ML16008A069

Response to Request for Clarification of NRC Staff Assessment Millstone Power Station 10 CFR 50.54(f) Seismic Reevaluation

ML16008A069
Person / Time
Site:	Millstone
Issue date:	12/21/2015
From:	Nicholas Difrancesco Japan Lessons-Learned Division
To:	Hotchkiss M Dominion Generation
References
Download: ML16008A069 (4)

Text

NRR-PMDAPEm Resource From: DiFrancesco, Nicholas Sent: Monday, December 21, 2015 1:49 PM To: Marc Hotchkiss (Generation - 6) <marc.hotchkiss@dom.com>

(marc.hotchkiss@dom.com)

Cc: Shams, Mohamed; Vega, Frankie; Divakar.Bhargava@dom.com

Subject:

Response to Request for Clarification of NRC Staff Assessment re: Millstone Power Station 10 CFR 50.54(f) Seismic Reevaluation Mr. Marc Hotchkiss, Thank you for your question regarding the re-screening language included in the staff assessment issued on December 15, 2015, for Millstone Units 2 and 3. As you indicate, the NRCs October 27, 2015, letter to you provides two options to complete the closure of the R2.1 Seismic 50.54(f) response for Millstone. Either option represents the set of information necessary for Millstone to submit in order to complete its response to the 50.54 (f) letter. The December 15, 2015, letter and the associated staff assessment contained language about the potential for re-screening Millstone in the event that the SPID criteria related to the IPEEE acceptance are not satisfied. The December 15, 2015, letter omitted highlighting that the NRCs October 27, 2015, letter Table 1b found that no seismic probabilistic risk assessment (SPRA) is warranted for the response to the March 12, 2012 50.54(f) letter for Millstone Units 2 and 3. That conclusion was based on the staffs comparison of the GMRS to the SSE and the review of additional existing hazard and risk information for group 3 and some group 2 plants. Reiterating the conclusion provided in the October 27, 2015, the staff concluded that a SPRA is not warranted for Millstone Units 2 and 3 regardless of satisfying the IPEEE acceptance criteria in the SPID for the response to the March 12, 2012 50.54(f) letter. In addition, no re-screening for Millstone is necessary regardless of which of the two options listed in the October 27, 2015, letter the licensee chooses to exercise to complete its response to the 50.54(f) letter.

In a separate regulatory track, Millstone continues to be expected to submit a mitigation strategies assessment with respect to the reevaluated hazards. If Millstone chooses not to complete the IPEEE relay review, then Path 3 would not be an option for the mitigating strategies assessment. Please let me know if you have additional questions or concerns.

This email will be placed in ADAMS a public document.

Thanks, Nick DiFrancesco Senior Project Manager - Seismic Reevaluation Activities U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Japan Lesson Learned Project Division nicholas.difrancesco@nrc.gov l Tel: (301) 415-1115 From: Marc Hotchkiss (Generation - 6) [1]

Sent: Wednesday, December 16, 2015 12:50 PM To: DiFrancesco, Nicholas <Nicholas.DiFrancesco@nrc.gov>

Cc: Vega, Frankie <Frankie.Vega@nrc.gov>

1

Subject:

[External_Sender] Request for Clarification of NRC Staff Assessment re: Millstone Power Station 10 CFR 50.54(f)

Seismic Reevaluation

Reference:

1. USNRC Letter dated December 15, 2015; ML15328A268

2. USNRC Letter dated October 27, 2015; ML15194A015

3. EPRI 3002004396; High Frequency Program Application Guidance

Nick, We reviewed the reference 1 NRC Staff Assessment (SA) letter for Millstone Units 2 and 3 Seismic Hazard and Screening Report submittal and have found a need to request clarification of the requirements for performing the full-scope IPEEE relay chatter review and the High Frequency (HF) sensitive equipment confirmation to complete the response to the 10 CFR 50.54(f) information request related to seismic reevaluation.

On page 4 of the SA, last paragraph, it states that the HF confirmation is not considered a substitute for the IPEEE relay chatter review. Page 11 of the SA further indicates that both the relay chatter review and the HF confirmation are required to be performed and that failure to meet the IPEEE program screening criteria in the SPID (potentially interpreted as unsuccessful / non-performance of relay chatter review) would merit re-screening by the SSE and performance of a seismic risk evaluation.

