ML102730376
| ML102730376 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/30/2010 |
| From: | Cotton K Plant Licensing Branch II |
| To: | Geoffrey Miller Dominion |
| Cotton K R, NRR/DORL, 301-415-1438 | |
| References | |
| Download: ML102730376 (2) | |
Text
From:
Cotton, Karen Sent:
Thursday, September 30, 2010 7:58 AM To:
Thorpe, April
Subject:
FW: RAI for LAR requesting JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM Please place in ADAMS.
- Thanks, Karen Karen Cotton NRR/DORL PM - Surry Units 1 and 2 Karen.Cotton@nrc.gov 301-415-1438 From: Cotton, Karen Sent: Thursday, September 30, 2010 7:57 AM To: 'Gary D Miller'
Subject:
RAI for LAR requesting JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM REQUEST FOR ADDITIONAL INFORMATION RELATED TO AN AMENDMENT TO IMPLEMENT TSTF-425 REVISION 3 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 DOCKET NO. 50-280 AND 50-281 The licensee identified that it performed a self-assessment of its internal events probabilistic risk assessment (PRA) model to the requirements of the standard as referenced in Regulatory Guide 1.200 Revision 1. The structure of the standard provides high level and supporting requirements, including separate documentation requirements.
In Table 1 of Attachment 2 of the submittal, the licensee presented a summary of the remaining (eight) open findings from this assessment as well as their disposition for this application. In its review, the staff noted that each of the items was identified against a specific non-documentation supporting requirement of the standard, but each was dispositioned as only a documentation issue. Since each high level requirements of the standard has a separate documentation part, it is not clear to the staff why the concerns from an internal self assessment were not identified as relevant to the documentation requirements, rather than the technical requirements, since the licensee controls the process.
Further, one item identified as Gap #2 is identified as a documentation issue, but then it is stated that the issue will be addressed as a sensitivity for this application. If the issue is documentation, it is not clear how a sensitivity analysis would be applicable.
The licensee needs to provide additional details as to how it determined that the findings from the self assessment, identified as deficiencies against the technical, and not the documentation, portions of the standard, were in fact only related to documentation and not actual technical issues with the PRA model.
E-mail Properties Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D029D2092467)
Subject:
FW: RAI for LAR requesting JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM Sent Date: 9/30/2010 7:57:39 AM Received Date: 9/30/2010 7:57:39 AM From: Cotton, Karen Created By: Karen.Cotton@nrc.gov Recipients:
April.Thorpe@nrc.gov (Thorpe, April)
Tracking Status: None Post Office:
HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 16191 9/30/2010 Options Expiration Date:
Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: