ML15070A252

Pre-Submittal Public Meeting Final Slides on Risk-Informed Completion Times.

ML15070A252
Person / Time
Site:	Palo Verde
Issue date:	02/18/2015
From:	Edington R K Arizona Public Service Co
To:	Watford M M Plant Licensing Branch IV
Singal B K
References
Download: ML15070A252 (34)

Text

Palo Verde/NRC Pre-submittal MeetingRisk Informed Completion TimesFebruary 18, 2015 IntroductionsBryan ThieleDepartment LeaderRisk Informed Project Manager Agenda*Introduction Bryan Thiele

• Palo Verde OverviewThomas Romay

• License Amendment Thomas Weber

• PRA Summary Everett DePue

• Implementation Plan Bryan Thiele

• Path Forward and Closing CommentsBryan Thiele 3

Desired Meeting Outcomes

• Summarize PVNGS design with focus on unique features

• Discuss license amendment content and variances from TSTF 505

• Provide overview of PRA models

• Discuss implementation plan

• Describe path forward 4

Palo Verde Design OverviewTom Romay Shift ManagerSenior Reactor Operator 6

Transmission Network 7

Palo Verde Design Features

• Three identical, separate Units, minimal shared SSCs

• No pressurizer PORVs

• Low leakage RCP seals following loss of seal cooling*Four channels of class instrumentation (two trains w/2 channels each) with separate power*Demonstrated capability to feed SG with no AC/DC power 8

License Amendment RequestThomas WeberDepartment LeaderNuclear Regulatory Affairs RICT Timeline 2012 2013 2014 2015 2016+10License Amendment Drafted and Sent Out for Cross Organization Review -

1 st CutBenchmarking with Vogtleand Diablo CanyonLAR SubmittalAll PRA Peer Reviews Complete (Internal Events, Fire, Flood, Seismic)Approval and ImplementationLAR Final PVNGS Internal ReviewFire and Seismic PRA Development PVNGS LAR Content

• Based on TSTF 505-A & NEI 06-09-A

-Scope includes components modeled in PRA

-25 LCOs -Mode 1 and 2 only

-New TS Section 5.5 Program

-Variances from TSTF 505 addressed in LAR and include:*RICT added to two LCOs not in TSTF 505

• Miscellaneous variances described in LAR 11 TS 3.4.12, Pressurizer Vents

• Not in TSTF 505 or NUREG 1432

• In PV Safety Analysis

• Modeled in PRA

• RICT added to Two Required Actions

-Note added to preclude use of RICT when all pressurizer vent paths are intentionally made inoperable 12 Pressurizer Vent Paths 13 Reactor Drain Tank S S S S S Pressurizer To Containment Atmosphere RCB-HV108 RCA-HV103 RCB-HV109 RCB-HV105RCA-HV106 TS 3.7.3, Main FeedwaterIsolation Valves (MFIVs)

• Not in TSTF 505 but is in NUREG 1432

• LAR adds restoration action

• MFIVs modeled in PRA

• RICT added to Two Required Actions 14 Miscellaneous Variances

-TS 3.7.2, Main Steam Isolation Valves (MSIVs)

• Did not add RICT for restoration conditions associated with MSIV actuator trains

-TS 3.7.4, Atmospheric Dump Valves (ADVs)

• Note added to preclude use of RICT when all ADV lines are intentionally made inoperable

-TS 3.7.9, Ultimate Heat Sink (UHS)

• Added new 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restoration condition for UHS

• Note added to preclude use of RICT when the UHS is intentionally made inoperable

-TS 3.8.7, Inverters

• Revised note since PVNGS design has two inverters per train supporting 4 channels of vital instruments

• Note precludes use of RICT for two or more inverters intentionally made inoperable resulting in a loss of safety function 15 Summary *LAR to remove "Second Completion Time" (TSTF 439) in progress

• Minimizing LARs at PVNGS that have changes to TSTF 505 LCOs

• Monitoring TSTF 505 Operating Experience

• Participating in Industry Committees

• Monitoring TSTF 505 RAIs 16 PRA ModelsEverett DePueSenior EngineerPRA Lead for TSTF-505 Summary of PRA Models

