ML12342A380
| ML12342A380 | |
| Person / Time | |
|---|---|
| Site: | Millstone  (NPF-049) |
| Issue date: | 12/18/2012 |
| From: | James Kim Plant Licensing Branch 1 |
| To: | Heacock D Dominion Nuclear Connecticut |
| Kim J NRR/DORL/LPL1-1 301-415-4125 | |
| References | |
| TAC ME9733 | |
| Download: ML12342A380 (5) | |
Text
REGUi UNITED STATES NUCLEAR REGULATORY COMMISSION "I;.
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..,.0 December 18, 2012
- 'i:"t*it Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT REVIEW OF MILLSTONE POWER STATION UNIT 3 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING RISK-INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (TAC NO. ME9733)
Dear Mr. Heacock:
By letter dated October 4,2012, Dominion Nuclear Connecticut, Inc. (the licensee) submitted an amendment to the Technical Specifications (TSs) for Millstone Power Station, Unit 3 (Agencywide Documents Access Management Systems ML12284A213). The proposed amendment would modify TSs by relocating specific surveillance frequencies to a licensee controlled program with the adoption of Technical Specification Task Force (TSTF)-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-Risk-Informed Technical Specification Task Force Initiative 5b."
The U.S. Nuclear Regulatory Commission staff has reviewed the information provided by the licensee and has determined that the enclosed request for additional information (RAI) is needed in order to complete the review. A response to this RAI is requested to be provided within 45 days.
If you have any questions regarding this matter, please contact me at 301-415-4125.
Sincerely,
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James Kim, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423
Enclosure:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION RELATED TO AN AMENDMENT TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-425. REVISION 3.
TO RELOCATE SPECIFIC SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM MILLSTONE POWER STATION UNIT 3 DOCKET NO. 50-423
- 1.
The submittal does not identify that technical specification (TS) Bases are adopted consistent with the U.S. Nuclear Regulatory Commission (NRC) letter issued April 14, 2010 Agencywide Documents Access and Management System (Accession Number ML100990099) subsequent to the adoption of (Technical Specification Task Force) TSTF-425. In addition, the submittal's "Insert #2" is not consistent with this letter.
Please provide confirmation that the TS Bases will be adopted consistent with this letter.
- 2.
Please discuss how the focused peer review met the peer review guidance in the American Society of Mechanical Engineers (ASME) standard ANS RA-Sa-2009 and the clarifications in Regulatory Guide 1.200.
- 3.
The submittal provides the open gap items for the updated probabilistic risk assessment (PRA) model (M310A). However, the staff also requests to review the closed findings and observations (F&Os) from the peer review, self assessment, and the focused peer review.
Please provide the F&Os which have been closed and detailed descriptions of their dispositions from those reviews.
- 4.
Gap #1. Please clarify if the interviews with plant personnel were to determine if potential initiating events have been overlooked. If not, describe the steps to address this supporting requirement.
- 5.
Gap #2. The disposition of this supporting requirement states this is a documentation issue only; however, no discussion is provided on the plant walkdowns and interviews mentioned in the supporting requirement. Please discuss these walkdowns and interviews which address this supporting requirement (SR).
- 6.
Gap #3 and #4. The submittal notes that human reliability analysis (HR) SRs HR-G5 and HR-G7 were met, however, an F&O was written for the SRs based on nonsystematic discrepancies that the PRA peer review team judged to require correction. Please correct the impacted human error probabilities.
- 7.
Gap #11. Describe the process for identifying human-induced flooding scenarios, and discuss its applicability to TSTF-425 application.
- 8.
Please identify the plan for closing findings that are identified as "Documentation, issues only."
Enclosure
- 2
- 9.
Table 3, "Status of Identified Gaps to Capability Category II of the ASME/ANS PRA Standard," the submittal notes that sensitivity studies will be performed in accordance with PRA procedures for certain gap items. It is not sufficient to perform sensitivity studies in accordance with PRA procedures. The sensitivity studies must be performed in accordance with Nuclear Energy Institute (NEI) 04-10 guidance. Please make this clarification as appropriate for the gap items.
- 10. The submittal indicates that fire risk and seismic risk would be qualitatively assessed.
