ML051610386
| ML051610386 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/31/2005 |
| From: | Lyon C NRC/NRR/DLPM/LPD3 |
| To: | Breene T Nuclear Management Co |
| Lyon C, NRR/DLPM, 415-2296 | |
| References | |
| TAC MC6916 | |
| Download: ML051610386 (18) | |
Text
Car! Lyon - AFW - SPLB RAI Response Page 1 From:
Carl Lyon To:
internet:Thomas.Breene @ nmcco.com Date:
5/31/05 6:58AM
Subject:
AFW - SPLB RAI Response The following clarifications are needed with respect to the draft responses to the SPLB questions:
- 01. Please discuss how testing will account for flow and discharge pressure considerations such that conservative results are assured. Also, please discuss the minimum margin to pump trip that is assured by the design and explain why this is sufficient to prevent unnecessary pump trips from occurring.
- 02. For completeness, please confirm that the system curve (and trip setpoints) includes the effect of the additional water inventory piping that was added.
- 03. Please confirm that the Kewaunee design criteria for safety-related applications will be satisfied in all respects.
Q4. Please discuss the minimum margin to pump trip that is assured by the design and explain why this is sufficient to prevent unnecessary pump trips from occurring.
- 05. For clarification purposes, please confirm that for all loss of heat sink events, the IPEOPs instruct operators to verify that there is at least 5% wide range level in the steam generator where AFW flow is being restored as a condition for restoring AFW flow to that steam generator consistent with the steam generator tube sheet thermal cycling analysis that has been completed.
Q6. Because turbine-driven pumps tend to be more sensitive to fluctuations in plant conditions and are typically more difficult to manually start than a motor driven pump, more operator response time may be needed when relying upon the turbine-driven AFW pump. Consequently, testing of the turbine-driven pump is also necessary to demonstrate the capability of the turbine-driven pump to perform as expected and to validate operator actions. Therefore, please supplement the response accordingly to confirm that the turbine-driven AFW pump will be tested and operator actions in this regard validated based on conditions that are deemed to be the most challenging such that conservative results are obtained.
- 07. The listing of potential accidents, transients, and occurrences is incomplete in that there is no discussion depressurization due to a main feedwater line break. Please revise the response accordingly.
Also, please confirm that validation of operator actions will include the time it takes for operators to establish and maintain AFW flow considering the most limiting situation of using either the motor-driven or turbine-driven AFW pumps, for the respective plant conditions and pump selection that is deemed to be the most time consuming. Finally, because there is some likelihood that the AFW pumps will trip while performing plant cooldown evolutions, please describe compensatory measures that will be taken to assure that AFW flow will not be interrupted when planning to proceed with plant cooldown.
CC:
internet:gerald.riste © nmcco.com
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AFW - SPLB RAI Response 5/31/05 6:58AM Carl Lyon CFL~nr-c.gov Recipients gerald riste CC (intemet:gerald.riste @nmcco.com)
Action Transferred Date & Time 05/31/05 06:59AM Thomas Breene (intemet:Thomas.Breene @nmcco.com)
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Carl Fwd: AFW - SPLB RAI ResponsP From:
Carl Lyon To:
internet:Thomas.Breene ©nmcco.com Date:
5/31/05 9:02AM
Subject:
Fwd: AFW - SPLB RAI Response Also, with respect to the last question and performing plant cooldown, and in general for any compensatory measures being taken, you should consider whether or not establishing a regulatory commitment would be appropriate, depending on how the compensatory measures will be implemented.
CC:
internet:geraid.riste @ nmcco.com
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Fwd: AFW - SPLB RAI Response Creation Date:
5/31/05 9:02AM From:
Carl Lyon Created By:
CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
Action Transferred Date & Time 05/31/05 09:03AM
.Thomas Breene (intemet:Thomas.Breene@nmcco.com)
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Carl Lyon - Human Factors Question Page 1 From:
Carl Lyon To:
internet:Thomas.Breene @nmcco.com Date:
5/31/05 11:33AM
Subject:
Human Factors Question As I mentioned in our discussion this morning, the following question goes with questions 2 and 3 of the original RAI for the Human Factors Section.
