ML100620202
| ML100620202 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/03/2010 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Jim Costedio, Hale S Point Beach |
| Poole Justin/DORL/LPL3-1/ 301-415-2048 | |
| References | |
| Download: ML100620202 (3) | |
Text
From:
Poole, Justin Sent:
Wednesday, March 03, 2010 10:17 AM To:
'Hale, Steve'; 'COSTEDIO, JAMES'
Subject:
Draft - Request for Additional Information from Fire Protection Branch RE: EPU Steve By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 7, 2009 (Agencywide Documents Access and Management System Accession No. ML091250564), FPL Energy Point Beach, LLC, submitted a request to increase each units licensed core power level from 1540 megawatts thermal (MWt) to 1800 MWt reactor core power, and revise the technical specifications to support operation at this increased core thermal power level.
The Fire Protection 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 Fire Protection RAI #1 In RS-001, Revision 0, Review Standard for Extended Power Uprates, Attachment 2 to Matrix 5, Supplemental Fire Protection Review Criteria, states that power uprates typically result in increases in decay heat generation following plant trips. These increases in decay heat usually do not affect the elements of a fire protection program related to (1) administrative controls, (2) fire suppression and detection systems, (3) fire barriers, (4) fire protection responsibilities of plant personnel, and (5) procedures and resources necessary for the repair of systems required to achieve and maintain cold shutdown. In addition, an increase in decay heat will usually not result in an increase in the potential for a radiological release resulting from a fire. However, the licensees license amendment request (LAR) should confirm that these elements are not impacted by the extended power uprate.
The staff note that LAR 261, Attachment 5, Section 2.5.1.4.2. Technical Evaluations, on page 2.5.1.4-5, specifically addresses only items (1) and (4) above. Provide statements to address items (2), (3), and (5).
Fire Protection RAI #2 LAR 261, Attachment 5, Section 2.5.1.4.2. Technical Evaluations, on page 2.5.1.4-7, states that, The FPER also addresses all required aspects of Separation Criteria for Safe Shutdown
Capability. The separation criterion is not affected by the EPU unless a modification is created.
As such, the modification process will control the changes to the alternative/dedicated or backup shutdown capability.
Other than modifications to the plant, governed by processes which assess the effect on Fire Protection Program, EPU does not affect the alternative shutdown methods. Modifications required as a result of EPU that modify the function of any mechanical component in the alternative safe shutdown flow paths, modify any components or circuits that provide power, control, or indication to components required for alternative safe shutdown, or introduce any plant equipment failure modes which will affect the ability to achieve any of the alternative shutdown functions, will be addressed as part of the plant modification process It is unclear to the staff whether there are fire protection program plant modifications planned (e.g., adding new cable trays, or re-routing of existing cables, or increases in combustible loading affecting fire barriers rating, or changes to administrative controls) at EPU conditions.
Clarify whether this request involves plant modifications, or changes to the fire protection program, including any proposed modifications to implement transition to Title 10 Energy of the Code of Federal Regulations (10 CFR) 50.48(c). If any, the staff requests the licensee to identify proposed modifications and discuss the impact of these modifications on the plants compliance with the fire protection program licensing basis, 10 CFR50.48, or applicable portions of 10 CFR 50, Appendix R.
Fire Protection RAI #3 LAR 261, Attachment 5, Section 2.5.1.4.2. Technical Evaluations, on page 2.5.1.4-11, states that, EPU Evaluation: The probability of a spurious SI pump start or spurious CS initiation is unchanged for EPU operations and the time required for mitigating actions as stated above is not changed. Pending LAR 241 (ML083450683) discusses modifications to the controls of these pumps and throttling the pump discharges, which may increase the time permissible prior to unacceptable consequences The staff notes that the LAR 241 evaluation has not yet been completed to address the possible case where the Nuclear Regulatory Commission (NRC) disapproves LAR 241, discuss how results of LAR 241 would impact the fire protection program at the EPU conditions.
Further, the staff notes that this request is based on a deterministic evaluation, not a probabilistic one; therefore, explain (1) the relevance of the probability of a spurious Safety Injection (SI) pump start or spurious Containment Spray (CS) initiation and (2), if relevant, why the probability and the time required for mitigating actions are unchanged for EPU operations.
Fire Protection RAI #4 LAR 261, Attachment 5, Section 2.5.1.4.2. Technical Evaluations, on page 2.5.1.4-12, states that, EPU Evaluation: The time to SG dryout in case of a spurious opening of an SG ADV has been verified for EPU to remain between 14 and 49 minutes, depending upon the unit involved and initial conditions and the time due to conservative assumptions in the original analysis At EPU conditions with higher decay heat, why does the time to Steam generator (SG) dryout in case of a spurious opening of an SG Atmospheric Dump Valve (ADV) still remain between 14 and 49 minutes. For example, was the original evaluation based on a range of possible
conditions sufficiently conservative so as to bound even the range now possible under EPU conditions? Discuss how the assumptions in the original analysis remain valid for EPU conditions.
Fire Protection RAI #5 Some plants credit aspects of their fire protection system for other than fire protection activities, e.g., utilizing the fire water pumps and water supply as backup cooling or inventory for non-primary reactor systems. If the Point Beach Nuclear Plant (PBNP) Units1 and 2, credits its fire protection system in this way, the EPU LAR should identify the specific situations and discuss to what extent, if any, the EPU affects these non-fire-protection aspects of the plant fire protection system. If the PBNP Units1 and 2, do not take such credit, the staff requests that the licensee verify this as well.
DRAFT