Letter Sequence RAI |
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CAC:MF8462, Implement 10 CFR 50, Appendix J, Option B (Approved, Closed) |
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Category:Letter
MONTHYEARIR 05000354/20230042024-02-0101 February 2024 Integrated Inspection Report 05000354/2023004 ML24030A8752024-02-0101 February 2024 Operator Licensing Examination Approval ML24009A1022024-01-26026 January 2024 Exemption from Select Requirements of 10 CF Part 73 (EPID L-2023-LLE-0045 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000354/20234012024-01-22022 January 2024 Material Control and Accounting Program Inspection Report 05000354/2023401 ML23341A1372024-01-16016 January 2024 Issuance of Amendment No. 235 Revise Trip and Standby Auto-Start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning ML23335A1122023-12-15015 December 2023 Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers ML23307A1532023-12-15015 December 2023 NRC Investigation Report No. 1-2023-001 ML23270C0072023-11-29029 November 2023 Notice of Proposed Amendment to Decommissioning Trust Agreement ML23324A3072023-11-17017 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000354/20230032023-11-0707 November 2023 Integrated Inspection Report 05000354/2023003 IR 05000272/20234022023-10-12012 October 2023 and Salem Nuclear Generating Station, Units 1 and 2 - Security Baseline Inspection Report 05000354/2023402, 05000272/2023402 and 05000311/2023402 (Cover Letter Only) LR-N23-0065, Submittal of 2023 Annual 10 CFR 50.46 Report2023-10-0202 October 2023 Submittal of 2023 Annual 10 CFR 50.46 Report LR-N23-0045, and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement2023-09-0808 September 2023 and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement ML23249A2612023-09-0606 September 2023 License Amendment Request to Modify the Salem and Hope Creek Exclusion Area Boundary IR 05000354/20230052023-08-31031 August 2023 Updated Inspection Plan for Hope Creek Generating Station (Report 05000354/2023005) ML23192A8212023-08-14014 August 2023 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Issuance of Amendment Nos. 234, 347, and 329 Revise Technical Specifications to Delete Meteorological Tower Location IR 05000354/20230022023-08-0303 August 2023 Integrated Inspection Report 05000354/2023002 and Independent Spent Fuel Storage Installation Inspection Report 07200048/2023001 IR 05000354/20230102023-08-0303 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000354/2023010 LR-N23-0052, Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers Per Technical Specification 4.6.2.12023-07-31031 July 2023 Retest Schedule for Drywell to Suppression Chamber Vacuum Breakers Per Technical Specification 4.6.2.1 LR-N23-0042, Spent Fuel Cask Registration2023-07-12012 July 2023 Spent Fuel Cask Registration LR-N23-0046, Emergency Plan Document Revisions Implemented June 28, 20232023-07-10010 July 2023 Emergency Plan Document Revisions Implemented June 28, 2023 IR 05000354/20230112023-05-0101 May 2023 Commercial Grade Dedication Report 05000354/2023011 ML23121A1412023-05-0101 May 2023 Senior Reactor and Reactor Operator Initial License Examinations LR-N23-0034, 2022 Annual Radiological Environmental Operating Report (AREOR) - Salem Nuclear Generating Station, Unit Nos. 1 and 2 and Hope Creek Generating Station2023-04-27027 April 2023 2022 Annual Radiological Environmental Operating Report (AREOR) - Salem Nuclear Generating Station, Unit Nos. 1 and 2 and Hope Creek Generating Station LR-N23-0035, 2022 Annual Radioactive Effluent Release Report (ARERR)2023-04-27027 April 2023 2022 Annual Radioactive Effluent Release Report (ARERR) IR 05000354/20230012023-04-26026 April 2023 Integrated Inspection Report 05000354/2023001 LR-N23-0010, License Amendment Request Revision of Technical Specification (TS) to Delete TS Section 5.5 - Meteorological Tower Location2023-04-21021 April 2023 License Amendment Request Revision of Technical Specification (TS) to Delete TS Section 5.5 - Meteorological Tower Location LR-N23-0009, License Amendment Request (LAR) to Revise the Hope Creek Trip and Standby Auto-start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning (HVAC) Trains2023-04-18018 April 2023 License Amendment Request (LAR) to Revise the Hope Creek Trip and Standby Auto-start Logic Associated with