ML022040708
| ML022040708 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  (DPR-043) |
| Issue date: | 07/12/2002 |
| From: | Warner M Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-02-054 | |
| Download: ML022040708 (5) | |
Text
Kewaunee Nuclear Power Plant N490 Highway 42 Kewaunee, WI 54216-9511 920.388.2560 Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241 920.755.2321 Committed to Nuclear Excellenc Kewaunee / Point Beach Nuclear Operated by Nuclear Management Company, LLC NRC-02-054 10 CFR 50.90 July 12, 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Ladies/Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Response to Nuclear Regulatory Commission request for additional information regarding Kewaunee Nuclear Power Plant proposed amendment 181.
References:
- 1) NRC letter from John Lamb (NRC) to Mark Warner (NMC), "Kewaunee Nuclear Power Plant - Request For Additional Information Related To Request For Proposed Amendment To Revise Kewaunee Nuclear Power Plant Technical Specification Section 3.10.f." (TAC NO. MB3825), dated May 3, 2002.
Attached is the Nuclear Management Company, LLC (NMC), response to a United States Nuclear Regulatory Commission Request for Additional Information (Reference 1) regarding the NMC application for permission to change Kewaunee Technical Specification 3.10.f on the allowed outage time for the Rod Position Indicator (RPI) system. Based on a telephone conversation between Mr.
Jerry Riste of my staff, Mr. John Lamb, and Mr. Shawn Peters of the NRC staff on June 17, 2002, at which time the due date for this response was extended.
If there are questions regarding this response, please contact either Mr. Jerry Riste at (920) 388-8424 or me at (920) 755-7611.
Docket 50-305 NRC-02-054 July 12, 2002 Page 2 To the best of my knowledge and belief, the statements contained in this document are true and correct. In some respects, these statements are not based entirely on my personal knowledge, but on information furnished by cognizant NMC employees and consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
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US NRC, Region III US NRC Senior Resident Inspector Electric Division, PSCW
ATTACHMENT 1 Letter from M. E. Warner (NMC)
To Document Control Desk (NRC)
Dated July 12, 2002 NMC Response to NRC's REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION SECTION 3.1O.f AMENDMENT FOR INDIVIDUAL ROD POSITION INDICATOR SYSTEM ALLOWED OUTAGE TIME KEWAUNEE NUCLEAR POWER PLANT
Docket 50-305 NRC-02-054 July 12, 2002, Page 1 NRC REOUEST 1:
With one rod position indicator channel inoperable, the current TS 3.10.fl.A requires the determination ofposition of the rod cluster control, "... at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or subsequent to rod motion exceeding a total displacement of 24 steps, whichever occurs first. " This TS implies that, following rod displacement, an immediate check of the rod position is required, i.e. prior to the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> already in effect. However, the proposed TSs would require an inspection within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the same rod displacement. Describe the safety significance of this change. Why is it acceptable to set 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as an inspection time when a more immediate requirement was set in the original TSs?
NMC RESPONSE TO REQUEST 1:
After reviewing the documentation and details of the NRC question, we have concluded that a change should be made to our original submittal. NMC will be following the guidance of standard Technical Specifications 3.1.7.C. I by using the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to verify rod position in the event of rod movement in excess of 24 steps when the IRPI is inoperable. This modification will be in a separate submittal.
NRC REQUEST 2:
It is our understanding that Kewaunee's Final Safety Analysis Report (FSAR) section 7.3.2, "System Design, "refers to the control rod demand position indication system as the "Digital System. " In reference to the Digital System, Kewaunee's FSAR states:
"The digital and analog systems are separate systems; each serves as backup for the other. Operating procedures require the reactor operator to compare the digital and analog readings upon receiving a rod deviation alarm.
Therefore, a single failure in rod position indication does not in itself lead the operator to take erroneous action in the operation of the reactor. "
10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants" '" Criterion 13, "Instrumentation and Control, "states that instrumentation to monitor variables and systems over their operating ranges during normal operation, anticipated operational occurrences, and accident conditions must be operable. In conjunction with this definition of instrumentation, NUREG-1431 Vol. 1, Rev. 2, "Standard Technical Specifications Westinghouse Plants "; TS 3.1.7, "Rod Position Indication" indicates that the Demand Position Indication System shall be operable.
However, it is our understanding that the proposed TSs do not contain requirements for the Digital System (Demand Position Indication System) to be operable. Given that both GDC 13 and NUREG 1431 indicate that the digital system shall be operable, and that the digital system operability is required to prevent erroneous action as a result of a single failure, explain why it is acceptable in the proposed TSs to exclude the conditions of NUREG-1431, TS 3.1.7.D, which require demand position indicator operability.
Docket 50-305 NRC-02-054 July 12, 2002, Page 2 NMC RESPONSE TO REQUEST 2:
NMC has reviewed the issue concerning the control rod demand position indication system and agrees that demand position should be added. NMC will be adding Demand position requirements to our TS and submitting a revised LAR.