ML15042A415

Pre-Submittal Public Meeting Draft Slides on Risk- Informed Completion Times

ML15042A415
Person / Time
Site:	Palo Verde
Issue date:	02/11/2015
From:	Watford M Plant Licensing Branch IV
To:	Edington R Arizona Public Service Co
Watford M
References
TAC MF5559, TAC MF5560, TAC MF5561
Download: ML15042A415 (30)

Text

Palo Verde / NRC Meeting Risk Informed Completion Times February 17, 2015

Introductions

Bryan Thiele Department Leader Nuclear Engineering

Agenda

• Introduction Bryan Thiele

• Palo Verde Overview Tom Romay

• License Amendment Thomas Weber

• PRA Summary Everett DePue

• Implementation Plan Tom Romay

• Path Forward and Closing Comments Bryan Thiele 3

Desired Meeting Outcomes

• Summarize PVNGS design with focus on unique features

• Discuss license amendment content and variances from TSTF 505

• Provide overview of PRA models

• Discuss implementation plan

• Describe path forward 4

Palo Verde Design Overview Tom Romay Shift Manager Senior Reactor Operator

Palo Verde Design Features

• Three identical, separate Units, minimal shared SSCs

• No pressurizer PORVs

• Low leakage RCP seals on loss of seal cooling

• Four channels of class instrumentation (two trains w/2 channels each)

• Four AC vital buses and DC buses

• Demonstrated capability to feed SG with no AC/DC power 6

RICT Timeline License Amendment Drafted and Sent Out for Cross Organization Review -

1st Cut Fire and Seismic PRA Development Benchmarking with Vogtle and Diablo Canyon All PRA Peer Reviews Complete (Internal Events, Fire, Flood, Seismic)

LAR Final PVNGS Internal Review LAR Submittal Approval and Implementation 2012 2013 2014 2015 2016+

7

License Amendment Request Thomas Weber Department Leader Nuclear Regulatory Affairs

PVNGS LAR Content

• Based on TSTF 505-A & NEI 06-09-A

- Scope includes components modeled in PRA

- 25 LCOs

- Mode 1 and 2 only

- New TS Section 5.5 Program

- Variances from TSTF 505 addressed in LAR and include:

• RICT added to two LCOs not in TSTF 505

• Miscellaneous variances described in LAR 9

TS 3.4.12, Pressurizer Vents

• NOT in TSTF 505 or NUREG 1432

• In PV Safety Analysis

• Modeled in PRA

• RICT added to Two Required Actions

- Note added to preclude voluntary entry with with all pressurizer vent paths inoperable 10

TS 3.7.3, MFIVs

• Not in TSTF 505 but is in NUREG 1432

• LAR adds restoration action

• MFIVs modeled in PRA

• RICT added to Two Required Actions

- Note added to preclude voluntary entry with both MFIVs in same flow path INOP 11

Miscellaneous Variances

- TS 3.7.2, MSIVs

• Did not add RICT for some restoration conditions

- TS 3.7.4, ADV

• Added note to preclude voluntary entry with all ADVs INOP

- TS 3.7.9, UHS

• Added restoration condition

• Added note to preclude voluntary entry

- TS 3.8.7, Inverters

• Revised note since PVNGS Design has two inverters per train supporting 4 channels of vital instruments 12

Summary

- TSTF 439 in progress

- Minimizing other LARs at PVNGS that have changes to TSTF 505 LCOs

- Communicating with other Utilities

- Participating in Industry Committees

- Monitoring TSTF 505 RAIs 13

PRA Models Everett DePue Senior Engineer PRA Lead for TSTF-505

Summary of PRA Models

• PRA models developed and peer reviewed

- Internal events

- Internal flood

- Internal fire

- Seismic

• RG 1.200 Rev. 2 hazards screened and peer reviewed

• Total CDF/LERF meet RG1.174 Rev. 2 limits

• Internal events and internal flood risk very low

• CDF/LERF dominated by internal fire and seismic hazards 15

Internal Events PRA

• Peer review by CEOG conducted in 1999

• Self-assessment performed against entire RA-Sa-2009 in 2015

• RA-Sa-2009 Supporting Requirements met to Capability Category II except:

- Some sub-elements of SY-C1, SY-C2 System Notebook Documentation need completion

• To be completed prior to RICT Program implementation 16

Internal Flood PRA

• Industry Peer Review conducted in 2010

• All ASME/ANS PRA requirements met to Capability Category II after peer review findings addressed 17

Internal Fire PRA

• PVNGS is not NFPA-805 plant,

- Complies with methods in NUREG/CR-6850

• Industry Peer Review conducted in 2012

• Follow-up Industry Peer Review conducted in 2014 - addressed 2012 findings

• All ASME/ANS requirements met to Capability Category II after peer review findings addressed 18

Seismic PRA

• Industry peer review conducted in 2013

• All ASME/ANS requirements met to Capability Category II after peer review findings addressed except

- SPR B7 Complementary Success Logic

• Meets CC II for ASME/ANS RA-Sb-2013 19

Plant-Specific Modeling

• RICT CRMP model will be either:

- Real time risk model as currently used for existing Technical Specification CRMP OR

- Pre-solved solutions (STP approach) 20

Plant Modifications

• PRA models rely on installation of modifications or taking compensatory measures

• RICT Program will not be implemented until modifications complete or compensatory measures in place

• FLEX strategies not yet reflected in the PRA models - conservatism 21

Implementation Plan Tom Romay Shift Manager Senior Reactor Operator

Implementation Plan

• Engineering coordinate RICT implementation

• Cross organization team supporting implementation

• RICT implemented in Modes 1 and 2 only

• CRMP tool PRA Models will include Internal Events, Internal Flooding, Fire, and Seismic

• Procedure changes, training, and qualifications will support RICT CRMP capability

- Extensive use of industry participation &

benchmarking to develop program, procedures, training 23

Procedures

• Revise 40DP-9RS01, Operations Department Online Nuclear Risk Management Mode 1 and 2, to include RICT, RMAT, and RMA determinations

• New RICT Program Procedure 24

Training

• Licensed Operators

- Hands-on training on RICT calculations

- Classroom training to address how RICT impacts Station Operations

• Station Management

- Affected managers trained on process, expectations, limitations

• Engineering, Work Management 25

Communications

• Industry peers via TSTF-505 task force

• Site-wide Articles at Station

- While submittal under review

- Once submittal is approved

• Leader Alignment Meetings

• Department All Hands Meetings 26

Credited Modifications

• DC ammeter circuits

• Non-class 1E DC motor circuits

• Replace RCP control cables with fire rated cables

• Install new permanently staged Steam Generator (SG) makeup pump that utilizes FLEX connections

• Breaker coordination on risk significant non-class 1E motor control centers/panels 27

Path Forward and Closing Comments Bryan Thiele Department Leader Nuclear Engineering

Path Forward

• Address Fire PRA peer review comments

• Submit LAR in June

• Finalize scope and install modifications

• Complete procedures, software and training in parallel with NRC review

• Implement in late 2016 29

We SAFELY and efficiently generate electricity for the long term 30