Our understanding in discussions with the staff during public meetings has been that the full scope relay evaluation for plants that used IPEEE to screen out of risk assessments is no longer required provided these plants performed a high frequency relay assessment (as applicable) per the NRC endorsed EPRI guidance (ref. 3). This understanding was confirmed, in the NRC letter transmitting the final determination of SPRAs (reference 2), Millstone was indicated as having the option to substitute the HF confirmation for the IPEEE Relay Chatter review in Option 2 of Table 1b of the letter. This seems contrary to the statements in the SA for required actions to complete the 10 CFR 50.54(f) information request submittals.

Please clarify the requirement for Millstone to perform IPEEE full-scope relay chatter review vs. the HF confirmation for the purposes of completing the 10 CFR 50.54(f) information request requirements. We are available to discuss further if needed.

Thanks, Marc Marc W. Hotchkiss Seismic Project Manager Dominion Beyond Design Basis Project Innsbrook Technical Center IN2SE 5000 Dominion Blvd.

Glen Allen, VA 23060 804-273-3084 ofc 804-241-2593 cell CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents 2

of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

3

Hearing Identifier: NRR_PMDA Email Number: 2582 Mail Envelope Properties (aa861eeebf4849aa82b5802a6f1287e5)

Subject:

Response to Request for Clarification of NRC Staff Assessment re: Millstone Power Station 10 CFR 50.54(f) Seismic Reevaluation Sent Date: 12/21/2015 1:48:51 PM Received Date: 12/21/2015 1:48:00 PM From: DiFrancesco, Nicholas Created By: Nicholas.DiFrancesco@nrc.gov Recipients:

"Shams, Mohamed" <Mohamed.Shams@nrc.gov>

Tracking Status: None "Vega, Frankie" <Frankie.Vega@nrc.gov>

Tracking Status: None "Divakar.Bhargava@dom.com" <Divakar.Bhargava@dom.com>

Tracking Status: None "Marc Hotchkiss (Generation - 6) <marc.hotchkiss@dom.com> (marc.hotchkiss@dom.com)"

<marc.hotchkiss@dom.com>

Tracking Status: None Post Office: HQPWMSMRS07.nrc.gov Files Size Date & Time MESSAGE 5884 12/21/2015 1:48:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

NRR-PMDAPEm Resource From: DiFrancesco, Nicholas Sent: Monday, December 21, 2015 1:49 PM To: Marc Hotchkiss (Generation - 6) <marc.hotchkiss@dom.com>

(marc.hotchkiss@dom.com)

Cc: Shams, Mohamed; Vega, Frankie; Divakar.Bhargava@dom.com

Subject:

Response to Request for Clarification of NRC Staff Assessment re: Millstone Power Station 10 CFR 50.54(f) Seismic Reevaluation Mr. Marc Hotchkiss, Thank you for your question regarding the re-screening language included in the staff assessment issued on December 15, 2015, for Millstone Units 2 and 3. As you indicate, the NRCs October 27, 2015, letter to you provides two options to complete the closure of the R2.1 Seismic 50.54(f) response for Millstone. Either option represents the set of information necessary for Millstone to submit in order to complete its response to the 50.54 (f) letter. The December 15, 2015, letter and the associated staff assessment contained language about the potential for re-screening Millstone in the event that the SPID criteria related to the IPEEE acceptance are not satisfied. The December 15, 2015, letter omitted highlighting that the NRCs October 27, 2015, letter Table 1b found that no seismic probabilistic risk assessment (SPRA) is warranted for the response to the March 12, 2012 50.54(f) letter for Millstone Units 2 and 3. That conclusion was based on the staffs comparison of the GMRS to the SSE and the review of additional existing hazard and risk information for group 3 and some group 2 plants. Reiterating the conclusion provided in the October 27, 2015, the staff concluded that a SPRA is not warranted for Millstone Units 2 and 3 regardless of satisfying the IPEEE acceptance criteria in the SPID for the response to the March 12, 2012 50.54(f) letter. In addition, no re-screening for Millstone is necessary regardless of which of the two options listed in the October 27, 2015, letter the licensee chooses to exercise to complete its response to the 50.54(f) letter.

