ML051100276
| ML051100276 | |
| Person / Time | |
|---|---|
| Site: | Brunswick, Crystal River  |
| Issue date: | 03/01/2005 |
| From: | Mozafari B NRC/NRR/DLPM/LPD2 |
| To: | Powell S - No Known Affiliation |
| References | |
| TAC MC5631 | |
| Download: ML051100276 (7) | |
Text
Brenda Mozafari - Fwd: Draft RAls for Crystal River Page 1 From:
Brenda Mozafari To:
sidney.powell @ pgnmail.com Date:
03/01/2005 4:24:22 PM
Subject:
Fwd: Draft RAls for Crystal River As we discussed. This may take some time to digest before we have a call.
Brenda L. Mozafari Senior Project Manager Brunswick Units 1 & 2 and Crystal River Unit 3 0-8H21 301-415-2020
I c:\\temp\\GW}OOOO1.TMP Page 1 I I c:\\temp\\GW)00001.TMP Page 1 l Mail Envelope Properties (4224DD86.A07: 11: 21140)
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Fwd: Draft RAIs for Crystal River 03/01/2005 4:24:22 PM Brenda Mozafari BLM@nrc.gov Recipients pgnmail.com PM Action Transferred Date & Time 03/01/2005 4:25:02 SIDNEY.POWELL (sidney.powell@pgnmail.com)
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Brenda Mozafari - Draft RAIs for Crystal River Page 1 From:
To:
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Martin Stutzke Brenda Mozafari 03/01/2005 3:22:25 PM Draft RAIs for Crystal River Attached.
Marty M.A.Stutzke NRR/DSSA/SPSB (301) 415-4105
Brenda Mozafari - MC5631_RALRO.wpd Page 1 I I Brenda Mozafari - MC5631-RAI-R0.wpd Page 1 l MEMORANDUM TO: Michael L. Marshall, Jr., Chief Project Directorate, 11-2 Division of Licensing Project Management FROM:
Mark P. Rubin, Chief Safety Program Section Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING CRYSTAL RIVER UNIT 3 LICENSE AMENDMENT REQUEST #289 FOR ONE-TIME INCREASES IN VARIOUS ALLOWED OUTAGE TIMES TO SUPPORT DECAY HEAT SEAWATER PUMP RWP-3B REFURBISHMENT (TAC MC5631)
The Probabilistic Safety Assessment Branch (SPSB) has reviewed Progress Enery Florida's risk assessment submitted in support of its request to increase, on a one-time basis, the allowed outage times (AOTs) in the Emergency Core Cooling System, Reactor Building Spray and Containment Cooling System, Decay Heat Closed Cycle Cooling Water System, and the Decay Heat Seawater System to support online refurbishment of Decay Heat Seawater Pump RWP-3B. SPSB has identified areas where additional information is needed to complete its review. The Request for Additional Information is provided as an attachment to this memorandum.
Attachment:
As stated.
CONTACT: Martin Stutzke, NRR/DSSA/SPSB 415-4105
I Brenda Mozafari - MC5631RALRO.wpd Page 2 I I Brenda Mozafari - MC5631-RAI-R0.wpd Page 2 l MEMORANDUM TO: Michael L. Marshall, Jr., Chief Project Directorate, 11-2 Division of Licensing Project Management FROM:
Mark P. Rubin, Chief Safety Program Section Probabilistic Safety Assessment Branch Division of Systems Safety and Analysis
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING CRYSTAL RIVER UNIT 3 LICENSE AMENDMENT REQUEST #289 FOR ONE-TIME INCREASES IN VARIOUS ALLOWED OUTAGE TIMES TO SUPPORT DECAY HEAT SEAWATER PUMP RWP-3B REFURBISHMENT (TAC MC5631)
The Probabilistic Safety Assessment Branch (SPSB) has reviewed Progress Enery Florida's risk assessment submitted in support of its request to increase, on a one-time basis, the allowed outage times (AOTs) in the Emergency Core Cooling System, Reactor Building Spray and Containment Cooling System, Decay Heat Closed Cycle Cooling Water System, and the Decay Heat Seawater System to support online refurbishment of Decay Heat Seawater Pump RWP-3B. SPSB has identified areas where additional information is needed to complete its review. The Request for Additional Information is provided as an attachment to this memorandum.
Attachment:
As stated.
