ML052590490
| ML052590490 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 09/27/2005 |
| From: | Bhalchandra Vaidya NRC/NRR/DLPM/LPD4 |
| To: | Conen J BWR Owners Group, DTE Energy |
| vaidya B, NRR/DLPM, 415-3308 | |
| References | |
| NEDO-33160, TAC MC5446 | |
| Download: ML052590490 (6) | |
Text
September 27, 2005 Mr. Joseph E. Conen BWR Owners Group DTE Energy - Fermi 2 200 TAC 6400 N. Dixie Highway Newport, MI 48166
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE BOILING WATER REACTOR OWNERS GROUP (BWROG) TOPICAL REPORT (TR)
NEDO-33160, "REGULATORY RELAXATION FOR THE POST ACCIDENT SRV
[SAFETY RELIEF VALVE] POSITION INDICATION SYSTEM" (TAC NO. MC5446)
Dear Mr. Conen:
By letter dated December 13, 2004, the BWROG submitted for NRC staff review TR NEDO-33160, "Regulatory Relaxation for the Post Accident SRV Position Indication System." The NRC staff has completed its preliminary review of your submittal, and has identified a number of items for which additional information is needed to continue its review.
The NRC staff requires responses to the enclosed request for additional information (RAI) questions in order to continue our review.
In our acceptance letter for TR NEDO-33160, the NRC staff agreed to a review completion date of January 30, 2006. To support the above completion date, in the telephone conversation held between the NRC staff and Jim Kenney of your staff, BWROG stated that the NRC staff will receive your response to the enclosed RAI by October 30, 2005.
Please call me at 301-415-3308, if you have any questions on this issue.
Sincerely,
/RA/
Bhalchandra Vaidya, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 691
Enclosure:
Request for Additional Information cc w/encl: See next page
September 27, 2005 Mr. Joseph E. Conen BWR Owners Group DTE Energy - Fermi 2 200 TAC 6400 N. Dixie Highway Newport, MI 48166
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE BOILING WATER REACTOR OWNERS GROUP (BWROG) TOPICAL REPORT (TR)
NEDO-33160, "REGULATORY RELAXATION FOR THE POST ACCIDENT SRV
[SAFETY RELIEF VALVE] POSITION INDICATION SYSTEM" (TAC NO. MC5446)
Dear Mr. Conen:
By letter dated December 13, 2004, the BWROG submitted for NRC staff review TR NEDO-33160, "Regulatory Relaxation for the Post Accident SRV Position Indication System." The NRC staff has completed its preliminary review of your submittal, and has identified a number of items for which additional information is needed to continue its review.
The NRC staff requires responses to the enclosed request for additional information (RAI) questions in order to continue our review.
In our acceptance letter for TR NEDO-33160, the NRC staff agreed to a review completion date of January 30, 2006. To support the above completion date, in the telephone conversation held between the NRC staff and Jim Kenney of your staff, BWROG stated that the NRC staff will receive your response to the enclosed RAI by October 30, 2005.
Please call me at 301-415-3308, if you have any questions on this issue.
Sincerely,
/RA/
Bhalchandra Vaidya, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 691
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
Public RidsNrrOd (JDyer/WBorchardt)
FAkstulewicz PDIV-2 Reading ADrozd AHowe RidsNrrPMBVaidya RidsNrrDlpm (TMarsh/CHaney)
RidsNrrLADJohnson RidsNrrDlpmPdiv (HBerkow)
RidsNrrAdpt (BSheron)
BMarcus RidsNrrDlpmPdiv2 (DCollins)
RLobel GThomas Accession No.:ML052590490 NRR-088
- No Substantial change from the Memorandum OFFICE PDIV-2/PM PDIV-1/LA EEIB-A/SC*
SRXB-A/SC*
SPSB-C/SC**
PDIV-2/SC(A)
NAME BVaidya DJohnson AHowe FAkstulewicz MKotzalas DCollins DATE 09/27/2005 09/27/2005 07/27 /2005 07/27 /2005 09/20/2005 09/27/2005 OFFICIAL RECORD COPY
BWR Owners Group Project No. 691 cc:
Mr. Randy C. Bunt Vice Chairman, BWROG Southern Nuclear Operating Company Bin B057 P.O. Box 1295 Birmingham, AL 35201 Mr. J. A. Gray, Jr.
Regulatory Response Group Vice Chairman BWR Owners Group Entergy Nuclear Northeast 440 Hamilton Avenue Mail Stop 12C White Plains, NY 10601-5029 Mr. H. Lewis Sumner Executive Chairman, BWROG Southern Nuclear Company 40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35242 Mr. Thomas G. Hurst GE Energy M/C A-16 3901 Castle Hayne Road Wilmington, NC 28401 Mr. Amir Shahkarami Executive Vice Chairman, BWROG Exelon Cornerstone II at Cantera 4300 Winfield Road Warrenville, IL 60555 Mr. William A. Eaton ENTERGY P.O. Box 31995 Jackson, MS 39286 Mr. Aloysius Wrape General Manager, Performance Services Mail Code GENPL4 Two North Ninth Street Allentown, PA 18101 Mr. Richard Libra DTE Energy - Fermi 2 M/C 280 OBA 6400 North Dixie Highway Newport, MI 48166 Mr. James F. Klapproth GE Energy M/C A-16 3901 Castle Hayne Road Wilmington, NC 28401 Mr. Kenneth Putnam Regulatory Response Group Chairman BWR Owners Group Nuclear Management Company Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324
REQUEST FOR ADDITIONAL INFORMATION BOILING WATER REACTOR OWNERS GROUP (BWROG)
TOPICAL REPORT (TR) NEDO-33160, "REGULATORY RELAXATION FOR THE POST ACCIDENT SRV POSITION INDICATION SYSTEM" PROJECT NO. 691 1.
