NRC 2009-0054, Response to Request for Additional Information License Amendment Request 241 Alternative Source Term
| ML091380113 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/15/2009 |
| From: | Meyer L Point Beach |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC 2009-0054, TAC ME0219, TAC ME0220 | |
| Download: ML091380113 (13) | |
Text
May 15,2009 NRC 2009-0054 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Response to Reauest for Additional lnformation License Amendment Request 241 Alternative Source Term
References:
(1 )
FPL Energy Point Beach, LLC letter to NRC, dated December 8, 2008, License Amendment Request 241, Alternative Source Term (ML083450683)
NRC letter to FPL Energy Point Beach, LLC, dated April 22, 2009, Point Beach Nuclear Plant, Units I and 2 - Request for Additional lnformation from Mechanical and Civil Engineering Branch Related to License Amendment Request No. 241 Alternate Source Term (TAC Nos. ME0219 and ME0220) (ML090900722)
NextEra Energy Point Beach, LLC (NextEra) submitted Point Beach Nuclear Plant (PBNP),
Units 1 and 2 proposed License Amendment Request 241 and subsequent supplemental information for Commission review and approval pursuant to 10 CFR 50.90 (Reference 1). The license amendment would revise the current licensing basis to implement the alternate source term (AST) through reanalysis of the radiological consequences of the PBNP Final Safety Analysis Report Chapter 14 Accidents.
Via a letter dated April 22, 2009 (Reference 2), NRC staff determined that additional information was required to enable the staff's review of the amendment request. provides the NextEra response to the NRC staff's request. Enclosure 2 provides the Control Room Ventilation Piping and Instrumentation Diagram (P&ID) as modified for AST. provides the Containment Spray P&ID as modified for AST. Enclosure 4 provides the Primary Auxiliary Building Ventilation System P&ID as modified for AST.
NextEra Energy Point Beach, LLC, 661 0 Nuclear Road, Two Rivers, WI 54241
Document Control Desk Page 2 This letter contains no new commitments and no revisions to existing commitments.
In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May 15, 2009.
Very truly yours, NextEra Energy Point Beach, LLC
/
Site Vice President Enclosure cc:
Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW
ENCLOSURE 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 241 ALTERNATIVE SOURCE TERM Via a letter dated April 22, 2009 (Reference I), the NRC staff determined that additional information was required to enable the staff's review of the License Amendment Request 241, Alternative Source Term. The following information is provided by NextEra Energy Point Beach, LLC (NextEra) in response to NRC staff's request.
Per the guidance outlined on page 1.183-8 of Regulatory Guide I. 183, licensees must consider and evaluate the nonradiological impacts of an alternate source term (AST) implementation and the impacts of the associated plant modifications. Section 5.2 of your December 8, 2008 submittal indicates that numerous changes will be made to the Control Room Ventilation (VNCR) system in support of the proposed AST implementation at Point Beach Nuclear Plant (PBNP). You indicated that selected components such as the charcoal filter fans, the control room recirculation fans, damper controllers, and the charcoal/HEPA/roughing filter, and the radiation monitors in the VNCR system have been upgraded to "augmented quality status" in support of the proposed AST implementation. Please discuss the methodology used for the seismic qualification of the aforementioned components.
NextEra Response As stated in Reference (2), the components of the Control Room Ventilation (VNCR) system in support of the proposed AST implementation at Point Beach Nuclear Plant (PBNP) have been upgraded to augmented quality (AQ). This quality classification means that all procurement, maintenance and operational activities associated with these components will fall under the 10 CFR 50, Appendix 9, Quality Assurance Program. This classification is the same classification applied to non-safety related components credited for fire protection, station blackout and radwaste processing. The VNCR system is within the scope of Maintenance Rule, License Renewal Program and is addressed in the PBNP Technical Specifications (TS 3.7.9).
With regard to the seismic qualification of VNCR components, per Appendix A.5 of the PBNP Final Safety Analysis Report (FSAR), the VNCR system is classified as Seismic Class Ill.
Seismic Class Ill is defined as structures and components which are not directly related to reactor operation or containment (Reference 3). Per FSAR Appendix A-5, the PBNP licensing basis does not require these components to be seismically designed or qualified.
Page 1 of 4
Resolution of Unresolved Safety Issue (USI) A-46, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors" (Reference 4)' is applicable to PBNP. Reference (4) does not require that loss of coolant accidents, high energy line breaks or other extraordinary events be postulated when addressing a safe shutdown earthquake (SSE) coincident with a loss of offsite power. Therefore, the VNCR system and components are not seismically qualified.
In the second paragraph of Section 5.2 in your December 8, 2008, submittal, you state that "FPL Energy Point Beach will modify the [VNCR] system to provide redundancy for all active components that are required to reposition from the normal operating position to the accident mode. " Please specify what the aforementioned modifications will consist of, such as the planned addition or modification of equipment in the VNCR system. For these items:
a) Indicate whether the equipment is new or existing.
b) Describe the location of the equipment and the seismic qualification method employed, such as the plant licensing basis or an NRC endorsed industry standard, c) Summarize the results of the seismic qualification of the equipment, indicating whether any modifications or re-design will be necessary in support of the AST.
