ML20236K457
| ML20236K457 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 06/29/1998 |
| From: | Long W NRC (Affiliation Not Assigned) |
| To: | Marchi M WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| TAC-M83633, NUDOCS 9807090328 | |
| Download: ML20236K457 (7) | |
Text
_ _ - _ _ _ _ _ _ - _ _ _ _ _ _ - _ - - - _ _ _ - - - _ _ _
-June 29, 1998 l
Mr. M. L. Marchi l
Site Vice President - Kewaunee Plant Wisconsin Public Service Corporation P.O. Box 19002 j
Green Bay, WI 54307-9002
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON KEWAUNEE IPEEE L
SUBMITTAL (TAC NO. M83633 )
i
Dear Mr. Marchi:
Based on our ongoing review of your Kewaunee Individual Plant Examination of External Events (IPEEE) submittal and your responses to our previous requests for additional l.
Information (RAls), we are unable to conclude at this time that the IPEEE meets the Intent of l
Supplement 4 to Generic Letter 88-20. Therefore, we have developed the attached RAI (additional or follow-up to previous RAls) related to the fire and high winds, floods, and other external events analyses. The RAls were prepared by the staff of the Office of Nuclear l
Regulatory Research. Your response is necessary in order to complete our IPEEE review.
We request that you respond respond within 90 days. If you have any questions regarding
(
this matter, please contact me at (301) 415-3026.
l l
Sincerely, L
Original signed by:
[
William O. Long, Sr. Project Manager Project Directorate 111-3 Division of Reactor Projects lil/lV Office of Nuclear Reactor Regulation L
Docket No. 50-331
Enclosure:
- As stated
/
cclw/ encl: See next page 7
m e-
'W DISTRIBUTION:
kb Ad OMd u@I bN Docket File ~
PUBLIC y
l PD3-3 Reading
~
L ARubin (RES/ DST /PRAB)
DOCUMENT NAME: G:\\KEWAUNEE\\lPEEE.RAI OFFICE PD33:PM E
PD33:LA E
PD33:D E
NAME WLong W EBarnhill f/4-RBellamy tw DATE~
(, /d./98
(, A?398
/ /98 b /t 3/98 OFFICIAL RECORD COPY N
L s
9807090328 900629 DR ADOCK 050 31 m
June 29,'1998 i
Mr. M. L. Marchi Site Vice President - Kewaunee Plant Wisconsin Public Service Corporation P.0, Box 19002 Green Bay, WI S4307-9002
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON KEWAUNEE IPEEE SUBMITTAL (TAC NO. M83633 )
Dear Mr. Marchi Based on our ongoing review of your Kewaunee Individual Plant Examination of Extemal
- Events (IPEEE) submittal and your responses to our previous requests for additional information (RAls), we are unable to conclude at thie time that the IPEEE meets the intent of
- Supplement 4 to Generic Letter 88-20. Therefore, we have developed the attached RAI -
l-
' (additional or follow-up to previous RAls) related to the fire and high winds, floods, and other l
' external events analyses.- The RAls were prepared by the staff of the Office of Nuclear L
Regulatory Research. Your response is necessary in order to complete our IPEEE review.
1 We request that you respond respond within 90 days. If you have any questions regarding -
this matter, please contact me at (301) 415-3026.
Sincerely, i
-j Original signed by:
William O. Long, Sr. Project Manager Project Directorate 111-3 l,.
Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation
_ Docket No. 50-331
Enclosure:
As stated cc w/ encl: See next page DISTRIBUTION:
Docket File
- PUBLIC PD3-3 Reading ARubin (RES/ DST /PRAB)
DOCUMENT NAME: G:\\KEWAUNEE\\lPEEE.RAI OFFICE PD33:PM E
PD33:LA E
PD33:D El-NAME WLong IF EBamhill f/3r RBellamy W l DATE I, Id./98 -
6 A3/98 -
/ /98 1, /L.'l/98 l
OFFICIAL RECORD COPY
/pur UNITED STATEP f*
j NUCLEAR REGULATORY COMMISSION i
e WASHINGTON, D.C. 200564J001 Mr. M. L. Marchi Site Vice Presideni Kewaunee Plant Wisconsin Public Service Corporation P.O. Box 19002 Green Bay, WI 54307-9002
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON KEWAUNEE IPEEE SUBMITTAL (TAC NO. M83633 )
Dear Mi. Marchi:
Based on our ongoing review of your Kewaunee Individual Plant Examination of Extema!
Events (IPEEE) submittal and your responses to our previous requests for additional information (RAls), we are unable to conclude at this time that the IPEEE meets the intent of Supplement 4 to Generic Letter 88-20. Therefore, we have developed the attached supplemental request for add 4ional information (SRAl) related to the fire and high winds, floods, and other external events analyses. This SRAI was prepared by the staff of the Office of Nuclear Regulatory Research. Your response is necessary in order to complete our IPEEE review.
