Letter Sequence RAI |
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MONTHYEARNMP2L2706, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2019-10-31031 October 2019
License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
Project stage: Request
ML19339E8542019-12-0505 December 2019
Supplemental Information Needed for Acceptance of Requested Licensing Action Adoption of Risk-Informed Completion Times
Project stage: Acceptance Review
NMP2L2718, Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22019-12-12012 December 2019
Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2
Project stage: Supplement
ML20023B1622020-01-21021 January 2020
Acceptance of Requested Licensing Action Use of Risk-Informed Completion Times
Project stage: Acceptance Review
ML20037B6542020-02-0606 February 2020
Audit Plan Regarding License Amendment Request to Implement Risk-Informed Extended Completion Times 50-410 (L-2019-LLA-0234)
Project stage: Other
ML20094J1562020-04-22022 April 2020
Audit Plan Supplement in Support of Review of License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times
Project stage: Other
ML20213A9352020-07-30030 July 2020
Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times
Project stage: RAI
NMP2L2739, Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22020-08-28028 August 2020
Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2
Project stage: Request
ML20246G6362020-09-0202 September 2020
Request for Additonal Information to Support Review of License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times
Project stage: Approval
ML20273A2372020-09-28028 September 2020
Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times
Project stage: RAI
ML20272A2802020-09-28028 September 2020
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
Project stage: RAI
ML20248H5192020-09-28028 September 2020
Changes to Draft Request for Additional Information Regarding Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times
Project stage: Draft RAI
NMP2L2745, Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22020-10-0202 October 2020
Request for Additional Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2
Project stage: Request
NMP2L2746, Supplemental Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22020-10-0202 October 2020
Supplemental Information for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2
Project stage: Supplement
NMP2L2749, Responses to Request for Additional Information Questions 17 and 26 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Rev. 22020-10-22022 October 2020
Responses to Request for Additional Information Questions 17 and 26 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Rev. 2
Project stage: Response to RAI
ML20351A1642020-12-15015 December 2020
Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times
Project stage: RAI
NMP2L2754, Responses to Request for Additional Information Questions 27 and 28 to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 22021-01-0707 January 2021
Responses to Request for Additional Information Questions 27 and 28 to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2
Project stage: Response to RAI
ML21082A2212021-04-29029 April 2021
Issuance of Amendment No. 186, Adoption of TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B
Project stage: Approval
2020-02-06
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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 May 17, 2007 (ADAMS Accession No. ML071200238). The NRC safety evaluation for NEI 0609, 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
