ML051220131
| ML051220131 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/18/2005 |
| From: | Palla R NRC/NRR/ADPT |
| To: | Emch R NRC/NRR/DRIP/RLEP |
| References | |
| Download: ML051220131 (12) | |
Text
Richard Emch - Re: Fwd: SAMA RAI 8 Page 1 ill Richard Emch - Re: Fwd: SAMA RAI 8 Page 1 II From:
Robert Palla To:
Richard Emch Date:
Mon, Apr 18, 2005 3:45 PM
Subject:
Re: Fwd: SAMA RAI 8 Rich - the draft response addresses only the 7 SAMAs that were found to be potentially cost-benef icial in the baseline analysis reported in the ER. That analysis was based on 7 percent discount rate, double replacement power costs (assuming loss of the second unit as well as the unit experiencing the accident),
and no consideration of uncertainties.
Impact of Considering a 3-Percent Discount Rate If the results of the 3-percent discount case are considered (as we have been doing in the more recent reviews, and expect to do for Brunswick), 4 additional SAMAs become potentially cost-benef icial beyond those found to be potentially cost-beneficial in the baseline analysis reported in the ER - SAMAs 13, 16, 18, and 34.
Alternatively, if the licensee adopts the response to RAI 7b as their new base case (based on 3-percent discount rate and replacement power costs for one unit), the GB SAMAs are 1, 13, 15, 17, 19, 25, 29, and 36 (i.e., only SAMA 13 is added the set of potentially cost beneficial SAMAs identified in the baseline analysis reported in the ER).
On page F-85 of the ER it is stated that "Implementation of these SAMAs should be considered.' Thus, we will need to have some explanationfiustification for why these SAMAs should not also be pursued. We have not made a final decision but will likely adopt the alternative case with replacement power costs for one unit as our base case.
Impact of Considering Uncertainties If the results of the uncertainty case are considered (as we have been doing in essentially all of the reviews, and expect to do for Brunswick), 8 additional SAMAs become potentially cost-beneficial beyond those found to be potentially cost-beneficial in the baseline analysis reported in the ER - SAMAs 6, 13,16, 18, 30, 31, 32 and 34. (This is based on the draft response to RAI 6b.) On page F-88 of the ER it is stated that 'the use of the 95th percentile PSA results is not considered to provide the most realistic assessment of the cost effectiveness of a SAMA." Thus, the licensee makes no statement as they did for the four SAMAs for the baseline case at 3-percent.
Although the licensee made no statement commiting to further evaluate those SAMAs that could become cost-beneficial based on uncertainties, I think that in order to prepare a defensible SER input (that will go thru concurrence without some late snafu in which we are second-guessed re: the 8 additional SAMAs) the licensee should expand the discussion in the RAI response to address all of the above-mentioned SAMAs. This may not sit well with the licensee, but I would rather ask for this information now rather than later.
Areas Where Additional Clarificationlinformation Would be Useful
- 1. It is is that it is not clear what "these SAMAs" refers to in the sentence: "The reduction in averted cost-risk for these SAMAs indicated that the proposed changes impact some of the same sequences addressed by the installation of a portable DC generator." Presumably it is SAMAs 17, 19 and 36. This should be clarified.
- 2. Presumably the last paragraph means that SAMAs 1, 15, 25, and 29 will be further evaluated. If SAMA 1 is not implemented then SAMAs 17, 19 and 36 might be cost beneficial. Progress should clearly state the status of SAMA 1 as they did in the telecon.
- 3. Additional information regarding the evaluation (of the impact of implementing SAMA 1 on other
Richard Emch - Re: Fwd: SAMA RAI 8 Page 2 potentially cost-beneficial SAMAs) should be provided as we will be relying on this in dispositioning the SAMAs. Was it an evalaution provided to the PRG prior to their decision, or a follow-up evaluation in response to NRC RAls? What was assumed regarding the implementation of SAMA 1 (e.g., single unit versus dual unit implementation) and effectiveness of SAMA 1 ? What were the net benefits for the remaining potentially cost-beneficial SAMAs after anticipated implementation of SAMA 1 ?
