ML052080069

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Response to a Request for Additional Information on NRC Bulletin 03-001, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors - Revision 1
ML052080069
Person / Time
Site: Farley, Vogtle  Southern Nuclear icon.png
Issue date: 07/22/2005
From: Stinson L
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-03-001, NL-05-1207
Download: ML052080069 (9)


Text

L M. Stinson (Mike)

Southern Nuclear Vice President Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5181 Fax 205.992.0341 SOUTHERNAM July 22, 2005 COMPANY Energy to Serve Your Wo rld Docket Nos.:

50-348 50424 NL-05-1207 50-364 50-425 U. S. Nuclear Regulatory Commission A1TN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Response to a Request for Additional Information on NRC Bulletin 2003-01 Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors - Revision I Ladies and Gentlemen:

The U. S. Nuclear Regulatory Commission (NRC) issued NRC Bulletin 2003-01 to inform licensees of the potential for additional adverse effects due to debris blockage of flowpaths necessary for Emergency Core Cooling System (ECCS) and Containment Spray System (CSS) recirculation and containment drainage. These additional adverse effects were based on NRC-sponsored research that identified the potential susceptibility of pressurized-water reactor (PWR) recirculation sump screens to debris blockage in the event of a high energy line break (HELB) that would require ECCS and CSS operation in the recirculation mode.

In accordance with 10 CFR 50.54(f), the NRC requested a response within 60 days of the date of the NRC Bulletin to either: 1) state that the ECCS and CSS recirculation functions have been analyzed with respect to the potentially adverse post-accident debris blockage effects identified in the NRC Bulletin and are in compliance with 10 CFR 50.46(b)(5) and all existing applicable regulatory requirements (Option 1); or 2) describe any interim compensatory measures that have been or wvill be implemented to reduce the risk which may be associated with the potentially degraded or nonconforming ECCS and CSS recirculation functions until an-evaluation to determine compliance has been completed (Option 2).

U. S. Nuclear Regulatory Commission NL-05-1207 Page 2 SNC provided, in a letter dated August 7, 2003, the Farley Nuclear Plant (FNP) and the Vogtle Electric Generating Plant (VEGP) responses to Option 2 of the Requested Information in Bulletin 2003-01, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," dated June 9, 2003. SNC received a facsimile request for additional information (RAI) on August 30, 2004 and subsequently discussed the RAI with the NRC staff via telecon on September 10, 2004. SNC provided the FNP and VEGP responses to the RAI in a letter dated October 29, 2004 in which SNC stated, "SNC has received the [Westinghouse Owner's Group] WOG operational guidance and is currently reviewing for implementation at FNP. Due to the current outage activities at FNP, the discussion of our plans to implement this new WOG guidance is not available at this time. SNC will provide this discussion by November 30, 2004." SNC responded to the RAI on WOG guidance for Farley Nuclear Plant in a letter dated November, 30, 2004.

On July 5, 2005, SNC participated in a conference call with the NRC staff to discuss the current response to Westinghouse proposed Candidates for Operator Action (COA) number 5. During the conference call, SNC agreed to update the current response to COA 5 to reflect SNC's intention to initiate filling of the Refueling Water Storage Tank (RWST) at the point when swap-over to cold leg recirculation is completed. The revised response for Farley Nuclear Plant is provided in Enclosure I and the revised response for Vogtle Electric Generating Plant is provided in Enclosure 2.

Mr. L. M. Stinson, states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY L. M. Stinson to and subC e

efore me this A; day of iUt 2005.

--j.' :

-.- Notary Public My commission expires: u/'.-& )

LMS/CHM/daj

Enclosures:

1. Farley Nuclear Plant Response to RAI - COA 5
2. Vogtle Electric Generating Plant Response to RAI - COA 5

U. S. Nuclear Regulatory Commission NL-05-1207 Page 3 cc:

Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. E. Grissette, Vice President - Plant Vogtle Mr. J. R. Johnson, General Manager - Plant Farley Mr. T. E. Tynan, General Manager - Plant Vogtle RType: CFA04.054; CVC7000; LC# 14302 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. C. Gratton, NRR Project Manager - Vogtle Mr. C. A. Patterson, Senior Resident Inspector - Farley Mr. G. J. McCoy, Senior Resident Inspector - Vogtle

Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Response to a Request for Additional Information on NRC Bulletin 2003-01 Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors - Revision I Farley Nuclear Plant Response to RAI - COA 5

Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Response to a Request for Additional Information on NRC Bulletin 2003-01 Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors - Revision 1 Farley Nuclear Plant Response to RAI - COA 5 On August 30, 2004 the following request for additional information was received from the NRC:

