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Category:SAFETY EVALUATION REPORT--LICENSING & RELATED ISSUES
MONTHYEARML20217B5401999-10-0606 October 1999 Safety Evaluation Supporting Amend 193 to License DPR-40 ML20211J9321999-09-0202 September 1999 Safety Evaluation Concluding That Licensee Proposed Alternatives Provide Acceptable Level of Quality & Safety. Proposed Alternatives Authorized for Remainder of Third ten- Yr ISI Interval for Fort Calhoun Station,Unit 1 ML20210G2181999-07-27027 July 1999 Safety Evaluation Supporting Amend 192 to License DPR-40 ML20210D9951999-07-22022 July 1999 Safety Evaluation Supporting Amend 191 to License DPR-40 ML20206L4241999-05-10010 May 1999 Safety Evaluation Supporting Corrective Actions to Ensure That Valves Are Capable of Performing Intended Safety Functions & OPPD Adequately Addressed Requested Actions Discussed in GL 95-07 ML20206M2601999-05-0606 May 1999 SER Concluding That Licensee IPEEE Complete Re Info Requested by Suppl 4 to GL 88-20 & IPEEE Results Reasonable Given FCS Design,Operation & History ML20205Q5831999-04-15015 April 1999 Safety Evaluation Supporting Amend 190 to License DPR-40 ML20198S3771998-12-31031 December 1998 Safety Evaluation Supporting Amend 189 to License DPR-40 ML20198S4831998-12-31031 December 1998 Safety Evaluation Supporting Amend 188 to License DPR-40 ML20154M4881998-10-19019 October 1998 Safety Evaluation Supporting Amend 186 to License DPR-40 ML20154N2411998-10-19019 October 1998 Safety Evaluation Supporting Amend 187 to License DPR-40 ML20236V4891998-07-30030 July 1998 Safety Evaluation Relating to Response to GL 87-02,suppl 1 for Fort Calhoun Station,Unit 1 ML20248C0671998-05-21021 May 1998 Safety Evaluation Granting Licensee Request for Exemption from Technical Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 ML20217L7201998-03-23023 March 1998 Safety Evaluation Supporting Amend 185 to License DPR-40 ML20203M4161998-02-0303 February 1998 Safety Evaluation Supporting Amend 184 to License DPR-40 ML20203A4291998-01-26026 January 1998 Safety Evaluation Supporting Amend 183 to License DPR-40 ML20199L0711997-11-24024 November 1997 Safety Evaluation Supporting Amend 182 to License DPR-40 ML20198Q4031997-10-28028 October 1997 Safety Evaluation Re Control Room Habitability Requirements ML20137L6241997-03-27027 March 1997 Safety Evaluation Supporting Amend 181 to License DPR-40 ML20134N7751997-02-13013 February 1997 Safety Evaluation Supporting Amend 180 to License DPR-40 ML20134M6171997-02-13013 February 1997 Safety Evaluation Denying Licensee Request for Approval to Use ASME Section XI Code Case N-416-1 W/Proposed Exception & Code Case N-498-2 as Alternative to Required Hydrostatic Pressure Test ML20133P9161997-01-23023 January 1997 Safety Evaluation Accepting Revised Temperature Limits for DG-1 & DG-2 ML20133C2771996-12-30030 December 1996 Safety Evaluation Supporting Amend 179 to License DPR-40 ML20132F4911996-12-0909 December 1996 Safety Evaluation Related to Individual Plant Evaluation Omaha Power District,Fort Calhoun Station,Unit 1 ML20134M0871996-11-19019 November 1996 Safety Evaluation Supporting Request for Relief from Modifying Supports SIH-3,SIS-63,SIS-65 & RCH-13 at Fort Calhoun Station ML20129H3371996-10-25025 October 1996 Safety Evaluation Supporting Amend 178 to License DPR-40 ML20128F6441996-10-0202 October 1996 Safety Evaluation Supporting Amend 177 to License DPR-40 ML20129G3131996-09-27027 September 1996 Safety Evaluation Supporting Amend 176 to License DPR-40 ML20059J1831994-01-14014 January 1994 Safety Evaluation Supporting Amend 160 to License DPR-40 ML20059J2491994-01-14014 January 1994 Safety Evaluation Supporting Amend 159 to License DPR-40 ML20058G9371993-12-0303 