• PRA models developed and peer reviewed

-Internal events

-Internal flood

-Internal fire

-Seismic*RG 1.200 Rev. 2 hazards screened and peer reviewed*Total CDF/LERF meet RG 1.174 Rev. 2 limits

• Internal events and internal flood risk very low*CDF/LERF dominated by internal fire and seismic hazards 18 Internal Events PRA

• Peer review by CEOG conducted in 1999

• Self-assessment performed against entire RA-Sa-2009 in 2015

• RA-Sa-2009 Supporting Requirements met to Capability Category II except:

-Some sub-elements of SY-C1, SY-C2 System Notebook Documentation need completion

• To be completed prior to RICT Program implementation 19 Internal Flood PRA

• Industry Peer Review conducted in 2010

• All ASME/ANS PRA requirements met to Capability Category II after peer review

findings addressed 20 Internal Fire PRA

• PVNGS is not NFPA-805 plant, -Fire PRA complies with methods in NUREG/CR-6850

• Industry Peer Review conducted in 2012

• Follow-up Industry Peer Review conducted in 2014 -addressed 2012 findings

• All ASME/ANS requirements met to Capability Category II after peer review findings

addressed 21 Seismic PRA

• Industry peer review conducted in 2013

• All ASME/ANS requirements met to Capability Category II after peer review findings addressed except

-SPR B7 Complementary Success Logic

• Meets Capability Category II for ASME/ANS RA-Sb-2013 22 Plant-Specific Modeling

• RICT CRMP model will be either:

-Real time risk model as currently used for existing Technical Specification CRMP OR-Pre-solved solutions (STP approach)

• Common Cause treatment will be in accordance with NEI 06-09-A or Regulatory Guide 1.177 Rev. 1 23 Plant Modifications

• PRA models rely on installation of modifications or taking compensatory

measures*RICT Program will not be implemented until modifications complete or compensatory measures in place

• FLEX strategies not yet reflected in the PRA models -conservatism 24 Summary*All hazards have been evaluated in accordance with RG 1.200 Rev. 2

• All PRA models peer reviewed

• Capability Category II met for all PRA models with three exceptions

• Total CDF/LERF meet RG 1.174 Rev. 2 25 Implementation PlanBryan Thiele Department LeaderRisk Informed Project Manager Implementation Plan

• Engineering coordinate RICT implementation

• Cross organization team supporting implementation

• RICT implemented in Modes 1 and 2 only

• CRMP tool PRA Models will include Internal Events, Internal Flooding, Fire, and Seismic

• Procedure changes, training, and qualifications will support RICT CRMP

capability

-Extensive use of industry participation & benchmarking to develop program, procedures, training 27 Procedures

• Revise 40DP-9RS01, Operations Department Online Nuclear Risk

Management Mode 1 and 2, to include

-RICT -Risk management action times

-Risk management action determinations

-PRA functionality

• New RICT Program Procedure 28 Training*Licensed Operators

-Hands-on training on RICT calculations

-Classroom training to address how RICT impacts Station Operations

• Station Management

-Affected managers trained on process, expectations, limitations

-Multi-discipline management representatives attend annual MIT nuclear operational risk management (NORM) course

• Engineering

• Work Management 29 Communications

• Industry peers via TSTF-505 task force

• Site-wide communication

-Newsletter

-VP weekly video

-While submittal under review

-Once submittal is approved

• Leader Alignment Meetings

• Department All Hands Meetings 30 Modifications

• DC ammeter circuits

• Non-class 1E DC motor circuits

• Replace RCP control cables with fire rated cables *Install new Steam Generator (SG) makeup pump that utilizes FLEX connections

• Breaker coordination on risk significant non-class 1E motor control centers/panels 31 Path Forward and Closing CommentsBryan ThieleDepartment LeaderRisk Informed Project Manager Path Forward

• Resolve Fire PRA peer review findings and complete documentation

• Submit LAR in June

• Finalize scope and install modifications

• Develop procedures, software and training in parallel with NRC review

• Implement in late 2016 33 34We SAFELY and efficientlygenerate electricity for the long term