ML21011A275

License Amendment Request (LAR) to Revise Containment Leakage Rate Testing Program Frequencies - NRC Pre-Submittal Meeting, January 6, 2021 (Presentation Slides)

ML21011A275
Person / Time
Site:	Palo Verde
Issue date:	01/06/2021
From:	Arizona Public Service Co
To:	Siva Lingam NRC/NRR/DORL/LPL3
Lingam S, 301-415-1564
References
Download: ML21011A275 (10)

Text

License Amendment Request (LAR) to Revise Containment Leakage Rate Testing Program Frequencies NRC Pre-Submittal Meeting Palo Verde Nuclear Generating Station January 6, 2021

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Background===

• This license amendment request (LAR) revises Technical Specification (TS) 5.5.16, Containment Leakage Rate Testing Program, to reflect the following:

• Replaces the reference to Regulatory Guide (RG) 1.163 with NEI 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, Revision 3-A, and the limitations and conditions specified in NEI 94-01, Revision 2-A

• Extends the testing frequencies for Type A integrated leakage rate test (ILRT) from 10 years to 15 years and select Type C local leakage rate tests (LLRTs) from 60 months to 75 months

• Adopts the use of ANSI/ANS 56.8-2002, Containment System Leakage Testing Requirements

• Adopts a more conservative allowable test interval extension of nine months, for Type A, Type B and Type C leakage rate tests 2

Background (Continued)

• This LAR also proposes the following administrative change to TS 5.5.16.a:

• Deletes the information regarding the performance of the next PVNGS Type A tests as these dates have already occurred and the associated Type A tests have been performed

• Change includes updates to the following UFSAR sections:

• Section 1.8 (RG 1.163), Performance-Based Containment Leak-Test Program

• Section 6.2.6, Containment Leakage Testing

• Section 19.1.30, 10 CFR 50, Appendix J 3

Proposed Technical Specification Change 4

Proposed Technical Specification Change 5

Risk Insights A plant specific risk assessment was conducted to support this proposed change.

• The risk assessment follows the guidelines of NRC RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Rev. 3 and RG 1.200, An Approach for Determining Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Rev. 2. Changing ILRT to one-in-fifteen-year frequency:

• Does not impact CDF

• Total LERF meets the acceptance guidelines in RG 1.174

• The total integrated plant risk for population dose meets the criteria defined in NEI 94-01

• Increase in conditional containment failure probability (CCFP) is small The risk assessment concludes that increasing the ILRT test frequency on a permanent basis to a one-in-fifteen-year frequency is considered to represent a small change in the PVNGS risk profile.

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Risk Insights (Continued)

A review of the Regulatory Guide 1.200 Revision 3 was conducted to determine if there were any impacts on this proposed change.

The PRA model used to assess this proposed change was issued on July 4, 2020 and reflected the following:

• Includes internal events, flooding, fire and seismic PRA models fully compliant with the endorsed ASME/ANS PRA Standard including NRC exceptions/clarifications at Capability Category II and these models have been peer reviewed

• All Other External Hazards listed in Regulatory Guide 1.200 Revision 3 except seismic events were screened out and the screening was peer reviewed

• Addressed all NRC license conditions from the 10 CFR 50.69 and Risk-Informed Completion Time License Amendments

• All Peer Review Facts and Observations Findings were closed by the NRC endorsed Closure Review Process (observed by NRC staff in June 2020)

• No newly developed methods were utilized in the PRA model

• No additional key assumptions or sources of uncertainty are applicable based on the updated guidance in Regulatory Guide 1.200 Revision 3 7

Precedents

• This LAR is similar in nature to the following approved license amendments to extend the Type A Test Frequency to 15 years and the Type C test frequency to 75 months:

• McGuire Nuclear Station, Units 1 and 2, issued January 31, 2018 (ADAMS Accession No. ML18009A842)

• Vogtle Electric Generating Plant, Units 1 and 2, issued October 29, 2018 (ADAMS Accession No. ML18263A039)

• Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, issued September 10, 2020 (ADAMS Accession No. ML20149K698) 8

Submittal Timeline

• Planning to submit the week of January 11, 2021

• Estimating a 1-year NRC review

• Requesting an implementation period of 90 days 9

Questions