By letter dated August 8, 2003,1 Southern Nuclear Operating Company (the licensee) provided the 60-day response to NRC Bulletin 2003-01 for the Joseph M. Farley Nuclear Plant - Units I and 2. The Bulletin requested the licensee to either (1) state that the emergency core cooling system (ECCS) and containment spray system (CSS) recirculation functions have been analyzed with respect to the potentially adverse post-accident debris blockage effects identified in the Bulletin and are in compliance with all existing applicable regulatory requirements, or (2) describe any interim compensatory measures that have been implemented or that will be implemented to reduce the interim risk associated with potentially degraded or nonconforming ECCS and CSS recirculation functions until an evaluation to determine compliance is complete. The staff has completed its preliminary review of the SNC response and has determined it needs the following additional information to complete its review:

NRC Ouestion 1 On page 2 of Attachment I to your response to Bulletin 2003-01 you state that "FNP

[Farley Nuclear Plant] will review WOG recommended procedural modifications when issued and determine if any FNP specific changes are required." The Westinghouse Owner's Group (WOG) has developed operational guidance in response to Bulletin 2003-01 for Westinghouse and CE type pressurized water reactors (PWRs). Please provide a discussion of your plans to consider implementing this new WOG guidance. Include a discussion of the WOG recommended compensatory measures that have been or will be implemented for your plant, and the evaluations or analyses performed to determine which of the WOG recommended changes are acceptable for your plant. Provide technical justification for those WOG recommended compensatory measures not being implemented by your plant. Also include a detailed discussion of the procedures being modified, the operator training being implemented, and your schedule for implementing these compensatory measures.

FNP provided this information in a letter dated November 30, 2004. Below is the revised response for COA 5 only.

' Actual date of letter was August 7, 2003.

Enclosure I FNP Revised Response for BL 2003 COA 5 Page 2 of 2 FNP Response Candidates for Operator Action (COAs) to be implemented pending final engineering analysis and training validation:

COA 5-Refill of RWST Basis: FNP has current guidance in ECP 1.1, Loss of Emergency Coolant Recirculation, to fill the RWST. The guidance is also included in ECP 1.3, Recirculation Sump Blockage. Similar guidance has been added to ESP 1.3, Transfer to Cold Leg Recirculation to start filling the RWST when transfer to Cold Leg Recirculation is complete.

Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Response to a Request for Additional Information on NRC Bulletin 2003-01 Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors - Revision 1 Vogtle Electric Generating Plant Response to RAI - COA 5

Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Response to a Request for Additional Information on NRC Bulletin 2003-01 Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors - Revision 1 Vogtle Electric Generating Plant Response to RAI - COA 5 On August 30, 2004 the following request for additional information was received from the NRC:

By letter dated August 8, 2003,2 Southern Nuclear Operating Company (the licensee) provided the 60-day response to NRC Bulletin 2003-01 for the Vogtle Electric Generating Plants - Units 1 and 2. The Bulletin requested the licensee to either (1) state that the emergency core cooling system (ECCS) and containment spray system (CSS) recirculation functions have been analyzed with respect to the potentially adverse post-accident debris blockage effects identified in the Bulletin and are in compliance with all existing applicable regulatory requirements, or (2) describe any interim compensatory measures that have been implemented or that will be implemented to reduce the interim risk associated with potentially degraded or nonconforming ECCS and CSS recirculation functions until an evaluation to determine compliance is complete. The staff has completed its preliminary review of your response and has determined it needs the following additional information to complete our review:

NRC Ouestion I On page 2 of Attachment 2 to your response to Bulletin 2003-01 you state that "VEGP [Vogtle Electric Generating Plant] will review WOG recommended procedural modifications when issued and determine if any VEGP specific changes are required." The Westinghouse Owner's Group (WOG) has developed operational guidance in response to Bulletin 2003-01 for Westinghouse and CE type pressurized wvater reactors (PWRs). Please provide a discussion of your plans to consider implementing this new WOG guidance. Include a discussion of the WOG recommended compensatory measures that have been or will be implemented for your plant, and the evaluations or analyses performed to determine which of the WOG recommended changes are acceptable for your plant. Provide technical justification for those WOG recommended compensatory measures not being implemented by your plant. Also include a detailed discussion of the procedures being modified, the operator training being implemented, and your schedule for implementing these compensatory measures.

VEGP provided this information in a letter dated October 29, 2004. Below is the revised response for COA 5 only.

2 Actual date of letter was August 7, 2003.

VEGP Revised Response for BL 2003 COA 5 Page 2 of 2 VEGP Response Candidates for Operator Action (COAs) to be implemented pending final engineering analysis and training validation:

COA 5-Refill of RWST Basis: VEGP has current guidance in ECA 1.1, Loss of Emergency Coolant Recirculation, to fill the RWST. The guidance is also included in ECA 1.3, Recirculation Stump Blockage. Similar guidance has been added to ES 1.3, Transfer to Cold Leg Recirculation to start filling the RWST when transfer to Cold Leg Recirculation is complete.