ML14203A030
| ML14203A030 | |
| Person / Time | |
|---|---|
| Issue date: | 07/17/2014 |
| From: | Nicholas Difrancesco Japan Lessons-Learned Division |
| To: | Mauer A Nuclear Energy Institute |
| References | |
| Download: ML14203A030 (8) | |
Text
1 NRR-PMDAPEm Resource From:
DiFrancesco, Nicholas Sent:
Thursday, July 17, 2014 11:10 AM To:
MAUER, Andrew (anm@nei.org)
Cc:
Jackson, Diane; Munson, Clifford; Whaley, Sheena; Kock, Andrea
Subject:
Transmittal of NRC Comments on the Expedited Seismic Evaluation Process (ESEP) Draft Template Rev 0b Attachments:
ESEP TOC Template - NRC July 17 2014 Comments.pdf
- Andrew, In support of the July 23, 2014, public meeting on the Expedited Seismic Evaluation Process (ESEP) Template enclosed are NRC working comments on the NEI draft template dated June 23, 2014.
A version of the NRC comments will be included as part of the public meeting summary.
- Thanks, Nick Project Manager - Seismic Walkdowns and Reevaluations U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Japan Lesson Learned Project Directorate nicholas.difrancesco@nrc.gov l Tel: (301) 415-1115
Hearing Identifier:
NRR_PMDA Email Number:
1436 Mail Envelope Properties (Nicholas.DiFrancesco@nrc.gov20140717111000)
Subject:
Transmittal of NRC Comments on the Expedited Seismic Evaluation Process (ESEP) Draft Template Rev 0b Sent Date:
7/17/2014 11:10:24 AM Received Date:
7/17/2014 11:10:00 AM From:
DiFrancesco, Nicholas Created By:
Nicholas.DiFrancesco@nrc.gov Recipients:
"Jackson, Diane" <Diane.Jackson@nrc.gov>
Tracking Status: None "Munson, Clifford" <Clifford.Munson@nrc.gov>
Tracking Status: None "Whaley, Sheena" <Sheena.Whaley@nrc.gov>
Tracking Status: None "Kock, Andrea" <Andrea.Kock@nrc.gov>
Tracking Status: None "MAUER, Andrew (anm@nei.org)" <anm@nei.org>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 621 7/17/2014 11:10:00 AM ESEP TOC Template - NRC July 17 2014 Comments.pdf 233433 Options Priority:
Standard Return Notification:
No Reply Requested:
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Normal Expiration Date:
Recipients Received:
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EXPEDITED SEISMIC EVALUATION PROCESS (ESEP) REPORT TEMPLATE Draft 0b June 23, 2014 Note: This version of the ESEP Template includes a proposed Table of Contents with some guidance on the proposed content in each section.
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EXPEDITED SEISMIC EVALUATION PROCESS REPORT TABLE OF CONTENTS EXECUTIVE
SUMMARY
(OPTIONAL) 1.0 Purpose and Objective This section should include text explaining the purpose of the ESEP and objective of the report.
TheintentoftheESEPistoperformaninterimactioninresponsetotheNRCs50.54(f)
lettertodemonstrateseismicmarginthroughareviewofasubsetoftheplant
equipmentthatcanbereliedupontoprotectthereactorcorefollowingbeyonddesign
basisseismicevents.
ItisimplementedusingthemethodologiesintheNRCendorsedguidanceinEPRI
3002000704,SeismicEvaluationGuidance:AugmentedApproachfortheResolutionof
FukushimaNearTermTaskForceRecommendation2.1:Seismic[1].
TheobjectiveofthisreportistoprovidesummaryinformationdescribingtheESEP
evaluationsandresults.Thelevelofdetailprovidedinthereportisintendedtoenable
NRCtounderstandtheinputsused,theevaluationsperformed,andthedecisionsmade
asaresultoftheinterimevaluations.
