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MONTHYEARML0719400092007-07-18018 July 2007 Request for Additional Information Regarding License Amendment Request No. 295 Rev. 0, Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times Project stage: RAI 3F0907-03, License Amendment Request 295, Revision 0: Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times Response to Request for Additional Information2007-09-0404 September 2007 License Amendment Request #295, Revision 0: Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times Response to Request for Additional Information Project stage: Response to RAI ML0724704962007-09-0606 September 2007 Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing (Tac No. MD5241) Project stage: Acceptance Review 3F0907-07, License Amendment Request 295, Revision 0: Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times Response to Request for Additional Information2007-09-13013 September 2007 License Amendment Request #295, Revision 0: Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times Response to Request for Additional Information Project stage: Response to RAI 3F0208-01, License Amendment Request 295, Revision 0: Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times - Response to Request for Additional Information2008-02-25025 February 2008 License Amendment Request #295, Revision 0: Extension of Allowed Outage Time to Seven Days and Elimination of Second Completion Times - Response to Request for Additional Information Project stage: Response to RAI 2007-09-04
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Category:Letter
MONTHYEARML23342A0942024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan ML23354A0632023-12-22022 December 2023 Cover Letter - Crystal River License Termination Plan Request for Additional Information ML23345A1882023-12-0606 December 2023 Fws to NRC Crystal River Species List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected by Your Proposed Project ML23320A2592023-11-17017 November 2023 STC-23 077 Notification of the Crystal River Unit 3 Generating Plant License Termination Plan Public Meeting and Federal Register Notice ML23313A1322023-11-15015 November 2023 Request for Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant ML23310A0712023-11-0707 November 2023 Audit Plan Cover Letter - Crystal River Unit 3 Nuclear Generating Plant LTP ML23187A1112023-07-25025 July 2023 Acceptance of Requested Licensing Action License Request to Add License Condition to Include License Termination Plan Requirements ML23107A2722023-06-13013 June 2023 Letter Transmitting NRC Survey Results for East Settling Pond ML23160A2962023-06-0909 June 2023 Response to Crystal River, Unit 3 Supplemental Information Needed for Acceptance on the Application for a License Amendment Regarding Approval of the License Termination Plan ML23107A2732023-06-0707 June 2023 Orise Independent Survey Report Dcn 5366-SR-01-0 IR 05000302/20220032023-05-25025 May 2023 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2022003 ML23103A1902023-04-19019 April 2023 Request for Supplemental Information Cover Letter ML23058A2532023-03-22022 March 2023 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River, Unit 3 - NRC Inspection Report No. 05000302/2022003 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 ML22265A0192022-09-26026 September 2022 Nuclear Generating Plant - U.S. Nuclear Regulatory Commission'S Analysis of ADP CR3, Llc'S Decommissioning Funding Status Report (License No. DPR-72, Docket Nos. 50-302 and 72-1035) IR 05000302/20220022022-08-0909 August 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report 05000302/2022002 IR 05000302/20220012022-05-0303 May 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report 05000302/2022001 ML22116A1752022-04-27027 April 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3- Independent Spent Fuel Storage Installation Security Inspection Report 07201035/2022401 ML22105A3992022-04-18018 April 2022 Nuclear Generating Plant - Change in NRC Project Manager ML22011A1362022-01-31031 January 2022 Independent Spent Fuel Storage Installation Security Inspection Plan IR 05000302/20210042022-01-24024 January 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2021004 ML22024A2142022-01-24024 January 2022 Nuclear Generating