SBK-L-12041, Response to Request for Additional Information Request for Alternative to Use ASME Code Case N-716 to Implement Risk-Informed Inservice Inspection Program
| ML12074A111 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/08/2012 |
| From: | Freeman P Nextera Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-12041 | |
| Download: ML12074A111 (5) | |
Text
NEXTeraTm ENERGY T
EA BROOK March 8, 2012 SBK-L-12041 Docket No. 50-443 U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 Seabrook Station Response to Request for Additional Information Request for Alternative to Use ASME Code Case N-716 to Implement Risk-Informed Inservice Inspection Program
References:
- 1. NextEra Energy Seabrook, LLC letter SBK-L-1197, "Request for Alternative to Use ASMECode Case N-71 6 to ImplementRisk-Informed Inservice Inspection Program,"
Dated November 7, 2011. (ML11319A016)
- 2. NRC Letter "Seabrook Station Unit 1 - Request for Additional Information Regarding the Request for Alternative to Use ASME Code Case N-71 6 to Implement the Risk-Informed Inservice Inspection Program, dated February 15, 2012." (ML120390570)
In Reference 1, NextEra Energy Seabrook, LLC (NextEra) submitted its request to use ASME Code Case N-716 to implement its Risk-Informed Inservice Inspection Program.
In Reference 2, the NRC requested additional information in order to complete its review of the request.
The attachment to this letter contains the requested additional information.
Should you have questions of a technical nature regarding the additional information, please contact Mr. Richard Turcotte, Principal Nuclear Engineer, at (603) 773-7530.
NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874
U.S Nuclear Regulatory Commission SBK-L-1204 1/Page 2 Should you have any questions regarding this submittal, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.
Sincerely, NextEra Energy Seabrook, LLC Paul Freeman Site Vice President
Attachment:
Response to Request for Additional Information - Request for Alternative to Use Risk-Informed Inservice Inspection Program cc:
W.M. Dean, J. G. Lamb, W. J. Raymond, NRC Region I Administrator NRC Project Manager, Project Directorate 1-2 NRC Resident Inspector
Attachment Seabrook Station Response to Request for Additional Information Request for Alternative to Use Risk-Informed Inservice Inspection Program
Seabrook Station Response to Request for Additional Information Request for Alternative to Use Risk-Informed Inservice Inspection Program NRC Question:
- 1.
In the submittal, the licensee stated that "the Internal Flood PRA [with supporting requirements as recommended in EPRI Report 1021467]... peer review resulted in 26 findings and observations," to which the licensee stated that "all 26 findings have been addressed in the SSPSS 2011 model update."
- a.
The SE makes changes to the language for the EPRI Report. Because of this, EPRI REPORT will be updated to "-A" version within three months of receipt of the final SE. Please confirm that the licensee's PRA conforms to the EPRI REPORT, as modified by the NRC staff's SE on January 18, 2012 (MLI 1325A340), or identify any areas where the quality of the PRA differs from that described in the version that will be developed after EPRI incorporates the SE into the Report.
NextEra Response:
The Seabrook PRA model SSPSS-20 11, including the internal flood model used in support of the RI-ISI Code Case N716 (streamline approach), will conform to the EPRI TR 1021467-A version of the topical report. All relevant internal flood peer/independent review findings have been addressed as necessary, and applicable changes have been incorporated into the PRA model, methods and documentation.
NRC Question:
- b.
The licensee states:
"All 26 internalflooding peer review findings have been addressed in the SSPSS-2011 model update. The three "B" level findings and associated disposition are summarized in the table below. Other findings had either a minor impact on the model or were related to improving documentation. "
The NRC safety evaluation for EPRI TR 1021467 "Nondestructive Evaluation: Probabilistic Risk Assessment Technical Adequacy Guidance for Risk-Informed In-Service Inspection Programs" in Attachment 1, Table 1 clarifies that for a supporting requirement to be considered met, all relevant peer and other independent review findings shall have been addressed and as necessary applicable changes made to PRA models, methods, and documentation. Please provide the NRC staff confirmation that all findings for those supporting requirements as identified in EPRI TR 1021467 are properly dispositioned and now meet the Capability Category appropriate for that SR as reflected in EPRI TR 1021467, as approved by the NRC SE. If any SR is not met at the appropriate Capability Category level, please describe the finding and its disposition for this application.
NextEra Response:
The Seabrook PRA model SSPSS-201 1, including the internal flood model used in support of the RI-ISI Code Case N716 (streamline approach), will conform to the EPRI TR 1021467-A version of the topical report.
All relevant internal flood peer/independent review findings have been addressed as necessary, and applicable changes have been incorporated into the PRA model, methods and documentation. The Seabrook PRA SSPSS-2011 meets or exceeds the Capability Category for the individual supporting requirements (SR) as reflected in EPRI TR 1021467, as approved by the NRC SE.