Bob P
>>> Richard Emch 04/18/05 09:35AM >>>
- Bob, Jan Kozyra at CP&L (Brunswick) is anxiously awaiting feedback on the attached draft response to SAMA 8.
Rich CC:
Bob Schmidt; kim green
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Re: Fwd: SAMA RAI 8 Mon, Apr 18, 2005 3:45 PM Robert Palla RLP3 @nrc.gov Recipients adelphia.net erschmidt CC (Bob Schmidt) islinc.com kim CC (kim green) nrc.gov OWGWPO02.HQGWDO01 RLE (Richard Emch)
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I Richard Emch
- Re: Fwd: SAM Paqe 1 I Richard Emch - Re: Fwd: SAMA RAI 8-Page 1 Ig From:
Kim Green <kimr@islinc.com>
To:
'Robert Palla" <RLP3@nrc.gov>
Date:
Mon, Apr 18, 2005 1:56 PM
Subject:
- Bob, Here are my thoughts on the draft response:
The seven they've identified as potentially cost beneficial are based on 7-percent, double replacement power cost, no uncertainty.
If they consider 3-percent, they should add 13, 16, 18, and 34. Their statement on page F-85 says, "Implementation of these SAMAs should be considered."
If they consider uncertainties, they should add 6,11, 21, 30, 31, and
- 32. Their statement on page F-88 says, 'However, the use of the 95th percentile PSA results is not considered to provide the most realistic assessment of the cost effectiveness of a SAMA." They make no statement as they did for the four SAMAs for the 3-percent case.
At the very least, they need to have a story for the 3-percent SAMAs.
OR, if you consider the response to RAI 7b, which is 3-percent, RPC for one unit, the CB SAMAs are 1, 13, 15,17, 19, 25, 29, and 36 (they picked up SAMA 13).
But it's up to you about the uncertainties. And dont forget we mentioned the AOSC factor to that guy from ERIN. So, if push comes to shove...
Kim At 09:42 AM 4/18/2005, you wrote:
>Rich - I just returned after a week out of office. I will try to get you
>some feedback (with input from Kim and Bob Schmidt) hopefully by later
>this morning.
>Kim, Bob - can you pis take a look at the attached draft response and
> >>> Richard Emch 04/18/05 09:35AM >>>
>Bob,
>Jan Kozyra at CP&L (Brunswick) is anxiously awaiting feedback on the
>attached draft response to SAMA 8.
Rich
>Date: Fri, 15 Apr 2005 11:41:14 -0400
>From: "Richard Emch" <RLE~nrc.gov>
>To: "Robert Palla" <RLP3@nrc.gov>
Subject:
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>From: "Kozyra, Jan" <jan.kozyra@pgnmail.com>
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>FILETIME=[D836C380:01 C540F5]
>1 am forwarding a draft of our revised response to SAMA RAI 8. Any comments?
><<SAMA 8 Draft Response R1 4 13 05.doc>>
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Re: Fwd: SAMA RAI 8 Mon, Apr 18, 2005 1:54 PM Kim Green <kim~islinc.com>
kim @islinc.com Recipients nrc.gov TWVGWPO01.HQG WDOO01 RLP3 (Robert Palla)
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i Richard Emch - Re: Fwd: SAMA RAI 8 Page 1 11 Richard Emch - Re: Fwd: SAMA RAI 8 Page 1 From:
'Bob Schmidt' <erschmidt @adelphia.net>
To:
"Robert Palla"I <RLP3@nrc.gov>
Date:
Mon, Apr 18, 2005 1 1:1 0 AM
Subject:
Re: Fwd: SAMA RAI 8 My comments are:
- 1. It is isthat it isnot clear what "these SAMAs" refers to inthe sentence "The reduction in averted cost-risk for these SAMAs indicated that the proposed changes impact some of the same sequences addressed by the installation of a portable DC generator."
Presumably it is SAMAs 17, 19 and 36.
- 2. Presumably the last paragraph means that SAMAs 1, 15, 25, and 29 will be further evaluated. If SAMA 1 is not implemented then SAMAs 17, 19 and 36 might be cost beneficial. They should clearly state the status of SAMA 1 as they did in the telecon.
