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Category:Letter
MONTHYEARML24022A1172024-01-23023 January 2024 Acceptance of Requested Licensing Action Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations ML24012A2422024-01-16016 January 2024 Acceptance of Requested Licensing Action License Transfer Request ML23236A0042023-12-27027 December 2023 Issuance of Amendment 274 Re Changes to Perm Defueled Emergency Plan and Perm Defueled Emergency Action Level Scheme ML23355A1242023-12-26026 December 2023 Withdrawal of an Amendment Request Re License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML23192A0772023-12-26026 December 2023 Letter Exemption from the Requirements of 10 CFR 140.11(a)(4) Concerning Offsite Primary and Secondary Liability Insurance ML23191A5222023-12-22022 December 2023 Exemption Letter from the Requirements of 10 CFR 50.54(W)(1) Concerning Onsite Property Damage Insurance (EPID - L-2022-LLE-0032) ML23263A9772023-12-22022 December 2023 Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation ML23354A2602023-12-21021 December 2023 Reference Simulator Inspection Request for Information L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 PNP 2023-030, License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations2023-12-14014 December 2023 License Amendment Request to Revise Renewed Facility Operating License and Permanently Defueled Technical Specifications to Support Resumption of Power Operations PNP 2023-035, Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements2023-12-12012 December 2023 Withdrawal of License Amendment Request - Revise License Condition to Eliminate Cyber Security Plan Requirements PNP 2023-028, Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments2023-12-0606 December 2023 Application for Order Consenting to Transfer of Control of License and Approving Conforming License Amendments L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23291A4402023-11-0303 November 2023 Acceptance of Requested Licensing Action Request for Exemption from 10 CFR 50.82(a)(2) to Support Reauthorization of Power Operations IR 05000255/20230032023-10-0404 October 2023 NRC Inspection Report No. 05000255/2023003(DRSS)-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23275A0012023-10-0202 October 2023 Request for Withholding Information from Public Disclosure for Palisades Nuclear Plant PNP 2023-025, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.822023-09-28028 September 2023 Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 PNP 2023-026, Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations2023-09-28028 September 2023 Pre-Submittal Meeting Presentation - Palisades Nuclear Plant License Transfer Application to Support Resumption of Power Operations PNP 2023-023, Special Report High Range Noble Gas Monitor Inoperable2023-08-0909 August 2023 Special Report High Range Noble Gas Monitor Inoperable ML23215A2302023-08-0303 August 2023 Notice of Organization Change - Chief Nuclear Officer IR 05000255/20230022023-07-19019 July 2023 NRC Inspection Report 05000255/2023002 DRSS-Holtec Decommissioning International, LLC, Palisades Nuclear Plant ML23087A0362023-05-0202 May 2023 PSDAR Review Letter ML23117A2172023-05-0101 May 2023 Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment PNP 2023-018, 2022 Annual Non-Radiological Environmental Operating Report2023-04-25025 April 2023 2022 Annual Non-Radiological Environmental Operating Report L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 PNP 2023-007, and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports2023-04-19019 April 2023 and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports PNP 2023-008, 2022 Radiological Environmental Operating Report2023-04-18018 April 2023 2022 Radiological Environmental Operating Report L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations PNP 2023-002, 6 to Updated Final Safety Analysis Report2023-03-31031 March 2023 6 to Updated Final Safety Analysis Report ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance PNP 2023-006, Report of Changes to Security Plan, Revision 202023-03-29029 March 2023 Report of Changes to Security Plan, Revision 20 PNP 2023-012, Presentation on Regulatory Path to Reauthorize Power Operations2023-03-16016 March 2023 Presentation on Regulatory Path to Reauthorize Power Operations ML23038A0982023-03-15015 March 2023 Request for Withholding Information from Public Disclosure ML23095A0642023-03-14014 March 2023 American Nuclear Insurers, Notice of Cancellation Rescinded PNP 2023-001, Regulatory Path to Reauthorize Power Operations2023-03-13013 March 2023 Regulatory Path to Reauthorize Power Operations PNP 2023-004, Report of Changes to Palisades Nuclear Plant Technical Specification Bases2023-03-0808 March 2023 Report of Changes to Palisades Nuclear Plant Technical Specification Bases PNP 2023-005, Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report2023-03-0101 