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FSAR Chapter 19, ProbabilisticRisk Assessment Information

and

PlantmSpecific!PRA

Public Meeting w/NRCJuly 9, 2005

Attachment 7

Main Topics

a Phased Development of FSAR Chapter 19 andplant-specific PRA

v FSAR Chapter 19 Format and Contentv Plant Specific PRA Characteristics (Scope,

Technical Quality, Schedule and Maintenance)v Availability of PRA-Related Documentation* Guidance for addressing Ch. 19 COL Itemsv Related Discussion

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Phased Development of FSAR Chapter19 and Plant-Specific PRA

As-built, as to be operated, information needed tomeaningfully update the Certified Design PRA willnot be available at time of COL Application or COLIssuance

i Ceftiirfid Design PRA' and, assessment of plant-specific' -differences suffice for COL application/licensing and Prior to OperationFour phases now envisioned (up from 2 identified inNEI 04701),-

* Phase 1: Pre-COLA to COLA* Phase 2: COLA to COL Issuance• Phase -3: COL Issuance to Fuel Loading,-• Phase 4: After Initial Fuel Loading N'leI

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Phased Development ofChapter 19 and PRA (continued)

* Phases 1 and 2 to support plant licensing -Monitor/assess plant-specific design and operationalcharacteristics and address as appropriate in Chapter 19and PRA documentation

* Phase 3 to support initial plant operation - DevelopRev.0 PRA and Address COL Items using Information thatReasonably Represents the As-Built, As-to-be OperatedPlant

* Phase 4 to support plant operation - Maintain the plant-specific PRA and update FSAR Ch. 19 as Appropriate

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Sample Timeline forFSAR Chapter 19 and P-S PRA

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Phase 1

-Chapter 19- Status &Plans

* PRA- Address

plant-specificdifferences

Phase 2

* Chapter 19Updatedannually

* PRA- Addressplant-specificdifferences

Phase 3

* Chapter 19Updatedannually

.- PRA- Rev. 0 toReasonablyRepresent As-built, As-to-beoperated Plant

* Chapter 19Update per § 50.71)(e)

* PRA- Maintain PRA

as appropriate

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Phase 4

Phases - FSAR Chapter 19 and P-S PRAPhase FSAR Chapter 19 Plant-Specific PRA

Summarize Status and Plans for COL Items Include in PRA documentationand p-s PRA 1) description of p-s design or

Provide assessment vs. design PRA of p-s operational changes, or site-specificdesign or operational changes, or site- topics, which could significantly affectspecific topics, which could significantly results and conclusions, andaffect results and conclusions, and an 2) an assessment of impacts, andassessment of impacts, and mitigation, mitigation, when practical.when practical.

2 Update Annually Continue to include in PRA1) based on NRC RAIs and Associated documentationResponses, and 1) description of design or operational

2) Address additional plant-specific changes changes, or site-specific topics, whichand/or site-specific topics could significantly affect results and

conclusions, and

2) an assessment of impacts, andmitigation, when practical.

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Phases - Chapter 19 and PRAPhase Chapter 19 Plant-Specific PRA

3 Update P-S PRA, "Revision 0" is Completed and Reviewed usingAnnually Information that Reasonably Represents the As-built, As-to-

be-operated Plant.

Continue monitoring/assessment of p-s changes

4 Updated per Maintain p-s PRFAas:appropriate'4.

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Chapter 19 Format and Content

* Standard Format and Content Proposed for Chapter 19* Provide Summary of PRA (Objectives, Scope, Approach and Results)• Address COL Items

* Appropriate to the COL Context• Different Purpose/Objectives for COL vs. Design Certification* Consistent with Operating Plant FSARs* Emerging Proprietary/Safeguards Issues* Support Plant Operational Needs (e.g., Maintenance Rule, ROP,

MSPI)* PRA is detailed and will be maintained separately from Chapter 19• Generic DCD Chapter 19 and PRA available with COLA

* Facilitate consistent NRC review* Would require exemption from current regulations

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Proposed Chapter 19 Format and Content(Table 4.3.9.19-4 of NEI 04-01, Rev. D)