December 1993 Safety Evaluation Supporting Amend 158 to License DPR-40 ML20058F5951993-11-22022 November 1993 Safety Evaluation Supporting Amend 157 to License DPR-40 ML20058C7491993-11-18018 November 1993 Safety Evaluation,Authorizing Alternative,On One Time Basis Only,W/Conditions That Licensee Perform Volumetric Exam of nozzle-to-vessel Welds During First Refueling Outage of Third 10-yr Insp Interval ML20059L7081993-11-10010 November 1993 Safety Evaluation Accepting Licensee Proposed Changes to Low Power Physics Testing Program ML20059G6601993-10-29029 October 1993 Safety Evaluation Supporting Amend 156 to License DPR-40 ML20057E3471993-10-0101 October 1993 Safety Evaluation Advising That Based on Determination That Alternative Testing Consistent w/OM-10,paragraph 4.3.2.2. Requirements,No Relief Required ML20056E5411993-08-12012 August 1993 Safety Evaluation Supporting Amend 155 to License DPR-40 ML20056E5371993-08-10010 August 1993 Safety Evaluation Supporting Amend 154 to License DPR-40 ML20056D6801993-07-26026 July 1993 Safety Evaluation Supporting Amend 153 to License DPR-40 ML20128B8241993-01-26026 January 1993 Safety Evaluation Supporting Amend 149 to License DPR-40 ML20128D4511992-11-30030 November 1992 Safety Evaluation Accepting Evaluation of 120-day Response to Suppl 1 to GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors, Unresolved Safety Issue A-46 ML20062G6621990-11-19019 November 1990 Safety Evaluation Supporting Amend 134 to License DPR-40 ML20216K0661990-11-14014 November 1990 Safety Evaluation Denying Util 900221 & 0622 Requests for Exemption from App R of 10CFR50 for Fire Area 34B,upper Electrical Penetration Room.Current Level of Fire Protection Does Not Meet Section III.G.2 Requirements ML20062B6161990-10-12012 October 1990 Safety Evaluation Supporting Amend 133 to License DPR-40 ML20055G0221990-07-0606 July 1990 Safety Evaluation Supporting Amend 132 to License DPR-40 ML20246A0741989-08-17017 August 1989 Safety Evaluation Re Inservice Testing Program for Pumps & Valves ML20245H9031989-08-15015 August 1989 Safety Evaluation Re Generic Ltr 83-28,Item 2.1 (Part 1), Equipment Classification (Reactor Trip Sys Components). Licensee Program Meets Requirements of Item 2.1 (Part 1) of Generic Ltr 83-28 & Acceptable ML20245K3481989-08-11011 August 1989 Safety Evaluation Accepting Electrical Isolation Devices for Interfacing Safety & Nonsafety Sys Re Implementation of ATWS Rule ML20247H6421989-07-24024 July 1989 Safety Evaluation Granting 890118 Request for Relief from Hydrostatic Testing Requirements of Section XI of ASME Code ML20248C0851989-06-0202 June 1989 Safety Evaluation Supporting Amend 122 to License DPR-40 1999-09-02
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML20217B5401999-10-0606 October 1999 Safety Evaluation Supporting Amend 193 to License DPR-40 ML20217A9931999-09-30030 September 1999 NRC Regulatory Assessment & Oversight Pilot Program, Performance Indicator Data LIC-99-0096, Monthly Operating Rept for Sept 1999 for Fcs,Unit 1.With1999-09-30030 September 1999 Monthly Operating Rept for Sept 1999 for Fcs,Unit 1.With ML20211J9321999-09-0202 September 1999 Safety Evaluation Concluding That Licensee Proposed Alternatives Provide Acceptable Level of Quality & Safety. Proposed Alternatives Authorized for Remainder of Third ten- Yr ISI Interval for Fort Calhoun Station,Unit 1 LIC-99-0084, Monthly Operating Rept for Aug 1999 for Fort Calhoun Station.With1999-08-31031 August 1999 Monthly Operating Rept for Aug 1999 for Fort Calhoun Station.With ML20216E6431999-08-26026 August 1999 Rev 19 to TDB-VI, COLR for FCS Unit 1 ML20210R1961999-07-31031 July 1999 Monthly Operating Rept for July 1999 for Fcs,Unit 1 ML20210G2181999-07-27027 July 1999 Safety Evaluation Supporting Amend 192 to License DPR-40 ML20210D9951999-07-22022 July 1999 Safety Evaluation Supporting Amend 191 to License DPR-40 ML20216E6361999-07-21021 July 1999 Rev 18 to TDB-VI, COLR for FCS Unit 1 ML20210R2081999-06-30030 June 1999 Revised Monthly Operating Rept for June 1999 for Fcs,Unit 1 LIC-99-0065, Monthly Operating Rept for June 1999 for Fort Calhoun Station,Unit 1.With1999-06-30030 June 1999 Monthly Operating Rept for June 1999 for Fort Calhoun Station,Unit 1.With ML20196H8621999-06-30030 June 1999 NRC Regulatory Assessment & Oversight Pilot Program, Performance Indicator Data, June 1999 Rept ML20210P5461999-06-0808 June 1999 Rev 0,Vols 1-5 of Fort Calhoun Station 1999 Emergency Preparedness Exercise Manual, to Be Conducted on 990810. Pages 2-20 & 2-40 in Vol 2 & Page 4-1 in Vol 4 of Incoming Submittal Not Included ML20195B4581999-05-31031 May 1999 Rev 3 to CE NPSD-683, Development of RCS Pressure & Temp Limits Rept for Removal of P-T Limits & LTOP Requirements from Ts ML20207H7401999-05-31031 May 1999 Performance Indicators Rept for May 1999 LIC-99-0053, Monthly Operating Rept for May 1999 for Fort Calhoun Station,Unit 11999-05-31031 May 1999 Monthly Operating Rept for May 1999 for Fort Calhoun Station,Unit 1 ML20195B4521999-05-17017 May 1999 Technical Data Book TDB-IX, RCS Pressure - Temp Limits Rept (Ptlr) ML20206L4241999-05-10010 May 1999 Safety Evaluation Supporting Corrective Actions to Ensure That Valves Are Capable of Performing Intended Safety Functions & OPPD Adequately Addressed Requested Actions Discussed in GL 95-07 ML20206M2601999-05-0606 May 1999 SER Concluding That Licensee IPEEE Complete Re Info Requested by Suppl 4 to GL 88-20 & IPEEE Results Reasonable Given FCS Design,Operation & History LIC-99-0047, Monthly Operating Rept for Apr 1999 for Fort Calhoun Station Unit 1.With1999-04-30030 April 1999 Monthly Operating Rept for Apr 1999 for Fort Calhoun Station Unit 1.With ML20195E8621999-04-30030 April 1999 Performance Indicators, for Apr 1999 ML20205Q5831999-04-15015 April 1999 Safety Evaluation Supporting Amend 190 to License DPR-40 ML20210J4331999-03-31031 March 1999 Changes,Tests, & Experiments Carried Out Without Prior Commission Approval for Period 981101-990331.With USAR Changes Other than Those Resulting from 10CFR50.59 ML20206G2641999-03-31031 March 1999 Performance Indicators Rept for Mar 1999 LIC-99-0034, Monthly Operating Rept for Mar 1999 for Fcs,Unit 1.With1999-03-31031 March 1999 Monthly Operating Rept for Mar 1999 for Fcs,Unit 1.With ML20205J8181999-02-28028 February 1999 Performance Indicators, for Feb 1999 LIC-99-0025, Monthly Operating Rept for Feb 1999 for Fort Calhoun Station,Unit 1.With1999-02-28028 February 1999 Monthly Operating Rept for Feb 1999 for Fort Calhoun Station,Unit 1.With ML20207F3291999-01-31031 January 1999 FCS Performance Indicators for Jan 1999 ML20203B0991998-12-31031 December 1998 Performance Indicators for Dec 1998 LIC-99-0026, 1998 Omaha Public Power District Annual Rept. with1998-12-31031 December 1998 1998 Omaha Public Power District Annual Rept. with LIC-99-0003, Monthly Operating Rept for Dec 1998 for Fort Calhoun Station.With1998-12-31031 December 1998 Monthly Operating Rept for Dec 1998 for Fort Calhoun Station.With ML20198S3771998-12-31031 December 1998 Safety Evaluation Supporting Amend 189 to License DPR-40 ML20198S4831998-12-31031 December 1998 Safety Evaluation Supporting Amend 188 to License DPR-40 ML20196G2251998-12-18018 December 1998 Rev 2 to EA-FC-90-082, Potential Over-Pressurization of Containment Penetration Piping Following Main Steam Line Break in Containment ML20198M3141998-11-30030 November 1998 Performance Indicators Rept for Nov 1998 LIC-98-0172, Monthly Operating Rept for Nov 1998 for Fort Calhoun Station,Unit 1.With1998-11-30030 November 1998 Monthly Operating Rept for Nov 1998 for Fort Calhoun Station,Unit 1.With LIC-98-0160, Special Rept:On 981113,MSL RM RM-064 Was Declared Inoperable Due to Leakage Past Isolation Valve HCV-922.Troubleshooting Has Indicated That Leakage Has Stopped & Cause of Leak Continues to Be Investigated1998-11-25025 November 1998 Special Rept:On 981113,MSL RM RM-064 Was Declared Inoperable Due to Leakage Past Isolation Valve HCV-922.Troubleshooting Has Indicated That Leakage Has Stopped & Cause of Leak Continues to Be Investigated ML20203B0721998-11-16016 November 1998 Rev 6 to HI-92828, Licensing Rept for Spent Fuel Storage Capacity Expansion ML20196E4981998-10-31031 October 1998 Performance Indicators Rept for Oct 1998 ML20196G2441998-10-31031 October 1998 Changes,Tests & Experiments Carried Out Without Prior Commission Approval. with USAR Changes Other than Those Resulting from 10CFR50.59 LIC-98-0154, Monthly Operating Rept for Oct 1998 for Fort Calhoun Station,Unit 1.With1998-10-31031 October 1998 Monthly Operating Rept for Oct 1998 for Fort Calhoun Station,Unit 1.With ML20154M4881998-10-19019 October 1998 Safety Evaluation Supporting Amend 186 to License DPR-40 ML20154N2411998-10-19019 October 1998 Safety Evaluation Supporting Amend 187 to License DPR-40 LIC-98-0136, Monthly Operating Rept for Sept 1998 for Fort Calhoun Station,Unit 1.With1998-09-30030 September 1998 Monthly Operating Rept for Sept 1998 for Fort Calhoun Station,Unit 1.With ML20155G4261998-09-30030 September 1998 Performance Indicators for Sept 1998 ML20154A1251998-08-31031 August 1998 Performance Indicators, Rept for Aug 1998 LIC-98-0122, Monthly Operating Rept for Aug 1998 for Fort Calhoun Station Unit 1.With1998-08-31031 August 1998 Monthly Operating Rept for Aug 1998 for Fort Calhoun Station Unit 1.With ML20238F7231998-08-17017 August 1998 Owner'S Rept for Isis ML18066A2771998-08-13013 August 1998 Part 21 Rept Re Deficiency in CE Current Screening Methodology for Determining Limiting Fuel Assembly for Detailed PWR thermal-hydraulic Sa.Evaluations Were Performed for Affected Plants to Determine Effect of Deficiency 1999-09-30
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- E NUCLEAR FsEGULATORY COMMISSION f WASHINGTON, D.C. 30ee6-4001
\.....,/ l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION !
PELATED TO THE INDIVIDUAL PLANT EVALUATION (IPE) !
l OMAHA DUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 1.0 INTRODUCT.lQN On December 1, 1993, Omaha Public Power District submitted the Fort Calhoun Nuclear Power Plant Individual Plant Evaluation (IPE) submittal in response to Generic Letter 88-20 and associated supplements. On September 12, 1995, the staff sent questions to the licensee requesting additional information. The licensee responded in a letter dated November 30, 1995.
A " Step 1" review of the Fort Calhoun IPE submittal was performed and involved the efforts of Science & Engineering Associates, Inc., Scientech, Inc./ Energy Research, Inc., and Concord Associates in the front-end, back-end, and human reliability analysis (HRA), respectively. The Step 1 review focused on whether the licensee's method was capable of identifying vulnerabilities.
Therefore, the review considered: (1) the completeness of the information, and (2) the reasonableness of the results given the Fort Calhoun design, operation, and history. A more detailed review, a " Step 2" review, was not performed for this IPE submittal. Details of the contractors' findings are in the attached technical evaluation reports (Appendices A, B, and C) of this staff evaluation report (SER).
