ML22305A592

Pre-Submittal Meeting Presentation Slides - Risk Informed Completion Time (TSTF-505) and Risk Informed Categorization and Treatmentof SSCs (10 CFR 50.69) Proposed License Amendments-Updated

ML22305A592
Person / Time
Site:	Nine Mile Point
Issue date:	11/03/2022
From:	Constellation Energy Generation
To:	NRC/NRR/DORL/LPL1
References
EPID L-2022-LRM-0087
Download: ML22305A592 (1)

Text

Nine Mile Point 1 RICT and 50.69 LARs

NRC Pre-Submittal Meeting

November 3, 2022 Introduction

• Agenda

-Overview of License Amendments

-Variances from TSTF-505-A Rev. 2

-Timeline for Submittals

-PRA Technical Adequacy

-Evaluation Of PRA Uncertainties and Assumptions

-External Hazards

-Submittal Efficiencies

1 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Overview of License Amendments

• 50.69 LAR based on NEI 00-04

-No deviation from LAR template (exceptseismic and extreme winds)

• RICT LAR based on TSTF-505-A Rev. 2

-NMP1 is a BWR/2 reactor design

-TS markups follow TSTF forBWR/4

• Variances from TSTF-505

-NMP1 TS are NOT ITS (Custom TS)

-Variances from TSTF-505 are mostly nomenclature, section numbering, and plant design

-TSTF-505 LCOs/Conditions not in NMP1 TS

-RICT added to plant-specific LCOs not inTSTF-505 (will be identified in Attachment 4)

2 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Variances from TSTF-505

• NMP1 is a BWR/2 design. The TSTF-505 markups applicable to NMP1 are based on NUREG-1433

• Attachment 4 (Xref between TSTF ITS and NM1 TS) will highlight the following:

NUREG-1433 TS included in TSTF-505 and corresponding NMP1 have differing numbers NUREG-1433 TS included in TSTF-505 that are not contained in the NMP1 TS

NMP1 TS included in TSTF-505 that are not contained in NUREG-1433. These TS perform functions similar to in-scope NUREG-1433 TS.

NMP1 TS that are not contained in NUREG-1433 and, therefore, are not included in the TSTF-505 mark-ups

• TSTF-505, Revision 2, includes an attachment for typed, camera-ready (revised) TS pages. NMP1 is not including such an attachment due to the large number of TS pages

• The STS terminology of Modes is not used in the NMP1 TS.

3 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Variances from TSTF-505 (cont.)

• NMP1 Action descriptions generally correspond to NUREG-1433 Required Actions.

• NMP1 Actions that have different numbering than the NUREG-1433 Required Actions

• NMP1 takes a plant-specific variation to TSTF-505, TS 3.5.1.C, High Pressure Core Spray (HPCS) System Inoperable

• NMP1 takes a plant-specific variation to TSTF-505, TS 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling

• NMP1 takes a plant-specific variation to TSTF-505, TS 3.6.2.4, Residual Heat Removal (RHR) Suppression Pool Spray

• NMP1 takes a plant-specific variation to TSTF-505, TS 3.7.1, Residual Heat Removal Service Water (RHRSW) System

4 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Timeline for Submittal

NMP 1 - 50.69 and RICT LARs

• Two separate applications

• Both submittals on same day (or close to same day)

• Late November - early December 2022

5 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING PRA Tech Adequacy

• FPIE PRA - Peer Reviewed to RG 1.200 Rev. 2 F&O Closure review performed No Open Finding F&Os

• Fire PRA - Peer Reviewed to RG 1.200 Rev. 2 F&O Closure review performed Four Open Finding F&Os (Already Addressed -Three Documentation-Related; One Technical-Related)

6 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Evaluation of PRA Uncertainties and Assumptions

• Both NMP1 submittals will follow the process defined in NUREG 1855 Rev. 1, and the guidance in EPRI 1016737 and EPRI 1026511, including:

Identification of Internal events/internal flooding PRA model plant-specific and generic sources of uncertainties per EPRI 1016737 Identification of Internal Fire PRA model plant-specificand generic sources of uncertainty per Appendix B of EPRI 1026511 Consideration of generic Level 2 model sources of uncertainty per Appendix E of EPRI 1026511, as applicable to LERF Assessment of potential sources of uncertainties that are key to the respective applications, and disposition or treatment for the application Consideration of Parameter and Completeness uncertainties

7 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING External Hazards Screening Process

• IPEEE InitialScreening

• Reviewed Current Hazard Information

• Updated Analysis Using Part 6 Screening Criteria of ASME/ANS PRA Standard RA-Sa-2009

• Performed conservative or bounding analyses where appropriate

• RICT - Incorporates NEI 06-09 guidance.

- Justify exclusion of external risk sources from the PRA models based on their insignificance to the calculation of configurationrisk

• 50.69 - Incorporates NEI 00-04 guidance

- Figure 5-6, Other ExternalHazards

- Seismic will use EPRI alternative approach (TR 3002017583) for Tier 1 plants

- Extreme winds will use a high winds safe shutdown equipment list

8 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING External Hazards - Flooding

• Screens Out

• Event damage potential is less than events for which plant is designed (C1)

• Several doors are credited to screen out local intense precipitation (LIP) for 50.69

- Normally installed and closed exterior doors keep water infiltration to a minimum and total ingress volume lower than required for impacting key SSCs during LIP event duration

- These doors will be treated as HSS per NEI 00-04 Figure 5-6

9 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING External Hazards - Extreme Wind or Tornado / Missiles

• Will use High Winds Safe Shutdown Equipment List for 50.69

• Still evaluating the potential to screen using PS3 Criterion

• Will Use Penalty Factor for TSTF-505

10NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING External Hazards - Seismic

• Not Screened

• Seismic hazard is relativelylow (EPRI Tier 1 Plant)

• RICT - Will Use Seismic Penalty Approach for RICT

• 50.69 - Will submit as an EPRI Seismic Alternative Tier 1 Plant For 50.69 Tier 1 definition: (1) GMRS peak acceleration derived from the seismic hazard is at or below 0.2g or (2) where the GMRS is below or equal to the SSE between 1.0 Hz and 10 Hz.

NMP1 meets second criterion.

11NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Submittal Efficiencies

• Overlaps in level of PRA acceptability in applications

12 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Submittal Efficiencies

• RICT -No deviation from Model SE

• 50.69 - No deviation from LAR template (except seismic and extreme winds)

• PRA Common assessment approach of PRA technical adequacy and sources of uncertainty for bothapplications Assessments are application-specific but related in terms of details to beconsidered

• External Hazards Common screening approach of hazards Application-specific assessment of screening impact but related in terms of details to be considered

• Same PRA teams reviewing PRA risk information

13NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING Questions?