Are you using an industry standard methodology to verify the time validation for the proposed operator manual actions? If so, is it a standard endorsed by the staff?
CC:
internet:gerald.riste @ nmcco.com
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Human Factors Question 5/31/05 11:33AM Carl Lyon CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
Action Transferred Date & Time 05/31/05 11:33AM Thomas Breene (intemet:Thomas.Breene@nmcco.com)
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i Carl Lyon-Additional EEIB RAI Questions Page 1 1 From:
To:
Date:
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Carl Lyon internet:Thomas.Breene @ nmcco.com 6/3/05 10:00AM Additional EEIB RAI Questions internet:gerald.riste @ nmcco.com Attached.
CC:
Carl Lvon - EEIB-RA12.wi)d Page 1 1l Ca, ;,,rl
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Additional questions on Kewaunee AFW LAR
- 1.
Your response to l&C Question #6 stated that there are two manual methods of aligning the circuit to allow starting the pump. Please address whether the features for manual initiation of protective action are in conformance with Reg. Guide 1.62, WManual Initiation of Protection Action."
- 2.
Please address whether information displays for manually controlled actions will be functional (e.g., power will be available and sensors are appropriately qualified) during plant conditions under which manual actions may be necessary.
- 3.
Your response to l&C Question #6 stated that the 'A' AFW pump suction and discharge pressure trips can also be defeated if the Dedicated Shutdown Panel (DSP)
Remote/Local switch is placed to 'LOCAL". Please reference the affected plant operating procedures, and confirm that this feature has been implemented in the procedures and the operators have been trained to follow this procedure.
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Additional EEIB RAI Questions 6/3/05 10:00AM Carl Lyon CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
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! Carl Lvon - RAI Response Question Paqe 1 1 Carl Lyon - RAI Response Question Paqe 1
From:
Carl Lyon To:
internet:Thomas.Breene ~nmcco.com Date:
6/7/05 6:58AM
Subject:
RAI Response Question Regarding AFW system flowrate indication:
In your draft response page 1 1 of 41, line 4 states that all indicators are non-safety related but of a high quality.
TMI Action Plan Requirement Item ll.E.1.2 Part 2, "Auxiliary Feedwater System Flowrate Indication" stated that the following requirements shall be implemented:
- 1. Safety-grate indication of auxiliary feedwater flow to each steam generator shall be provided in the control room.
- 2. The auxiliary feedwater flow instrument channels shall be powered from the emergency buses consistent with satisfying the emergency power diversity requirements of the AFW system set forth in Standard Review Plan, Section 10.4.9.
Please clarify the Kewaunee Nuclear Power Plant licensing bases with respect to the above requirements.
CC:
internet:gerald.riste @nmcco.com
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RAI Response Question 6/7/05 6:58AM Carl Lyon CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
Action Transferred Date & Time 06/07/05 06:59AM Thomas Breene (intemet:Thomas.Breene@nmcco.com)
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Carl Lyon - AFW Phoncon Page 1 q From:
Carl Lyon To:
internet:Thomas.Breene~nmcco.com Date:
6/8/05 7:16AM
Subject:
AFW Phoncon Today at 9AM (EDT).
Here are some of the comments on the draft RAI response:
IOHS 03: The basis for not using ANSI-58.8 for validating operator actions only addresses item (2), and does not address items (1) and (3). If the AFW pumps trip and AFW is not properly restored, the RCS will heat up to the point of lifting the pressurizer safety valves, potentially compromising the reactor coolant pressure boundary. If the RCS is not cooled down and depressurized within 49 minutes, the offsite dose will increase beyond what was assumed in the accident analysis for the steam generator tube rupture event. Also, if AFW trips and is not properly restored, the RCS temperature limitations for maintaining the safe shutdown conditions referred to in item (2) will be exceeded. Given these considerations, the local actions do appear to be safety-related pursuant to ANSI-58.8.
IOHS 03: The licensee indicates that "a process for conducting time validations was developed based on benchmarking of several nuclear power plants." Without additional explanation, it is not clear how this applies to Kewaunee and establishes a bounding operator response time that can be relied upon for completing the assumed actions.