Safety Related Heating, Ventilation and Air Conditioning (HVAC) Trains ML23087A1492023-04-17017 April 2023 NRC to PSEG Salem, Transmittal of the National Marine Fisheries Service'S March 24, 2023, Biological Opinion GAR-2020-02842 Concerning Salem and Hope Creek ML23089A0942023-04-17017 April 2023 NRC to PSEG Hope Creek, Transmittal of the National Marine Fisheries Service'S March 24, 2023, Biological Opinion GAR-2020-02842 Concerning Salem and Hope Creek ML23103A3232023-04-13013 April 2023 Submittal of Updated Final Safety Analysis Report, Rev. 26, Summary of Revised Regulatory Commitments for Hope Creek, Summary of Changes to PSEG Nuclear LLC, Quality Assurance Topical Report, NO-AA-10, Rev. 89 ML23095A3682023-04-12012 April 2023 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Threshold Determination for Proposed Transfer of Land Ownership LR-N23-0024, Submittal of Hope Creek Generating Station Technical Specification Bases Changes2023-03-29029 March 2023 Submittal of Hope Creek Generating Station Technical Specification Bases Changes LR-N23-0006, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-24024 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23086A0912023-03-24024 March 2023 NMFS to NRC, Transmittal of Biological Opinion for Continued Operations of Salem and Hope Creek Nuclear Generating Stations LR-N23-0019, and Salem Generating Station, Units 1 and 2 - Guarantees of Payment of Deferred Premiums2023-03-21021 March 2023 and Salem Generating Station, Units 1 and 2 - Guarantees of Payment of Deferred Premiums ML23037A9712023-03-0909 March 2023 and Salem Nuclear, Unit Nos. 1 and 2 Issuance of Amendment Nos. 233, 344, and 325 Relocate Technical Specification Staff Qualification Requirements to the PSEG Quality Assurance Topical Report IR 05000354/20220062023-03-0101 March 2023 Annual Assessment Letter for Hope Creek Generating Station (Report 05000354/2022006) LR-N23-0016, and Salem Generating Station, Units 1 and 2 - Report of Changes, Tests, and Experiments2023-02-28028 February 2023 and Salem Generating Station, Units 1 and 2 - Report of Changes, Tests, and Experiments LR-N23-0018, Technical Specification 6.9.1.5.b - 2022 Annual Report of SRV Challenges2023-02-27027 February 2023 Technical Specification 6.9.1.5.b - 2022 Annual Report of SRV Challenges LR-N23-0012, Annual Property Insurance Status Report2023-02-24024 February 2023 Annual Property Insurance Status Report LR-N23-0014, Stations Submittal of 2022 Annual Report of Fitness for Duty Performance Data Per 10 CFR 26.203(e) and 10 CFR 26.7172023-02-23023 February 2023 Stations Submittal of 2022 Annual Report of Fitness for Duty Performance Data Per 10 CFR 26.203(e) and 10 CFR 26.717 IR 05000354/20220042023-01-24024 January 2023 Integrated Inspection Report 05000354/2022004 LR-N23-0011, In-Service Inspection Activities - 90 Day Report: Twenty-Fourth Refueling Outage2023-01-19019 January 2023 In-Service Inspection Activities - 90 Day Report: Twenty-Fourth Refueling Outage LR-N22-0096, and Salem Generating Station, Units 1 and 2 - Request for Threshold Determination2023-01-0505 January 2023 and Salem Generating Station, Units 1 and 2 - Request for Threshold Determination LR-N22-0094, Emergency Plan Document Revisions Implemented November 21, 20222022-12-14014 December 2022 Emergency Plan Document Revisions Implemented November 21, 2022 LR-N22-0091, Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments2022-12-0202 December 2022 Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments ML22335A0412022-12-0101 December 2022 Notification of Commercial Grade Dedication Inspection (05000354/2023011) and Request for Information IR 05000354/20220032022-11-0303 November 2022 Integrated Inspection Report 05000354/2022003 2024-02-01
