ML15308A107

TSTF-505 LAR - NRC Pre-Submittal, November 5, 2015 Meeting Slides

ML15308A107
Person / Time
Site:	Calvert Cliffs
Issue date:	11/05/2015
From:	Exelon Corp
To:	Office of Nuclear Reactor Regulation
References
TAC MF6978, TAC MF6979, TSTF-505
Download: ML15308A107 (23)

Text

Calvert Cliffs/NRC Calvert Cliffs/NRC Pre-Submittal Meeting Ri k I f d C l ti Ti Risk Informed Completion Times TSTF-505 License Amendment Request November 5, 2015

Agenda

• Introduction

• License Amendment Request q

• PRA Models and CRMP Summary

• Implementation p

• Next Steps

• Closing Remarks Closing Remarks 2

Desired Meeting Outcomes

• Discuss license amendment content

• Identify variances from TSTF-505 y

• Provide overview of Configuration Risk and PRA models

• Discuss NFPA 805 and associated modifications

• Confirm level of specificity (e.g., functionality) in LAR p

y (

g y)

• Validate timeline for December 2015 submittal 3

License Amendment Request License Amendment Request

CCNPP LAR Content Based on TSTF-505 and NEI 06-09

• 27 LCOs

• Modes 1 and 2 only

• New TS Section 5.5 Program

• Variances from TSTF-505

-RICT added to LCOs not in TSTF-505 O h i

-Other variances 5

CCNPP TS 3 7 3 Auxiliary Feedwater (AFW)

CCNPP TS 3.7.3, Auxiliary Feedwater (AFW)

System

• Conditions not in TSTF-505 or NUREG-1432 (CEOG ITS)

CCNPP TS 3 7 3 B One motor driven AFW pump

-CCNPP TS 3.7.3.B - One motor-driven AFW pump inoperable

-CCNPP TS 3.7.3.C - Two AFW pumps inoperable p

p p

-Note: CCNPP AFW is a two-train system

• AFW is modeled in PRA

• RICT added to each respective Required Action

-Consistent with similar TSTF-505 changes 6

CCNPP TS 3.7.6, Service Water (SRW) System

• Condition not in TSTF-505 or NUREG-1432

-CCNPP TS 3.7.6.A - One SRW heat exchanger inoperable SRW i d l d i PRA

• SRW is modeled in PRA

• RICT added to Required Action Consistent ith similar TSTF 505 changes

-Consistent with similar TSTF-505 changes 7

CCNPP TS 3 7 15 Main Feedwater Isolation CCNPP TS 3.7.15, Main Feedwater Isolation Valves

• LCO/Condition not in TSTF-505 but is in NUREG-1432 CCNPP TS 3 7 15 A One or more MFIVs inoperable

-CCNPP TS 3.7.15.A - One or more MFIVs inoperable

- Already includes restoration action

• MFIVs modeled in PRA MFIVs modeled in PRA

• RICT added to existing Required Action

-Consistent with similar TSTF-505 changes Consistent with similar TSTF 505 changes 8

Other Variances

• TSTF-505 LCOs/Conditions that CCNPP TS currently do not have will not be adopted N

R i

d A ti ith 1 h CT th ti

• New Required Actions with 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> CT or the option to use RICT Consistent with TSTF 505

-Consistent with TSTF-505

• Subtle differences in Condition/RA wording

• Typed TS pages not included

• Typed TS pages not included 9

Additional Activities

• Participating in NEI TSTF-505 Industry Task Force

• Monitoring TSTF-505 RAIs from other applicants

• Addressing TSTF-505 issues raised by NRC

- PRA Functionality and Loss of Function Detailed Risk Management Actions

- Detailed Risk Management Actions

- Maintaining safety margin 10

PRA Models and Configuration PRA Models and Configuration Risk Management Program (CRMP)

(CRMP)

I t l E t PRA Internal Events PRA

• Peer review by PWROG conducted in June 2010 y

• Performed against requirements in PRA Standard Parts 2 (Internal Events) and 3 (Internal Flooding)