Regulatory Guide (RG) 1.97 groups the variables to be monitored during and after an accident into five types. Type D variables provide the operator with information on the operation of individual safety systems and systems important to safety. For Boiling Water Reactors (BWRs), RG 1.97 recommends that the Type D key variables be monitored by instrumentation that meet the Category 2 criteria. The Category 2 criteria includes environmental qualification, augmented quality, and reliable power. One of the Type D systems is the main steam system. RG 1.97 recommends that primary system safety relief valve (SRV) position, during automatic depressurization, flow through, or pressure in valve lines is a key variable for providing detection of accident and boundary integrity indication for the main steam system and, therefore, should meet the Category 2 criteria. In addition to the Category 2 recommendation for Type D key variables, RG 1.97 recommends that Type D variables that provide backup information should meet the Category 3 criteria.
TR NEDO-33160 recommends that SRV position be removed from the RG 1.97 Type D Category 2 instrumentation. The basis of this recommendation is the claim that SRV position indication is not used for accident detection and mitigation or boundary integrity indication.
TR NEDO-33160 states, "for a BWR, the knowledge of SRV position provides no essential information for ensuring a post-accident safety-related function." The RG 1.97 purpose for SRV position is not to provide information about a plant safety function.
Types A, B, and C instrumentation provide information about plant safety functions.
SRV position is a Type D variable because it provides system status. Therefore, NEDO-33160s discussion about plant safety functions should be replaced by a discussion about downgrading SRV position indication from Type D, Category 2 to Type D, Category 3.
2.
NUREG-0737, Item II.D.3 requires that plants have SRV position indication in the control room. Section 50.34(f)(2)(xi) of Title 10 of the Code of Federal Regulations (10 CFR) requires plants to provide direct indication of relief and safety valve position (open or closed) in the control room. Per this requirement, BWRs are required to have instrumentation that provide operators with direct indication of SRV position. However, this requirement does not state the design and qualification criteria the instrumentation must meet.
In the Executive Summary of TR NEDO-33160, the last paragraph on page 4 states, "Other participating owners plan to remove the system." Please confirm that if the NEDO-33160 is approved, the regulatory requirements of NUREG-0737 Item II.D.3 and 10 CFR 50.34(f)(2)(xi) will continue to be met.
3.
Since RG 1.97 recommends that main steam system status be monitored by SRV position instrumentation, TR NEDO-33160 needs to be revised to address all variables that provide key information about SRV position status. The TR has addressed reactor vessel pressure and suppression pool temperature as key variables for determining SRV operation. However, TR NEDO-33160 should also address other variables that provide the operator with information from which he can determine the SRV position (open or closed) and meet or exceed the Category 2 criteria.
4.
TR NEDO-33160 states that BWR plants have other instrumentation that can provide the operator with information about SRV position. Some of these other instruments are commercial grade and do not meet the Category 2 criteria. TR NEDO-33160 should provide details about these other instruments including an analysis to determine if these instruments meet the Category 2 or Category 3 criteria. If these instruments do not meet the Category 2 or Category 3 criteria in entirety, describe the portions of the Category 2 or Category 3 criteria that are not met.
5.
In the Conclusions and Recommendations of TR NEDO-33160, the first sentence of the second paragraph on page 12 states, "For the BWR, a post-accident SRV position provides no safety benefit, and thus should not be a RG 1.97 Type D indication." The staff does not agree with this conclusion. While a downgrade from the RG 1.97 Category 2 criteria to the Category 3 criteria is possible, SRV position indication would remain a Type D variable and the requirements of NUREG-0737 Item II.D.3 and 10 CFR 50.34(f)(2)(xi) remain unchanged. The conclusion of TR NEDO-33160 should be revised accordingly.
6.
The reviewers note in Technical Specification (TS) Table 3.3.3.1-1 of both NUREG-1433 and NUREG-1434 reads: "Table 3.3.3.1-1 shall be amended for each plant as necessary to list: 1. All Regulatory Guide 1.97, Type A instruments, and 2. All Regulatory Guide 1.97, Category 1, non-Type A instruments specified in the plants Regulatory Guide 1.97, Safety Evaluation Report." Based on a cursory review, the NRC staff is unaware of any BWR plant that has SRV position as a Type A variable.
Therefore, since SRV position is not a Type A variable or a Category 1 variable, licensees for plants that currently have SRV position in their plant specific post accident monitoring (PAM) TSs, could request SRV position be removed from their plant specific PAM TSs, without reliance on TR NEDO-33160. TR NEDO-33160, therefore, would not be applicable for a plant that has SRV position as a Type A variable and the licensee would be expected to maintain the TS status of SRV position indication. Please identify any plant that has SRV position as a Type A variable.
7.
Describe the effects of the proposed change on the BWR emergency operating procedures. Describe how the information from these instruments is used now, and how the operator will obtain the same information without these instruments.