CONTACT: Martin Stutzke, NRR/DSSANSPSB 415-4105 DISTRIBUTION:
File Center BMozafari SPBS R/F MStutzke ADrozd ACCESSION #:ML G:\\SPSB\\Stutzke\\MC5631 RAI-RO.wpd NRR-106 OFFICE SPSB:DSSA SC:SPSB:DSSA NAME MAStutzke MPRubin DATE 3/
/05 3/
/05 OFFICIAL RECORD COPY
I Brenda Mozafari - MC5631-RAI-RO.wpd Page 3 Brnd Moafr
.C61RARp Pag 3 SPSB REQUEST FOR ADDITIONAL INFORMATION REGARDING REGARDING CRYSTAL RIVER UNIT 3 LICENSE AMENDMENT REQUEST #289 FOR ONE-TIME INCREASES IN VARIOUS ALLOWED OUTAGE TIMES TO SUPPORT DECAY HEAT SEAWATER PUMP RWP-3B REFURBISHMENT (TAC MC5631)
- 1.
In both Attachment A (Page 12, first paragraph) and Attachment E (Calculation No.
P-05-0001, Table 1, Note 2), it is stated that the PRA evaluation of the proposed license amendment assumed no maintenance will be scheduled on risk-sensitive equipment beyond that required for the refurbishment of RWP-3B (Nuclear Services and Decay Heat Seawater System, Decay Heat System, Decay Heat Closed Cycle Cooling Water System, Nuclear Services Closed Cycle Cooling Water, Emergency Diesel Generators, Emergency Feedwater System, Emergency Feedwater Initiation and Control System, and the Auxiliary Feedwater Pump). However, there is no regulatory commitment in Attachment F to forbid or limit maintenance on risk-sensitive equipment during the refurbishment of RWP-3B. Please resolve this apparent contradiction.
- 2.
On Page 12 of Attachment A, it is stated that "...the bounding risk due to internal events for this activity [the proposed license amendment] is estimated with a Change in Core Damage Frequency (ACDF) of 1.5E-6 and a sensitivity based on fire risk add about 2.72E-6." However, Attachment E (Calculation No. P-05-0001, Table 1) indicates that the value "1.5E-6" is the incremental conditional core-damage probability (ICCDP) for internal events. Attachment E (Calculation No. P-05-0001, Section 5.2) also indicates that the value "2.72E-6" is an estimate of the ICCDP due to internal fires. Please explain what the values "1.5E-6" and "2.72E-6" signify (ACDF or ICCDP).
Comment: If these values are ICCDPs, then it is not appropriate to compare them to the risk acceptance guidelines in RG 1.174 as was done on Page 12 of Attachment A; rather, they should be compared to the risk acceptance guidelines in RG 1.177.
- 3.
On Page 12 of Attachment A, only one type risk metric was provided (apparently the internal events and internal fires ICCDP values associated with the proposed license amendment). Attachment E (Calculation No. P-05-0001, Table 1) also provides the incremental conditional large early release probability (ICLERP) for internal events.
Please provide either the ICLERP associated with internal fires or a qualitative assessment of the proposed license amendment's impact on the likelihood of large early release following internal fires. In addition, in accordance with RG 1.177, Section 2.4, "Acceptance Guidelines for TS Changes," please provide the risk metrics discussed in RG 1.174 (total ACDF versus total CDF, and total ALERF versus total LERF) associated with the proposed license amendment.
- 4.
Attachment A, Page 12 and Attachment F indicate that compliance procedure CP-253, "Power Operation Risk Assessment and Management" will be performed. Either provide CP-253 or summarize its contents, indicating how it satisfies the guidance in RG 1.177, Section 2.3, "Tier 3: Risk-informed Configuration Risk Management" and RG 1.177, Section 2.3.7, "Contemporaneous Configuration Control." The following questions should be addressed:
- a.
Is CP-253 intended to satisfy the requirements of 10 CFR 50.65, i.e., is CP-253 the mechanism for complying with Paragraph (a)(4) of the Maintenance Rule?
I Brenda Mozafari - MC5631-RAI-RO.wpd Page 4 I Brenda Mozafari - MC5631_RAIRO.wpd Page 4 I
- b.
Does CP-253 relate to Chapter 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants?' If so, describe any differences between CP-253 and NUMARC 93-01, Chapter 11.
- c.
In CP-253, what provisions are provided for assessing the need for additional actions after the discovery of additional equipment-out-of-service conditions while RWP-3B is being refurbished? What criteria or guidelines are provided to help decide whether or not additional actions are either needed or not needed?
Who makes the decision (the operating crew, plant management, utility management)? Does CP-253 impose any timeliness limits on reaching the decision about additional actions?
- d.
What tools or techniques are used to help assess the risk of various plant configurations, e.g., real-time risk monitoring software. What quality assurance activities have been taken to ensure that these tools and techniques are adequate, e.g., periodic updates, reviews, etc.