ML032770006

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Request for Additional Information Modification of Main Steam Isolation Valve Leakage Pathway and License Condition 2.C.(6)
ML032770006
Person / Time
Site: Cooper Entergy icon.png
Issue date: 10/02/2003
From: Michelle Honcharik
NRC/NRR/DLPM/LPD4
To: Warren C
Nebraska Public Power District (NPPD)
honcharik, M C, NRR/DLPM, 415-1774
References
TAC MB7376
Download: ML032770006 (6)


Text

October 2, 2003 Mr. Clay C. Warren Chief Nuclear Officer Nebraska Public Power District P. O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING MODIFICATION OF THE MAIN STEAM ISOLATION VALVE LEAKAGE PATHWAY AND LICENSE CONDITION 2.C.(6) (MB7376)

Dear Mr. Warren:

Nebraska Public Power District (NPPD or the licensee) requested the NRC staff approve changes related to the main steam line isolation valve (MSIV) leakage pathway seismic evaluation and License Condition 2.C.(6). A meeting was held on July 23, 2003, between the licensee and the NRC staff to discuss the issues related to the MSIV leakage pathway seismic adequacy for iodine plate-out credit in radiological dose assessment of design basis accidents.

The staff has reviewed the information provided during the July 23, 2003, meeting with NPPD and determined that additional information is required in order to complete the review and approval of the changes. The request for additional information is enclosed. Based upon discussions with NPPD staff, a mutually agreeable date for your response is within 60 days of receipt of this letter.

Sincerely,

/RA/

Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

As stated cc w/enclosure: See next page

Mr. Clay C. Warren October 2, 2003 Chief Nuclear Officer Nebraska Public Power District P. O. Box 98 Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING MODIFICATION OF THE MAIN STEAM ISOLATION VALVE LEAKAGE PATHWAY AND LICENSE CONDITION 2.C.(6) (MB7376)

Dear Mr. Warren:

Nebraska Public Power District (NPPD or the licensee) requested the NRC staff approve changes related to the main steam line isolation valve (MSIV) leakage pathway seismic evaluation and License Condition 2.C.(6). A meeting was held on July 23, 2003, between the licensee and the NRC staff to discuss the issues related to the MSIV leakage pathway seismic adequacy for iodine plate-out credit in radiological dose assessment of design basis accidents.

The staff has reviewed the information provided during the July 23, 2003, meeting with NPPD and determined that additional information is required in order to complete the review and approval of the changes. The request for additional information is enclosed. Based upon discussions with NPPD staff, a mutually agreeable date for your response is within 60 days of receipt of this letter.

Sincerely,

/RA/

Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosure:

As stated cc w/enclosure: See next page DISTRIBUTION:

PUBLIC PDIV-1 r/f RidsNrrDlpmLpdiv (H. Berkow)

RidsNrrDlpmLpdiv-1 (R. Gramm)

RidsNrrPMMHoncharik RidsNrrLAMMcAllister RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn4MailCenter (K. Kennedy)

Devender Reddy (DSSA/SPLB)

Yong Kim (DE/EMEB)

James Bongarra (DIPM/IROB)

ACCESSION NO: ML032770006 OFFICE PDIV-1/PM PDIV-1/LA PDIV-1/SC NAME MHoncharik MMcAllister RGramm DATE 10/1/03 10/1/03 10/1/03 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION ISSUES RELATED TO MAIN STEAM LINE ISOLATION (MSIV)

LEAKAGE PATHWAY SEISMIC EVALUATION COOPER NUCLEAR STATION (CNS) 1.

Describe and justify any exceptions that are proposed to the flowpath criteria that are included in Appendix C to NEDC-31858P, Rev. 2.

2.

With respect to the turnbuckle device, explain what role/purpose the device serves and why it is needed relative to the guidance specified in NEDC-31858P, Rev. 2, and confirm that the fraction of MSIV leakage to the high pressure turbine (i.e., ratio of flow areas) satisfies the criteria specified in Appendix C of NEDC-31858P, Rev. 2.

3.

