ML101890230

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Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) - Kewaunee ITS Conversion Database
ML101890230
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 06/03/2010
From:
Dominion Energy Kewaunee
To:
Office of Nuclear Reactor Regulation
References
Download: ML101890230 (15)


Text

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 1 of 15 ITS NRC Questions Id 1111 NRC Question ALK-001 Number Category Technical ITS Section 2.0 ITS Number 2.0 DOC Number JFD Number JFD Bases Number Page 2.0-1 Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Rev. 0 of the ITS pages, Section 2.1.1.1 (page 2.0-1) states: 2.1.1.1 The departure Question from nucleate boiling ratio (DNBR) shall be maintained 1.17 for the WRB-1 DNB correlation and 1.14 for the HTP DNB correlation. Revision 21 of the KPS USAR mentions the HTP DNB correlation; however, Revision 21.5 of the KPS USAR does not discuss the HTP DNB correlation. Please clarify whether the 1.14 for the HTP DNB correlation wording in ITS Section 2.1.1.1 remains applicable to KPS. If this correlation is applicable to KPS, then please explain why this information is no longer contained in the KPS USAR. If this correlation is no longer applicable to KPS, then please provide the supporting documentation and applicable changes to the ITS amendment request.

Attach File 1 Attach File 2 Issue Date 11/19/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/19/2009 9:59 AM Notification Audrey Klett Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 1 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1111 06/03/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 2 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1071 NRC Question ALK-001 Number Select Licensee Response Application

Response

12/2/2009 8:55 AM Date/Time Closure Statement Response The HTP DNB correlation was removed from the USAR Section 3 (Section 3 is the Statement Reactor Section of the USAR) based on a recent (August 2009) USAR section 3 update. The HTP DNB correlation only applies to the Framatome (FRA) HTP fuel design. The FRA HTP fuel design was not used in the Cycle 30 reload core design (Cycle 30 core was loaded in the reactor in October 2009) and is not intended to be used in future KPS reload core designs. USAR Section 3 was changed based on change objectives that included: 1) the section should reflect the current design basis and 2) there should be reduced emphasis on the FRA fuel design that is not intended to be used in future reload core designs. Consistent with these USAR change objectives much of the FRA fuel design information including the FRA fuel HTP DNB correlation was removed from the USAR Section 3. Some FRA fuel design information was retained in USAR Section 3, however. The 1.14 for the HTP DNB correlation wording in ITS Section 2.1.1.1 remains applicable to KPS. It reflects the KPS license basis DNB correlation and limit for the FRA HTP fuel design. Although the FRA HTP fuel design is not currently used and is not intended for use in future reload core designs there is a remote potential for the use of the FRA HTP fuel design in future reload core designs, e.g. under emergency reload core re-design conditions. The HTP DNB correlation and the associated HTP DNB correlation limit of 1.14 remain in the TS for the possible use of the FRA fuel design.

To maintain consistency between ITS Section 2.1.1 and the USAR, KPS plans to change USAR section 3 and add back in information and reference to the FRA fuel HTP DNB correlation.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 12/2/2009 8:56 AM Modified By Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 2 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1071 06/02/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 3 of 15 Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 3 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1071 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 4 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1231 NRC Question ALK-001 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 12/14/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/14/2009 8:30 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 4 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1231 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 5 of 15 ITS NRC Questions Id 1121 NRC Question ALK-002 Number Category Technical ITS Section 2.0 ITS Number 2.0 DOC Number JFD Number JFD Bases Number Page Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question Revision 21.5 of the KPS USAR discusses a W-3 correlation. Please discuss the basis for why this correlation is not specified as a safety limit in Section 2.1.1.1 of the ITS.

Attach File 1 Attach File 2 Issue Date 11/19/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/19/2009 10:02 AM Notification Audrey Klett Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 5 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1121 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 6 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1061 NRC Question ALK-002 Number Select Licensee Response Application

Response

12/2/2009 8:30 AM Date/Time Closure Statement Response ITS 2.1.1.1 specifies the primary DNB correlation and limit for the current KPS Statement fuel designs. The W-3 correlation was replaced as the primary DNB correlation when new fuel designs were implemented in the operating history of KPS. The replacement DNB correlations were the HTP DNB correlation for the FRA HTP fuel design and the WRB-1 DNB correlation for the Westinghouse 422 V+ fuel design. These two DNB correlations are the DNB correlations documented in the current KPS CTS and in the proposed KPS ITS.

The W-3 DNB correlation has only limited application in the current reload design and safety analyses with the Westinghouse 422 V+ fuel design. The W-3 DNB correlation applies when any one of the following reactor conditions is outside the range of the WRB-1 correlation (that is, pressure, mass flux and local quality). As a result, the W-3 DNB correlation is only applied in the main steam line break (MSLB) and the rod withdrawal from subcritical (RWSC) accident analyses and below the first mixing vane grid. In these specific cases the conditions are outside the range of the WRB-1 correlation and the W-3 DNB correlation applies.

Therefore because W-3 is not a primary DNB correlation for the current KPS fuel designs and because it has only limited application in the KPS safety analyses the W-3 DNB correlation is not included in CTS 2.1 and ITS 2.1.1.1. This is also consistent with STS for other plants that have only limited application of the W-3 DNB correlation.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 12/2/2009 8:54 AM Modified By Date Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 6 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1061 06/02/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 7 of 15 Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 7 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1061 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 8 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1241 NRC Question ALK-002 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 12/14/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/14/2009 8:31 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 8 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1241 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 9 of 15 ITS NRC Questions Id 1131 NRC Question ALK-003 Number Category Editorial ITS Section 2.0 ITS Number 2.0 DOC Number JFD Number JFD Bases Number Page Number B 2.1.1-2 (s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC Question Page B 2.1.1-2 of the ITS Bases, Section 2.1.1: The first sentence in the Safety Limits section of the ITS Bases states, in part, The figure provided in the COLR shows the loci of points . Because the COLR contains several figures, please specify the applicable figure number in the ITS Bases (e.g., Figure [#] provided in the COLR shows the loci of points ).

Attach File 1 Attach File 2 Issue Date 11/19/2009 Added By Audrey Klett Date Modified Modified By Date Added 11/19/2009 10:04 AM Notification Audrey Klett Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 9 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1131 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 10 of 15 Licensee Response/NRC Response/NRC Question Closure Id 891 NRC Question ALK-003 Number Select Licensee Response Application

Response

11/20/2009 11:00 AM Date/Time Closure Statement Response ITS 2.1.1 (Volume 4, Page 9) states that the combination of THERMAL Statement POWER, Reactor Coolant System (RCS) highest loop average temperature, and pressurizer pressure shall not exceed the limits in the COLR. Thus, the ITS does not identify the actual figure number. The ISTS Bases quoted in the NRC reviewer's question is discussing this ITS Safety Limit requirement. The ISTS Bases does not identify the specific COLR number, it just references the COLR. Note that the COLR for all plants have multiple figures to cover various requirements in the COLR (e.g., ITS 3.1.6 limits are provided in a figure), and these Figures are not identified by number in the ITS Bases. The KPS COLR specifically identifies the current Technical Specification requirement and the associated figure which provides the limits. Therefore, KPS does not believe that it is necessary to identify the specific figure in the ITS Bases. This is also consistent with the ISTS Bases, which does not identify COLR figure numbers. Furthermore, identifying the specific figure would create additional work for KPS every time the COLR was updated - KPS would be required to update the ITS Bases if the figure number changed.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Victor Cusumano Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 11/20/2009 10:58 AM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 10 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=891 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 11 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1151 NRC Question ALK-003 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question Closure 12/3/2009 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/3/2009 12:54 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 11 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1151 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 2 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 12 of 15 ITS NRC Questions Id 1141 NRC Question ALK-004 Number Category Technical ITS Section 2.0 ITS Number 2.0 DOC Number JFD Number JFD Bases Number Page B 2.1.1-2 Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Add Name Branch POC Conf Call N

