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| | number = ML11321A221 | | | number = ML11321A221 |
| | issue date = 11/09/2011 | | | issue date = 11/09/2011 |
| | title = Comanche Peak, Response to Request for Additional Information, Risk Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program - Tacs ME6789 and ME6790 | | | title = Response to Request for Additional Information, Risk Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program - Tacs ME6789 and ME6790 |
| | author name = Madden F W | | | author name = Madden F W |
| | author affiliation = Luminant Generation Co, LLC, Luminant Power | | | author affiliation = Luminant Generation Co, LLC, Luminant Power |
Revision as of 20:08, 4 April 2019
Letter Sequence Response to RAI |
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TAC:ME6789, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed) TAC:ME6790, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed) |
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MONTHYEARML1123509342011-08-23023 August 2011 Acceptance Review Email, License Amendment Request to Relocate Specific Surveillance Frequencies from Technical Specifications to a Licensee Controlled Program Project stage: Acceptance Review ML1129901462011-10-26026 October 2011 Request for Additional Information, Amendment Request to Adopt TSTF-425-A, Rev. 3, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5b. Project stage: RAI ML1129901252011-10-26026 October 2011 Email, Request for Additional Information, Amendment Request to Adopt TSTF-425-A, Rev. 3, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5b. Project stage: RAI CP-201101565, Response to Request for Additional Information, Risk Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program - Tacs ME6789 and ME67902011-11-0909 November 2011 Response to Request for Additional Information, Risk Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to Licensee Controlled Program - Tacs ME6789 and ME6790 Project stage: Response to RAI ML12067A2442012-06-29029 June 2012 Issuance of Amendment Nos. 156 and 156, Adoption of TSTF-425-A, Rev. 3, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specifications Task Force (RITSTF) Initiative 5b Project stage: Approval ML22208A1582022-07-29029 July 2022 Correction to Issuance of Amendment Nos. 156 and 156 Relocation of Surveillance Frequencies from the Technical Specifications to a Licensee-Controlled Document Project stage: Approval 2011-08-23
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Category:Letter
MONTHYEARCP-202400030, License Renewal Application Revision 0 - Supplement 3, Revision 12024-01-31031 January 2024 License Renewal Application Revision 0 - Supplement 3, Revision 1 IR 05000445/20230042024-01-29029 January 2024 Integrated Inspection Report 05000445/2023004 and 05000446/2023004 CP-202400034, (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1)2024-01-29029 January 2024 (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1) ML24024A2102024-01-29029 January 2024 Summary of Regulatory Audit Regarding a License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML24025A0052024-01-25025 January 2024 Review of the Spring 2023 Steam Generator Tube Inspection Report ML24023A0242024-01-24024 January 2024 Correction to Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident Methodology ML24018A1072024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000445/2024012 and 05000446/2024012) and Request for Information ML23159A2082023-12-20020 December 2023 Request for Withholding Information from Public Disclosure ML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23348A2392023-12-19019 December 2023 Nonacceptance of License Amendment Request to Relocate Technical Specification 3.9.3, Nuclear Instrumentation, to the Technical Requirements Manual CP-202300575, (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 22023-12-13013 December 2023 (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 2 ML23333A0872023-12-13013 December 2023 Transmittal of Dam Safety Inspection Report - Public CP-202300566, (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation2023-12-12012 December 2023 (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation CP-202300494, License Renewal Application Revision 0, Supplement 32023-12-0606 December 2023 License Renewal Application Revision 0, Supplement 3 ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23291A4382023-11-30030 November 2023 Notice of Availability of the Draft Plant-Specific Supplement 60, to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Comanche Peak Nuclear Power Plant, Unit Numbers 1 and 2, License Renewal Applica ML23325A0182023-11-30030 November 2023 Schedule Revision for the License Renewal Application Review IR 05000445/20234022023-11-30030 November 2023 NRC Security Inspection Report 05000445/2023402 and 05000446/2023402 