NextEra Response The Piping and Instrumentation Diagram (P&ID) of the VNCR system, as modified for AST, has been provided as Enclosure 2. New components are clouded to distinguish them from the existing components. Modifications to the VNCR system include the addition of a balancing damper in the outside air flow path to the control room filter fans and the addition of control components and associated cabling to address single failure vulnerabilities. A list of new and existing redundant, active components and their location is provided below:
The NextEra response to Question 1 summarizes the seismic qualifications for VNCR system components. Additional modifications or redesign will not be required to address seismic qualification of the equipment in support of AST implementation.
Component Filter Fans and Motors Recirculation Fans and Motors Dampers Radiation Monitors Control Components Page 2 of 4 Existing X
X X
X X
New X
Location Control Building, El. 66' Control Building, El. 66' Control Building, El. 66' Control Building, El. 44' and El. 74' Control Building, El. 44' and El. 66' Seismic Qualification Non-seismic Non-seismic Non-seismic Non-seismic
Please provide a list of any additional mechanical equipment or systems not mentioned above which will be credited as part of the implementation of the AST at PBNP. For these items:
a) Indicate whether the equipment is new or existing.
b) Describe the location of the equipment and the seismic qualification method employed, such as the plant licensing basis or an NRC endorsed industry standard, c) Summarize the results of the seismic qualification of the equipment, indicating whether any modifications or re-design will be necessary in support of the AST.
In addition to the VNCR system described in the responses to Questions 1 and 2 above, additional systems credited as part of the implementation of AST at PBNP include the containment spray system, the residual heat removal (RHR) system and the primary auxiliary ventilation (VNPAB) system (Reference 2).
A list of new and existing redundant and active components and their location is provided below:
The P&ID for the containment spray system, as modified for AST, has been provided as. Modifications to the containment spray system include the addition of restriction orifices downstream of motor-operated valves (MOVs) 1 (2)SI-860B and 1 (2)SI-860D at the discharge of the containment spray pumps and the modification of electrical power supplies to MOVs 1 (2)SI-860B and 1 (2)SI-860C.
Component Containment Spray Pump Discharge MOV Power Supplies RHR Core Deluge MOVs Controls and Motors VNPAB Exhaust Fans and Motors VNPAB Dampers VNPAB Control Components Modification to the RHR system include a change to the control circuits for MOVs l(2)SI-852A and l(2) SI-852B. Per FSAR Appendix A.5, the RHR and containment spray systems are classified as safety-related and Seismic Class I (Reference 3). As such, the modifications to the containment spray and RHR systems will be designed and installed to Seismic Class I requirements.
The VNPAB exhaust fans are being upgraded to AQ quality status. NextEra is adding this system to the scope of the Maintenance Rule and the License Renewal Program, and addressing the system in the PBNP Technical Specifications (Reference 5).
Existing X
X X
X X
Page 3 of 4 New X
Location Auxiliary Building, El. 8' Unit 1 and 2 Containments, El. 46' Auxiliary Building, El. 8' Auxiliary Building, El. 8' Auxiliary Building, El.
26', Control Building, El. 44' Seismic Qualification SQUG GIP-2 for Components; Analysis for Piping SQUG GIP-2 for Components; Anal sis for Pi in Non-seismic Non-seismic Non-seismic
The VNPAB exhaust fans are also classified Seismic Class Ill, as previously discussed for the VNCR system in the response to Question 1 (see Reference 4). Therefore, the VNPAB exhaust fans are not seismically qualified. No additional modifications or redesign will be required to address seismic qualification of the equipment in support of AST implementation.
The P&ID for the VNPAB system, as modified for AST, has been provided as Enclosure 4. New components are clouded to distinguish them from the existing components. Modifications to the system include the replacement of control dampers with backdraft dampers at the discharge of the VNPAB exhaust fans and stack fans, and modifications to the interlocks between the VNPAB stack and exhaust fans. The purpose of the damper modifications is to ensure the auxiliary building vent stack is the source of the release associated with emergency core cooling system leakage during a design basis event. The purpose of the fan control modifications is to ensure independence between controls for the two sets of fans.
References (1)
NRC letter to FPL Energy Point Beach, LLC, dated April 22, 2009, Point Beach Nuclear Plant, Units 1 and 2 - Request for Additional Information from Mechanical and Civil Engineering Branch Related to License Amendment Request No. 241 Alternate Source Term (TAC Nos. ME021 9 and ME0220) (ML090900722)
(2)
FPL Energy Point Beach, LLC letter to NRC, dated December 8, 2008, License Amendment Request 241, Alternative Source Term (ML083450683)
(3)
Point Beach Nuclear Plant Final Safety Analysis Report, Appendix A-5, Seismic Design Analysis (4)
NRC letter, dated May 22, 1992, Supplement No. 1 to Generic Letter (GL) 87-02 that Transmits Supplemental Safety Evaluation Report No. 2 (SSER No. 2) on SQUG Generic Implementation Procedure, Revision 2, as Corrected on February 14, 1992 (GIP-2) (ML031140292)
(5)
NextEra Energy Point Beach, LLC letter to NRC, dated April 17, 2009, Supplement to License Amendment Request 241, Proposed Technical Specifications for Primary Auxiliary Building Ventilation (VNPAB) (ML091100182)
Page 4 of 4
ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 CONTROL ROOM HVAC SYSTEM P&ID, AS MODIFIED FOR AST (I
page follows)
ENCLOSURE 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 CONTAINMENT SPRAY SYSTEM P&ID, AS MODIFIED FOR AST (2 pages follow)
ENCLOSURE 4 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 PRIMARY AUXILIARY BUILDING VENTILATION SYSTEM P&ID, AS MODIFIED FOR AST (I page follows)