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML22006A3212022-01-0606 January 2022 NRR E-mail Capture - Final RAI - Hope Creek - Revise TS Limits for Ultimate Heat Sink ML21300A0222021-10-27027 October 2021 Notification of Conduct of a Fire Protection Team Inspection ML21041A3972021-02-18018 February 2021 Request for Additional Information Revise Low Pressure Safety Limit to Address General Electric Part-21 Safety Communications (Non-Proprietary) ML20295A4922020-10-21021 October 2020 NRR E-mail Capture - Hope Creek - Final RAI Revise ECCS TS with Respect to HPCI System Inoperability (L-2020-LLA-0131) ML18263A1442018-09-12012 September 2018 NRR E-mail Capture - Final RAI from Apla: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0101) ML18250A3142018-09-0606 September 2018 NRR E-mail Capture - Final RAI: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0101) ML18150A6912018-05-30030 May 2018 NRR E-mail Capture - Hope Creek - Final RAI Revise TS to Adopt TSTF-542 ML18120A2482018-04-27027 April 2018 Information Request for the Cyber-Security Inspection, Notification to Perform Inspection 05000354/2018403 ML18094B0832018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to P. Duke RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for Salem and Hope Creek, and Peach Bottom ISFSIs Docket Nos. 72-48 and 72-29) ML17349A0812017-12-14014 December 2017 NRR E-mail Capture - Final Request for Additional Information for Reactor Systems Branch (Srxb) - Hope Creek Mur ML17348A9972017-12-14014 December 2017 NRR E-mail Capture - Final Request for Additional Information for Steam Dryer Analysis with the Hope Creek Measurement Uncertainty Recapture Uprate Request (L-2017-LLS-002) ML17348A6242017-12-14014 December 2017 NRR E-mail Capture - Final Request for Additional Information for Human Factors Associated with the Hope Creek Measurement Uncertainty Recapture Uprate Request (L-2017-LLS-002) ML17331A0072017-11-21021 November 2017 E-mail Regarding Final Eicb Request for Additional Information - Hope Creek Power Uprate ML17348A6282017-11-21021 November 2017 NRR E-mail Capture - Draft Request for Additional Information for Steam Dryer Analysis with the Hope Creek Measurement Uncertainty Recapture Uprate Request (L-2017-LLS-002) ML17324A2602017-11-17017 November 2017 NRR E-mail Capture - Final Request for Additional Information - Hope Creek Mur Electrical Instrumentation and Controls ML17320A2152017-11-16016 November 2017 NRR E-mail Capture - Hope Creek Measurement Uncertainty Recapture Application Review - Electrical Engineering (Eeob) Request for Additional Information (L-2017-LLS-0002) ML17290B0132017-10-17017 October 2017 NRR E-mail Capture - Hope Creek Mur Request for Additional Information for Apla and Snpb ML17222A1652017-08-10010 August 2017 NRR E-mail Capture - Hope Creek: Final Request for Information, Pressure-Temperature Limit Report Request (MF9502) ML17181A1352017-06-29029 June 2017 NRR E-mail Capture - Request for Additional Information Related to Hope Creek and Salem Emergency Action Level Scheme Change License Amendment Request (MF9268/69/70) ML17164A4062017-06-13013 June 2017 NRR E-mail Capture - Hope Creek - Final Request for Additional Information Concerning ILRT (MF8462) ML17027A3282017-02-27027 February 2017 Request for Additional Information Regarding License Amendment Request to Permanently Extend Type a and Type C Leak Rate Test Frequencies ML16321A4642016-11-21021 November 2016 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Request for Additional Information Regarding License Amendment Request to Remove Certain Training Requirements ML16277A5142016-11-0303 November 2016 Request for Additional Information Regarding License Amendment Request to Permit Operability of Low Pressure Coolant Injection While Aligned to Shutdown Cooling ML16271A2052016-11-0202 November 2016 Request for Additional Information Regarding Request to Delete Technical Specifications Action Statement 3.4.2.1.b Associated with Stuck Open Safety/Relief Valves ML16231A4272016-08-24024 August 2016 Request for Additional Information Regarding Relief Request VR-02, Associated with the Fourth 10-Year Inservice Test Interval ML16217A4302016-08-17017 August 2016 Request for Additional Information Regarding Digital Power Range Neutron Monitoring System Upgrade ML16007A1742016-05-31031 May 2016 Request for Additional Information Regarding Review of Post-EPU Steam Dryer Stress Calculation Acoustic Circuit Model Software Error ML16089A0792016-05-0505 May 2016 Request for Additional Information Regarding Relief Requests GR-01, PR-01, PR-02, VR-01, and VR-02, Associated with the Fourth 10-Year Inservice Test Interval ML16124A5802016-05-0303 May 2016 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Redacted - Request for Additional Information Review of Security Plan Revision 17 Changes ML15055A3772015-03-10010 March 2015 and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Request for Additional Information Request to Update Appendix B to Renewed Facility Operating License DPR-70, DPR-75 and NPF-57 ML14197A6192014-07-24024 July 2014 and Salem Nuclear Generating Station, Units 1 and 2 - Request for Additional Information Regarding Cyber Security Plan Milestone 8 Implementation Schedule (Tac Nos. MF3384, MF3385 and MF3386) ML14168A2352014-07-0202 July 2014 Request for Additional Information Regarding Flooding Hazard Reevaluation ML13309B5922013-11-22022 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13168A2762013-08-12012 August 2013 Peach Bottom, Units 2 and 3, Request for Additional Information Decommissioning Funding Status Report (TAC No. MF2202; MF2227; MF2228) ML13193A2912013-07-22022 July 2013 Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) TAC MF1031 ML13204A2532013-07-19019 July 2013 Draft RAIs - Decommissioning Funding Status Report for Hope Creek and Peach Bottom ML13190A2212013-07-0202 July 2013 RAIs for Hope Creek Regarding Response to Order EA-12-051 ML13154A4952013-06-0404 June 2013 Rai'S Following Ifib Analysis of Pseg'S 2013 Decommissioning Funding Status Report for Hope Creek Generating Station ML12334A3102012-12-0505 December 2012 Request for Additional Information Request to Correct Technical Specification and Facility Operating License Editorial Items ML12310A1672012-11-0101 November 2012 Draft RAI to License Amendment Request Regarding Average Power Range Monitoring Operability Requirements in Operational Condition 5 ML1227901012012-10-0505 October 2012 Clarifying Information for Question No. 4 (with Attachment) ML12212A1032012-08-0808 August 2012 and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Request for Additional Information ML12216A1792012-08-0303 August 2012 Draft RAI Related to Request for Exemption from Certain Requirements of the Fitness for Duty Rule ML12213A6162012-07-30030 July 2012 Draft Request for Additional Information Related to Request for Exemption from Certain Requirements of the Fitness for Duty Rule ML1209002372012-03-29029 March 2012 and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Draft Request for Additional Information ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic 2022-01-06
[Table view] |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Peter P. Sena, Ill President and Chief Nuclear Officer PSEG Nuclear LLC -N09 P.O. Box 236 Hancocks Bridge, NJ 08038 February 27, 2017 SUBJECT: HOPE CREEK GENERATING STATION -REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO PERMANENTLY EXTEND TYPE A AND TYPE C LEAK RATE TEST FREQUENCIES (CAC NO. MF8462) Dear Mr. Sena: By letter dated October 7, 2016,1 PSEG Nuclear LLC (PSEG or the licensee) submitted a license amendment request to revise the Hope Creek Generating Station (Hope Creek) Technical Specifications by incorporating Nuclear Energy Institute (NEI) topical report 94-01, Revision 3-A, and the conditions and limitations specified in NEI topical report 94-01, Revision 2-A, as the implementation document for the Hope Creek performance based containment leakage rate testing program. Based on guidance in NEI 94-01, Revision 3-A, the proposed change would allow the Hope Creek Type A Test (Integrated Leak Rate Test, or ILRT) frequency to be extended from 10 to 15 years, and the Type C Tests (Local Leak Rate Tests, or LLRTs} frequency to be extended from 60 to 75 months. In addition, the amendment would delete a one-time extension of the test frequencies previously granted in License Amendment No. 14 7 (dated April 16, 2003). Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (1 O CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 1 O CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations. The U.S. Nuclear Regulatory Commission staff has reviewed the licensee's application and, based upon this review, determined that additional information is needed to complete our review. On January 25, 2017, a draft of these questions were sent to Mr. Paul Duke of your staff to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On February 14, 2017, and Feburary 21, 2017, teleconferences were held to clarify the questions. On Feburary 24, 2017, Mr. Duke indicated that PSEG will submit a response within 30 days of the date of this letter. 1 Agencywide Documents Access and Management System Accession No. ML 16281A139.