* 19.1 Introduction- 19.1 .1- Objectives19.1.2 Format and Content of Chapter 19

19.2 Scope and Approach to development of plant-specific PRA19.2.1 Scope19.2.2 Approach

19.3 Information addressing COL Items* 19.4 PRA Results

-1-9.4.1 - Reference to design PRA results19.4.2/19.4.3 - Assessment of plant-specific design differences

versus design PRA results19.4.4 - Insights from plant-specific PRA

* 19.5 Support of plant programs, e.g. for D-RAP, MR, Tech Specs,FIFE, etc. (summary level)

* 19.6 References, including:. Generic DCD. Design PRA

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AP1000 Chapter 19 COL Items

COL Items in Chapter 19 are:* Evaluation of As-Built Plant versus Design in AP 1000

PRA and Site-Specific PRA External Events

E As-Built SSC HCLPF Comparison to Seismic MarginEvaluation

E Internal Fire and Flood Analyses Comparison

E Develop and Implement SAMGs

* Equipment Survivability (thermal lag assessment)

COL Items not Completed/Closed at time ofCOL Issuance will be restated in the FSAR

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Table 4.3.9.19-1: COLA Items from Chapter 19 of the AP1000 DCD

19.15.10-1. As-Built SSC HCLPF Comparison to Seismic Margin EvaluationThe Combined License applicant referencing the AP1000 certified design will reviewdifferences between the as-built plant and the design used as the basis for the AP1000 seismicmargins analysis. A verification'walkdown will be performed with the purpose of identifyingdifferences between the as-built plant and the design. Any differences will be evaluated todetermine if there is a significant adverse effect on the seismic margins analysis results. Spatialinteractions are addressed by COL information item 3.7-3. Details of the process will bedeveloped by the Combined License applicant.-';

The combined License applicant referencing 'the API 000 certified design should compare theas-built SSC HCLPFs to those assumed in theAP1000 seismic margin evaluation. Deviationsfrom the HCLPF values or assumptions in the seismic margin evaluation should be evaluatedto determine if vulnerabilities have been introduced. The requirements to which the equipmentis to be purchased are included in the equipment specifications. Specifically, the equipmentspecifications include:

1. Specific minimum seismic requirements consistent with those used to define the Table19.55-1 HCLPF values.

This includes the known frequency range used to define the HCLPF by comparing the requiredresponse spectrum (RRS) and test response spectrum (TRS). The range of frequency responsethat is required for the equipment with its structural support is defined.

2. Hardware enhancements that were determined in previous test programs and/or analysisprograms will be implemented.

19.15.10-2. Evaluation of As-Built Plant versus Design in AP1000 PRA and Site-SpecificPRA External EventsThe Combined License applicant referencing the API000 certified design will reviewdifferences between the as-built plant and the design used as the basis for the AP1000 PRAand Table 19.59-18. If the effects of the differences are shown, by a screening analysis, topotentially result in a significant increase in core damage frequency or large release frequency,the PRA will be updated to reflect these differences.Based on site-specific information, the COL should also reevaluate the qualitative screening ofexternal events (PRA Section 58.1). If any site-specific susceptibilities are found the PRAshould be updated to include the applicable external event.

Table 4.3.9.19-1: COLA Items from Chapter 19 of the AP1000 DCD

19.15.10-3. Internal Fire and Internal Flood AnalysesThe Combined License applicant referencing the APIOQO certified design will reviewdifferences between the as-built plant and the design used as the basis for the AP 1000 internalfire and internal flood analysis. Differences will be evaluated to determine if there issignificant adverse effect on the internal fire and internal flood analysis results.

19.15.10-4. Develop and Implement Severe Accident Management GuidanceThe Combined License applicant referencing the API000 certified design will develop andimplement severe accident management guidance using the suggested framework provided inWCAP-13914, "Framework for AP600 Severe Accident Management Guidance," (Reference19.59-1).

19.15.10-5, Equipment SurvivabilityThe Combined License applicant referencing the AP1000 certified design will perform athermal lag assessment of the as-built equipment required to mitigate severe accidents(hydrogen igniters and containment penetrations) to provide additional assurance that thisequipment can perform its severe accident functions during environmental conditions resultingfrom hydrogen burns associated with severe accidents. This assessment is required only foriequipment used for severe accident mitigation that has not been tested at severe accidentconditions. The Combined License applicant will assess the ability of the as-built equipmentto perform during severe accident hydrogen burns using the Environment Enveloping methodor the Test Based Thermal Analysis method discussed in EPRI NP4354 (Reference 19.59.2).