March 2023 Response to Palisades Nuclear Plant - Request for Additional Information Related to the Post-Shutdown Decommissioning Activities Report ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23052A1092023-02-17017 February 2023 FEMA Letter to NRC, Proposed Commission Paper Language for Palisades Nuclear Plant Emergency Plan Decommissioning Exemption Request ML23032A3992023-02-0101 February 2023 Regulatory Path to Reauthorize Power Operations IR 05000255/20220032022-12-28028 December 2022 NRC Inspection Report No. 05000255/2022003(DRSS); 07200007/2022001 (Drss) Holtec Decommissioning International, LLC, Palisades Nuclear Plant L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 PNP 2022-037, Report of Changes to Security Plan, Revision 192022-12-14014 December 2022 Report of Changes to Security Plan, Revision 19 ML22321A2852022-11-17017 November 2022 LLC Master Decommissioning Trust Agreement for Palisades Nuclear Plant IR 05000255/20224012022-11-0909 November 2022 Decommissioning Palisades Nuclear Plant - Decommissioning Security Inspection Report 05000255/2022401 PNP 2022-036, Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2022-11-0808 November 2022 Response to Request for Additional Information Regarding License Amendment Request for Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme PNP 2022-035, International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations2022-11-0202 November 2022 International - Notification of Commitment Cancellations for Remaining Activities Related to Beyond-Design-Basis Seismic Hazard Reevaluations PNP 2022-024, Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance PNP 2022-026, Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance2022-10-26026 October 2022 Request for Exemption from 10 CFR 50.54(w)(1) Concerning Onsite Property Damage Insurance ML22292A2572022-10-25025 October 2022 Permanently Defueled Emergency Plan License Amendment RAI Letter 2024-01-23
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23354A2602023-12-21021 December 2023 Reference Simulator Inspection Request for Information ML23055A1542023-02-24024 February 2023 Attachment: Request for Additional Information on the Palisades PSDAR ML22292A2582022-10-31031 October 2022 PDEP-EAL Amendment RAI ML22102A2482022-04-14014 April 2022 Request for Additional Information Regarding License Amendment Request for Permanently Defueled Technical Specifications ML21274A4172021-10-0505 October 2021 Request for Information for an NRC Triennial Heat Exchanger/Sink Performance Inspection and Request for Information Inspection Report 05000255/2021004 ML21028A4092021-01-27027 January 2021 NRR E-mail Capture - Palisades Nuclear Plant - Acceptance of Holtec Exemption Request from 10CFR50.82(a)(8)(i)(A) and 10CFR50.75(h)(1)(iv) ML21028A0552021-01-27027 January 2021 NRR E-mail Capture - Palisades Nuclear Plant - Acceptance of License Transfer Application ML20272A0112020-09-26026 September 2020 Request for Additional Information - Palisades Relief Request RR 5-8 (Proposed Alternative) for Reactor Pressure Vessel Head Penetration Repairs ML20133K0562020-05-14014 May 2020 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML19357A2752019-12-23023 December 2019 Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000255/2020011 ML19226A2932019-08-14014 August 2019 NRR E-mail Capture - Request for Additional Information Re License Amendment Request to Adopt TSTF-425, Revision 3 for the Palisades Nuclear Plant ML19226A2922019-08-0505 August 2019 NRR E-mail Capture - Draft Request for Additional Information for Palisades License Amendment Request to Adopt TSTF-425 ML19122A4852019-04-29029 April 2019 NRR E-mail Capture - Request for Additional Information for Palisades License Amendment Request to Revise License Conditions Related to NFPA 805 Modifications ML19009A5392019-01-0909 January 2019 NRR E-mail Capture - Request for Additional Information for Palisades License Amendment Request to Revise Emergency Diesel Generator Degraded Voltage Surveillance Requirement 3.3.5.2a ML19009A5382018-12-12012 December 2018 NRR E-mail Capture - Draft Request for Additional Information for Palisades License Amendment Request to Revise Emergency Diesel Generator Degraded Voltage Surveillance Requirement 3.3.5.2a ML18337A1382018-11-30030 November 2018 NRR E-mail Capture - Request for Additional Information Related to Palisades Relief Request Number RR 5-7 ML18337A1402018-11-29029 November 2018 NRR E-mail Capture - Draft Request for Additional Information Related to Palisades Relief Request 5-7 ML18309A1342018-11-0808 November 2018 Supplemental Information Needed for Acceptance or Requested Licensing Action Amendment Request to Revise Technical Specifications to Adopt TSTF-425, Revision 3 ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18081A2962018-03-22022 March 2018 NRR E-mail Capture - Palisades Nuclear