2.0 Brief Summary of the FLEX Seismic Implementation Strategies This section should include text summarizing the plant FLEX seismic implementation strategy including the key equipment and cooling water sources credited in the strategy.
The summary should include a description of components selected to achieve functions related to seismic implementation strategies. The text should be derived from, and refer to, the plant FLEX submittal. This description is expected to be a few paragraphs long.
As necessary, the information provided should include or refer to Phase 1 Equipment, Phase 2 and 3 Equipment and Connections in relation to the plant [P&ID] piping and instrumentation diagram.
3.0 List of Selected Equipment (ESEL) 3.1 Equipment Selection Process and ESEL This section should include text describing the equipment selection process, in accordance with Section 3 of the Augmented Approach guide. This should include the selected items from the installed plant equipment credited in the FLEX strategies during Phase 1, 2 and 3 mitigation of a Beyond Design Basis External Event (BDBEE).
A complete list of the ESEL items should be included as a table in Attachment A of the submittal. At a minimum, the table should identify the equipment (Equipment ID and description), location of the equipment, and the Normal State and Desired
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State for the FLEX strategy and any other relevant information unique or necessary for review as stated in the augmented approach guidance.
3.2 Justification for use of Equipment that is not the primary means for FLEX implementation In accordance with the Augmented Approach guide, the ESEL should typically use equipment that is the primary means of implementing the FLEX strategy; however, alternate equipment may be used with justification. For any ESEL equipment that is not considered the primary means, justification should be provided explaining the basis for selecting the alternate equipment.
4.0 GMRS 4.1 Plot of GMRS submitted by the Licensee This section should include the site horizontalControl Point elevation and Control Point GMRS as submittedused in the sitesESEP evaluation. If the aforementioned are different from the March 2014 submittal, a description of the differences should be included.
4.2 Comparison to SSE.
The section should include a comparison of the site GMRS to the horizontal SSE as explained in the sites March 2014 submittal.
5.0 Review Level Ground Motion 5.1 Description of RLGM selected This section should include a description of the selected review level ground motion (RLGM) for the ESEP in accordance with the criteria described in Section 4 of the Augmented Approach guide. This would typically be a scaled version of the plants SSE, not to exceed two times the SSE, and/or the GMRS1.
Generally, RLGM is a scaled version of the plants SSE, not to exceed two times the SSE, and/or the GMRS2. The maximum ratio of GMRS/SSE used and the frequency at which it happens should be described. The RLGM should be provided in tabular form (frequency and acceleration at 5% damping) and as a plot.
5.2 Process to estimate ISRS
1SomeplantsmayusethescaledSSEforequipmentmountedinstructures(whereISRSestimateswouldbe
necessary)andtheGMRSforsurfacemounteditems(whereISRSestimateswouldnotbenecessary).
2SomeplantsmayusethescaledSSEforequipmentmountedinstructures(whereISRSestimateswouldbe
necessary)andtheGMRSforsurfacemounteditems(whereISRSestimateswouldnotbenecessary).
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This section should describe the process used to develop in-structure response spectra (ISRS) for the ESEP. The primary options will typically be either scaled ISRS derived from the SSE using the RLGM scale factor or new ISRS derived using the GMRS.
Alternatively, if the ISRS and other parameters were developed using a method other than scaling, a description of the method must be included. This description should include: applicable guidance, assumptions, and approach.
6.0 Seismic Margin Evaluation Approach 6.1 Summary of methodologies used This section should describe the methodologies used to perform the seismic margin evaluations. Typically, these would include seismic walkdowns as described in EPRI NP 6041, screening evaluations using EPRI NP-6041 screening tables, HCLPF calculations, and fragility calculations.
6.2 HCLPF screening process This section should describe how HCLPF based screening evaluations were performed. Results of the screening should be included.
6.3 HCLPF calculation process This section should describe how equipment specific HCLPF calculations were performed, including information related to the deterministic or probabilistic (fragility) process as applicable.
