ML14191B148
| ML14191B148 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 07/17/2014 |
| From: | Plant Licensing Branch III |
| To: | |
| References | |
| Download: ML14191B148 (1) | |
Text
Updated Talking Points for July 17, 2014, Public Teleconference with Exelon Regarding Braidwood and Byron AFW Cross-tie Amendment Proposed Talkingq Points for Public Teleconference
- 1. The NRC staff supports the concept of utilizing the AFW cross tie to provide an extra layer of defense in depth for mitigating a beyond design basis event.
- 2. Preliminary Position on GDC 5. (Lead: Balance of Plant Branch)
In accordance with GDC 5, SSCs shall not be shared among nuclear power units unless it can be shown that such sharing will not significantly impair their ability to perform their safety functions, including, in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining units.
One plant does not have sufficient excess AFW flow capacity to supply two units while sustaining a single failure. Therefore, the plant cannot meet the GDC 5 criteria for sharing AFW flow without significantly impairing its safety function.
- 3. Preliminary Position on Entering an Action Statement to Use an AFW Train on another Unit.
(Lead: Technical Specifications Branch)
The STS states that reasons for intentionally entering an action statement include performing corrective maintenance, preventative maintenance, surveillances, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. The STS bases states that intentional entry should not be for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead.
Currently, STS 3.0.2 does not specifically delineate authorization for intentionally entering an action statement for the purpose of using that safety related train on another unit on site.
A license change to allow such entry is not supported.
- 4. Preliminary Position on Entry into 50.54(x). (Lead: Technical Specifications Branch)
The utilization of the AFW cross tie at Byron and Braidwood nuclear station to mitigate the consequences of a beyond design basis event would fall under the authority granted to the licensee under 10 CFR 50.54(x).
- 5. Preliminary Position on writing a preplanned contingency procedure. (Lead: Balance of Plant Branch)
The licensee's actions to prepare a procedure and train station personnel in the use of this procedure are sensible actions. However, the procedure should not direct the station personnel to invoke 10 CFR 50.54(x), for the authority to invoke 10 CFR 50.54(x) lies with the licensed senior reactor operator under 10 CFR 50.54(y). An alternative may be that the procedure have an entry condition that 50.54 (x) has been invoked.
For example, procedures that direct operators to utilize beyond design bases of the plant should not be located in APs or EOPs but should be in beyond design bases procedures such as Mitigating Strategies Procedures.