Bob Schmidt 301-473-7010
Original Message ---
From: "Robert Palla" <RLP3@nrc.gov>
To: "Richard Emrch" <RLE@ nrc.gov>
Cc: <erschmidt @adelphia.net>; <kim @islinc.com>
Sent: Monday, April 18, 2005 9:42 AM
Subject:
Re: Fwd: SAMA RAI 8 Rich - I just returned after a week out of office. I will try to get you some feedback (with input from Kim and Bob Schmidt) hopefully by later this morning.
Kim, Bob - can you pls take a look at the attached draft response and
>>> Richard Emch 04/18/05 09:35AM >>>>
- Bob, Jan Kozyra at CP&L (Brunswick) is anxiously awaiting feedback on the attached draft response to SAMA 8.
Rich CC:
CC:
<kim ©islinc.com>
i Richard Emch - Fwd: SAMA RAI 8 Page 1 1i I
--. I -, I From:
To:
Date:
Subject:
Richard Emch Robert Palla Mon. Apr 18, 2005 9:35 AM Fwd: SAMA RAI 8
- Bob, Jan Kozyra at CP&L (Brunswick) is anxiously awaiting feedback on the attached draft response to SAMA 8.
Rich
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Fwd: SAMA RAI 8 Mon, Apr 18, 2005 9:35 AM Richard Emch RLE@nrc.gov Recipients nrc.gov TWGWPOOI.HQGWDO0I RLP3 (Robert Palla)
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Richard Emch - SAMA RAI 8 Page 1 From:
NKozyra, Jan" <jan.kozyraGpgnmail.com>
To:
'Richard Emch" <RLE~nrc.gov>
Date:
Thu, Apr 14, 2005 9:29 AM
Subject:
SAMA RAI 8 I am forwarding a draft of our revised response to SAMA RAI 8. Any comments?
<<SAMA 8 Draft Response RI 4 13 05.doc>>
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SAMA RAI 8 Thu, Apr 14, 2005 9:28 AM "Kozyra, Jan" <jan.kozyra@pgnmail.com>
jan.kozyra@pgnmail.com Recipients nrc.gov OWGWPO02.HQGWDO01 RLE (Richard Emch)
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RichaIrd Emch - SAMA 8 Draft Response 131 4 13 05.doc Paqe 1 I Richard Emch - SAMA 8 Draft Response Ri 4 13 05.doc Pacie 1 DRAFT SAMA 8 Draft Response SAMA 8 The ER states that several cost-beneficial SAMAs exist that could be examined further. However, it is not clear which SAMAs will be further reviewed. Identify (list) which SAMAs Progress Energy plans to further evaluate, and describe the anticipated process for performing such an evaluation, e.g., the plant's action tracking system, or corrective action program.
Response
The ER identified seven cost-beneficial SAMAs as summarized below:
SAMA 1 - Portable generator of DC power SAMA 15 - Diverse EDG HVAC logic SAMA 17 - Alternate feeds to panels supplied only by DC bus 2A-1 SAMA 19 - Provide an alternate means of supplying the instrument air header SAMA 25 - Proceduralize battery charger high voltage shutdown circuit inhibit SAMA 29 - Portable EDG fuel oil transfer pump SAMA 36 - Use fire water as a back up for containment spray None of these SAMAs are age related.
All cost-beneficial SAMAs have been reviewed by the BSEP Plant Review Group (PRG). The PRG is responsible for oversight of plant projects. The PRG recognized that the high positive impact of implementing SAMA 1 could impact the cost-effectiveness of the remaining cost effective SAMAs. An evaluation was performed that found that, if SAMA 1 was implemented, SAMA 15, 25, and 29 would remain cost effective and SAMA 17, 19, and 36 would not. The reduction in averted cost-risk for these SAMAs indicated that the proposed changes impact some of the same sequences addressed by the installation of a portable DC generator. As certain failures are already reduced by SAMA 1, further reduction of those failures does not greatly impact the results.
Based on this evaluation, the PRG has directed that an assessment be performed to make recommendations for further evaluation of the cost-effective SAMAs. Completion of this evaluation is being tracked in the site's action tracking system.
DRAMT