CP-202300349, License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation2023-11-20020 November 2023 License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation ML23308A0032023-11-17017 November 2023 Letter to R. Nelson, Executive Director; Achp; Re., Comanche Peak Draft Environmental Impact Statement ML23308A0022023-11-17017 November 2023 Letter to M. Wolfe, Executive Director; Shpo; Re., Comanche Peak Draft Environmental Impact Statement ML23317A3002023-11-13013 November 2023 Letter to R. Sylestine, Chairman, Alabama-Coushatta Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2972023-11-13013 November 2023 Letter to R. Martin, President, Tonkawa Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2872023-11-13013 November 2023 Letter to J. Garza, Chairman, Kickapoo Traditional Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2832023-11-13013 November 2023 Letter to D. Dotson, President, Delaware Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2852023-11-13013 November 2023 Letter to E. Martinez, President, Mescalero Apache Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23306A0302023-11-13013 November 2023 Letter to J. Cernek, Chairman; Coushatta Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2902023-11-13013 November 2023 Letter to M. Pierite, Chairman, Tunica Biloxi Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2982023-11-13013 November 2023 Letter to R. Morrow, Town King, Thlopthlocco Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2842023-11-13013 November 2023 Letter to D. Kaskaske, Chairman, Kickapoo Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2822023-11-13013 November 2023 Letter to D. Cooper, Chairman, Apache Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2962023-11-13013 November 2023 Letter to M. Woommavovah, Chairman, Comanche Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2812023-11-13013 November 2023 Letter to C. Hoskin, Principal Chief, Cherokee Nation; Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2862023-11-13013 November 2023 Letter to J. Bunch, Chief, United Keetoowah Band of Cherokee Indians Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3032023-11-13013 November 2023 Letter to W. Yargee, Chief, Alabama-Quassarte Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2882023-11-13013 November 2023 Letter to L. Johnson, Chief, Seminole Nation of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3012023-11-13013 November 2023 Letter to S. Yahola, Mekko, Kialegee Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2792023-11-13013 November 2023 Letter to B. Gonzalez, Chairman, Caddo Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3022023-11-13013 November 2023 Letter to T. Parton, President, Wichita and Affiliated Tribes Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2892023-11-13013 November 2023 Letter to L. Spottedbird, Chairman, Kiowa Indian Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23360A6312023-10-26026 October 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the Comanche Peak Nuclear Power Plant Medical Services Drill Evaluated on August 23, 2023 CP-202300416, Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements2023-10-12012 October 2023 Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements CP-202300432, Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 42023-10-0404 October 2023 Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 4 ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23263A0242023-09-21021 September 2023 Revision of Schedule for the Environmental Review of the Comanche Peak Nuclear Power Plant Units 1 and 2 License Renewal Application 2024-01-31
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a Luminant Rafael Flores Senior Vice President& Chief Nuclear Officer Rafael.Flores@Luminant.com Luminant Power P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201101565 Log # TXX-11136 Ref. # 10CFR50.90 November 9, 2011 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION, RISK INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO LICENSEE CONTROLLED PROGRAM -TACS ME6789 AND ME6790
REFERENCES:
- 1. Letter logged TXX-11093 dated August 1, 2011 from Rafael Flores to the NRC submitting License Amendment Request (LAR)11-001, Application For Technical Specification Change Regarding Risk-Informed Justification For The Relocation Of Specific Surveillance Frequency Requirements To A Licensee Controlled Program.2. Letter logged TXX-11100 dated August 15, 2011 from Rafael Flores to the NRC submitting Supplement To License Amendment Request (LAR)11-001, "Application For Technical Specification Change Regarding Risk-Informed Justification For The Relocation Of Specific Surveillance Frequency Requirements To A Licensee Controlled Program".3. Email dated October 26, 2011 from Balwant Singal of the NRC to Timothy Hope of Luminant Power requesting additional information regarding License Amendment Request (LAR)11-001.
