT OF REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT RISK-INFORMED COMPLETION TIMES (EPID L-2019-LLA-0234) | NINE MILE POINT NUCLEAR STATION, UNIT 2 - WITHDRAWAL AND REPLACEMENT OF REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT RISK-INFORMED COMPLETION TIMES (EPID L-2019-LLA-0234) | ||
Date: | Date: | ||
By letter dated October 31, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19304B653), as supplemented by letters dated December 12, 2019 and August 28, 2020 (ADAMS Accession Nos. ML19346F427 and ML20241A044, respectively), Exelon Generation Company, LLC (Exelon, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend the Appendix A, Technical Specifications, of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (Nine Mile Point 2). Exelons proposed license amendment request (LAR) would revise technical specification requirements to permit the use of risk-informed completion times (RICTs) for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on Technical Specifications Task Force Traveler 505 (TSTF-505), Revision 2, Provide Risk Informed Extended Completion Times - RITSTF [Risk Informed Technical Specification Task Force] Initiative 4b, dated July 2, 2018 (ADAMS Accession No. ML18269A041). | Monday, September 28, 2020 3:09:00 PM Hello Ron: | ||
By {{letter dated|date=October 31, 2019|text=letter dated October 31, 2019}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19304B653), as supplemented by letters dated December 12, 2019 and August 28, 2020 (ADAMS Accession Nos. ML19346F427 and ML20241A044, respectively), Exelon Generation Company, LLC (Exelon, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend the Appendix A, Technical Specifications, of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (Nine Mile Point 2). Exelons proposed license amendment request (LAR) would revise technical specification requirements to permit the use of risk-informed completion times (RICTs) for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on Technical Specifications Task Force Traveler 505 (TSTF-505), Revision 2, Provide Risk Informed Extended Completion Times - RITSTF [Risk Informed Technical Specification Task Force] Initiative 4b, dated July 2, 2018 (ADAMS Accession No.ML18269A041). | |||
By e-mail dated September 2, 2020, the NRC staff sent you requests for additional information (RAI) numbered 6 to 25 (ADAMS Accession No. ML20246G636). The NRC staff has determined that RAI 17 needs to be replaced to make it more consistent with similar RAIs to information requests on other TSTF-505 LARs being reviewed by the NRC. | By e-mail dated September 2, 2020, the NRC staff sent you requests for additional information (RAI) numbered 6 to 25 (ADAMS Accession No. ML20246G636). The NRC staff has determined that RAI 17 needs to be replaced to make it more consistent with similar RAIs to information requests on other TSTF-505 LARs being reviewed by the NRC. | ||
The NRC staff is withdrawing RAI 17 and replacing it with a revised RAI 17. The revised RAI 17 was discussed with you on September 17, 2020, and it was agreed that your response would be provided within 30 days of the date of this e-mail. | The NRC staff is withdrawing RAI 17 and replacing it with a revised RAI 17. The revised RAI 17 was discussed with you on September 17, 2020, and it was agreed that your response would be provided within 30 days of the date of this e-mail. | ||
===RAI 17=== | ===RAI 17=== | ||
Section 2.3 of LAR Attachment 1 states that the application of an RICT will be evaluated using the guidance provided in Nuclear Energy Institute topical report (NEI) 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Industry Guidance Document, which was approved by the NRC on | Section 2.3 of LAR Attachment 1 states that the application of an RICT will be evaluated using the guidance provided in Nuclear Energy Institute topical report (NEI) 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Industry Guidance Document, which was approved by the NRC on May17, 2007 (ADAMS Accession No. ML071200238). The NRC safety evaluation for NEI0609, Revision 0-A, states, The impact of the proposed change should be monitored using performance measurement strategies. NEI 06-09 considers the use of NUMARC 93-01, Revision F (ADAMS Accession No. ML18120A069), as endorsed by Regulatory Guide (RG)1.160, Revision 4 (ADAMS Accession No. ML18220B281), for the implementation of the Maintenance Rule. NUMARC 93-01, Section 9.0, contains guidance for the establishment of performance criteria. | ||
Furthermore, Section 2.3 of LAR Attachment 1 states: | Furthermore, Section 2.3 of LAR Attachment 1 states: | ||
In addition, the NEI 06-09-A, methodology satisfies the five key safety principles specified in Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decision making: Technical Specifications, dated | In addition, the NEI 06-09-A, methodology satisfies the five key safety principles specified in Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decision making: Technical Specifications, dated | ||
August 1998 (ADAMS Accession No. ML003740176), relative to the risk impact due to the application of a RICT. | August 1998 (ADAMS Accession No. ML003740176), relative to the risk impact due to the application of a RICT. | ||
Staff position C.3.2 provided in RG 1.177 for meeting the fifth key safety principle acknowledges the use of performance criteria to assess degradation of operational safety over a period of time. It is unclear to NRC staff how the licensees processes for the RICT application captures performance monitoring for the structures, systems, and components (SSCs) within-scope of the application. In light of these observations, address either (i) or (ii) below: | Staff position C.3.2 provided in RG 1.177 for meeting the fifth key safety principle acknowledges the use of performance criteria to assess degradation of operational safety over a period of time. It is unclear to NRC staff how the licensees processes for the RICT application captures performance monitoring for the structures, systems, and components (SSCs) within-scope of the application. In light of these observations, address either (i) or (ii) below: | ||
