ML051610251

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Response to NRC Request for Additional Information License Amendment Request 213 to the Kewaunee Nuclear Power Plant Technical Specifications, Auxiliary Feedwater Pump Protection
ML051610251
Person / Time
Site: Kewaunee 
Issue date: 06/09/2005
From: Gaffney M
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-05-072
Download: ML051610251 (3)


Text

Commifted to Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC June 9,2005 NRC-05-072 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Kewaunee Nuclear Power Plant Docket 50-305 License No. DPR-43 Response to NRC Request for Additional information re: License Amendment Request 21 3 To The Kewaunee Nuclear Power Plant Technical Specifications, Auxiliary Feedwater Pump Protection

Reference:

1) Letter from Nuclear Management Company, LLC to Document Control Desk, "License Amendment Request 21 3 To The Kewaunee Nuclear Power Plant Technical Specifications: Auxiliary Feedwater Pump Protection," dated May 5,2005 The Nuclear Management Company, LLC (NMC) submitted license amendment request (LAR), 21 3 to the Kewaunee Nuclear Power Plant (KNPP) Technical Specifications (TS) to modify the auxiliary feedwater (AFW) pump suction protection requirements.

Subsequently, the NRC staff has requested additional information to clarify parts of the submittal. Enclosure 1 contains NMC's response to the NRC staff's questions.

Enclosures 2, 3, and 4 contain supplemental information to clarify the responses provided in Enclosure 1. The information contained in this response does not alter the conclusions reached in the no significant hazards determination and environmental considerations contained in reference 1.

A complete copy of this submittal has been transmitted to the State of Wisconsin as required by 10 CFR 50.91 (b)(l ).

NMC requests approval of LAR 21 3 as delineated in reference 1 Summary of Commitments This letter makes the following new commitments:

N490 Highway 42 Kewaunee, Wisconsin 54216-951 1 Telephone: 920.388.2560

Document Control Desk Page 2 As an interim action, an operator will be maintained available outside of the turbine building to perform the local manual actions of throttling AFW pump discharge valves as required. This interim action will remain in place until the turbine building Main Steam Line Break (MSLB) High Energy Line Break (HELB) study has been completed and demonstrates that interim action is no longer required.

All operators will attend training on the procedure changes required for this license amendment. In addition, simulator walkthroughs will be conducted for all licensed personnel. All Nuclear Auxiliary Operators (NAOs) will be trained on the use of diverse pathways that may be required to access the AFW pumps in an accident situation. All qualified NAOs will also conduct walkthroughs of local actions that may be required to maintain or restore AFW flow. Support personnel will likewise be trained on the interfaces between their groups and Operations to support this task. Procedural changes and training will be completed prior to exceeding 350 degrees F in the reactor coolant system.

Procedures will be revised to prescribe local manual operator actions to ensure AFW pump availability if the non-safety related equipment is unexpectedly lost.

AFW pump procedures shall be approved prior to declaring the pumps operable.

Additional testing will be performed to determine the Turbine Driven Auxiliary Feedwater (TDAFW) PumpITurbine performance capability at low Steam Generator (SG) pressures. These tests will be conducted during plant heat up.

The test data will be used to verify the TDAFW pump capabilities and will be used to train the operators or change operating procedures for improved operator guidance, as necessary. The TDAFW pump testing, procedure changes, and shift briefings will be completed prior to exceeding 15% reactor power. Any additional training for the operators beyond that previously described will be completed within 90 days from the completion of the pump testing.

The station will complete a simultaneous start of all three AFW pumps at hot shutdown conditions. NMC will confirm that this test along with the analysis will demonstrate that the low suction pressure trip setpoints are adequate to: a) prevent damage to the AFW pumps, and b) prevent undesirable AFW pump trips from occurring.

Each individual pump will have a timed coast down test performed at bounding flow rates prior to declaring the pumps operable.

During pump operationltesting, additional system and pump performance data will be collected and comparedlbenchmarked against the AFW system flow model for verification of analysis. NMC will confirm that these tests along with the analysis will demonstrate that the low discharge pressure trip setpoints are adequate to: a) prevent damage to the AFW pumps, and b) prevent undesirable AFW pump trips from occurring.

For conditions requiring a plant cooldown in conjunction with the Integrated Plant Emergency Operating Procedures (IPEOPs), the IPEOPs will contain a step to maintain AFW Pump discharge pressure >I 000 psig. The IPEOPs will be revised prior to exceeding 350 degrees F in the reactor coolant system.

Document Control Desk Page 3 NMC also proposes the following license condition:

The need for local manual operator actions as described in the License Amendment Request submitted May 5,2005, and supplemented on June 9,2005, shall be eliminated no later than completion of Kewaunee RFO R-29.

If you have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 9,2005.

Michael G. ~ a f f n w Site Vice president, Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosures (4) cc:

Administrator, Region Ill, USNRC Senior Resident Inspector, Kewaunee, USNRC Project Manager, Kewaunee, USNRC Public Service Commission of Wisconsin