6.4 Functional evaluations This section should describe functional evaluations for functional failure modes of electrical and mechanical portions of the installed Phase 1 equipment (Augmented Approach Section 3.2) 6.5 Tabulated ESEL HCLPF values (including Key failure modes)
This section should provide a discussion of the HCLPF values for the items on the ESEL, including an indication of the controlling failure mode (e.g. anchorage, equipment capacity, functional failure). For items screened out using NP 6041 screening tables, the screening level can be provided as the HCLPF value and the failure mode can be listed as Screened, (unless the controlling HCLPF value is governed by anchorage). If there are ESEL items that are screened by other methods such as large available margins in a previous calculation, the screening basis should be stated.
Tabulated HCLPF values should be included in Attachment B.
6.6 Assessment of Exceedance above 2x SSE (as applicable)
This section should describe an assessment of seismic margin for ESEL plant equipment where the GMRS exceeds 2x the SSE in 1 to 10 Hz frequency range.
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Generally, this section would be included for Group 1 and a limited number of Group 2 plants based on the Section 4 GMRS. The description should address how the exceedance above the scaled SSE is being dispositioned.
7.0 Inaccessible Items 7.1 Identification of ESEL items inaccessible for walkdowns Any ESEL items that were inaccessible (e.g. in-containment or electrically energized) and require follow up seismic walkdowns3 should be identified. A description of why the items were inaccessible.
7.2 Planned walkdown/evaluation schedule (dates for completion)
A schedule for performing seismic walkdowns for the inaccessible items identified above should be provided. A Regulatory Commitment in Section 8.4 tracking submittal of a letter summarizing the results of walkdowns and evaluations of all inaccessible items and the expected date of the submittal should be provided.
8.0 ESEP Conclusions and Results 8.1 ESEP Conclusions This section should describe the overall ESEP conclusions from the review.
8.2 Identification of Required Modifications/Mitigating Strategies This section should describe any ESEL equipment plant modifications necessary to achieve HCLPF values that bound the RLGM.
8.3 Modification/Mitigating Strategies Implementation Schedule This section should include the implementation schedule for the modifications identified above. [Modifications should be made within 2 years of submitting the plant specific ESEP to the NRC. If a plant outage is required to implement the ESEL item modification, the modifications should be completed within 2 outages of submitting the ESEP. ] The submittal should identify the outage for the planned modification(s). A Regulatory Commitment in Section 8.4 should be provided to track completion of the planned modifications and a letter provided to the NRC following completion of the equipment modifications.
3ThewalkdowncriteriainEPRINP6041providesforanumberofwaysofconfirmingtheinstalledconditionof
equipment,includingdetailedseismicwalkdowns,walkbysforsomeequipment,andphotographicorother
confirmatoryevidence.ThekeycriterionisthattheSeismicReviewTeamneedstohaveadequateconfidencein
theinstalledconditionoftheequipment,includingmaterialcondition,installedanchorage,andapplicable
potentialseismicinteractionconcerns.Thesecriteriashouldhelplimitthenumberofinaccessibleitemsrequiring
followupseismicwalkdowns.
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8.4 Summary of Regulatory Commitments This section will provide a table summary of Regulatory Commitments associated with inaccessible walkdown items, completion of equipment modifications, and transmittal of associated letter updates.
9.0 References
- 1)
Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1 - Seismic. EPRI, Palo Alto, CA: May 2013. 3002000704.
- 2)
A Methodology for Assessment of Nuclear Power Plant Seismic Margin, Rev. 1, August 1991, Electric Power Research Institute, Palo Alto, CA. EPRI NP-6041
- 3)
PLANT NTTF 2.1 Seismic March 31 Submittal
- 4)
PLANT FLEX Documentation Attachments Attachment A - ESEL List Attachment B - ESEL Seismic Margin Results (Screened out at RLGM or HCLPF values and associated key failure modes)