P. Sena, Ill -2 -If you have any questions, please contact me at (301) 415-1603 or by e-mail at Carleen.Parker@nrc.gov. Docket No. 50-354 Enclosure: Request for Additional Information cc w/enclosure: Distribution via Listserv Sincerely, {\ I\ . arker, Project Manager Plant Lie sing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation P. Sena, Ill -3 -SUBJECT: HOPE CREEK GENERATING STATION -REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO PERMANENTLY EXTEND TYPE A AND TYPE C LEAK RA TE TEST FREQUENCIES (CAC NO. MF8462) DATED FEBRUARY 27, 2017 DISTRIBUTION: PUBLIC LPL 1 R/F RidsNrrLALRonewicz Resource RidsACRS_MailCTR Resource RidsNrrDraApla Resource RidsNrrDssStsb Resource RidsNrrDeEmcb Resource CTilton, NRR RidsNrDorl Resource RidsNrrDorlLpl1 Resource RidsNrrPMHopeCreek Resource RidsRgn1 MailCenter Resource DHoang, NRR RidsNrrDssSbpb Resource SVasavada, NRR JBettle, NRR ADAMS A ccess1on N ML 17027A328 o.: *b *1 d t d ,Y e-ma1 ae OFFICE DORL/LPL 1/PM DORL/LPL 1 /LA DRA/APLA/BC* DORL/LPL 1 /BC(A) NAME CParker LRonewicz SRosenberg SKoenick DATE 02/15/17 01 /31/17 01/09/17 02/15/17 OFFICIAL RECORD COPY DORL/LPL 1/PM CParker 02/27/17 REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT REQUEST TO PERMANENTLY EXTEND TYPE A AND TYPE C LEAK RATE TEST FREQUENCIES PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354 By letter dated October 7, 2016,1 PSEG Nuclear LLC (PSEG or the licensee) submitted a license amendment request (LAR) to revise the Hope Creek Generating Station (Hope Creek or HCGS) Technical Specifications by incorporating Nuclear Energy Institute (NEI) topical report 94-01, Revision 3-A, and the conditions and limitations specified in NEI topical report 94-01, Revision 2-A, as the implementation document for the Hope Creek performance based containment leakage rate testing program. Based on guidance in NEI 94-01, Revision 3-A, the proposed change would allow the Hope Creek Type A Test (Integrated Leak Rate Test, or ILRT) frequency to be extended from 10 to 15 years, and the Type C Tests (Local Leak Rate Tests, or LLRTs) frequency to be extended from 60 to 75 months. In addition, the amendment would delete a one-time extension of the test frequencies previously granted in License Amendment No. 147 (dated April 16, 2003).2 The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff has reviewed the application and, based upon this review, determined that the following additional information is needed to complete our review: 1. LAR Attachment 3, Section 5.7.3, "Other External Events Discussion," states that other external hazards, including high winds and tornadoes, external floods, transportation accidents, and nearby facility accidents, were assumed to not impact the results and conclusion of the risk assessment. These hazards were determined to be negligible contributors to overall plant risk based on the individual plant examination for external events (IPEEE) analysis. Since the IPEEE studies are outdated (one-time review completed in 1997), discuss, in the context of the current plant and its environs, the applicability of the IPEEE conclusions for the current LAR. Also, discuss the impact of any updated risk studies, such as the reevaluated external hazards for Hope Creek arising from the Near-Term Task Force (NTTF)3 recommendation. 2. Based on the individual contributors to the total large early release frequency (LEAF) reported in LAR Attachment 3, Table 5.7-7, "Impact of 15-YR ILRT Extension on LERF 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML 16281A139. 2 ADAMS Accession No. ML030660099. 3 The NTTF was established in response to Commission direction to conduct a systematic and methodical review of NRG processes and regulations to determine whether the agency should make additional improvements to its regulatory system and to make recommendations to the Commission for its policy direction, in light of the accident at the Fukushima Dai-ichi Nuclear Power Plant (ADAMS Accession No. ML 111861807). Enclosure