In accordance with Generic Letter 88-20, Fort Calhoun proposed to resolve Unresolved Safety Issue (USI) A-45, " Shutdown Decay Heat Removal Requirements." No other specific USIs or generic safety issues (GSIs) were proposed for resolution as part of the Fort Calhoun IPE.
The submittal states that the licensee intends to maintain a "living" probabilistic risk assessment.
2.0 EYALUAIION Fort Calhoun is a Combustion Engineering PWR with a large containment. The Fort Calhoun IPE has estimated a core damage frequency (CDF) of 1.4E-05 per reactor-year from internally initiated events, including the contribution of 2E-06 from internal floods. The Fort Calhoun CDF compares reasonably well with that of other PWR planu. Station blackout contributes 35 percent; transients, 31 percent; internal flooding,14 percent; loss of coolant accidents (LOCAs), 8 percent; steam generator tube rupture, 6 percent; 9612240294 961209 PDR ADOCK 05000295 P PDR
interfacing systems LOCA (ISLOCA), 5 percent; and anticipated transients !
without scram, 2 percent. The most important system / equipment contributors to the estimated CDF that appear in the top sequences are:
- 1. Common cause unsuccessful load shed from 4.16 kV AC buses IA3 and IA4.
- 2. Failure of the diesel driven auxiliary feedwater pump.
- 3. Failure of RCP seals given insufficient cooling.
- 4. Diesel generator failure to run.
The licensee's Level 1 analysis appears to have examined the significant initiating events and dominant accident sequences.
Based on the licensee's IPE process used to search for decay hoat removal (DHR) vulnerabilities, and review of Fort Calhoun plant-specific features, the staff finds the licensee's DHR evaluation consistent with the intent of the USI A-45 (DHR Reliability) resolution and is, therefore, acceptable.
The licensee performed an HRA, including both pre- and post-initiator human actions to document and quantify potential failures in human-system interactions and to quantify human-initiated recovary of failure events. The licensee identified the following operator actions as important, based on the Fussel-Vesely importance measure, in the estimate of the CDF:
- 1. Operator failure to use diesel driven feedwater pump to replenish emergency feedwater storage tank.
- 2. Operator fails to use diesel driven fire pump to replenish emergency feedwater storage tank.
- 3. Operator fails to manually tiip 4.16 kV AC circuit breaker, given that breaker does not trip automatically.
However, there appear to be certain limitations in the analysis. For example, there are some characteristics associated with the modeling of mistakes that can lead to seemingly inconsistent results. The model uses different time / reliability correlations depending on whether actions are verification, rule-based, or "other" actions, whether they occur inside or outside the control room, and whether the operators are burdened. It appears that differences in quantification results based on these correlations may be significant. In addition, there appears to be no specific guidance as to which actions should be assigned to include burden. This factor, also, can affect the estimated failure probability.
Despite these lini',ations, the Fort Calhoun HRA analysis appears to include all the appropriate classes of human actions that are likely to contribute to the frequency of core damage, such as, maintenance, test and calibration actions in the pre-accident phase, and failure in decision-making (mistakes) and task execution (slips) in the post-accident phase. It also explicitly
( describes how the human actions should be incorporated into the PRA logic models. For these reasons, the staff believes the HRA portion of the analysis, while containing the weaknesses discussed above, does consitute an l adequate component of the IPE analysis in the search for vulnerabilities.
l l The licensee evaluated and quantified the results of the severe accident progression through the use of a containment event tree and considered uncertainties in containment response through the use of sensitivity analyses.
The licensee's back-end analysis appeared to have considered important severe accident phenomena. According to the licensee, the Fort Calhoun conditional containment failure probabilities are as follows: early containment failure (defined as that occurring at or within one hour of reactor vessel failure),
two percent with hydrogen combustion and direct containment heating the primary contributors; late containment failures, 28 percent with overpressure failure caused by loss of containment heat removal being the primary contributor; bypass five percent with ISLOCA being the primary contributor; l and containment isolation failure, five percent, with SGTR (along with assumed ;
4ailure to isolate the affected steam generator) being the primary 1 contributor. Alpha mode failure and basemat melt-through failures were '
reported to be negligible. According to the licensee, the containment remains intact 60 percent of the time. Early radiological releases are dominated by l
ISLOCA and SGTR and late releases are dominated by station blackout and sequences. The licensee's response to containment performance improvement i program recommendations is consistent with the intent of Generic Letter 88-20 i and associated Supplement 3. j According to the licensee, some insights and unique plant safety features identified by the licensee at Fort Calhoun are:
- 1. Ability to feed and bleed once through cooling.