SPLB 03: With respect to the design changes that are being made, the licensee has not provided confirmation that the Kewaunee design criteria for safety-related applications will be satisfied in all respects as previously requested.
SPLB 04: The last sentence refers to IOHS 01, but I think that it should be referring to SPLB 01.
SPLB 05: The last line on page 25 says: "In the current integrated plant, operating procedures (IPEOPs)..." Should this be referring to "integrated plant emergency operating procedures?"
SPLB 06: The response indicates that additional testing will be performed to determine the TDAFW Pump/Turbine performance capability at low SG pressures; and that the tests will be conducted during plant heat up, and the test data will be used to verify the TD AFW pump capabilities and will be used to train the operators or change operating procedures for improved operator guidance, as necessary. With respect to this process, please explain: (a) how the "worst-case" operator response time for establishing and maintaining AFW flow using the turbine driven AFW pump will be determined, and (b) what criteria will be used to assess whether or not the required actions can be completed consistently and reliably within the time limitations that exist. Also, please establish a regulatory commitment to complete these actions and to confirm that the acceptance criteria has been satisfied prior to exceeding 10 percent reactor power.
SPLB 07: The licensee's response (pgs. 34 and 35) indicates that although the FLB was not identified explicitly, the list of accidents, transients, and occurrences in response to plant systems branch RAI #7 is considered a complete list of bounding events. To be clear, the request that was made by SPLB 07 was not for a complete listing of "bounding" events, but for a complete listing of all postulated accidents, transients, and occurrences that could be affected, along with confirmation that the limiting cases referred to in the submittal are bounding. To the extent that the response is not complete in this regard, please provide any additional information that may be required to fully address this question.
Additional comments:
I was also wondering why they chose not to address the 3 parts that defines the safety-related operator actions to show whether it did or did not need to be evaulated against the proposed local actions for the AFW. They also do not reveal what other plants these actions were benchmarked against to show the consistency of the times established for each scenario as part of their time validation process.
Carl Lyon - AFW Phoncon Page 2 q As related to the IOHS section, I think we should also get additional clarification on how they consider the local actions not to be safety-related as described by ANSI 58.8 as well as clarification of how they was able to establish the time validity of the local actions by comparing them to what other plants have used.
CC:
internet:gerald.riste @ nmcco.com
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AFW Phoncon 6/8/05 7:16AM Carl Lyon CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
Action Transferred Date & Time 06/08/05 07:17AM Thomas Breene (intemet:Thomas.Breene@nmcco.com)
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Carl Lyon - Revised RAI Question
-Page 1 q Carl Lyon - Revised RAI Question Page 1 II From:
Carl Lyon To:
internet:Thomas.BreeneO nmcco.com Date:
6/8/05 10:05AM
Subject:
Revised RAI Question Based on our phoncon this morning, please revise SPLB 07 to state:
Please provide a complete listing of all postulated accidents, transients, and occurrences that could be affected by the proposed changes along with a brief summary of the potential impact and any actions that are required as a consequence. Also, please confirm that the limiting cases that are discussed in the submittal bound these other postulated situations in all respects.
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internet:gerald.riste @ nmcco.com
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Revised RAI Question 6/8/05 10:05AM Carl Lyon CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
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Carl Lyon - Draft RAIl Response Pa~g'el1 From:
Carl Lyon To:
internet:Thomas.13reene@ nmcc o.com Date:
6/9/05 7:35AM
Subject:
Draft RAI Response One recommendation is for Page 8 of 32, second line from bottom, which states that "All indicators are non-safety related but of a high quality."
This sentence should be deleted, because this statement may cause confusion with next sentence which states that AFW indication meets NUREG 0737, item ll.E.1.2, Part 2, which requires safety-grate indication for AFW flow.
CC:
internet:gerald.riste @nmcco.com; internet:Theodore.maloney@ nmcco.com
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Draft RAI Response 6/9/05 7:35AM Carl Lyon CFL@nrc.gov Recipients gerald riste CC (intemet:gerald.riste@nmcco.com)
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