-2 -for HCGS," it appears that the total LEAF would be 4.82E-6 per year, instead of the reported value of 8.17E-6 per year. In addition, the values for delta LEAF in LAR Attachment 3, Table 5.6-1, "HCGS ILRT Cases: Base, 3 to 10, and 3 to 15 YR Extensions (Including Age Adjusted Steel Liner Corrosion Likelihood)," and Table 5.6-2, "HCGS ILRT Extension Results Comparison to Acceptance Criteria, are inconsistent. Address the cited discrepancies in total LEAF and delta LEAF. 3. In LAR Attachment 3, Appendix A, Section A.2.4, "Consistency with Applicable PRA Standards, the licensee provided a summary of peer reviews and self-assessments for the internal events probabilistic risk assessment (PRA) model. a. Confirm that the 2009 peer review was a full-scope peer review of the internal events and internal flooding PRA model. b. Describe all changes, including any new analyses or incorporation of new methodology, performed in the internal events and internal flooding PRA model after the peer review, and justify whether any of the changes fit the definition and criteria of 2009 American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS) PRA Standard (ASME/ANS RA-Sa-2009) for a PRA upgrade. c. If a focused-scope peer review is deemed necessary based on the response to item b above, provide the results of such a review addressing the associated facts and observations (F&Os) and their disposition. 4. The following requests for information apply to the internal events F&Os and their corresponding resolutions as reported in Table A-1, "Resolution of Peer Review F&Os, of Appendix A, Attachment 3, to the LAR: a. F&O LE-G1-01, Level 2 Analysis roadmap detail enhancement, states that the Hope Creek Level 2 analysis notebook was not "written in a manner conducive to demonstrating the requirements of the standard were met" and that it "limited the ability of the Peer-Review team to perform an adequate review." The corresponding resolution compares the Hope Creek Level 2 analysis notebook to those used and peer-reviewed elsewhere. However, the F&O statements appear to imply that the peer review team, due to the limitations cited in the F&O, did not review, or only partially reviewed, the Level 2 analysis against the LEAF analysis (LE) supporting requirements of the 2005 ASME PRA standard. Since LEAF is a key metric in the risk assessment supporting the LAR, justify, in the context of the cited F&O and the foregoing discussion, why a focused-scope peer review of the Level 2 PRA model is not required. b. F&O QU-E4-01, Uncertainty analysis structured sensitivity evaluations, identified that the evaluation of uncertainties did not identify or address any plant specific sources of uncertainty. In the F&O resolution the licensee stated that this issue has not yet been resolved, because there was no published guidance on the treatment of uncertainties at the time the resolution was documented. This
-3 -resolution appears to no longer be valid since NUREG-1855, Volume 1, "Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decision Making,4 and supplemental Electric Power Research Institute (EPRI) guidance, such as EPRI Technical Report (TR)-1016737 and EPRI TR-1026511, on the treatment of uncertainties in PRA have been issued. Further, contrary to the F&O resolution stating that the PRA standard does not require evaluation of sources of model uncertainty, such an evaluation is required per the 2009 ASME/ANS PRA Standard (ASME/ANS RA-Sa-2009) endorsed by Regulatory Guide (RG) 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities."5 The F&O resolution contradicts the results of the self-assessment, which concluded that supporting requirement QU-E4 of ASME/ANS RA-Sa-2009 is met. i. Describe how the uncertainty evaluation mentioned in F&O QU-E4-01 was performed, given that relevant guidance on the treatment of uncertainties is available. Discuss the impact of the results of the uncertainty evaluation on the LAR. ii. If the uncertainty evaluation mentioned in the F&O has not been performed, justify the conclusion that the lack of the uncertainty analysis would have no impact on the current