Dear Sir or Madam:
Per references 1 and 2, Luminant Generation Company LLC (Luminant Power) previously submitted License Amendment Request (LAR)11-001 requesting changes to the Comanche Peak Nuclear Power Plant (CPNPP) Technical Specifications (TSs) for adoption of the Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF) -425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -RITSTF [Risk-Informed TSTF] Initiative 5b." Per reference 3, the NRC provided a request for additional information regarding the subject license amendment request.Luminant Power has provided the information requested per reference 3 in the Attachment to this letter.This communication contains no new commitments regarding Comanche Peak Units 1 and 2.Should you have any questions, please contact Mr. Rob Slough at (254) 897-5727.A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Diablo Canyon -Palo Verde
- South Texas Project -Wolf Creek U. S. Nuclear Regulatory Commission TXX-11136 Page 2 of 2 Sincerely, Luminant Generation Company LLC Rafael Flores By: K Mirer WMaddeh Director, Oversight
& Regulatory Affairs RAS
Attachment:
Response To Request For Additional Information
-Risk Informed Justification For The Relocation Of Specific Surveillance Frequency Requirements To Licensee Controlled Program -TACs ME6789 and ME6790 c -E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak Ms. Alice Rogers Environmental
& Consumer Safety Section Texas Department of State Health Services 1100 West 49th Street Austin, Texas 78756-3189 Attachment to TXX-11136 Page 1 of 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
-RISK INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO LICENSEE CONTROLLED PROGRAM -TACS ME6789 AND ME6790 The following questions were provided to Luminant Power in the email dated October 26, 2011 from Balwant Singal of the NRC to Timothy Hope of Luminant Power (Reference
- 3) requesting additional information regarding LAR 11-001: 1. The summary of finding and observation (F&O) 2-13 for supporting requirement (SR) AS-A7 identifies that the documentation of assumptions and key sources of uncertainty for accident sequence modeling is incomplete, and two examples are provided by the peer reviewer.
The disposition of this F&O was to specifically address these two examples, but there is no discussion of any review to identify other sources of uncertainty not documented.
Since the peer review identifies the two specific items as examples, the U. S. Nuclear Regulatory Commission's (NRC)staff would not expect the licensee to close out this F&O until a more thorough review was conducted to assure all sources of uncertainty and assumptions are identified and discussed in the documentation.
Please discuss how this F&O was reviewed to determine the extent of condition for missing assumptions and key sources of uncertainty related to accident sequence modeling.2. The summary of F&O 4-31 for SR QU-F4 states that the effect of sources of uncertainty on the Probabilistic Risk Assessment (PRA) model is not clear. The resolution states that the documentation identifies the application of an industry guidance document to the evaluation of uncertainties.
This does not seem to address the underlying issue that the documentation should characterize sources of uncertainty and assumptions underlying the PRA model.Please clarify how this F&O was addressed to assure characterization of sources of uncertainty and assumptions on the effects on the PRA model is described in the documentation.
Luminant Power's Response to Question 1: F&O 2-13 included two proposed resolutions from the Peer Review team. The first proposed resolution dealt with the possible uncertainty from not including further development of offsite power recovery sequences.
The second proposed resolution dealt with potential uncertainties resulting from deviations in the incorporation of the WCAP-15831 ATWS model. The LAR submittal described the incorporation of these proposed resolutions into the CPNPP PRA model and/or model documentation.
Both of these items were added to the list of potential uncertainties in the respective PRA notebooks.
The proposed resolutions were limited to the two specific examples, and the performance of the uncertainty analysis (see RAI response #2) did not identify any additional sources of uncertainty that would impact Accident Sequence development.
Luminant Power's Response to Question 2: The proposed resolution to this F&O by the peer team was the following:
Consider using the approach recommended in the EPRI report 1016737, "Treatment of Parameter and Model Uncertainty for Probabilistic Risk Assessments," December 2008.The EPRI document identifies all sources of model uncertainty that are pertinent to a general PRA model in meeting the SRs: QU-E1, QU-E2, QU-E4, QU-F4, and LE-F3. Table A-1 from that document generically characterizes these sources. Per the peer review suggestion, the CPNPP PRA "Sensitivity and Uncertainty" notebook was updated to include this table (A-1) with the 4 Attachment to TXX-11136 Page 2 of 2 identification of the plant-specific approach used for each case and where each source of uncertainty can impact the model. The notebook (with its Level 2 reference) documents over 50 sensitivity cases performed on the model involving the full range of the uncertainties identified in the table. The revised "Sensitivity and Uncertainty" notebook documents the characterization of the sources of uncertainty and assumptions underlying the PRA model and resolves the Peer Review F&O.