ML12156A205

Presentation to NRC for LAR 12

ML12156A205
Person / Time
Site:	Comanche Peak
Issue date:	05/31/2012
From:	Slough R Luminant Generation Co, Luminant Power
To:	Balwant Singal Plant Licensing Branch IV
Singal B
Shared Package
ML12156A209	List: ML12156A134 ML12156A205
References
TAC ME8616, TAC ME8615
Download: ML12156A205 (21)

Text

Addition of New Transformer XST1A CPNPP

Luminant PreApplication Meeting Agenda

Introductions

Current/Proposed Plant Design Proposed Plant Modification Overview TS 3.8.1. and Extended CT Current and Proposed Risk Analysis Proposed Schedule Questions/Feedback Closing l Remarks/Summary k/

Current CPNPP Offsite AC Power Sources 345 Kv Switchyard Protected Area Parker 2 Oncor Control House 2ST Parker 1 2MT2/1 Relay Turbine Generator House Comanche Switch MOAS Unit 2 Johnson Switch XST2 Unit 1 Everman 1ST Turbine XST2A Generator Wolf Hollow/

Benbrook 1MT2/1 XST1 DeCordova Relay Stephenville House 25 Kv K Loop L

Protected Area DeCordova 25 Kv Loop 138 Kv Switchyard

Proposed CPNPP Offsite AC Power Sources 345 Kv Switchyard Protected Area Parker 2 Oncor Control 2ST House Parker 1 2MT2/1 Relay Turbine Generator House Comanche Switch MOAS Unit 2 Johnson Switch XST2 Unit 1 Everman 1ST Turbine XST2A Generator Wolf Hollow/

Benbrook 1MT2/1 XST1 DeCordova XST1A Relay Stephenville House 25 Kv K Loop L

Protected Area DeCordova 25 Kv Loop 138 Kv Switchyard

Current Current Technical Specification 3.8.1 Proposed Proposed Technical Specification 3.8.1

XST1A Pad XST1

32-0 32-0 14-10 14-2 2-10 37-0 14-0 28-5 26-10

Risk Analysis y

• Objectives for this section

- Summarize PRA Model Scope and Quality

- Describe the Risk Assessment

- Discuss the Sensitivity Analyses

- Discuss the Configuration Risk Management Program and Risk Reduction Measures

PRA Model Scope p and Qualityy

• Internal Events and Internal Flooding models were developed per RG 1.200 Rev 2 requirements and have been Peer Reviewed Per the Peer Review Team Overall, the CPNPP PRA was found to substantially meet the ASME PRA Standard at Capability Category II and can be used to support risk riskinformed informed applications applications

PRA Model Scope and Quality

• Subsequent q to the Peer Review, Findings g and Observations were addressed and incorporated into the current Revision 4A model All Not Not Met Met now Cat II or better 4 of 7 previous Cat I now Cat II or better Remaining 3 with no application impact All Findings were resolved and incorporated All but one suggestion incorporated One was deferred with no application impact All remaining SRs meet Cat II or better

• External Events based on IPEEE and will be used for insights only

PRA Model Scope and d Quality li

• Adequately addresses asbuilt, asoperated plant

• Plant specific data and plant specific best estimate TH address success criteria

• Loss of Offsite Power modeling is robust

• Electric power systems modeling is robust; Alternate Power Generator is installed and modeled in the PRA

• SBO / RCP Seall LOCA modeling d li isi robust b and d uses the h WOG 2000 modeld l with high temperature seals

• Convolution method used for LOOP recovery analyses

Description of Risk Assessment

• Applicable pp Guidance and Criteria

• Rev 2 of RG 1.174 and RG 1.200, and Rev 1 of RG 1.177

• Q Quantitative tit ti A Analyses l for f IInternal t l Events E t and d Fl Flood, d Level I and II

• Qualitative Analyses for External Events

• Qualitative discussion combined with IPEEE risk insights for the Fire, High Winds (Tornado), and Seismic (Margins)

• Supported by detailed walkdown of plant

Discussion of Sensitivity Analyses

• Sensitivity studies are used to address uncertainties.

These studies will include but are not limited to:

- Reliability of components important to the risk contributions of the CT extension

- Increased I d duration d ti off XST1 CT

- LOOP Weather and Plant Centered frequencies

- Deferred maintenance

• Uncertainty analysis will be performed per NUREG 1855.

855.

- Common Cause Failure discussion

Configuration Risk Management Program

• CPNPP has a Configuration Risk Management Program

- Incorporates the characteristics of the model Configuration Risk Management Program described in RG 1.177

- CRMP description has been incorporated into plant Technical Specifications - 5.5.18 5 5 18

- Previously approved for one time 14day change to Technical Specifications for AC Sources - Operating - B 3.8.1 Required Action A.3 (XST2A transformer installation)

• CRMP is a requirement off the h Maintenance Rule l Program.

CPNPP endorses the guidance in NUMARC 9301, Industry Guideline For Monitoring the Effectiveness Of Maintenance At Nuclear Power Plants Plants

• CPNPP will meet the fire (a)(4) requirement by December 1, 2013

Configuration Risk Management Program -

Risk Mitigation Actions

[Implemented during the extended CTs]

1. Restricted Access to and Suspension of Maintenance in the Switchyard.

2. Testing of Diesel Generators (EDG and APG) and Turbine Driven Auxiliary Feedwater Pumps within the Two (2) Weeks Prior to the Start of the XST1 extended CT.

3. Rescheduling of Testing and Maintenance on the EDGs, APGs, TDAFWPs, XST2, CCWPs and SSWPs to occur outside the extended CT window.

4. Suspension of Hot Work Activities Near XST2 Power and Control Cabling.

5. Roving Hourlyl Fire Watch h Along l Paths h off XST2 Power and d Controll Cabling.

bl

6. Selection of Time of Year Due to Weather Considerations.

7. Operations preparations and grid monitoring during the CT.

Preliminary Conclusions of Risk Assessment

• Based upon previous LAR submittal and the current update to the PRA model, model the preliminary PRA results show that the extension of the XST1 CT will have minimal impact on plant risk

Proposed Schedule Luminant Power requests approval of the proposed License Amendment by September 30, 2013, to be implemented within 120 days of the issuance of the license amendment.

Questions? Feedback?