ML091530604

"Draft Acceptance Review" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.

Draft Questions from the Staff on Missing Information for AFW Modification Needed for Acceptance Review

ML091530604
Person / Time
Site:	Point Beach
Issue date:	06/02/2009
From:	Justin Poole Plant Licensing Branch III
To:	Hale S Florida Power & Light Energy Point Beach
Poole Justin/DORL/LPL3-1/ 301-415-2048
References
Download: ML091530604 (5)

Text

From:

Justin Poole Sent:

Tuesday, June 02, 2009 3:44 PM To:

'Steve_Hale@fpl.com' Cc:

Lois James

Subject:

Draft questions from the Staff on missing information to the AFW modification Steve below are a rough draft of what the staff feels is information missing from your application that is required to continue our review. Please remember these deal only with the AFW modifications.

Justin C. Poole Project Manager NRR/DORL/LPL3-1 U.S. Nuclear Regulatory Commission (301)415-2048 email: Justin.Poole@nrc.gov

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

DRAFT

1. Provide a detailed summary of the calculations and supporting documentation for the motor-driven auxiliary feedwater (MDAFW) design change such as the voltage drop, short circuit, switchgear ratings, breaker ratings, cable ampacity/design rating, and protective coordination. Also, provide details of the maximum pump and motor design load requirements assuming a single failure of the turbine-driven AFW pump including its nameplate ratings.

2. Describe the impact of the electrical design change on the Emergency Diesel Generator (EDG) and provide supporting calculations to show the electrical loads being added including maximum loading on the EDGs and the remaining margins available, changes required for the EDG sequencer, dynamic analysis to show motor starting/running conditions within the EDG design capabilities, and EDG fuel oil requirements.

3. The license amendment request (LAR) states that the existing 460 Vac MDAFW pump (250 HP) is redesignated as Standby Steam Generator pump. Explain whether this additional load has been accounted in the EDG load. If not, provide basis for not considering this load. Is this load required to be added to the EDGs by any operating procedures?

4. Describe the changes required for Section 3.8 of the Technical Specifications (TS) to verify the capability of the EDGs as a result of the design change. Explain why an EDG endurance and load margin test (24 -hr) is not performed to demonstrate the capability of the EDGs to carry the emergency loads above the continuous rating.

5. Provide an electrical one-line diagram and schematics that include the newly configured electrical design. Also, explain how the MDAFW cables are routed and how it meets the electrical separation and independence requirements.

6. If the MDAFW pumps are credited in the Point Beach Units 1 and 2 station blackout mitigation strategy, explain any impacts of increased loading on the station blackout gas turbine generator.

7. TS SR3.3.4.3 identifies changes to the time delay relays for 4.16 kV and 480 V loss of voltage relays and the EDG breaker close delay relay. Provide supporting calculations and bases for the change including your evaluations to show the accident analysis assumptions remain the same. Also, provide schematics and logic diagram for the undervoltage protection scheme.

8. Describe the post-maintenance testing for the MDAFW pump replacement. Include the surveillances that will be performed to demonstrate that the MDAFW pump is OPERABLE. Also include any post-maintenance testing of the electrical power system. Describe the plant conditions under which the post-maintenance testing will be performed. Are there approved procedures to perform the post-maintenance testing?

9. In addition to the NRC Regulatory Commitments provided in the LAR, the staff finds that the following compensatory measures should be officially docketed as NRC Regulatory Commitments if the modifications are done during operating Modes 1,2, and 3.

The scheduling of the MDAFW pump replacement will be avoided during seasons when the probability of severe weather or grid stress conditions is high or forecasted to be high. Adverse weather contingency procedures will be enacted for meteorological conditions that could potentially affect offsite power availability.

Prior to and during the MDAFW pump replacement, the Transmission System Operator will be contacted once per day to ensure no significant grid perturbations are expected.

Component testing or maintenance of safety systems and important non-safety equipment, including offsite power systems (auxiliary and startup transformers), that increase the likelihood of a plant transient or loss of offsite power will be avoided.

10. In their description of TS changes, the licensee states that the new minimum condensate storage tank (CST) level to support the EPU is not available. The CST is credited as a source of water for the AFW system. Standard Review Plan (SRP)

Section 10.4.9 acceptance criteria reference the AFW system meeting the criteria of GDC 5 for shared systems and GDC 19 for maintaining reactor shutdown. SRP requires staff to confirm that the AFW system provide minimum flow under all flow conditions, regardless of the water source. The licensee will have to provide an acceptable CST level based upon any impact from the newly installed AFW pump system.

Note: on page 2.5.4.5-21, the licensee describes the CST as part of the AFW system, and proposes a new CST level of 15,410 gallons assuming both CSTs are available, and 30,820 gallons if only one CST is available.

11. In their description of TS changes, the licensee states that the AFW pump suction transfer low pressure setpoint to support the EPU is not available. On page 2.5.4.5-21, the licensee describes the alternate service water (SW) supply as a part of the AFW system. The SW system is credited as the safety-related source of water. SRP Section 10.4.9 requires the staff to confirm that design features provide for automatic switch-over to the safety-related water supply without an interruption in water flow.

