ML12053A424
| ML12053A424 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/16/2011 |
| From: | Schulten C NRC/NRR/DSS |
| To: | Robert Elliott NRC/NRR/DSS |
| References | |
| FOIA/PA-2011-0357 | |
| Download: ML12053A424 (4) | |
Text
Elliott, Robert
/
From:
Schulten, Carl Sent:
Friday, September 16, 2011 4:39 PM To:
Elliott, Robert
Subject:
FYI: FW: OEDO monthly meeting Attachments:
North Anna OEDO Monthly meeting Comments on Adequacy of licensee scope of review for ODP.docx From: Schulten, Carl-.
Sent: Friday, September 16, 2011 2:13 PM To: Khanna, Meena Cc: Wilson, George; Manoly, Kamal; Karwoski, Kenneth
Subject:
RE: OEDO monthly meeting
- Meena, Attached are my comments provided in Word Track Changes.
From: Khanna, Meena \\
X-*
i Sent: Friday, September 16, 2011 11:26 AM To: Schulten, Carl Cc: Wilson, George; Manoly, Kamal; Karwoski, Kenneth
Subject:
FW: OEDO monthly meeting Carl, pls let us know what you think regarding this proposed acceptance criteria for the assessment of North Anna. We are available to discuss when you have time. Thanks.
Technical Acceptance Criteria for demonstrating the acceptability for plant restart (short-term):
Confirm the adequacy of the scope of licensee's inspections, testing and analysis to demonstrate no functional damage (i.e., must demonstrate SSCs are operable/functional for thecurrent licensing basis). For definitions of operable/functional, pis. see NRC Inspection Manual Part 9900, "Operability Determinations and Functionality Assessments for Resolution of Degraded or NonConforming Conditions Adverse to Quality or Safety."
For long term (post-restart), the licensee shall evaluate the need to revise its CLB with regards to the new seismic risk (based on the SSE seen at the site as well as the GI-199 information).
From: Khanna, Meena Sent: Friday, September 16, 2011 9:24 AM To: Guitter, Joseph; Howe, Allen Cc: Wilson, George; Evans, Michele; Karwoski, Kenneth
Subject:
RE: OEDO monthly meeting Response on why we don't make them modify their licensing basis prior to restart:
- 1. IPEEE shows that the plants have 0.3 g High Confidence, Low Probability of Failure (HCPLF) with a few exceptions that do not impede the plant's shutdown capability and the capacity of these exceptions exceed the measured accelerations.
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- 2. The staff evaluation in the safety assessment report of GI-199 indicates that North Anna is among the subset of plants in the CEUS that were calculated to have a delta core damage frequency between 10 E-4 and 10 E-5, which the staff considered reasonable for continued operation. Not knowing whether some equipment may exceed their design basis limits does not preclude inoperability. However, the staff expects that functionality of equipment, that may have exceeded its DB, shall be ascertained via walkdowns, analysis, and testing.
From: Glitter, Joseph 1 Sent: Friday, Septemb r16, 20117:14 AM To: Howe, Allen Cc: Wilson, George; Khanna, Meena; Evans, Michele
Subject:
RE: OEDO monthly meeting Nicely done. Have in your hip pocket a response on why we don't make them modify their licensing basis prior to restart.
From: Howe, Allen
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Sent: Thursday, September 15, 2011 5:32 PM To: Leeds, Eric Cc: Wilson, George; Evans, Michele; Giitter, Joseph; Khanna, Meena
Subject:
OEDO monthly meeting Eric - George Wilson and I plan to support you at the OEDO monthly meeting to discuss North Anna. We coordinated with RII to be ready to status the AIT. I have included some info below that I plan to use to outline our approach and answer questions.
EDO Monthly Briefinq - Agenda Item: North Anna Restart (Requirements and Approval)
Draft Talking Points:
Region IH:
Overview of AIT findings/exit meeting, etc.
Discuss plans for startup inspection NRR:
" Public meeting was held with Dominion on September 8.
o Technical staff provided questions that Dominion should consider for plant restart.
o Public interest from a 2.206 petition, Office of the AG of NY State, Rep Markey to Chairman.
o Additional Public Meetings with full meeting support (broadcast, phone lines, transcription, closed captioning, etc.) should be anticipated prior to restart because of the level of interest (requires OPA support).
NRR is developing an Action Plan and a Communication Plan to address North Anna Restart.
Following the September 8 th public meeting, the staff continues to develop questions for Dominion to consider with respect to plans for restart.
o To date, questions regarding fuels and reactor systems have been issued.
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o Other questions are being developed, using the SRP, EPRI NP-6695 guidelines, and the IAEA Safety Report No. 66 regarding the Japan KK lessons learned/short and long term actions taken.
Dominion plans to submit its restart report COB, today or on Saturday.
o Report to address characterization of event, post earthquake inspections (to include those of reactor vessels and internals, new and irradiated fuel, spent fuel racks), ISFSI installation, near term actions prior to start-up.
" Audit planned for week of Sept 19 on fuels.
Path Forward:
o Perform technical, legal, and licensing review of startup plan from Dominion and submit questions per the RAI process.
o Continuing to schedule audits at site, as necessary.
o Coordinating with Region II on all activities - including additional audits and inspections.
o Staff has contacted OGC for support in drafting an Order.
" Requirements and Approval:
o The staffs assessment will utilize the guidance provided in NRC's Regulatory Guide (RG) 1.167, which endorses the EPRI's guidelines as useful information to inform its technical review. In addition, the staff will utilize the IAEA Safety Report Series No. 66, "Earthquake Preparedness and Response for Nuclear Power Plants," to provide insights as to the adequacy of the licensee's restart determinations. It should be noted that the IAEA Safety Report acknowledges the prospect that hidden damage (especially after an SSE) is a real possibility and its effects should be evaluated with analytical work.
o The staff plans to issue an order reiterating (and augment as needed) plant restart commitments/actions, may include analysis and plant modifications based on the technical evaluation and safety evaluation report for the restart plan. Any modifications will need to satisfy 10 CFR 50.109(a)(4)(ii) [adequate protection] requirements.
o 10 CFR Part 100, App. A requirements (OGC has provided verbal feedback that advice that Pt 100, App A, section V(a)(2) applies to NA situation.).
Thanks - Allen 3
Comments on: Short-Term Technical Acceptance Criteria Formatted: Centered For Demonstrating The Acceptability For North Anna Plant Restart Confirm the adequacy of the scope of licensee's inspections, tests wtg-and analyseis to demonstrate no functional damage resulted from [the earthquake] to systems. subsystems, trains, components and devices ((ic., must dcmncstrptc SSCs)s for the current licensing basis (1) that are required to be operable by TSs and SSCs not explicitly required to be operable by TSs, but that perform required support functions as specified by the TSs definition of operability:
and (2) SSCs that are not described in TSs but which warrant programmatic controls to ensure that SSC availability and reliability are maintained.
belfunctiona, 1 fr thc currnt.............
Formatted: Font: Bold
.nsing basis). For Refer to definitions f p.rablefc...
pis. see NRC Inspection Manual Formatted: Font: Not Bold Part 9900, "Operability Determinations and Functionality Assessments for Resolution of Degraded or NonConforming Conditions Adverse to Quality or Safety-" for more detailed guidance for determinations of operability and resolution of degraded or nonconforming conditions.
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Contact:
Carl Schulten, NRR/ITSB