Plant - Request for Additional Information Regarding Proposed Changes to Site Emergency Plan for Permanently Defueled Condition (CAC MG0198: EPID L-2017-LLA-0305) ML18059A8202018-02-28028 February 2018 NRR E-mail Capture - Palisades Nuclear Plant - Request for Additional Information Regarding Proposed Alternative for Relevant Condition ML17335A1042017-11-30030 November 2017 NRR E-mail Capture - Palisades Nuclear Plant - RAI Regarding Proposed Changes to Administrative Controls Section of the Technical Specifications for Permanently Defueled Condition (CAC MG0021; EPID L-2017-LLA-0266) ML17118A3342017-04-18018 April 2017 E-Mailed Request for Information Dated 04/18/2017 for Palisades Nuclear Power Station, Unit 1, Inservice Inspection - Part B Items (Exf) ML17118A3312017-04-18018 April 2017 E-Mailed Request for Information Dated 04/18/17 for Palisades Nuclear Power Station, Unit 1, Inservice Inspection - Part a Items ML17072A2752017-03-10010 March 2017 NRR E-mail Capture - Palisades Nuclear Plant - Final Request for Additional Information Regarding Relief Request No. RR 4-25 ML16238A0302016-08-29029 August 2016 Supplemental Information Needed for Acceptance of Requested Licensing Action Control Rod Drive Exercise Surveillance ML16130A0762016-05-11011 May 2016 Request for Additional Information Regarding the License Amendment Request for Implementation of an Alternative Repair Criterion on the Steam Generator Tubes ML16013A0642016-01-13013 January 2016 NRR E-mail Capture - Request for Additional Information Entergy CNRO-2015-00023 - Revision to Entergy Quality Assurance Program Manual (Fleet Submittal CAC Nos. MF7086-MF7097) ML15341A1662015-12-0707 December 2015 NRR E-mail Capture - Entergy Fleet RR-EN-15-1, Request for Additional Information (CACs MF6341-MF6349) ML15258A2432015-09-0101 September 2015 NRC Supplement to NRC Letter - Notification of NRC Inspection and Request for Information Dated May 1, 2015 - Palisades Nuclear Plant ML15149A2462015-05-28028 May 2015 Information Request to Support NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection (Mxg) ML15072A2542015-03-19019 March 2015 Request for Additional Information Regarding the License Amendment Request to Implement 10 CFR 50.61a CNRO-2015-00008, Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company2015-02-18018 February 2015 Responses to NRC Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company ML15022A1382015-01-22022 January 2015 E-Mail - Palisades Request for Information ML15016A1842015-01-20020 January 2015 Request for Additional Information Regarding the License Amendment Request to Implement 10 CFR 50.61a ML15012A3052015-01-15015 January 2015 Request for Additional Information Regarding the License Amendment Request for an Equivalent Margin Analysis Completed in Accordance with 10 CFR 50, Appendix G ML14318A4002014-12-17017 December 2014 Vermont Yankee Nuclear and Big Rock Point - Request for Additional Information Regarding Change in Corporate Form of Entergy Nuclear Holding Company (Tac Nos. MF3218 - MF3221) ML14157A3642014-06-0505 June 2014 CDBI Request for Information ML13353A0422013-12-16016 December 2013 NRR E-mail Capture - Request for Additional Information - Palisades - Proposed Revision to Palisades Site Emergency Plan (SEP) Emergency Response Organization (ERO) MF2321 ML13312A4232013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13051A7772013-02-19019 February 2013 Request for Additional Information, 2012 SG Inspection Report ML12314A4222012-11-0808 November 2012 ME8074 - Request for Additional Information Regarding Replacement of Spent Fuel Pool Region I Storage Racks ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML12206A4042012-07-24024 July 2012 Request for Additional Information (Revised) - Palisades - SFP Rerack LAR - ME8074 ML12206A3322012-07-19019 July 2012 E-mail Combined Request for Additional Information for Several Branches of NRR for the Submittal on Palisades re-sack LAR ML12121A7032012-04-27027 April 2012 Relief Request - Proposed Alternative - Use of Alternate ASME Code Case N-770-1 Baseline Examination - ME8492 ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML12068A3882012-04-0202 April 2012 Request for Additional Information Regarding License Renewal Commitment to Submit Alloy 600 Program ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic 2023-02-24
[Table view] |
Text
June 13, 2002 Mr. Douglas E. Cooper Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING RISK-INFORMED INSERVICE INSPECTION PROGRAM (TAC NO. MB4420)
Dear Mr. Cooper:
The NRC staff is reviewing your letter of March 1, 2002, requesting approval to implement a risk-informed inservice inspection (RI-ISI) program as an alternate to the American Society of Mechanical Engineers Code,Section XI, ISI requirements for piping at Palisades. We find that additional information, as identified in the enclosure, is needed to complete our review.
On the basis of discussions with R. Gerling of your organization, a mutually agreeable date for your response is within 60 days of the date of this letter.
If you have questions regarding this letter or if unexpected circumstances prevent you from meeting the response date, please contact me at (301) 415-3049 or by e-mail at dsh@nrc.gov.
Sincerely,
/RA/
Darl S. Hood, Senior Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
Request for Additional Information cc w/encl: See next page
June 13, 2002 Mr. Douglas E. Cooper Site Vice President Palisades Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES PLANT - REQUEST FOR ADDITIONAL INFORMATION REGARDING RISK-INFORMED INSERVICE INSPECTION PROGRAM (TAC NO. MB4420)
Dear Mr. Cooper:
The NRC staff is reviewing your letter of March 1, 2002, requesting approval to implement a risk-informed inservice inspection (RI-ISI) program as an alternate to the American Society of Mechanical Engineers Code,Section XI, ISI requirements for piping at Palisades. We find that additional information, as identified in the enclosure, is needed to complete our review.
On the basis of discussions with R. Gerling of your organization, a mutually agreeable date for your response is within 60 days of the date of this letter.
If you have questions regarding this letter or if unexpected circumstances prevent you from meeting the response date, please contact me at (301) 415-3049 or by e-mail at dsh@nrc.gov.
Sincerely,
/RA/
Darl S. Hood, Senior Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC MRubin PDIII-1 Reading PPatnaik LRaghavan SMalik DHood OGC RBouling ACRS TChan AVegel, RIII SDinsmore Adams: ML021650156 *Previously Concurred OFFICE PDIII-1/PM PDIII-1/LA EMCB/SC* SPSB/SC* PDIII-1/SC NAME DHood RBouling TChan MRubin LRaghavan DATE 6/12/02 6/12/02 06/12/02 06/12/02 6/12/02 OFFICIAL RECORD COPY
Palisades Plant cc:
Mr. Robert A. Fenech, Senior Vice President Michigan Department of Attorney General Nuclear, Fossil, and Hydro Operations Special Litigation Division Consumers Energy Company 630 Law Building 212 West Michigan Avenue P.O. Box 30212 Jackson, MI 49201 Lansing, MI 48909 Arunas T. Udrys, Esquire Mr. Roy A. Anderson Consumers Energy Company Executive Vice President and 212 West Michigan Avenue Chief Nuclear Officer Jackson, MI 49201 Nuclear Management Company, LLC 700 First Street Regional Administrator, Region III Hudson, WI 54016 U.S. Nuclear Regulatory Commission 801 Warrenville Road Laurie A. Lahti Lisle, IL 60532-4351 Manager - Licensing Nuclear Management Company, LLC Supervisor 27780 Blue Star Memorial Highway Covert Township Covert, MI 49043 P. O. Box 35 Covert, MI 49043 Steven T. Wawro Nuclear Asset Director Office of the Governor Consumers Energy Company P. O. Box 30013 Palisades Plant Lansing, MI 48909 27780 Blue Star Memorial Highway Covert, MI 49043 U.S. Nuclear Regulatory Commission Resident Inspectors Office Mr. John Paul Cowan Palisades Plant Senior Vice President 27782 Blue Star Memorial Highway Palisades Plant Covert, MI 49043 Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Drinking Water and Radiological Covert, MI 49043 Protection Division Michigan Department of Environmental Quality 3423 N. Martin Luther King Jr Blvd P. O. Box 30630 CPH Mailroom Lansing, MI 48909-8130 March 2002
REQUEST FOR ADDITIONAL INFORMATION RISK-INFORMED INSERVICE INSPECTION (RI-ISI) PROGRAM PALISADES PLANT
- 1. In the enclosure to the Nuclear Management Companys (the licensees) letter dated March 1, 2002, Table 3.7-1 and the associated notes indicate that, on the basis of their judgement, the expert panel moved 27 piping segments having risk-reduction-worth (RRW) values greater than 1.005 from the category of high safety significant (HSS) to low safety significant (LSS). The Nuclear Regulatory Commission (NRC) staff recognizes that Topical Report WCAP-14572, Revision 1-NP-A, allows the expert panel to use deterministic information to place segments with RRW values greater than 1.005 into the LSS category, but page 143 of the Topical Report states that HSS segments should not be classified lower by the expert panel without sufficient justification that is documented as part of the [RI-ISI] program. The expert panel should be focused primarily on adding piping to the higher classification. The expert panel apparently used three factors to move HSS segments to LSS: (1) non-proceduralized operator actions, (2) proceduralized operator actions, and (3) other considerations. Each of these is addressed below.
1.1 Operator Actions The notes in Table 3.7-1 indicate that some of the segments were placed in the LSS category based upon the expert panels judgment that the with operator action RRWs are credible and may be used as a basis for the segment classification, while the without operator action RRWs are inappropriate and discarded. The with and without operator action rankings are intended to reduce the impact of the highly uncertain human error evaluation on the categorization to facilitate preparation and review of short, template RI-ISI relief requests. Reducing the safety significant category based upon the expert panels judgement about the likelihood of successful operator actions weakens this important element in the approved process.
1.1.1 Non-Proceduralized Operator Actions The notes in Table 3.7-1 indicate that some of the operator actions credited by the expert panel to move HSS segments into the LSS category are not proceduralized actions. Crediting non-proceduralized operator actions is generally not acceptable in PRA analyses unless they are simple, skill-of-the-craft actions such as manually starting a standby pump following a failure of auto-start. When the expert panel moves a HSS segment into the LSS category based upon an operator action, the judgement on the incredibility of failure of the operator to perform the required action becomes the dominate contributor to the final disposition of the segment in RI-ISI, and thereby of the inspection requirements in the segment. The actions required to mitigate pipe ruptures must be taken in response to highly unusual and stressful events such as ENCLOSURE
loss-of-coolant accidents (LOCAs) outside containment. The selection of the with human action RRW as the only credible result assumes that the operator will always succeed. This assumption is inconsistent with acceptable probabilistic risk assessment (PRA) methodologies because it assumes the non-proceduralized action will always be successfully performed, and inconsistent with the approved RI-ISI methodology where the RRW values with and without operator action are used to reduce the sensitivity of the results on the highly uncertain human error evaluation. The uncertainties in the evaluation of these actions are further increased due to the non-proceduralized action.
Because discarding the "without operator action" RRW negates a major element of the approved methodology, and recognizing the greater than normal uncertainty associated with evaluating the likelihood of success of non-proceduralized actions, the NRC staff believes that sufficient justification does not exist for moving HSS segments to the LSS category based on the judgement of the expert panel about the incredibility of the without operator action RRW for non-proceduralized operator actions. Please identify all piping segments placed in the LSS category based upon crediting non-proceduralized actions, place the segments in the category specified in the Topical Report (e.g., HSS if any of the four RRWs is greater than 1.005), and modify your inspection location selection accordingly.
1.1.2 Proceduralized Operator Actions The notes in Table 3.7-1 indicate that some of the operator actions credited are proceduralized. Proceduralized actions must be more than credible before the without operator action RRWs may be discarded. The failure of proceduralized operator actions are not discarded (i.e., success assumed with a probability of 1.0) in PRA analyses. When the expert panel moves a HSS segment into the LSS category based upon an operator action, the judgement regarding the likelihood of the action becomes the dominate contributor to the final disposition of the segment in the RI-ISI.
Justification and documentation of each of these actions must be of sufficient quality to support this judgement as the final arbitrator of safety significance. The justification for each action should include:
- Identification of the procedure containing the required action.
- The indications available to the operators to identify the specific action.
- The location of the action.
- The time available to perform the action.
- The time required to perform the action.
- Identification and characterization of the performance shaping factors that might influence the ability of the operators to accomplish the task.
- An integrated discussion of the above information justifying that the failure of the operator to perform the action is of such a low likelihood that the without operator action RRW may be discarded.
Please identify all piping segments placed in the LSS category based upon crediting proceduralized actions and provide a copy of the justification and documentation developed by the expert panel for each segment. If the original documentation developed by the expert panel does not include the information discussed above, please provide a copy of the original documentation that was developed, and also provide the requested information.