However, NEI 04-10 guidance for fire events mentions quantitative assessment methods (fire PRA or Fire Induced Vulnerability Evaluation (FIVE)), or qualitative screening. For seismic events, it mentions quantitative assessment (seismic PRA), qualitative assessment (seismic margins analysis), or qualitative screening. Please describe in more detail how fire and seismic events would be assessed in terms of NEI 04-10 guidance.
- 11. The submittal provides no discussion on assessing high winds, floods and other external events. Please describe how these events would be assessed in terms of NEI 04-10 guidance.
- 12. The submittal provides no discussion on assessment for shutdown events. Please describe how these events would be assessed in terms of NEI 04-10 guidance.
- 13. Table 4.3-2 shows the Emergency Generator Load Sequencer marked in the TS under the actuation logic test column, as well as other functional units with the corresponding notation (1). The notation (1) is shown as deleted. Notation (1) is "Each train shall be tested at least every 62 days on a STAGGARD TEST BASIS." This is also the case for notation (7) in Table 4.3-1 for different functional units. Please discuss why the requirement to test each train is being deleted and why it is consistent with the TSTF-425 program which relocates the frequency of the surveillance to the surveillance frequency control program (SFCP).
- 14. Similarly, surveillance requirement 4.3.2.2 deletes requirements on what to test. Discuss why it is consistent with TSTF-425.
- 15. It is noted that TS 4.8.2.1.f is shown in the matrix table as belonging to the SFCP, but it has no markup. Since the surveillance has an age-related component it would not meet the criteria to be in the SFCP. Please clarify why the submittal proposes to include TS 4.8.2.1.f in the SFCP.
- 16. The following MPS3-specific systems identified in the cross-reference table to NUREG-1431 have no corresponding standard technical specification section: Radiation Monitoring Instrumentation MPS3:
Shutdown Margin Monitoring MPS3 pH Tri-sodium Phosphate Storage Baskets Steam Jet Air Ejectors Secondary Containment MPS3
- 3 In addition, the following surveillance requirement identified in the cross-reference table is not in the TSTF-425 scope for the section "RCS Specific Activity":
Verify XE-133 Justify why these are included in the scope of TSTF-425, or withdraw their proposed inclusion in the SFCP.
- 17. Do the failure probabilities of structures, systems, and components modeled in the MPS3 PRA include a standby time-related contribution and a cyclic demand-related contribution?
If not, please describe how standby time-related contribution is addressed for extended intervals.
December 18, 2012 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT REVIEW OF MILLSTONE POWER STATION UNIT 3 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING RISK-INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (TAC NO. ME9733)
Dear Mr. Heacock:
By letter dated October 4,2012, Dominion Nuclear Connecticut, Inc. (the licensee) submitted an amendment to the Technical Specifications (TSs) for Millstone Power Station, Unit 3 (Agencywide Documents Access Management Systems ML12284A213). The proposed amendment would modify TSs by relocating specific surveillance frequencies to a licensee controlled program with the adoption of Technical Specification Task Force (TSTF)-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - Risk-Informed Technical Specification Task Force Initiative 5b."
The U.S. Nuclear Regulatory Commission staff has reviewed the information provided by the licensee and has determined that the enclosed request for additional information (RAJ) is needed in order to complete the review. A response to this RAI is requested to be provided within 45 days.
If you have any questions regarding this matter, please contact me at 301-415-4125.
Sincerely, IRAI James Kim, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-423
Enclosure:
As stated cc w/encl: Distribution via Listserv Distribution:
PUBLIC RidsNrrDorlDpr Resource RidsOgcRp Resource LPLI-1 RIF RidsNrrDorlLpl1-1 Resource RidsNrrDraApla Resource RidsNrrLAKGoldstein Resource RidsNrrPMMilistone Resource DO'Neal, NRR RidsRgn1 MailCenter Resource RidsAcrsAcnw_MailCTR Resource ADAMS Accession No.: ML12342A380
- via memo dated November 28,2012 OFFICE LPL 1-1/PM LPL1-1/LA DRAlAPLAlBC LPL1-1/BC vKim KGoldstein I DHarrison*
GWilson DATE 12/18/12 12/11/12 11/28/12 12/18/12 OFFICIAL RECORD COpy