You stated in Reference 1 that... Five manual isolation valves to be installed on Main Steam branch lines in order to limit the amount of piping to be credited for the MSIV leakage flowpath (and hence, maintained as seismically robust). Post-accident Operator action will be required to close these valves (which will be located in the Turbine Building)... We request your responses to the following:

(a)

Explanation as to how those five manual isolation valves will be seismically qualified.

(b)

Provide a comparison between the CNS MSIV leakage path proposed manual isolation valves and the earthquake experience database concerning seismic performance of this class of equipment.

(c)

Indicate whether the leakage path with the manual isolation valves installed meets the provisions in the SQUG-GIP 2 (Reference 2). If it does not, identify how the outlier conditions were resolved.

(d)

Indicate whether the five manual valves will be part of the CNS Inservice Testing (IST) program. If they are not, provide justification as to why they should not be part of the IST program.

4.

You stated in Reference 3 that... The cross-sectional leakage area is being reduced by mechanically adjusting the Stop Valve actuator/control shaft positions through use of a special pre-staged tool, applied as a post-Loss of Coolant Accident manual action...

The NRC staff requests responses to the following:

(a)

Explanation as to how the mechanically adjusted Stop Valve actuator/control shaft with a special pre-staged tool will be seismically robust.

(b)

Provide a comparison between the MSIV leakage path Stop Valve actuator with the proposed adjustment and the earthquake experience database concerning seismic performance of the equipment class that encompasses the reconfigured Stop Valve.

Enclosure (c)

Explain how the post-Loss of Coolant Accident (post-LOCA) manual action is accomplished. Supplemental information, such as diagrams/photos/illustrations of the pre-staged tool, Stop Valve actuator, location of task to be performed, etc.,

will be beneficial to include in the response. At a minimum, the following questions should be addressed in the explanation:

1.

What step(s) is/are involved in performing the action(s), i.e., how much physical and mental effort does the task require? How many Stop Valves will require manual adjustment? If more than one valve is involved, where are the valves located in relation to one another?

2.

Is the action taken locally or from the control room?

3.

How much time is required to successfully accomplish the task (including time that may be required to access the location from where the task is performed)? How much time is available to take the action(s) before adverse consequences occur?

4.

What are the consequences of failing to perform the task?

5.

How does the operator know when to perform the task, e.g., are there specific alarms, cues, directions, instructions, etc.?

6.

What are the conditions under which the task will be performed (e.g., lighting, noise, temperature, humidity, radiation levels expected, smoke, toxic gas, etc.)?

7.

What is the pre-staged tool?

8.

In addition to the pre-staged tool, are there any other special tools/equipment required to successfully accomplish the task?

9.

How has it been determined that the required manual action(s) can be successfully completed in the time allowed, especially considering other tasks required to be performed under post-LOCA conditions?

10.

What procedure(s) is/are involved in performing the task and how have the operators been trained to use the procedures?

References 1.

Letter, Nebraska Public Power District to U.S. NRC, License Condition 2.C.(6) Seismic Evaluation, Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46, dated February 26, 2002.

2.

Seismic Qualification Utility Group, Generic Implementation Procedure (GIP) for Seismic Verification of Nuclear Power Plant Equipment, Revision 2, corrected February 14, 1992.

3.

Letter, Nebraska Public Power District to U.S. NRC, Additional Information Related to License Condition 2.C.(6) Seismic Evaluation, Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46, dated December 19, 2002.

August 2003 Cooper Nuclear Station cc:

Mr. William J. Fehrman President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Thomas J. Palmisano Site Vice President Nebraska Public Power District P. O. Box 98 Brownville, NE 68321 Mr. John R. McPhail, General Counsel Nebraska Public Power District P. O. Box 499 Columbus, NE 68602-0499 Mr. Paul V. Fleming, Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. Michael J. Linder, Director Nebraska Department of Environmental Quality P. O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Ms. Cheryl K. Rogers, Program Manager Nebraska Health & Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P. O. Box 95007 Lincoln, NE 68509-5007 Mr. Ronald A. Kucera, Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Jerry Uhlmann, Director State Emergency Management Agency P. O. Box 116 Jefferson City, MO 65101 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 Mr. Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health 401 SW 7th Street Suite D Des Moines, IA 50309 Mr. Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570