application. c. F&O SY-814-01, Missing Common Piping Failure Modeling, found that, "it cannot be demonstrated that components/failure modes which fail multiple systems have been included," as required, and provided an example that failure of common piping between the high pressure core injection(HPCl)/feedwater (FW)/core spray (CS) and reactor core isolation cooling (RCIC)/FW systems was not modeled. The resolution provides an explanation of how the example cited in the F&O was addressed. The resolution states that the model modification resulting from the F&O's concerns "has been evaluated and assessed as a negligible impact on PRA risk metrics." However, the resolution also states that, "it has been included as the highest priority model change in 2009." i. Confirm that the failure of common piping between HPCl/FW/CS and RCIC/FW systems has been included in the internal events PRA model used for the LAR or, alternatively, if not included in the model, provide the basis for concluding that there is "negligible impact." ii. Discuss how it was ensured that other than the example identified by the peer review team, no other possible instances of common piping that could fail multiple systems are left unaddressed in the internal events PRA model. 4 ADAMS Accession No. ML090970525. 5 ADAMS Accession No. ML090410014.
-4 -d. F&O AS-82-01 identified that the operation of the automatic depressurization system (ADS), under conditions of a stuck open relief valve (SORV) with failure of the high pressure makeup, appears to be modeled as always successful. The resolution of this F&O states that this is a documentation issue only. However, it appears that the issue may point to a flaw in the PRA model that precludes a dependent failure that is logically possible. Explain whether or not the F&O identified a flaw in the PRA model logic. Further, if a flaw exists, either correct it and reevaluate the model to determine the effect on the current submittal, or justify why it does not adversely impact the current submittal. e. F&O SC-A6-01, Basis for the fire pump flow rate, questioned the basis for crediting the diesel-driven firewater pump as a low pressure source of makeup to the reactor vessel after depressurization, stating that the pump flow curve has not been rigorously analyzed. In the resolution to this F&O, the licensee performed a detailed deterministic calculation of the fire pump flow curve and identified that additional equipment, such as a fire pumper truck" to boost pressure, is required for the success of the diesel-driven firewater pump. Confirm that given the changes to the PRA model described in the F&O resolution, human failure events associated with the changes, such as the need to stage and operate the fire pumper truck, have been considered and incorporated into the PRA model. 5. The resolutions of the Hope Creek fire PRA (FPRA) peer review F&Os are presented in LAR Attachment 3, Appendix A, Table A-4, "Resolution of FPRA Peer Review F&Os." Some of the modeling choices made during the resulting FPRA model modifications appear to be non-conservative. Examples of such choices include, but are not limited to, the use of point estimates due to unquantified uncertainties (F&Os 1-11, 5-27, 5-40, 5-52, and 6-4), possible use of a probability of failure of alternate shutdown capability deemed to be non-conservative by the peer reviewers (F&Os 4-9 and 5-32), and the use of a potentially non-conservative value for the fraction of cable length participating in cable tray fires (F&Os 5-33 and 5-35). In addition, the resolution of F&O 4-14 appears to indicate the non-suppression probability in the Hope Creek FPRA are based on NUREG/CR-6850, "EPRl/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, instead of the updated values in NUREG-2169, "Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database."6 Identify all potential non-conservatisms in the Hope Creek FPRA and justify, preferably quantitatively, why the FPRA does not result in an prediction of the fire risk for the current LAR. 6 ADAMS Accession No. ML 15016A069.