ML092880112
| ML092880112 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/15/2009 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Jim Costedio, Flentje F, Hale S Point Beach |
| Poole Justin/DORL/LPL3-1/ 301-415-2048 | |
| References | |
| Download: ML092880112 (3) | |
Text
From:
Poole, Justin Sent:
Thursday, October 15, 2009 9:28 AM To:
'Hale, Steve'; COSTEDIO, JAMES; 'Flentje, Fritzie'
Subject:
Draft - RAI on the Main Feedwater Isolation Valve
- Steve, By letter dated April 7, 2009, FPL Energy Point Beach, LLC, submitted a license amendment application for Point Beach Nuclear Plant Units 1 and 2 which included modifications to the auxiliary feedwater system. Included with this review is the addition of a main feedwater isolation valve.
The Balance of Plant 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
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DRAFT SBPB - FW - RAI - 1 In the amendment dated April 7, 2009, the licensee states that The current safety-grade FRVs are being modified with a non-safety grade internal trim and operators. Based upon this statement the licensee may intend to downgrade the main feedwater regulating valves (MFRVs); yet, the MFRVs are credited in Chapter 14 analyses for providing backup isolation in the event of a failure of the main feedwater isolation valve (MFIV).
The staff recognizes that NUREG-0138 allows a licensee to take credit for nonsafety-grade components in the main feedwater line even though they are not designed seismic category I, to perform a backup isolation in certain accident scenarios, because the staff does not require that an earthquake be assumed to occur coincident with the postulated main steam line break.
However, NUREG-0138 does prescribes that in order to rely on these non-safety-grade components, their design and performance must be compatible with the accident conditions they are called upon to credited in, and the reliability of these valves is of the same order of magnitude as that accepted for nuclear safety-grade components.
Request The staff requests the licensee justify their position in continuing to use the MFRV as a credited in their safety analyses as back-up isolation based upon their proposal to start using non-safety
grade components in these MFRVs. Explain whether the MFRVs will continue to safety-related?
SBPB - FW - RAI - 2 The licensee proposed to modify the technical specification surveillance requirements, adding a test every 18 month for the new MFIVs to isolate. The conditions that the MFIVs will be tested at may affect the response times.
Request The staff requests the licensee provide stroke time curves for MFIVs if available, explain the conditions that they will perform surveillance testing of the MFIV, and the criteria used to ensure that the valve closure times meet any safety analyses limits.
SBPB - FW - RAI - 3 The licensee proposes to install the new MFIVs just upstream of the two safety-related containment isolation check valves. Since the main feedwater line is high pressure and high temperature, the MFIVs and the surrounding components may create a possible missile hazard; in addition, the safety-related MFIVs may be a target from possible missiles in accordance with
General Design Criteria (GDC) 4 and their applicable current licensing design basis, PBNP GDC 40.
Request The staff requests the licensee to evaluate whether the MFIVs have adequate protection against the dynamic effects and missiles that might result from plant equipment failures.
SBPB - FW - RAI - 4 The licensees Inservice Testing (IST) program document details the technical basis and provides the overall description of the activities planned to fulfill the IST requirements for pumps and valves as specified in 10 CFR 50.55a(f)(4)(ii), and required by PBNP Technical Specification 5.5 [TS 5.5.2.10]. The new MFIVs are safety-related and credited in the design basis accident in the event of a MSLB. The valve will be needed to be added to the IST Program.
Request The staff requests the licensee verify that the MFIVs have been added correctly to the IST program.
DRAFT