The licensee has to provide an acceptable CST level based upon any impact from the newly installed AFW pump system.

12. On page 2.5.4.5-22, the licensee describes net positive suction head (NPSH) available for the AFW system. The licensee has not completed their evaluation of the limiting available NPSH condition that occurs when the suction to the AFW pumps is from the CSTs. The licensee states that the CST is assumed to be available for AFW pump supply for LOCA or MSLB accidents in the SW system model. SRP Section 10.4.9 requires staff to confirm that design features provide for automatic switch-over to the safety-related water supply without an interruption in water flow. The licensee still has to confirm that adequate NPSH is maintained to the AFW pumps.

13. On page 2.5.4.5-25, the licensee describes the AFW room ventilation for the location of the new MDAFW pumps in the 8 elevation of the primary auxiliary building (PAB).

The licensee states that there is a large opening to the general area of the PAB, but the EPU modification design process has to verify that adequate cooling is provided to the AFW pump room to ensure operability and confirm that the licensing basis of the PAB ventilation is still met. SRP Section 10.4.9 acceptance criteria reference the AFW system meeting the criteria of GDC 5 for shared systems. The licensee still has to confirm that the PAB ventilation system is adequate to support the AFW pumps.

14. On page 2.5.4.5-20, the licensee describes the design verses the operating pressures and temperatures of AFW system. The licensee states that the pressure rating on the discharge side of the AFW pumps will be subject to the shutoff head of the new MDAFW pumps. The new piping and valves will require a higher pressure rating.

The licensee states that the existing AFW discharge piping and valves will remain bounded by the original design pressure. However, the new AFW pump discharge does tie into the existing MDAFW piping; hence the existing AFW piping will be subject to the new pumps discharge pressure.

The licensee states that the final piping design will be established during the modification process ensuring adequate pressure rating of all new piping and components. SRP Section requires the system pumps, valves, and piping are compatible with the expected service conditions. The licensee still has to confirm that the new and existing AFW system is adequate to support operation of the new AFW pumps.

15. The staff noted sections of the amendment where the license makes a statement that they do not have to perform an analysis of a particular accident because they claim it is not part of their licensing basis. These sections include:

a. On page 2.8.5.1.1-5, under the section 2.8.5.1.1.2.2, Increase in Feedwater Flow, the licensee states that this event is not part of the Point Beach licensing basis.

b. On page 2.8.5.2.4-1, under the section 2.8.5.2.4, Feedwater System Pipe Breaks Inside and Outside Containment, the licensee states that feedwater system pipe breaks are not required to be analyzed per the Point Beach current licensing basis.

Appendix B and C of SRP Section 3.6.1, Plant Design for Protection against Postulated Piping Failures in Fluid System outside Containment, Branch Technical Position SPLB 3-1, licensees had to evaluate double ended rupture of the largest pipe in the feedwater system. In addition, since the feedwater line is classified as a high energy line, then the licensee is required to evaluate for a feedwater rupture in their, high energy line break analysis. These type accidents are among the list of accidents listed in Appendix A, Safety Evaluation Report Compliance, of their application, A.3 -

RETRAN for Non-LOCA Safety Analysis, and A.4 - LOFTRAN for Non-LOCA Safety Analysis. Therefore, the license should analyze the feedwater system for pipe breaks.

Additionally, a failure in the main feedwater control system can cause a steam generator overfill condition. As a result of Generic Letter 89-19 the staff concluded that all pressurized water reactor plants should provide automatic steam generator overfill protection to mitigate main feedwater overfeed events during reactor power operation. Therefore, the licensee should evaluate accidents that involve an increase in feedwater flow.

16. Regulation 10 CFR 50 Appendix A, Criterion 57--Closed system isolation valves, states that each line that penetrates primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere shall have at least one containment isolation valve. The licensee currently credits the feedwater check valves as a feedwater line containment isolation valve. However, Criterion 57 also states that a simple check valve may not be used as the automatic isolation valve.

The licensee is installing new fast closing (5 second) air operated MFIVs to the feedwater system to limit the feedwater flow to the containment during a main steam line break event. These valves are classified as safety related and will be evaluated for addition to the IST program. However, the licensee is not crediting them as containment isolation valves. Even though the licensing of PBNP predates the adoption of the GDCs in 10 CFR 50 Appendix A, the licensee corresponding reference in their UFSAR is Criterion 53, Containment Isolation Valves. Since the licensee is installing these new MFIVs for having the safety-related function of main feedwater isolation, then the licensee should incorporate the MFIVs as having the function for main feedwater line containment isolation.

17. The licensee failed to provide the Failure Mode and Effects Analysis for the new AFW system DRAFT

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Subject:

Draft questions from the Staff on missing information to the AFW modification Sent Date: 6/2/2009 3:37:31 PM Received Date: 6/2/2009 3:44:00 PM From: Justin Poole Created By: Justin.Poole@nrc.gov Recipients:

Steve_Hale@fpl.com ('Steve_Hale@fpl.com')

Tracking Status: None Lois.James@nrc.gov (Lois James)

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