In a separate regulatory track, Millstone continues to be expected to submit a mitigation strategies assessment with respect to the reevaluated hazards. If Millstone chooses not to complete the IPEEE relay review, then Path 3 would not be an option for the mitigating strategies assessment. Please let me know if you have additional questions or concerns.

This email will be placed in ADAMS a public document.

Thanks, Nick DiFrancesco Senior Project Manager - Seismic Reevaluation Activities U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Japan Lesson Learned Project Division nicholas.difrancesco@nrc.gov l Tel: (301) 415-1115 From: Marc Hotchkiss (Generation - 6) [2]

Sent: Wednesday, December 16, 2015 12:50 PM To: DiFrancesco, Nicholas <Nicholas.DiFrancesco@nrc.gov>

Cc: Vega, Frankie <Frankie.Vega@nrc.gov>

1

Subject:

[External_Sender] Request for Clarification of NRC Staff Assessment re: Millstone Power Station 10 CFR 50.54(f)

Seismic Reevaluation

Reference:

1. USNRC Letter dated December 15, 2015; ML15328A268

2. USNRC Letter dated October 27, 2015; ML15194A015

3. EPRI 3002004396; High Frequency Program Application Guidance

Nick, We reviewed the reference 1 NRC Staff Assessment (SA) letter for Millstone Units 2 and 3 Seismic Hazard and Screening Report submittal and have found a need to request clarification of the requirements for performing the full-scope IPEEE relay chatter review and the High Frequency (HF) sensitive equipment confirmation to complete the response to the 10 CFR 50.54(f) information request related to seismic reevaluation.

On page 4 of the SA, last paragraph, it states that the HF confirmation is not considered a substitute for the IPEEE relay chatter review. Page 11 of the SA further indicates that both the relay chatter review and the HF confirmation are required to be performed and that failure to meet the IPEEE program screening criteria in the SPID (potentially interpreted as unsuccessful / non-performance of relay chatter review) would merit re-screening by the SSE and performance of a seismic risk evaluation.

Our understanding in discussions with the staff during public meetings has been that the full scope relay evaluation for plants that used IPEEE to screen out of risk assessments is no longer required provided these plants performed a high frequency relay assessment (as applicable) per the NRC endorsed EPRI guidance (ref. 3). This understanding was confirmed, in the NRC letter transmitting the final determination of SPRAs (reference 2), Millstone was indicated as having the option to substitute the HF confirmation for the IPEEE Relay Chatter review in Option 2 of Table 1b of the letter. This seems contrary to the statements in the SA for required actions to complete the 10 CFR 50.54(f) information request submittals.

Please clarify the requirement for Millstone to perform IPEEE full-scope relay chatter review vs. the HF confirmation for the purposes of completing the 10 CFR 50.54(f) information request requirements. We are available to discuss further if needed.

Thanks, Marc Marc W. Hotchkiss Seismic Project Manager Dominion Beyond Design Basis Project Innsbrook Technical Center IN2SE 5000 Dominion Blvd.

Glen Allen, VA 23060 804-273-3084 ofc 804-241-2593 cell CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents 2

of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

3

Hearing Identifier: NRR_PMDA Email Number: 2582 Mail Envelope Properties (aa861eeebf4849aa82b5802a6f1287e5)

Subject:

Response to Request for Clarification of NRC Staff Assessment re: Millstone Power Station 10 CFR 50.54(f) Seismic Reevaluation Sent Date: 12/21/2015 1:48:51 PM Received Date: 12/21/2015 1:48:00 PM From: DiFrancesco, Nicholas Created By: Nicholas.DiFrancesco@nrc.gov Recipients:

"Shams, Mohamed" <Mohamed.Shams@nrc.gov>

Tracking Status: None "Vega, Frankie" <Frankie.Vega@nrc.gov>

Tracking Status: None "Divakar.Bhargava@dom.com" <Divakar.Bhargava@dom.com>

Tracking Status: None "Marc Hotchkiss (Generation - 6) <marc.hotchkiss@dom.com> (marc.hotchkiss@dom.com)"

<marc.hotchkiss@dom.com>

Tracking Status: None Post Office: HQPWMSMRS07.nrc.gov Files Size Date & Time MESSAGE 5884 12/21/2015 1:48:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: