ML082490148

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Draft RAI on Proposed Amendment Re. Steam Line Isolation Applicability
ML082490148
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 09/02/2008
From: Tam P
Plant Licensing Branch III
To: Riste G, Sly C
Dominion Energy Kewaunee
Tam P
References
TAC MD8544
Download: ML082490148 (3)


Text

Accession No. ML082490148 From: Peter Tam Sent: Tuesday, September 02, 2008 4:17 PM To: Jerry Riste (gerald.o.riste@dom.com); Craig Sly (craig.d.sly@dom.com); Jack Gadzala (jack.gadzala@dom.com)

Cc: Samir Darbali

Subject:

Kewaunee - Draft RAI re. proposed amendment on steam line isolation function applicability (TAC MD8544)

Jack and Craig:

This is regarding your application for amendment dated 4/14/08 (steam line isolation function applicability). The amendment would add a footnote to TS Table 3.5-4, Instrument Operating Conditions for Isolation Functions, Functional Unit 2, Steam Line Isolation, allowing the SLI channels to be inoperable when both Main Steam Isolation Valves (MSIVs) are closed and de-activated.

Samir Darbali of our Instrumentation and Control Systems Branch would like to discuss with you the items below in a conference call. We may or may not need to formally issue the questions in final form.

1. Modes of Operation: Currently TS 3.5 does not specify for which modes the SLI functions are required to be operable. Therefore, the SLI functions are required to be operable in all modes. However, the first paragraph of page 4 of 10 of the application states: The steam line isolation function (manual and automatic) currently must be operable in the OPERATING, HOT STANDBY, HOT SHUTDOWN and INTERMEDIATE SHUTDOWN modes.
a. Since TS 3.5 does not specify the modes in which the SLI functions are required, discuss the basis for the request to limit the modes of operability.
b. Describe how TS 3.5 is currently being applied.
c. Explain the basis for the applicability of NUREG 1431 (STS), Table 3.3.2-1 in lieu of the requirements of TS 3.5.
d. Explain the apparent discrepancy between the TS 3.5 requirement for operability in all modes and the first paragraph of page 4 of 10 of the LAR.
2. TS 3.5 Relationship with the STS: The application proposes that the SLI functions be operable in the OPERATING, HOT STANDBY, HOT SHUTDOWN, and INTERMEDIATE SHUTDOWN modes, unless both MSIVs are closed and de-activated. The STS requires the SLI functions to be operable during POWER OPERATION (Mode 1), STARTUP (Mode
2) and HOT STANDBY (Mode 3). Describe how the modes in the Kewaunee TS relate to the modes in the STS.
3. OPERATING Mode: The application proposes that if both MSIVs are closed and de-activated, the SLI function is not required for the OPERATING mode. The STS footnote is only applicable in HOT STANDBY (Mode 3) for the Steam Line Pressure Negative Rate -

High function and in STARTUP and HOT STANDBY modes (Modes 2 and 3) for the other SLI functions. The STS footnote is not applicable for the POWER OPERATION mode (Mode 1). Discuss the basis for proposing that the OPERATING mode be included in the proposed change.

4. HOT SHUTDOWN Mode: The application proposes that the SLI functions be operable in the HOT SHUTDOWN mode, unless both MSIVs are closed and de-activated. The STS does not require the SLI to be operable in HOT SHUTDOWN (Mode 4), regardless of MSIV position. Discuss the basis for proposing that the HOT SHUTDOWN mode be included in the proposed change.

The sole purpose of this e-mail is to prepare you and others for the requested conference call. This e-mail does not convey a formal NRC staff position, and does not formally request for additional information.

Peter S. Tam, Senior Project Manager Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Tel. 301-415-1451 E-mail Properties Mail Envelope Properties ()

Subject:

Kewaunee - Draft RAI re. proposed amendment on steam line isolation function applicability (TAC MD8544)

Sent Date: 09/02/2008 3:59:48 PM Received Date: 09/02/2008 4:17:00 PM From: Peter Tam Created By: Peter.Tam@nrc.gov Recipients:

gerald.o.riste@dom.com (Jerry Riste (gerald.o.riste@dom.com))

Tracking Status: None craig.d.sly@dom.com (Craig Sly (craig.d.sly@dom.com))

Tracking Status: None jack.gadzala@dom.com (Jack Gadzala (jack.gadzala@dom.com))

Tracking Status: None Samir.Darbali@nrc.gov (Samir Darbali)

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 15870 09/02/2008 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: