Comment (5) of Scott A. Bauer, on Behalf of Stars Alliance LLC, on NRC Draft Regulatory Guide DG-1322, Alternate Risk-Informed Approach for Addressing He Effects of Debris on Post-Accident Long-Term Cooling| ML15189A067 |
| Person / Time |
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| Site: |
Wolf Creek, Summer, Diablo Canyon, Callaway, Yankee Rowe, Plum Brook  |
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| Issue date: |
07/02/2015 |
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| From: |
Bauer S
STARS Alliance |
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| To: |
Cindy Bladey
Rules, Announcements, and Directives Branch |
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| References |
|---|
| 80FR21658 00005, DG-1322, NRC-2015-0095, STARS-15005 |
| Download: ML15189A067 (5) |
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- /A~ww.fdm s.gov~ffdms/getcontent?objectld= 0900006481b6a985&fo m at=-x m I&s howorig= false As of: 7/6/15 10:25 AM PUBLC PUBICSBMISIONStatus:
UBMSSIN ........... Pending_Post .'S~ S Tracking No. ljz-8jt8-nvi2 Comments Due: July 06, 20115 Submission Type: Web Docket: NRC-20 15-0095 Alternate Risk-Informed Approach for Addressing the Effects of Debris on Post-Accident Long-Term Core Cooling Comment On: NRC-2015-0095-0001 Alternate Risk-Informed Approach for Addressing the Effects of Debris on Post-Accident Long-Term Core Cooling; Draft Regulatory Guide for Co m ment ."*-i/z /
Document: NRC-2015-0095-DRAFT-0005 /
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Submitter Information Name: Scott Bauer ::
Address:
1626 N. Litchfield Rd. Suite 230 ..
Goodyear, AZ, 85395-:
Email: scott. bauer@starsalliance .corn...
- ©,L General Comment See attached file(s)
Attachments STARS- 15005 Letter STARS-i15005 Attachment SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 Add= ~
https://www.fdms.gov/fdm stgetcontent~objectld= 0900006481b6a985&format= xml&showorig= false1/ 1/1
STARS Alliance Alliance Members.
Callaway Energy Center Diablo Canyon Power Plant www.sta rsalliance.corn 1626 N Litchfield Rd Suite 230 Palo Verde Nuclear Generating Station Goodyear, AZ 85395 Wolf Creek Generating Station T 623-209-7549 STARS-15005 July 2, 2015 Ms. Cindy Bladey Office of Administration Mail Stop: OWFN-12H08 U.S. Nuclear Reguiatory Commission Washington, DC 20555-0001
Subject:
STARS Alliance LIC Comments on NRC Draft Regulatory Guide (DG) DG-1322, "Alternate Risk-Informed Approach for Addressing the Effects of Debris On Post-Accident Long-Term Core Cooling," dated April, 2015 (Docket ID NRC-2015-0095)
References:
- 1. Federal Register Notice Volume 80, No. 75 (80FR21658), dated April 20, 2015, Docket ID NRC-2015-0095
- 2. Letter from STP Nuclear Operating Company to Cindy Bladey, U.S. Nuclear Regulatory Commission, Office of Administration, "South Texas Project Units 1 and 2, Comments on Draft Regulatory Guide DG-1322 - Risk-Informed Approach for Addressing the Effects of Debris On Post-Accident Long-Term Core Cooling, Docket ID NRC-2015-0095-0002," dated June 24, 2015
Dear Ms. Bladey:
As noted in Reference 1, the Nuclear Regulatory Commission (NRC) issued for public comment NRC Draft Regulatory Guide (DG) DG-1322, "Risk-Informed Approach for Addressing the Effects of Debris On Post-Accident Long-Term Core Cooling," Docket ID NRC-2015-O095. STARS Alliance LLC (STARS) appreciates the opportunity to comment on this document.
STARS endorses the comments submitted by STP Nuclear Operating Company in Reference 2.
STARS submits the items in the attachment to this letter as additional comments.
STARS-1S005 Page 2 of 2 If you have any questions, please contact me at 623-239-4359, or scott.bauer~starsalliance.com.
Sincerely, Scott A. Bauer Regulatory Affairs Functional Area Manager Attachment
Attachment to STARS-25005 July 2, 2015 DG-1322, April 2015 Comments Draft Regulatory Guide Paragraph Number Paragraph C.1 The guidance should limit the operating mode of concern to at-power events, consistent with the full power (plus 2%) Appendix K models used to run [BLOCA and SBLOCA analyses. There should be no need to require a low-power or shutdown PRA model.
Paragraph C.4.f It is unclear how the examples in C.4.f (e.g., strainer blockage, in-vessel effects, and ex-vessel downstream effects) relate to the requirement that licensees utilize integrated models to evaluate strainer and downstream system performance including effects of safety-related and non-safety related system activation. It would be clearer to provide examples of system actuations (e.g., automatic suction swap-over, initiation of containment spray, etc.).
Paragraph C.5 The guidance should limit the operating mode of concern to at-power events, consistent with the full power (plus 2%) Appendix K models used to run/LBLOCA and SBLOCA analyses. There should be no need to require a low-power or shutdown PRA model.
Paragraph C.6.c Clarify that the effects of latent debris may be neglected when testing demonstrates no impact on strainer performance.
Paragraph C.8 Paragraph C.8 is worded in a way that implies the need for conservatism in evaluating containment pressure. Consider rewording this paragraph to emphasize realistic modeling. The last sentence should be revised to state that licensees should use realistic, sequence-specific containment pressures in NPSH computations. The basis for the containment pressure used in NPSH calculations should be clearly documented.
Paragraph C.9 Paragraph C.9 allows the user to skip steps C.20 through C.23 but paragraph C.9.a refers the user to paragraphs C.12 and C.13. It is recommended that the reference to paragraphs C.11 and C.13 in paragraph C.9.a. be deleted.
Alternately, instead of referencing C.11 and C.13, provide guidance that the simplified approach uses values that bound all scenarios (demonstrated through testing) for chemical effects and debris strainer penetration downstream effects.
Paragraph C.13.f The end of the sentence is, "and analogies of ." Complete the sentence to indicate the scope of acceptable bases for the penetrated debris effects model.
Paragraphs C.14 and C.15 These sections presume that licenses modify existing PRA models to incorporate the results of the risk informed modelling. If ACDF and ALERF can be calculated independent of the existing PRA model, then it should not be required to modify the existing model.
Page 1 of 2
Attachment to STARS-i5005 July 2, 2015 Paragraph C.14.d.1 Consider rewording paragraph C.14.d.1 as the term HELB has a very specific definition as a Hazard Event which is beyond the scope of DBA mitigation requirements.
Paragraph C.18 This paragraph indicates that parameter values should be consistent with licensing basis calculations, which are inherently conservative. This should be revised to state that realistic parameters should be used and clearly documented.
Paragraph C.19 Paragraph C.19 needs to be re-worded to be consistent with the guidance in RG 1.174 regarding quality program requirements associated with aspects of the risk assessment.
Paragraph C.20 This paragraph refers to an implementation and monitoring program. If the NRC intent is that the design change process be followed for NRC approved inputs to the PRA model, this paragraph should state that requirement. There is no need for an implementation and monitoring program to ensure configuration control in containment.
References Add, "Generic Safety Issue (GSI)-191, Assessment of Debris Accumulation on PWR Sump Performance," which is discussed in Section B on page 3.
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