ML091540313
| ML091540313 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/03/2009 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Hale S Florida Power & Light Energy Point Beach, Point Beach |
| Poole Justin/DORL/LPL3-1/ 301-415-2048 | |
| References | |
| Download: ML091540313 (4) | |
Text
From:
Justin Poole Sent:
Wednesday, June 03, 2009 11:32 AM To:
'Steve_Hale@fpl.com' Cc:
'COSTEDIO, JAMES'; 'Flentje, Fritzie'
Subject:
DRAFT RAI questions from Containment and Ventilation Branch on AST Amendment
- Steve, By letter dated December 8, 2008, NextEra Energy, LLC (formerly FPL Energy, LLC), submitted a license amendment application for Point Beach Nuclear Plant Units 1 and 2 to revise the current licensing basis to implement the alternate source term through reanalysis of the radiological consequences of the FSAR Chapter 14 accidents.
The Containment and Ventilation Branch has reviewed the information provided and determined that in order to complete its evaluation, additional information is required. We would like to discuss the questions, in draft form below, with you in a conference call.
This e-mail aims solely to prepare you and others for the proposed conference call. It does not convey a formal NRC staff position, and it does not formally request for additional information.
Justin C. Poole Project Manager NRR/DORL/LPL3-1 U.S. Nuclear Regulatory Commission (301)415-2048 email: Justin.Poole@nrc.gov
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
DRAFT SCVB#1 The license amendment request (LAR) proposes to modify the control room emergency filtration system (CREFS) to create a new alignment for the accident mode that provides a combination of filtered outside air and filtered recirculation air. In addition, it is proposed that the CREFS fans will be automatically loaded onto their associated diesel generator during a loss of offsite power (LOOP) coincident with a Loss of Coolant Accident (LOCA).
1a. In the proposed change to Surveillance Requirement (SR) 3.7.9.6, the capability of the CREFS fan to maintain a positive pressure of 0.125 inches water gauge in the control room envelope (CRE) during emergency mode is verified at a flow rate of 4950 cubic feet per minute (cfm) +/- 10%. The proposed amendment requires a combination of filtered and re-circulated air with a minimum requirement of 1955 cfm recirculated. Please explain the significance of the 1955 cfm to the AST amendment and why it is not necessary to verify this air quantity by the surveillance requirement (i.e. in addition to verifying the total flow rate).
1b. The LAR proposes to revise the licensees commitment from to provide technical specification changes to reference an acceptable surveillance methodology (and plans for any associated plant modifications to the CRE) to support requested information in GL 2003-01, Item (c), for PBNP no later than 180 days following NRC approval of TSTF-448, to FPL Energy Point Beach will submit a LAR addressing CR habitability surveillance methodology in accordance with TSTF-448, as modified by TSTF-508, within 60 days of approval of the AST LAR. The NRC staff has not completed its review of proposed TSTF-508 and a schedule for completion has not been established. The staff requests that the LAR for the control room surveillance methodology be separated into two parts, one that proposes adoption of approved TSTF-448 and, if desired, a second LAR to be submitted after TSTF-508 has been approved.
This will prevent delaying review of your request to adopt TSTF-448 TS changes.
SCVB#2 The proposed change credits the non-safety related Control Room Ventilation System (VNCR) and also the non-safety related Primary Auxiliary Building Ventilation (VNPAB) System in the dose analysis. This means that non-safety related structures, systems and components will be used to perform a safety related function. The LAR further states that VNCR has already been upgraded to augmented quality status in the current licensing basis and that VNPAB will be upgraded to augmented quality as part of the effort to adopt AST. These statements imply that at PBNP, non-safety related components with an augmented quality status are allowed to perform and taken credit for a safety related function.
2a Please provide a detailed explanation of what augmented quality means and how this status is achieved and maintained at PBNP.
2b Does the VNCR and VNPAB comply with 10 CFR 50.49, Environmental qualification of electrical equipment important to safety for nuclear power plants, and General Design Criteria (GDC) 4, Environmental and dynamic effects design bases?
2c The LAR states that VNPAB will be manually started during post-accident conditions.
Can the system be started from the CR, if not, what actions are required external to the CR?
SCVB#3 In your letter dated February 20, 2009, you stated that the CREFS, which is a portion VNCR that supports the radiological habitability of the CR is currently in PBNP TS, and that it is also within the scope of the Maintenance Rule (10 CFR 50.65) and License Renewal (10 CFR 54.37(b)). The letter also stated that VNPAB will be added to the TS, Maintenance Rule, and the License Renewal Program. By letter dated April 17, 2009, you submitted proposed TS for VNPAB. The staff notes that the proposed TS for VNPAB did not include verification of flow quantity. Did the AST dose analysis take credit for this system to operate at a minimum air flow quantity, if so, why is verification of the flow rate not included in the TS?
SCVB#4 The LAR proposes to revise TS Section 5.5.15, Containment Leakage Rate Testing Program, item c, to change the maximum allowable containment leakage rate, La at Pa from 0.4% to 0.2%
of containment air weight per day. Please provide the leakage margins available at PBNP.
4a When was the most recent integrated leak rate test performed? Based on the margins available in this test, can the proposed change be achieved without any modifications, if not, what modifications are planned in order to achieve the results in the proposed TS change?
4b Please summarize the results of your most recent integrated leak rate test and the two most recent local leak rate tests.
4c When is the next integrated leak rate scheduled?
SCVB#5 The LAR proposes to direct continued containment spray (CS) while on sump recirculation, if radiological conditions and/or core damage indicates it is required. In addition, the LAR proposes to modify CS and residual heat removal (RHR) systems to provide throttling capability of CS and RHR during the emergency core cooling system (ECCS) recirculation phase. What effects will these actions have on pos-accident containment pressure and temperature, short term or long term? Also confirm that these changes will have no impact in satisfying review guidance in Standard Review Plan (NUREG-0800) Section 6.2.1.1.A, which states that containment pressure should be reduced to less than 50% of peak calculated pressure for the design basis LOCA within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the postulated accident.
DRAFT