i) Confirm that the Nine Mile Point 2 Maintenance Rule program incorporates the use of performance criteria to evaluate SSC performance as described in the NRC-endorsed guidance in NUMARC 93-01. | i) Confirm that the Nine Mile Point 2 Maintenance Rule program incorporates the use of performance criteria to evaluate SSC performance as described in the NRC-endorsed guidance in NUMARC 93-01. | ||
or ii) Describe the approach/method used by Nine Mile Point 2 for SSC performance monitoring as described in Regulatory Position C.3.2 referenced in RG 1.177 for meeting the fifth key safety principle. In the description, include criteria (e.g., | |||
or | |||
ii) Describe the approach/method used by Nine Mile Point 2 for SSC performance monitoring as described in Regulatory Position C.3.2 referenced in RG 1.177 for meeting the fifth key safety principle. In the description, include criteria (e.g., | |||
qualitative or quantitative) along with the appropriate risk metrics for the RICT application, and explain how the approach and criteria demonstrates the intent to monitor the potential degradation of SSCs for the applicable process of the risk-informed application. | qualitative or quantitative) along with the appropriate risk metrics for the RICT application, and explain how the approach and criteria demonstrates the intent to monitor the potential degradation of SSCs for the applicable process of the risk-informed application. | ||
Best Regards, Michael L. Marshall, Jr. | Best Regards, Michael L. Marshall, Jr. | ||
Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-2871 Docket No. 05-410}} | Senior Project Manager | ||
Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation | |||
301-415-2871 | |||
Docket No. 05-410}} | |||
Latest revision as of 18:24, 29 November 2024
| ML20272A280 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/28/2020 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Reynolds R Exelon Nuclear |
| Marhsall M, NRR/DORL/LPL, 415-2871 | |
| References | |
| EPID L-2019-LLA-0234 | |
| Download: ML20272A280 (2) | |
Text
From:
Marshall, Michael To:
[Licensee] Ron Reynolds (Exelon)
Cc:
Danna, James
Subject:
NINE MILE POINT NUCLEAR STATION, UNIT 2 - WITHDRAWAL AND REPLACEMENT OF REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT RISK-INFORMED COMPLETION TIMES (EPID L-2019-LLA-0234)
Date:
Monday, September 28, 2020 3:09:00 PM Hello Ron:
By letter dated October 31, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19304B653), as supplemented by letters dated December 12, 2019 and August 28, 2020 (ADAMS Accession Nos. ML19346F427 and ML20241A044, respectively), Exelon Generation Company, LLC (Exelon, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend the Appendix A, Technical Specifications, of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (Nine Mile Point 2). Exelons proposed license amendment request (LAR) would revise technical specification requirements to permit the use of risk-informed completion times (RICTs) for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on Technical Specifications Task Force Traveler 505 (TSTF-505), Revision 2, Provide Risk Informed Extended Completion Times - RITSTF [Risk Informed Technical Specification Task Force] Initiative 4b, dated July 2, 2018 (ADAMS Accession No.ML18269A041).
By e-mail dated September 2, 2020, the NRC staff sent you requests for additional information (RAI) numbered 6 to 25 (ADAMS Accession No. ML20246G636). The NRC staff has determined that RAI 17 needs to be replaced to make it more consistent with similar RAIs to information requests on other TSTF-505 LARs being reviewed by the NRC.
The NRC staff is withdrawing RAI 17 and replacing it with a revised RAI 17. The revised RAI 17 was discussed with you on September 17, 2020, and it was agreed that your response would be provided within 30 days of the date of this e-mail.
RAI 17
Section 2.3 of LAR Attachment 1 states that the application of an RICT will be evaluated using the guidance provided in Nuclear Energy Institute topical report (NEI) 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Industry Guidance Document, which was approved by the NRC on May17, 2007 (ADAMS Accession No. ML071200238). The NRC safety evaluation for NEI0609, Revision 0-A, states, The impact of the proposed change should be monitored using performance measurement strategies. NEI 06-09 considers the use of NUMARC 93-01, Revision F (ADAMS Accession No. ML18120A069), as endorsed by Regulatory Guide (RG)1.160, Revision 4 (ADAMS Accession No. ML18220B281), for the implementation of the Maintenance Rule. NUMARC 93-01, Section 9.0, contains guidance for the establishment of performance criteria.
Furthermore, Section 2.3 of LAR Attachment 1 states:
In addition, the NEI 06-09-A, methodology satisfies the five key safety principles specified in Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decision making: Technical Specifications, dated
August 1998 (ADAMS Accession No. ML003740176), relative to the risk impact due to the application of a RICT.
Staff position C.3.2 provided in RG 1.177 for meeting the fifth key safety principle acknowledges the use of performance criteria to assess degradation of operational safety over a period of time. It is unclear to NRC staff how the licensees processes for the RICT application captures performance monitoring for the structures, systems, and components (SSCs) within-scope of the application. In light of these observations, address either (i) or (ii) below:
i) Confirm that the Nine Mile Point 2 Maintenance Rule program incorporates the use of performance criteria to evaluate SSC performance as described in the NRC-endorsed guidance in NUMARC 93-01.
or
ii) Describe the approach/method used by Nine Mile Point 2 for SSC performance monitoring as described in Regulatory Position C.3.2 referenced in RG 1.177 for meeting the fifth key safety principle. In the description, include criteria (e.g.,
qualitative or quantitative) along with the appropriate risk metrics for the RICT application, and explain how the approach and criteria demonstrates the intent to monitor the potential degradation of SSCs for the applicable process of the risk-informed application.
Best Regards, Michael L. Marshall, Jr.
Senior Project Manager
Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
301-415-2871
Docket No.05-410