(

)

(

g)

• 97% of Supporting Requirements meet PRA Standard Capability Category II

-Majority of peer review findings related to documentation

-Findings addressed in latest internal events PRA model update

-No significant impact on CDF or LERF No significant impact on CDF or LERF

-Supporting Requirements met at Capability Category II after resolution of findings 12

Internal Fire PRA

• Peer review by PWROG conducted in January Peer review by PWROG conducted in January 2012

• Performed against requirements in PRA Standard Performed against requirements in PRA Standard Part 4 (Internal Fire) and RG 1.200, R2 following NEI 07-09 peer review process

• Supporting Requirements judged to meet Capability Category II with limited exceptions:

-All findings dispositioned as part of NFPA-805 submittal process

-Supporting Requirements met at Capability Category II after resolution of findings g

13

Seismic Risk

• No Current CCNPP Seismic PRA

• Current hazard (EPRI 2013) lower than IPEEE

-Seismic risk estimated using NRC approach for GSI-199

-Same as Vogtle TSTF-505 submittal approach Plant level HCLPF SSC based on IPEEE and CCNPP

-Plant level HCLPF SSC based on IPEEE and CCNPP EDG AOT

• Seismic penalty will be applied to all RICTs p

y pp 14

High Wind Risk

• Peer-reviewed high wind PRA model not available Peer reviewed high wind PRA model not available

• CCNPP Wind/Tornado Methodology

• Site walk-down to identify vulnerable SSCs for safe shutdown y

• Tornado strike frequency based on NUREG/CR-4661, Rev. 2

• Point and line strike model applied for tornadoes of all strengths strengths

• Assumes off-site power and any SSC failures are non-recoverable C l l t b

di i k b d

th hi h t

• Calculate a bounding risk based on the highest value, for cases not already limited by front-stop Hi h i d i k lt ill b li d t ll RICT

• High wind risk penalty will be applied to all RICTs 15

RICT CRMP Model

• Real time risk model as currently used for existing Technical Specification CRM U

PARAGON ft

• Uses PARAGON software

• Incorporates RICT/RMAT calculation, tracking, and t

di f

t trending features

• Handles multiple overlapping configurations D

l d

ith t

i t

• Developed with operator input 16

Plant Modifications

• Fire PRA models rely on installation of modifications

• RICT Program not implemented until modifications complete

• Most Unit 1 modifications scheduled for implementation in 2016; Unit 2 in 2017 17

Summary of PRA Models

• PRA models developed and peer-reviewed

-Internal events Internal fire

-Internal fire

• Updated screening for RG 1.200, Rev. 2 hazards

-Only seismic and high wind not screened Only seismic and high wind not screened

• Total CDF/LERF meet RG 1.174, Rev. 2 criteria 18

Implementation Plan Implementation Plan

Implementation

• Operations coordinates RICT implementation

• Cross-functional team supporting implementation

• RICT implemented in Modes 1 and 2 only

• CRMP tool and PRA Models updated to support RICT

• Procedure changes, training, and qualifications Sit id C

i ti L

d Ali t

• Site-wide Communications, Leader Alignment Meetings, and Department All Hands Meetings 20

Procedures and Training

• Procedures

• Procedures

-Revised to address risk management action times, PRA functionality, and incremental risk tracking New RICT Program Procedure

-New RICT Program Procedure

• Level 1 Training

-Hands-on (detailed) training for Operators and Work M

t Management

-Classroom training to address how RICT impacts Station Operations I t t d ith t

li

-Integrated with current online processes

• Level 2 Training

-Support training for managers on process, expectations, pp g

g p

p limitations

• Level 3 Training

-Awareness training for all others 21

Next Steps

• Submit the LAR by December 2015

• Develop procedures, refine software and conduct p p training in parallel with NRC review in 2016

• Ready to implement in 2017

• Pilot lessons for fleet application 22

Closing Remarks Closing Remarks