ML20248H467

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Rict & 50.69 LARs - NRC Pre-Submittal Meeting Slides
ML20248H467
Person / Time
Site: Callaway Ameren icon.png
Issue date: 09/04/2020
From:
Union Electric Co
To: Mahesh Chawla
NRC/NRR/DORL/LPL4
Chawla M
References
Download: ML20248H467 (24)
v • d • e


Text

Callaway RICT & 50.69 LARs NRC Pre-submittal Meeting

Ameren Presenters

  • Stephanie Banker, Vice President of Nuclear Engineering
  • Andrew Burgess, 50.69 Project Manager
  • Nathan Casey, Operations Supervisor-Licensed
  • Justin Hiller, PRA Supervising Engineer
  • Tom Elwood, Licensing Supervising Engineer 2

Agenda

  • Scope of Requests
  • PRA Model Technical Adequacy
  • PRA Model Uncertainties and Assumptions
  • Potential Review Efficiencies
  • Timeline for Submittals 3

Scope of License Amendment Requests

  • TSTF-439 - Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO 4

50.69 License Amendment Request

  • Passive categorizations will be performed using the Arkansas Nuclear One (ANO) methodology
  • The use of this method was previously approved by the NRC in the Vogtle 10 CFR 50.69 application
  • Based on Revision 9 to the NEI template
  • Reviewed by NEI LAR Coordinating Committee 5

TSTF-505

  • RICTs apply to 19 Limiting Conditions for Operation (LCOs), and 49 LCO Conditions
  • Applicable in Modes 1 and 2
  • Obsolete one-time completion times will be removed from existing TS 6

Optional Variations from TSTF-505

  • Condition 3.3.2.R, AFAS and SGBIS from LOOP, one or both train(s) inoperable
  • Condition 3.3.2.S, SLIS and Turbine trip/FWIS on MSFIS, one train inoperable
  • Condition 3.7.2.B, Two MSIV actuator trains inoperable for different MSIVs when the inoperable actuator trains are not in the same separation group

Optional Variations from TSTF-505

  • Differences in Condition/Required Action (RA) wording
  • CEC TS are based on Revision 1 of NUREG-1431, Standard Technical Specifications Westinghouse Plants
  • Administrative changes
  • TS formatting changes
  • Changed some condition letters to use make use of previously Not Used conditions
  • Cross-reference list for TSTF-505 markups to CEC site-specific TS RAs provided 8

TS 3.3.2 - Engineered Safety Feature Actuation System (ESFAS) Instrumentation (Example Attachment 1 Variation)

  • Function 6.C-AFW Automatic Actuation Logic and Actuation Relays (Balance of Plant ESFAS)
  • Function 10.b-Steam Generator Blowdown and Sample Line Isolation Automatic Actuation Logic and Actuation Relays (BOP ESFAS)
  • 24-hour Completion Time (CT) front stop
  • Function is modeled in PRA

TS 3.7.2 - Main Steam Isolation Valves (MSIVs), Main Steam Isolation Valve Bypass Valves (MSIVBVs), and Main Steam Low Point Drain Isolation Valves (MSLPDIVs) (Example Attachment 1 Variation)

  • 72-hour CT front stop
  • MSIV Actuators are not explicitly modeled in PRA
  • MSIVs are modeled; loss of the associated signal train will be used as a conservative surrogate for the MSIV actuators

PRA Model Technical Adequacy The PRA models associated with these submittals have been assessed against the ASME/ANS PRA Standard (RA-Sa-2009 and Part 5 Code Case) and RG 1.200, Revision 2, consistent with NRC RIS 2007-06.

All F&O closure reviews were performed in accordance with the process documented in Appendix X to NEI 05-04, NEI 07-12, and NEI 12-13 as accepted by the NRC (ML17079A427), as well as the requirements published in the ASME/ANS PRA Standard (RA-Sa-2009).

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PRA Model Technical Adequacy

  • Internal Events & Internal Flood PRA
  • Full scope peer reviewed to ASME/ANS RA-Sa-2009 in April 2019
  • Appendix X to NEI 05-04 finding closure reviews completed over several reviews, the final review being in June 2020
  • No open Finding F&Os
  • The Fire PRA was prepared using the methodology defined in NUREG/CR-6850, Fire PRA Methodology for Nuclear Power Facilities, to support a transition to NFPA Standard 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants
  • Full scope peer reviewed to ASME/ANS RA-Sa-2009 in October 2009
  • Appendix X to NEI 07-12 finding closure review completed over two reviews, final review in June 2020
  • No open Finding F&Os 12

PRA Model Technical Adequacy

  • Full scope peer review conducted in June 2018 against the requirements of the Code Case for ASME/ANS RA-Sb-2013, as amended by the NRC on March 12, 2018.
  • Appendix X to NEI 12-13 Finding closure review completed over several reviews, the final review being in June 2020
  • No open Finding F&Os
  • The External Hazards Screening Assessment and the High Winds PRA were reviewed against the technical elements in Sections 6 and 7 of the ASME/ANS PRA Standard in April 2019
  • Appendix X to NEI 05-04 and 12-13 Finding closure review completed in Nov. 2019
  • No open Finding F&Os 13

PRA Model Technical Adequacy

  • Special Note
  • As part of a PRA improvement update Callaway implemented the methodology provided in PWROG-18027-NP, for assessing the loss of room cooling in PRA modeling. During the peer review of the internal events PRA model a Finding F&O was generated related to implementation of this method.
  • Despite the assessment that this method did not necessarily meet the definition of a NDM, Callaway decided to suspend resolution of the associated F&O until the NDM peer review and closure of any F&Os on the method itself were completed using the process established in NEI 17-07 and the NDM requirements defined in PWROG-19027-NP.

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PRA Model Technical Adequacy

  • Based on the results of this review, all applicable NDM requirements are met and there are no open peer review Findings against the method in PWROG-18027-NP Rev. 0.
  • In June 2020, a focused scope peer review was conducted for the Callaway Energy Center.

This review determined that all of the SRs that were examined, including the SR associated with the F&O related to implementation of the method in PWROG-18027-NP, satisfy Capability Category II, or higher, requirements. There were no new F&Os generated as a result of this review.

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PRA Model Technical Adequacy In conclusion:

  • The method documented in PWROG-18027-NP Rev. 0 has been reviewed using the most current NDM requirements and peer review guidance
  • There are no outstanding F&Os on the method
  • Implementation of the peer reviewed method in the Callaway PRAs has also been reviewed with no open F&Os 16

PRA Model Uncertainties and Assumptions Callaway followed the process defined in NUREG-1855, EPRI 1016737, and EPRI 1026511

  • Assessment of potential sources key to respective applications and disposition/treatment for the application
  • Identification of plant-specific sources and generic sources for all Hazards per EPRI 1016737
  • Identification of Fire and Seismic PRA plant-specific sources and generic sources per Appendices of EPRI 1026511
  • Consideration of generic Level 2 sources per EPRI 1026511 Appendix E as applicable to LERF
  • Consideration of both parameter & completeness uncertainties 17

TSTF-439

  • Eliminates second Completion Times (limiting time from discovery of failure to meet an LCO) for Required Actions in favor of administrative controls.
  • As stated in TSTF-505, Revision 2, it is necessary to adopt TSTF-439 in order to adopt TSTF-505 for those Required Actions that are affected by both travelers.

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Potential Review Efficiencies

  • Both RICT and 50.69 license amendment requests are consistent with their applicable templates or model applications
  • PRA technical adequacy and key sources of uncertainty similar for both applications
  • All models have been recently peer reviewed
  • NRC observed most of these peer reviews
  • No open Findings
  • Streamlined approach where both are reviewed together 19

Timeline for Submittals

  • Two separate submittals will be made
  • 50.69 LAR is expected to be submitted in late 3rd Quarter 2020
  • RICT LAR is expected in 4th Quarter 2020
  • Changes to the schedule will be communicated to the NRC Project Manager in a timely manner 20

Additional Information 22

Example of TS with Second Completion Time 23

Example of TS with Second Completion Time 24

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