ML22301A013
| ML22301A013 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/03/2022 |
| From: | Constellation Energy Generation |
| To: | NRC/NRR/DORL/LPL1 |
| References | |
| EPID L-2022-LRM-0087 | |
| Download: ML22301A013 (1) | |
Text
Nine Mile Point 1 RICT and 50.69 LARs NRC Pre-Submittal Meeting November 3, 2022
- Agenda
-Overview of License Amendments
-Variances from TSTF-505-A Rev. 2
-Timeline for Submittals
-PRA Technical Adequacy
-Evaluation Of PRA Uncertainties and Assumptions
-External Hazards
-Submittal Efficiencies Introduction NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 1
-No deviation from LAR template (except seismic)
- RICT LAR based on TSTF-505-A Rev. 2
-NMP1 is a BWR/2 reactor design
-TS markups follow TSTF for BWR/4
- Variances from TSTF-505
-NMP1 TS are NOT ITS (Custom TS)
-Variances from TSTF-505 are mostly nomenclature, section numbering, and plant design
-TSTF-505 LCOs/Conditions not in NMP1 TS
-RICT added to plant-specific LCOs not in TSTF-505 (will be identified in )
Overview of License Amendments NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 2
- NMP1 is a BWR/2 design. The TSTF-505 markups applicable to NMP1 are based on NUREG-1433
NUREG-1433 TS included in TSTF-505 and corresponding NMP1 have differing numbers NUREG-1433 TS included in TSTF-505 that are not contained in the NMP1 TS NMP1 TS included in TSTF-505 that are not contained in NUREG-1433. These TS perform functions similar to in-scope NUREG-1433 TS.
NMP1 TS that are not contained in NUREG-1433 and, therefore, are not included in the TSTF-505 mark-ups
- TSTF-505, Revision 2, includes an attachment for typed, camera-ready (revised) TS pages. NMP1 is not including such an attachment due to the large number of TS pages
Variances from TSTF-505 NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 3
- NMP1 Action descriptions generally correspond to NUREG-1433 Required Actions.
- NMP1 Actions that have different numbering than the NUREG-1433 Required Actions
- NMP1 takes a plant-specific variation to TSTF-505, TS 3.5.1.C, High Pressure Core Spray (HPCS) System Inoperable
- NMP1 takes a plant-specific variation to TSTF-505, TS 3.6.2.3, Residual Heat Removal (RHR) Suppression Pool Cooling
- NMP1 takes a plant-specific variation to TSTF-505, TS 3.6.2.4, Residual Heat Removal (RHR) Suppression Pool Spray
- NMP1 takes a plant-specific variation to TSTF-505, TS 3.7.1, Residual Heat Removal Service Water (RHRSW) System Variances from TSTF-505 (cont.)
NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 4
- Two separate applications
- Both submittals on same day (or close to same day)
- Late November - early December 2022 Timeline for Submittal NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 5
- Fire PRA - Peer Reviewed to RG 1.200 Rev. 2 F&O Closure review performed Four Open Finding F&Os (Already Addressed - Three Documentation-Related; One Technical-Related)
PRA Tech Adequacy NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 6
- Both NMP1 submittals will follow the process defined in NUREG 1855 Rev. 1, and the guidance in EPRI 1016737 and EPRI 1026511, including:
Identification of Internal events/internal flooding PRA model plant-specific and generic sources of uncertainties per EPRI 1016737 Identification of Internal Fire PRA model plant-specific and generic sources of uncertainty per Appendix B of EPRI 1026511 Consideration of generic Level 2 model sources of uncertainty per Appendix E of EPRI 1026511, as applicable to LERF Assessment of potential sources of uncertainties that are key to the respective applications, and disposition or treatment for the application Consideration of Parameter and Completeness uncertainties Evaluation of PRA Uncertainties and Assumptions NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 7
- IPEEE Initial Screening
- Reviewed Current Hazard Information
- Updated Analysis Using Part 6 Screening Criteria of ASME/ANS PRA Standard RA-Sa-2009
- Performed conservative or bounding analyses where appropriate
- Justify exclusion of external risk sources from the PRA models based on their insignificance to the calculation of configuration risk
- 50.69 - Incorporates NEI 00-04 guidance Figure 5-6, Other External Hazards Seismic will use EPRI alternative approach (TR 3002017583) for Tier 1 plants External Hazards Screening Process NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 8
- Screens Out
- Event damage potential is less than events for which plant is designed (C1)
- Several doors are credited to screen out local intense precipitation (LIP) for 50.69 Normally installed and closed exterior doors keep water infiltration to a minimum and total ingress volume lower than required for impacting key SSCs during LIP event duration These doors will be treated as HSS per NEI 00-04 Figure 5-6 External Hazards - Flooding NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 9
- Hazard Screens Out for 50.69
- Will Use Penalty Factor for TSTF-505 External Hazards - Extreme Wind or Tornado / Missiles NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 10
- Not Screened
- Seismic hazard is relatively low (EPRI Tier 1 Plant)
- 50.69 - Will submit as an EPRI Seismic Alternative Tier 1 Plant For 50.69 Tier 1 definition: (1) GMRS peak acceleration derived from the seismic hazard is at or below 0.2g or (2) where the GMRS is below or equal to the SSE between 1.0 Hz and 10 Hz.
NMP1 meets second criterion.
External Hazards - Seismic NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 11
- Overlaps in level of PRA acceptability in applications Submittal Efficiencies NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 12
- 50.69 - No deviation from LAR template (except seismic)
- PRA Common assessment approach of PRA technical adequacy and sources of uncertainty for both applications Assessments are application-specific but related in terms of details to be considered
- External Hazards Common screening approach of hazards Application-specific assessment of screening impact but related in terms of details to be considered
- Same PRA teams reviewing PRA risk information Submittal Efficiencies NINE MILE POINT 1 NRC PRE-SUBMITTAL MEETING 13
Questions?