ML14174A402

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6/24/2014, Pre-Submittal Meeting Slide for St. Lucie and Turkey Point Re. License Amendment Request Adoption of TSTF-505 Risk-Informed Completion Time
ML14174A402
Person / Time
Site: Saint Lucie, Turkey Point  NextEra Energy icon.png
Issue date: 06/24/2014
From:
Nextera Energy
To:
Plant Licensing Branch II
Klett A
References
Download: ML14174A402 (20)
v • d • e


Text

License Amendment Request Adoption of TSTF-505 Risk-Informed Completion Times Pre-submittal Meeting June 24, 2014 NextEra Energy Proprietary Information/Confidential

Agenda

  • License amendment request (LAR) scope and schedule
  • Implementation of risk-informed completion times (RICT)
  • Training and communication
  • Takeaways
  • Questions/Staff Feedback 2

LAR Scope

  • RICT program will be implemented in Modes 1 and 2 only 3

LAR Schedule

  • Planned submittals

- Third quarter 2014 St. Lucie Unit 1 & 2 (PSL)

Turkey Point 3 & 4 (PTN) 4

LAR Clarifications for TSTF-505

  • Different TS Format and Numbering from Improved Standard Technical Specifications (ITS)

- PSL

- PTN

- Cross references TSTF-505 and plant-specific Technical Specifications (TS)

- Identifies candidate TS for RICT

- Cross references Required Actions (RAs) in TSTF-505 and corresponding RAs for PTN TS 5

LAR Clarifications for TSTF-505

  • TS Bases

- Bases revised, as applicable, to discuss completion times consistent with TSTF-505

- Bases revised to discuss the actions and notes related to conditions for two or more inoperable trains or subsystems

- TS 3.3.1, Function 20 is missing the Condition for two or more channels inoperable

- PTN LAR proposes to include action for two or more channels inoperable (reactor trip breaker trip mechanisms) 6

LAR Clarifications for TSTF-505

- TS not in non-ITS plant; function included in PTN ESF TS

- ITS already addresses two or more channels inoperable

- PTN LAR proposes to add new action to address two or more channels inoperable

- ITS actions based on ECCS flow capability

- Non-ITS plants do not address flow capability

- PTN LAR proposes RICT for component inoperability 7

LAR Clarifications for TSTF-505

  • Trains / Components

- ITS address single and multiple inoperable trains

- Non-ITS plants address inoperable components rather than trains

- PTN LAR proposes RICT for single and multiple inoperable components

  • Electrical Power

- PTN TS actions for operable equipment without emergency power source

- PTN LAR proposes to apply RICT when emergency power source unavailable (consistent with applying RICT to TS for AC Sources) 8

PRA Model Status

  • All sites conform to NRC PRA Quality Standard (RG 1.200 Rev 2) for Internal Events PRA

- Duane Arnold (PDA) NFPA 805 fully implemented. PTN, PSL, and Point Beach (PBN) in review by NRC.

Seabrook (SEA) staying with Appendix R (MSOs incorporated)

  • External Events assessment

- GAP assessment performed in 2012 for SEA as a fleet model

- Tornado/High Winds PRA completed for PBN

- Seismic risk being calculated based on new GMRS

  • 9 9

PRA Model Status

  • Shutdown modes (4 & 5) will only be included for Seabrook since other plants do not have shutdown models 10

PRA Model Status

  • Peer review findings/observations have either been closed or will be addressed in the LAR with a resolution path identified with respect to risk-managed tech specs (RMTS) application
  • PRA model is under configuration control with approved procedures for periodic and immediate updating to reflect as-built, as-operated plant 11

Impact of External Events Fire

  • Modifications have been credited in development of NFPA 805. Compensatory actions as addressed in NFPA 805 LAR will be implemented until plant modifications are complete
  • For Seabrook, Fire PRA does not conform to RG 1.200. A gap assessment has been performed against the RG and efforts underway to close gaps.

Any gaps not closed will be addressed in the LAR for their impact

  • Insights from fire have been incorporated into maintenance rule (a)(4) 12

Impact of External Events Seismic

  • Seismic for PTN, PSL, PBN and PDA

- Justification will be provided for minimal impact on RICT calculation

  • Seabrook has all modes PRA that takes into account seismic contribution. The seismic part is not RG 1.200, therefore impact will be addressed 13

14 Configuration Risk Control

  • Configuration Risk Calculations

- All plants use CAFTA for PRA quantification and model development except that SEA uses Riskman

  • EPRI Phoenix Risk Monitor will be used for Risk Managed Tech Specs, Configuration Risk Management Program (CRMP), and RICT program
  • Maintenance Rule (a)(4) plans to use same calculation method and tool for non-RMTS conditions 15

Risk Informed Completion Times

  • The RICT processes and technical approach will be structured similar to South Texas Project (Operations/Work Control centered)
  • Software tools and procedures will be implemented to ensure compliance with requirements
  • Organization and position specific training and communication plan will be established to appropriately train plant staff 16

Risk Informed Initiatives Site 4b FIRE MR (a)(4)

Planned LAR Submittal Implemented PSL 3rd Quarter 2013 PTN 3rd Quarter 2013 PDA 3rd Quarter 2013 PBN 4th Quarter 2013 SEA 4th Quarter 2013

  • 17 17

Training and Communication

  • Scope of training for RICT Program

- Requirements of the program

- Configuration risk management program software

- TS Actions included in the program

- Implementing procedures

  • Selected Site and Corporate Personnel 18

Take Aways

- Required for Risk Informed applications, LARs, etc.

  • External events gap assessment completed
  • Effective plant communications of risk insights
  • Transition to NFPA 805 at 4 sites provides confidence in the PRA quality
  • Control of model will be maintained by one set of fleet procedures and a common implementation tool
  • Implementing risk informed initiatives for fleet

- 4b and 5b.

  • 19 19

Questions /

Staff Feedback

  • 20 20
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