1.2 Other Considerations The notes in Table 3.7-1 indicate that a number of piping segments were moved from the HSS category to the LSS category by the expert panel based upon considerations other than the potential for operator actions. The justification should include:
- The specific weakness in the quantitative evaluation that causes the segment to be inappropriately placed in HSS.
- A discussion of the more appropriate assumption that corrects the weakness.
- A discussion of the magnitude of the impact of the more appropriate assumption that supports moving the HSS segment into LSS.
For example, Note 7 states that there are no active failure mechanism in several pressurizer (PRZ) segments and that they would be subjected to the lowest temperature of all PCS [primary coolant system]/PRZ segments. If the environment in these segments is so benign, why were they HSS according to the RRW values? What is the inappropriate assumption that lead to the HSS categorization? What is the more appropriate assumption and how much does it influence the consequence and/or the frequency of the segments failure? Please identify each of these segments and provide a copy of the justification developed and documented by the expert panel to move the segment from the HSS to the LSS category. If the original documentation developed by the expert panel does not include the information discussed above, please provide the original documentation that was developed, and also provide the requested information.
- 2. In the NRC Staff Evaluation Report (SER) on the Palisades Individual Plant Examination (IPE), dated February 7, 1996, the NRC staff concluded that there were limitations in the human reliability assessment (HRA) approach used by the licensee that could limit the Palisades IPE in future regulatory uses. These limitations include:
- Treatment of pre-initiator and post-initiator errors using the Technique for Human Error Rate Prediction which limits the degree of insights about plant-specific factors influencing human performance.
- Use of screening values that are significantly lower than values typically used for post-initiator actions and not including dependencies in the initial quantification.
- Treatment of diagnosis for post-initiator actions, which is not consistent with most nuclear power plant HRAs.
- In one of the two post-initiator actions that was quantified using the Accident Sequence Evaluation Program model, the calculated human error probability (HEP) was the lowest value of all post-initiator HEPs.
Please explain how these limitations in the HRA have been addressed during the evaluations performed in support of this relief request.
- 3. In the enclosure to your letter dated March 1, 2002, Section 1.2, PSA Quality, states that the Combustion Engineering Owners Group peer review performed in May 2000 found a weakness in performing a thorough dependancy analysis for the operator actions modeled in the PSA. You state that the weakness related to the appropriateness of the magnitude of human error probabilities used in the model given the possibility that dependent operator actions may not have been adequately considered. In general, omitting the dependencies between multiple operator actions yields lower human error rates for a sequence of actions. Your reported investigation that observed a slight increase in risk after including the dependencies in a number of multiple actions is consistent with this general observation. However, on page 2, you continued that you chose not to remove further some of the conservatism by assessing more human error combinations...[because]...additional evaluation is not considered necessary due to the already small increase in [core damage frequency] CDF.
Including dependencies between human actions does not remove conservatism -- it removes non-conservatism. The small increase in CDF observed from the completed evaluation does not alone support the conclusion that further evaluation would not yield larger increases.
Please explain how the incomplete review of dependencies could affect the evaluations performed in support of this relief request.
- 4. On page 3 of the enclosure to your letter dated March 1, 2002, in the section on Deviations, you state that four piping segments in the safety injection/refueling water tank and containment sump system are in a category of thin-walled piping and have attributes of low pressure, low temperature, low design stress, and low fatigue stress, that are not appropriate for use with the Westinghouse statistical (Perdue) model.
These attributes do not appear to be outside the bounds of applicability of the Perdue model listed on page 178 of WCAP-14572. You further state that a 7.5-percent sample was selected from each of the segments as an alternative to running the Perdue model.
Please explain why the Perdue model is not applicable to these four piping segments.
- 5. In Section 3.1 on page 4 of the enclosure to your letter dated March 1, 2002, you state that the reactor cavity flood system was excluded from system scope consideration in the RI-ISI program. What is the basis stated in the documentation maintained at the site for excluding this system?
- 6. Table 5-1 of the enclosure to your letter dated March 1, 2002, shows that, for the primary coolant system, there are 5 volumetric examinations in the 29 HSS piping segments. Please explain why only 5 volumetric examinations are performed.
- 7. Will the RI-ISI program be updated every 10 years and submitted to the NRC consistent with the current ASME Code,Section XI, requirements?
- 8. Under what conditions would the RI-ISI program be resubmitted to the NRC before the end of any 10-year interval?
- 9. Since 66 percent of the scheduled examinations under the RI-ISI program are being examined by the end of the third inspection interval, how will the welds be selected in terms of risk category?