Requested NRC ITS 2.1.1, Reactor Core SLs, states, in part, that the combination of thermal power, Question RCS highest loop average temperature (emphasis added, as opposed to coolant temperature or RCS average temperature in the CTS), and pressurizer pressure shall not exceed the limits specified in the COLR. ITS Bases, page B 2.1.1-2, Safety Limits states, in part, that the figure in the COLR shows the loci of points of thermal power, RCS pressure, and average temperature (emphasis added) for which the minimum DNBR is not less than the safety analysis limit. This bases statement could be interpreted as an inconsistency with the TS if not written in terms RCS highest loop average temperature. The KPS COLR, Cycle 30, Revision 1, Figure 1, Reactor Core Safety Limits Curve (1772 Mwt) (Cores Containing 422V+ fuel) (TS 2.1.a), uses Reactor Coolant Average Temperature to establish the safety limit curves. Please clarify if and how Figure 1 in the COLR will be modified to reflect that the temperature input should be the RCS highest loop average temperature, and please make the corresponding clarification to the referenced statement in the ITS Bases on page B 2.1.1-2.

Attach File 1

Attach File 2

Issue Date 11/20/2009 Added By Audrey Klett Date Modified Modified By Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 12 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1141 06/02/2010

Kewaunee ITS Conversion Database Page 2 of 2 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 13 of 15 Date Added 11/20/2009 9:55 AM Notification NRC/LICENSEE Supervision Audrey Klett Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 13 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1141 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 14 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1121 NRC Question ALK-004 Number Select Licensee Response Application

Response

12/2/2009 2:35 PM Date/Time Closure Statement Response The quoted words from Page B 2.1.1-2 were maintained in the KPS ITS to Statement be consistent with the ISTS wording. ISTS 2.1.1 uses the term "highest loop average temperature," but the ISTS Bases just states "average temperature." However, the Bases also references the figure in the COLR as the location of the required values. The Figure in the COLR will be changed as part of converting to the ITS to include the term "highest loop average temperature" in lieu of the current term "average temperature."

KPS does not believe that it is necessary to change the wording in the ISTS, since it is not believed that the words in the Bases could be construed to allow an "average of both loops" in lieu of the actual wording in the Technical Specifications that the limit is based on the "highest average loop." However, if the NRC reviewer believes that the ISTS (NUREG-1431) Bases as written are not satisfactory, KPS will make the clarifying change.

Question Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Audrey Klett Ray Schiele Added By Robert Hanley Date Added 12/2/2009 2:37 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 14 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1121 06/02/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 15 of 15 Licensee Response/NRC Response/NRC Question Closure Id 1171 NRC Question ALK-004 Number Select NRC Question Closure Application

Response

Date/Time Closure In its response, the licensee stated, "However, if the NRC reviewer believes that the ISTS (NUREG-1431) Bases Statement as written are not satisfactory, KPS will make the clarifying change." Clarifying the subject KEW ITS Bases statement may help reinforce the TS change and its interpretation for KEW staff, and a change to the ISTS Bases may eliminate the need to ask this question for future TS conversions; however, because the KEW ITS and COLR will require that the highest loop average temperature be used, a change to the KEW ITS Bases is not required to understand the intent of the KEW ITS. This question is closed, and no further information is required at this time to draft the Safety Evaluation.

Response

Statement Question 12/3/2009 Closure Date Attachment 1

Attachment 2

Notification NRC/LICENSEE Supervision Added By Audrey Klett Date Added 12/3/2009 1:23 PM Modified By Date Modified Enclosure, Q&A to Attachment 1, Volume 04 (Chapter 2.0) Page 15 of 15 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1171 06/02/2010