- 2. Use of self contained radiators for diesel generator cooling which do not require external cooling from plant cooling water systems.
- 3. Diverse means of supplying AFW to the steam generators, i.e., by either a motor driven, turbine driven, or diesel driven pump. Without credit for the diesel driven AFW pump, the CDF would increase by a factor of 5.
- 4. More robust design (according to the licensee) of the reactor coolant pumps (RCPs) which are stated to be highly resistant to seal leakage.
Without this assumed enhanced performance the CDF would increase by r.
factor of 10.
- 5. Lack of a requirement for emergency core cooling system (ECCS) pump external cooling during the injection mode.
- 6. Lack of a " piggy-back" requirement for high pressure coolant injection (HPCI) pumps from low pressure coolant injection (LPCI) pumps during recirculation.
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l 7. It was assumed that a large LOCA could be mitigated without the use of 3 i LPSI pumps; specifically during the early phase of a large LOCA, one HPSI i pump and three safety injection pumps meet the success criteria. This success criteria is more optimistic than reported in many PWR IPE submittals which typically assume that the large LOCA requires at least 1 one LPSI pump. '
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- 7. Automatic switchover of ECCS from injection to recirculation.
- 8. Open design of the auxiliary building, which encourages natural circulation, making it unlikely that heating, ventilation, and air i conditioning (HVAC) will be required to cool many items of plant equipment.
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- 9. The plant design includes a containment air co which provides containment cooling independent,oling and filtering of the containment spraysystem, system.
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- 10. Ability to use a diesel driven fire pump for plant functions, such as, l for delivering long term makeup to the emergency feedwater storage tank and for providing backup cooling to the component cooling water system.
The licensee adopted criteria from the Nuclear Management and Resource Council (NUMARC) to screen for plant-specific vulnerabilities. These criteria were applied to the functional core damage sequences. Based on this definition, the licensee did not identify any vulnerabilities. Plant improvements, however, were identified. These improvements, listed below, have been implemented, with the exception of four (4), which is still in progress:
- 1. Install a door to facilitate mitigation of RCP seal cooler ISLOCA.
- 2. Periodically leak test downstream shutdown cooling valve (on ISLOCA path.)
- 3. . Install anti-galloping devices on 161 kV offsite power source.
- 4. For internal flood scenarios, revise procedures to establish appropriate position of the door to the spent / regenerative tank / pump room.
Taken together, the licensee reported that the total CDF reduction from the four improvements listed above was 1.8E-05, which then resulted in the reported actual CDF of 1.4E-05.
3.0 CONCLUSION
Based on the above findings, the staff notes that: (1) the licensee's IPE is complete with regard to the information requested by Generic Letter 88-20 (and associated guidance in NUREG-1335), and (2) the IPE results are reasonable given the Fort Calhoun design, operation, and history. As a result, the staff l concludes that the licensee's IPE process is capable of identifying the I most likely severe accidents and severe accident vulnerabilities, and therefore, that the Fort Calhoun IPE has met the intent of Generic Letter 88-20.
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It should be noted that the staff's review primarily focused on the licensee's ability to examine Fort Calhoun for severe accident vulnerabilities. Although l certain aspects of the IPE were explored in more detail than others, the review is not intended to validate the accuracy of the licensee's detailed findings (or quantification estimates) that stemmed from the examination.
Therefcre, this SER does not constitute NRC approval or endorsement of any IPE ;
material for purposes other than those associated with meeting the intent of l Generic Letter 88-20. The staff has identified a weakness in the HRA portion i of the IPE and believes that application of the IPE in support of risk-based ;
regulatory applications, beyond those associated with Generic Letter 88-20, ,
require additional treatment in that area. '
Principal Contributor: J. Lane Date: December 9, 1996 i
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1 APPENDIX A FRONT-END TECHNICAL EVALUATION REPORT l
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