Plant - NMFS NRC Letter - Crystal River Energy Complex Biological Opinion Status (License No. DPR-72, Docket Nos. 50-302 and 72-1035) ML21351A0052021-12-20020 December 2021 NRC Analysis of ADP CR3, LLC Decommissioning Funding Status Report for the Crystal River Unit 3 Nuclear Generating Plant (License No. DPR-72, Docket Nos. 50-302 and 72-1035) ML21322A2702021-11-24024 November 2021 Nuclear Generating Plant - Issuance of Amendment No. 260 Approving the Independent Spent Fuel Storage Installation Only Security Plan, Rev 3 IR 05000302/20210032021-11-0909 November 2021 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report Nos. 05000302/2021003 and 07201035/2021001 ML21288A4292021-10-18018 October 2021 Letter - Crystal River Unit 3 Nuclear Generating Plant - Correction to Safety Evaluation Related to the Issuance of Amendment No. 259 Approving the Independent Spent Fuel Storage Installation Only Emergency Plan ML21238A0952021-10-13013 October 2021 Issuance of Amendment No. 259 Approving the ISFSI-Only Emergency Plan, Revision Draft a IR 05000302/20210012021-08-12012 August 2021 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report Nos. 05000302/2021001 and 05000302/2021002 ML21182A1032021-07-0606 July 2021 Request for Additional Information (RAI) Related to the ISFSI-Only Emergency Plan ML21159A0422021-06-28028 June 2021 VY and CR Indirect License Transfer Package ML21060B4142021-04-12012 April 2021 U.S. Nuclear Regulatory Commission Analysis of Duke Energy Florida, Llc'S Initial Decommissioning Funding Plan for the Crystal River Independent Spent Fuel Storage Installation ML21028A5912021-03-0202 March 2021 Letter to Reid Forwarding Exemption from 10 CFR Part 20, Appendix G, Section Iii.E ML21055A7832021-02-25025 February 2021 Letter to Reid, Change in NRC Staff Project Management for Crystal River Unit 3 Nuclear Generating Plant ML21012A3142021-01-13013 January 2021 Independent Spent Fuel Storage Installation Security Inspection Plan IR 05000302/20200012020-11-19019 November 2020 NRC Inspection Report No. 05000302/2020001, Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3, Crystal River, Florida ML20269A2922020-10-0707 October 2020 NRC Form 311 QA Program Approval Revision 10 Related to Crystal River 3 ML20101G5822020-04-10010 April 2020 CR-3 License Transfer SE Corrected Cover Letter ML20069A0232020-04-0101 April 2020 Order Approving Transfer of Licensed Authority from Duke Energy Florida, LLC, to ADP CR3, LLC, and Draft Conforming Administrative License Amendment ML20050D0142020-02-19019 February 2020 NRC Independent Spent Fuel Storage Installation Inspection Report No. 07201035/2020001, Duke Energy Florida, LLC, Crystal River Unit 3, Crystal River, Florida ML20050F7702020-02-14014 February 2020 30-Day Notice of Payment from the City of Tallahassee Trust Fund Non-Qualified Nuclear Decommissioning Trust Fund for Crystal River Unit 3 ML20015A5672020-01-15015 January 2020 Independent Spent Fuel Storage Installation Security Inspection Plan ML20009D0432020-01-10010 January 2020 Letter to Hobbs, Crystal River Unit 3 Nuclear Generating Plant - Corrected Safety Evaluation for Approval of Partial Site Release for Facility Operating License No. DPR-72 ML19339G5092020-01-0202 January 2020 Letter to Hobbs, Crystal River Unit 3 Nuclear Generating Plant - Approval of Partial Site Release for Facility Operating License No. DPR-72 ML19343A8252019-12-0606 December 2019 Letter from Erika Bailey, Oak Ridge Institute for Science and Education, to John Hickman, NRC, Forwarding Independent Confirmatory Survey Summary and Results for the 3,854-Acre Area Partial Site Release at the Crystal River Energy Complex IR 05000302/20190022019-11-20020 November 2019 NRC Inspection Report No. 05000302/2019002 and Independent Spent Fuel Storage Installation Inspection Report No. 07201035/2019002, Duke Energy Florida, LLC, Crystal River Unit 3, Crystal River, Florida ML19317D0932019-10-25025 October 2019 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance - Engine Systems, Inc. Report No. 10 CFR21-0127, Rev. 0, Emd Fuel Injectors - Seized Plunger and Bushing ML19261A0702019-09-19019 September 2019 VEGP U3 Proficiency Watches Prior to Fuel Load ML19177A0802019-06-26026 June 2019 Nuclear Generating Plant (CR-3) - Notification of Revised Post-Shutdown Decommissioning Activities Report (Revised PSDAR) ML19170A1942019-06-14014 June 2019 Application for Order Consenting to Direct Transfer of Control of Licenses and Approving Conforming License Amendment ML19129A1402019-05-15015 May 2019 Letter to Hobbs, Correction to Amendment No. 257 Approving Independent Spent Fuel Storage Installation (ISFSI)-Only Emergency Plan, Revision 1 2024-01-09
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23354A0632023-12-22022 December 2023 Cover Letter - Crystal River License Termination Plan Request for Additional Information ML23354A0642023-12-22022 December 2023 Enclosure - Crystal River License Termination Plan Request for Additional Information ML23313A1322023-11-15015 November 2023 Request for Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant ML23103A1922023-04-19019 April 2023 Request for Supplemental Information Enclosure ML21182A1032021-07-0606 July 2021 Request for Additional Information (RAI) Related to the ISFSI-Only Emergency Plan ML16032A1772016-02-0404 February 2016 J. Hickman, NRC, Letter to T. Hobbs, Crystal River 3, Request for Additional Information for Emergency Plan Change ML15026A4162015-02-0202 February 2015 Request for Additional Information Regarding the 10 CFR 50.54(p) Changes to the Security Plans ML14274A1392015-01-0808 January 2015 Request for Additional Information, License Amendment Request to Revise Technical Specifications and License Conditions to Create Permanently Defueled Technical Specifications ML14133A5032014-05-14014 May 2014 Correction, Request for Additional Information on the Post Shutdown Decommissioning Activities Report ML14104A0392014-04-28028 April 2014 Request for Additional Information on the Post Shutdown Decommissioning Activities Report ML13175A2152013-06-28028 June 2013 Request for Additional Information Regarding Request to Rescind Fukushima-Related Orders ML13018A3072013-02-0101 February 2013 Request for Additional Information for Extended Power Uprate License Amendment Request ML12355A6592012-12-21021 December 2012 Nuclear Generating Plant - RAI 9.3 of the Near-Term Task Force Fukushima Dai-ichi.. ML12333A0892012-12-19019 December 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12310A2912012-11-15015 November 2012 Request for Additional Information for Changes to Security Plan ML12240A0152012-08-28028 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12219A1912012-08-16016 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12213A3032012-08-0303 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request (Srxb) ML12202A0602012-08-0202 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12125A1622012-08-0101 August 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request ML12194A4172012-07-17017 July 2012 Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request ML12174A2922012-07-0505 July 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12171A3472012-07-0505 July 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12102A0442012-05-0404 May 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML12052A1302012-03-0202 March 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12003A2172012-02-0808 February 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request ML11326A2312011-12-0707 December 2011 Request for Additional Information for Extended Power Uprate License Amendment Request ML11308A6592011-11-17017 November 2011 Generating Plant - Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, Mitigating Strategies ML11301A1142011-11-0808 November 2011 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1128602942011-10-12012 October 2011 IR 05000302-11-005; 11/14-18/2011; Crystal River Unit 3, Notification of Inspection and Request for Information ML11175A1512011-06-30030 June 2011 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML11137A1742011-06-22022 June 2011 Nuclear Generating Plant; H. B. Robinson Steam Electric Plant, 2; and Shearon Harris Nuclear Power Plant, Unit 1 Request for Additional Information Regarding 2011 Decommissioning Funds ML1115403412011-06-0202 June 2011 Nuclear Generating Plant - Notification of Inspection and Request for Information 05000302/2011501 ML11122A0002011-05-26026 May 2011 Request for Additional Information for the Review of the Crystal River, Unit 3, License Renewal Application ML1112501592011-05-0505 May 2011 Notice of Inspection and Request for Information 05000302/2011003 ML1108202262011-03-31031 March 2011 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1031402722010-11-16016 November 2010 Request for Additional Information for the Review of the Crystal Review Unit 3 Nuclear Generating Plant, License Renewal Application ML1029503292010-11-0808 November 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant License Renewal Application ML1030202942010-10-28028 October 2010 Nuclear Generating Plant - Notification of Inspection and Request for Information IR 05000302-10-005 ML1027100652010-10-19019 October 2010 09/27/10 Summary of Telephone Conference Call Held Between NRC and Florida Power Corp., Concerning Draft Request for Information Related to Crystal River, Unit 3, License Renewal Application ML1026002432010-10-14014 October 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1022800102010-08-11011 August 2010 Nuclear Generating Plant - Draft RAIs Regarding Crystal River Unit 3 Part 26 Exemption Request ML1017404972010-07-0808 July 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1015303972010-07-0808 July 2010 RAI for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1014105122010-06-0202 June 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application 2023-04-19
[Table view] |
Text
July 18, 2007 Mr. Dale E. Young, Vice President Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, Florida 34428-6708
SUBJECT:
CRYSTAL RIVER, UNIT NO. 3, REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST NO. 295 REV. 0, EXTENSION OF ALLOWED OUTAGE TIME TO SEVEN DAYS AND ELIMINATION OF SECOND COMPLETION TIMES (TAC NO. MD5241)
Dear Mr. Young:
By letter dated April 13, 2007, the Florida Power Corporation (FPC) submitted an application to change the Crystal River, Unit No. 3, Technical Specifications (TSs) related to low pressure injection, reactor building spray, decay heat closed cycle cooling water, and decay heat seawater systems. The proposed changes would revise the applicable TSs, in part, to extend the allowed outage time associated with one inoperable train of these systems from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days, consistent with the staff approved Technical Specifications Task Force (TSTF) traveler TSTF-430, which implements approved topical report BAW-2295, Revision 1, Justification for Extension of Allowed Outage Time for Low Pressure Injection and Reactor Building Spray Systems. The Nuclear Regulatory Commission staff has determined that it needs additional information in order to complete its review. The enclosed questions were sent by e-mail to FPC on July 3, 2007, and discussed during a conference call on July 12, 2007.
Please respond to the enclosed questions within 30 days of the date of this letter. This schedule was discussed and agreed to by Mr. Paul Infanger of FPC.
Please contact me at 301-415-1321 if you have any questions on this issue.
Sincerely,
/RA/
Stewart N. Bailey, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302
Enclosure:
As stated cc: See next page
ML071940009 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA APLA/BC LPL2-2/BC NAME SBailey BClayton MRubin SBailey for TBoyce DATE 07/17/07 07/17/07 6/25/2007* 07/18/07
- by memo Mr. Dale E. Young Crystal River Nuclear Plant, Unit 3 Florida Power Corporation cc:
Mr. R. Alexander Glenn Mr. Jon A. Franke Associate General Counsel (MAC-BT15A) Director Site Operations Florida Power Corporation Crystal River Nuclear Plant (NA2C)
P.O. Box 14042 15760 W. Power Line Street St. Petersburg, Florida 33733-4042 Crystal River, Florida 34428-6708 Mr. Michael J. Annacone Senior Resident Inspector Plant General Manager Crystal River Unit 3 Crystal River Nuclear Plant (NA2C) U.S. Nuclear Regulatory Commission 15760 W. Power Line Street 6745 N. Tallahassee Road Crystal River, Florida 34428-6708 Crystal River, Florida 34428 Mr. Jim Mallay Ms. Phyllis Dixon Framatome ANP Manager, Nuclear Assessment 1911 North Ft. Myer Drive, Suite 705 Crystal River Nuclear Plant (NA2C)
Rosslyn, Virginia 22209 15760 W. Power Line Street Crystal River, Florida 34428-6708 Mr. William A. Passetti, Chief Department of Health David T. Conley Bureau of Radiation Control Associate General Counsel II - Legal Dept.
