ML17341B311

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Acceptance Review Letter, Request to Revise Updated Final Safety Analysis Report to Incorporate Tornado Missile Risk Evaluator Methodology Into Licensing Basis
ML17341B311
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 12/08/2017
From: Ellen Brown
Special Projects and Process Branch
To:
Entergy Operations
Eva Brown, NRR/DORL/LSPB, 301-415-2315
References
EPID L-2017-LLA-0371, GNRO-2017/00061
Download: ML17341B311 (3)


Text

Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 8, 2017

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 -ACCEPTANCE OF PILOT APPLICATION FOR TORNADO MISSILE RISK EVALUATOR METHODOLOGY (EPID L-2017-LLA-0371) (GNR0-2017/00061)

Dear Sir or Madam:

By letter dated November 3, 2017, as supplemented by a letter dated December 6, 2017 (Agencywide Documents Access and Management System (ADAMS) Nos. ML17307A440 and ML173406025, respectively), Entergy Operations, Inc. (the licensee), submitted a pilot license amendment for Grand Gulf Nuclear Station, Unit 1. The proposed amendment request pilots the Nuclear Energy Institute (NEI) 17-02, Revision 1, "Tornado Missile Risk Evaluator Industry Guidance Document" (TMRE), September 2017 ADAMS Accession No. ML17268A036). The proposed amendment request screens systems, structures, and components, using risk values (assessment of external hazard frequencies, system responses, and mitigating actions) to determine whether physical protection from tornado-generated missiles is warranted. The methodology would only be applicable to discovered conditions where tornado missile protection should be but is not currently provided. Future modifications to the facility requiring tornado missile protection would not be evaluated using the TMRE methodology. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 10 CFR 50.34 addresses the content of technical information required.

This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The NRC staff has reviewed your application and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staff's ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, you will be advised by separate correspondence.

The NRC staff did have a comment regarding the characterization of the compliance of the proposed change with current regulations. It is recognized that the submittal is risk-informed and outlines how the proposed change addresses the five principles of risk-informed decision making. As discussed in a public teleconference on November 8, 2017, the discussion in Section 4.1 of the Enclosure to the submittal indicates that the threshold for relief is the risk-based criteria related to the overall plant core damage frequency or large early release frequency. The NRC staff notes that the description regarding continuing compliance with regulations could be enhanced by a more comprehensive discussion of the existing design bases, which is based on the concept that the frequency of damage to unprotected essential safety-related features is sufficiently small and therefore acceptable to not be protected.

As approved in a letter dated July 3, 2017 (ADAMS Accession No. ML17130A742), the NRC staff approved a waiver of the fees in support of the NRC staff's review of the TMRE methodology and the amendment request related to this project. As there is an approved fee waiver, no estimate of resources will be provided. It should be noted that based on the information provided, the NRC staff expects to complete this review no later than July 2018. If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date, the reasons for the changes, will be communicated during the routine interactions with the assigned tornado missile risk evaluator project manager.

The schedule is based on the NRC staff's initial review of the application and it could change, due to several factors including requests for additional information and unanticipated addition of scope to the review.

If you have any questions, please contact me at (301) 415-2315.

Docket No. 50-416 cc: Listserv Sincerely, IRA/

Eva A. Brown, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ML173418311 OFFICE NRR/DORL/LSPB/PM NRR/DORL/LSPB/LA NAME EBrown JBurkhardt DATE 12/08/2017 12/8/17 NRR/DORL/LSPB/BC DBroaddus 12/08/2017