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! Chapter 19 COL Items/CommitmentsAs-built versus Standard Design - Phases I and 2

Phase Description

Include Summary of Status and PlansIdentify plant-specific design or operational changes, or site-specific topics,and address as appropriate

2 Continue to identify p-s design or operational changes, or site-specifictopics, and address as.appropriateAnnual Update of Chapter 19, as appropriate.

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Chapter 19 COL Items/CommitmentsAs-built versus Standard Design - Phases 3 and 4

Phase Description

Complete Review Using Information Reasonably Representing the As-built, As-to-be operated Plant, and address differences from the design PRA, asappropriate.Complete PRA Revision 0, including Review to Prevailing Standards Applicableto the Certified Design PRA Scope at COL Issuance minus 6 months.

Complete Revision 0 Seismic Margin Analyses if Necessary, including Review toPrevailing Standards Applicable to the Certified Design Scope at COL Issuanceminus 6 months.Address External Events Consistent with Certified Design Approach. ReferenceOther Sections (e.g., Section 2 for Externals Events if appropriate)Annual Update of Chapter 19, as appropriate.

Monitor/assess Design and Operational Characteristics for significant changesand Address per Plant ProgramsComplete, Assess, and Document supporting evaluations L a1.-Update Chapter 19 as appropriate

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Chapter 19 COL Items/Commitments:SAMGGs and Equipment SurvivabilityPhase ;Description

1&2 Identify in Ch. 19 Plans to develop/implement SAMGs prior to plantoperation

> Identify in Ch. 19 Plans to complete assessment of equipment survivabilityof as-built SSCs

Complete 'SAMGs!aind' Associated' Training

Complete Equipment Survivability Evaluations '

4 Maintain per Plant Programs

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Plant-Specific PRACharacteristics

* Plant-specific PRA, Revision 0, to be completed on a time frame tosupport plant operation (Phase 3)

e Scope Consistent with Certified Design PRA* Developed and maintained consistent with PRA Standards Applicable to

the Certified Design PRA Scope in effect six months prior to COL issuance* Peer review will be Conducted, and Findings will be Addressed Consistent

with COL and Operational Needs

* PRA Revision 0 to Reasonably Represent the As-built, As-to-beOperated Plant

Changes will be Monitored, Assessed, and Documented• Appropriate Confirmatory Actions, such as Walkdowns, will be Conducted

and Documented (Consistent with Other design Verification Activities)* Resulting Actions will be Taken and Documented• Consistent with Current Good Practices

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Format and Content of PRAn PRA will support Chapter 19 and Other Uses

* PRA Content will :Meet Applicable IndustryConsensus PRA Standards Prevailing at COLIssuance minus- 6. MonthsPRA- Format could be Same as, or Similar. to,Certified Design PRA, but address As-built,As-to-be operated, Information

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Availability of PRA Information

* PRA Summary to be Included in FSARChapter 19

a PRA Report, Calculation Files, and ComputerModels to be Retained and Available forAudit

* Documentation of Peer Review and Responseto be Retained and Available for Audit

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Conclusions* Phased Development of FSAR Chapter 19 and p-s PRA is appropriate

Standard Format and Content is Proposed for Chapter 19* COL Items will be Addressed as Infonnation is Available

Plant Specific PRA Characteristics are:Rev. 0 Available to support fuel load and initial plant operation

• Scope (Initiators, Operating Modes and Damage Level) to be Consistentwith Certified Design PRA

* Technical Capability to be Consistent with Prevailing StandardsApplicable to the Certified Design PRA Scope at COL Issuance minus 6months

* Will Reasonably Represent the As-to-be-Built, As-to-be-Operated Plant* Changes to be Monitored and Addressed* PRA to be Maintained Consistent with Prevailing PRA Standards and

Good Practices for Life of PlantPRA Information to be Available as:

* Summary in Chapter 19* Detailed Model, Calculations, and PRA Documentation Retained and

Available for Audit . _ v .5-

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Discussion

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