2020 Capital Circle, SE, Bin #C21 Progress Energy Service Company, LLC Tallahassee, Florida 32399-1741 Post Office Box 1551 Raleigh, North Carolina 27602-1551 Attorney General Department of Legal Affairs Mr. Daniel L. Roderick The Capitol Vice President, Nuclear Projects &
Tallahassee, Florida 32304 Construction Crystal River Nuclear Plant (SA2C)
Mr. Craig Fugate, Director 15760 W. Power Line Street Division of Emergency Preparedness Crystal River, Florida 34428-6708 Department of Community Affairs 2740 Centerview Drive Mr. David Varner Tallahassee, Florida 32399-2100 Manager, Support Services - Nuclear Crystal River Nuclear Plant (SA2C)
Chairman 15760 W. Power Line Street Board of County Commissioners Crystal River, Florida 34428-6708 Citrus County 110 North Apopka Avenue Inverness, Florida 34450-4245 Mr. Stephen J. Cahill (Acting)
Engineering Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, Florida 34428-6708
REQUEST FOR ADDITIONAL INFORMATION CRYSTAL RIVER UNIT NO. 3 IMPLEMENTATION OF TSTF-430 AND TSTF-439 DOCKET NO. 50-302 By letter dated April 13, 2007, the Florida Power Corporation (FPC, the licensee) submitted License Amendment Request No. 295 for Crystal River Unit No. 3 (CR-3). The proposed amendment would change the CR-3 Technical Specifications, in part, to extend the allowable completion time associated with one inoperable train of low pressure injection (LPI), reactor building spray, decay heat closed cycle cooling water, and decay heat seawater systems from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days, consistent with the staff approved Technical Specifications Task Force (TSTF) traveler TSTF-430, which implements approved topical report BAW-2295, Revision 1, Justification for Extension of Allowed Outage Time [AOT] for Low Pressure Injection and Reactor Building Spray Systems. The Nuclear Regulatory Commission staff has determined that it needs responses to the following questions in order to continue the review:
- 1. In the submittal with regards to the quality of the CR-3 probabilistic risk assessment (PRA), the licensee does not state the scope of their model (i.e., internal events, external events, fires, seismic, etc., as well as at-power, transition, shutdown). The quantitative results presented are compared to the acceptance guidance of Regulatory Guides (RGs) 1.174 and 1.177, which are based on a full scope risk analysis. The submittal later states that the licensee does not have a fire PRA model. The licensee is requested to clarify the scope of their risk analysis used for this application.
- 2. In the submittal (Attachment A, page 15 of 27), the licensee states that the only potentially significant external events that could influence the risk are fires and severe weather. This conflicts with the conclusions of the topical report BAW-2295-A Rev. 1, which was the basis for the staff approval of TSTF-430, on which this amendment request is based. BAW-2295-A concluded that the impact of the proposed changes had a negligible impact on external events risk. The basis for the licensees conclusion identifies a review of the CR-3 Individual Plant Examination (IPE) and supporting data.
Since external events, including fires, were not in the scope of the IPE, the basis for this conclusion is not clear. The licensee is requested to provide its disposition of external events (other than fires and severe weather) not included in the risk assessment results (such as seismic events, external flooding, high winds, transportation accidents), and a basis for its conclusions regarding the low-risk significance of each of these events for this application.
- 3. In the submittal, the licensee identified general assumptions relevant to their risk analysis, including that During performance of the AOT, the corresponding opposite train equipment and diesel are considered to be protected. The term protected should be more clearly defined as to what specifically is prohibited while the equipment is protected. The specific scope of equipment should be stated, and appropriate regulatory commitments identified.
- 4. In the submittal (Attachment E, Section 5.3), the licensee states that 96 additional hours of unavailability are assumed for each train of the affected systems, and that the unavailability would be incurred simultaneously for each train of the systems. No basis has been provided to justify either of these assumptions based on maintenance practices and past component maintenance history. This assumption is also inconsistent with the topical report BAW-2295-A Rev. 1. BAW-2295-A identified an increase from 80 to 93 hours0.00108 days <br />0.0258 hours <br />1.537698e-4 weeks <br />3.53865e-5 months <br /> of unavailability per train per year. Further, the licensee identified a compensatory measure (Attachment A, page 17) to schedule concurrent outages of raw water and decay heat systems, if possible. This appears to conflict with an assumption of concurrent outages, since it identifies that such concurrent scheduling may not be possible in some circumstances. The licensee should justify these assumptions and clarify the intent of the compensatory measures regarding concurrent outages, or provide more realistic risk analyses accounting for nonconcurrent outage scheduling.
- 5. The submittal did not analyze emergent component failures (i.e., unplanned maintenance) and the potential impact on risk from increased probability of common cause failure. Since the applicability of the extended AOT is not limited to planned maintenance activities, the risk analysis should address emergent repairs per RG 1.177 Section 2.3.3.1 and Appendix A Section A.1.3.2.
- 6. The submittal discusses the development of a fire risk sensitivity study and presents its results. The staff requests additional clarifications regarding the fire risk of the proposed changes:
- a. The submittal does not discuss the role of the LPI subsystem and its cooling water support systems for mitigation of fire events for achieving a safe shutdown.
The licensee should discuss the anticipated role of these systems given a fire in the plant.
- b. The fire zones of interest are identified as those which contain circuits of the systems for which the AOT extension is requested. However, fires which disable other systems resulting in a demand for the LPI and supporting systems would also be impacted by the AOT extension. For example, fire-induced failure of emergency feedwater components would increase the likelihood of requiring core cooling by bleed-and-feed once through cooling, which may ultimately require the use of LPI systems for long term decay heat removal. The licensee should justify the selection of fire scenarios.
- c. The submittal states that fires which impact manual actions that are credited in the Fire Study are expected to have a minimal risk impact. It is not understood to what the term Fire Study refers, nor are the manual actions identified in any way, therefore the basis for this statement is not clear. The licensee should clarify the intent of this assumption and assure it has a proper basis.
- d. The development of the compensated frequency adjusts for equipment which will not be operated without special precautions. It is not understood to what special precautions refers, to what equipment these precautions apply, and whether these are associated with any licensee commitments specific for this application. The licensee should clarify the scope and intent of this assumption.
- e. The licensee applied a 0.1 conditional core damage probability given a fire and identified this as a conservative assumption. However, no specific basis has been provided to justify this value as conservative. Further, the final results of the fire sensitivity study using this assumption do not demonstrate low sensitivity to fire risk, which would indicate that the use of a conservative screening value may be inappropriate. The licensee should justify the use of 0.1 as the conditional core damage probability, or consider applying a more realistic value to better establish a less conservative estimate of fire risk during the extended AOT.
- f. The results of the sensitivity study show that fire risk dominates the risk impact of the extended AOT, and the acceptance guidance of RG 1.177 of 5E-7 incremental conditional core damage probability is exceeded by almost a factor of 10. The licensee has not drawn any conclusions from these results, nor have specific compensatory measures been identified to offset this risk. (The licensee has proposed an undefined periodic fire watch in the decay heat pump room and seawater rooms, which contain the equipment subject to the extended AOT.
However, in their fire analysis the decay heat pump rooms have a compensated frequency of 0 since the pumps are not running, so this compensatory fire watch does not directly offset any specific source of the fire risk.) The licensee should discuss the implications of the fire risk sensitivity study to the overall conclusions of the risk impacts associated with the extended AOTs, and consider implementing specific compensatory measures to address fire risk as a significant contributor to the risk profile.
- 7. The submittal did not identify whether the risk analyses provided point estimates of the mean or actual means, nor was there any discussion of uncertainty analyses to support the calculations. The licensee is requested to address PRA model and parametric uncertainty using the guidance of RG 1.174 Section 2.2.5 and RG 1.177 Section 2.3.5.
- 8. The submittal did not address the truncation level used for this analysis. The licensee is requested to provide this information consistent with RG 1.177 Section 2.3.3.4.
- 9. The submittal (Attachment A, page 16) ends the first bulleted compensatory measure with a phrase These protective measures . . . , which is not completed. The licensee is requested to provide the missing information.
- 10. The submittal (Attachment A, page 16) identifies a commitment to avoid an AOT . . .
that results in Higher Risk (Orange Color Code). The licensee is requested to clarify the intended meaning of avoiding an AOT, and to specify the basis for the Higher Risk (Orange Color Code) in terms of risk impact.
- 11. RG 1.177 Section 2.3.7.2 identified the key components of a configuration risk management program. The licensee has not identified whether the program applied under plant procedure CP-253 satisfies all aspects of RG 1.177, specifically:
- The scope of structures, systems, and components (SCCs) included.
- Applicability if additional SSCs become inoperable or non-functional while in a risk-informed AOT.
- Consideration of external events and level 2 issues.
The licensee is requested to clarify this issue.