We request that you respond respond within 90 days. If you have any questions regarding this matter, please contact me at (301) 415-3026.
Sincerely, w
William O. Long, Sr. Project Manager Project Directorate lil-3 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosure:
As stated cc w/ encl: See next page t
1 0
i M. L. Marchi Wisconsin Public Service Corporation Kewaunee Nuclear Power Plant l
cc:
Foley & Lardner ATTN: Bradley D. Jackson One South Pinckney Street P.O. Box 1497 Madison, WI 53701-1497-Chairman Town of Carlton Route 1 Kewaunee,WI 54216 Harold Reckelvorg, Chairman Kewounse County Board Kewaunee County Courthouse Kewaunee,WI 54216 Attomey General 114 East, State Capitol Madison,WI 53702 U.S. Nuclear Regulatory Commission Resident inspectors Office Route #1, Box 999 Kewaunee,WI 54216-9511 Regional Administrator-Region ill U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4531 James D. Loock, Chief Engineer Pcblic Service Commission of Wisconsin P. O. Box 7854 Madison, WI 53707-7854 C.___________________
l l
l f
l KEWAUNEE IPEEE Supplemental Request for Additional information FIRE QUESTION 1
1.
In the October 13,1995, response to the Kewaunee Fire PRA question F.1, it is stated that:
"All circuits within the control room are fused, it is therefore ressumed that a fire h
would cause the fuse to blow and the equipment to fail in its normal mode."
This does not take into consideration the fact that hot shorts in control enoles can simulate the closing of contrel switches, leading, for example, to the repositioning of valves, spurious operation of motors and pumps, or the shutdown of operating equipment. Such hot shorts would not cause a fuse to blow. These types of faults might, for example, lead to a LOCA, diversion of flow within various plants systems, deadheading and failure of important pumps, premature or undesirable switching of pump suction sources, undesirable equipment operations, and unrecoverable damage to motor-operated valves.
The analysis of a fire in Mechanical Control Console C (see p.5 of the October 13,1995, submittal) assumes that a fire can cause spurious opening of a PORV, but that the PORV will close when the fuse blows. ' But, since the fire may simulate the closing of a switch, there is no reason to assume the fuse will blow.
It appears that the actual emergency operating procedures for the plant may take into consideration the possibility that hot shorts in a control room fire may hcve adverse effects, and that as a result emergency operating procedures E-0-06 or E-0-07 are invoked for control room fires. However, it is not clear that these procedures were properly incorporated into the accident sequence delineation and quai.tification for control room fires, in the October 13,1995, submittal. In particular, because these.
operating procedures E-0-06 and E-0-07 require the isolation of offsite power, and perhaps the isolation of one train of equipment (either the dedicated train or the alternate train), then almost any control room fire requires, by the procedures, to consider a reactor trip with loss of offsite power. In addition, one train of AC electric power (either train A or train B) may be isolated. Examples where offsite power and one train of electric power may be isolated are fires in Mechanical Control Console C, which could potentially affect the pressurizer PORVs, and h fire in Mechanical Control Console B, which could affect the charging pumps and their associated valves. It is not clear from the submittal whether, because of the concern about het shorts in the control room, control of plant will be transferred to points outside the control room, for a control room flre, even when the contral room can still be occupied. Accordingly, please provide the following information:
1.
According to plant operating procedures, for what control room fires are eitherprocedures E-0-06 or E-0-07 it":oked? For what controlroom fires will offsite power be isolated? For what control rocm fires wil! offsite power and one train of electric power be bolated? For what control room m
[
N fires will cont. ci be transferred from the control roorn to the dedicated shutdown panel, or to otherlocations outside the control room?
2.
For those control room fires in which controlis transferred to outside the control rcom, and the dedicated train of shutdown equipment is not available (as a consequence of the controlroom fire), describe it.b actions required to bring the plant to safe shutdown.
3.
For those control room fires in which E-0-06 or E-0-07 are invoked, or offsite poweris isolated, delineate the accident sequences and provide the details of their quantification.
4.
If there are any control room fires where offstle power and a train of electric poweris not isolated, b>. a hot short is possible which simulates the closing of a switch (and therefore does not blow a fuse), delineate and quantify the accident sequences. For example. a fire in Mechanical Control Console C may open a PORV because of a not short, and a fuse may not blow, 5.
Provide a copy ofprocedures E-0-06 and E-0-07.
HIGH WINDS, FLOODS, AND OTHER EXTERNAL EVENTS (HFO) QUESTION 1.
. This question concems tha resolution cf GI-103, Design for Probable Maximum Precipitation (PMP). The IPEEE submittal (see p. 5-25ff) calculates, using NOAA Hydrometeorological Report (HMR) No. 52, a runoff of 1.9 inches (see p. 5-50 of the IPEEE submittal).; The submittal then states (see p. 5-29) that "due to the immense size of Lake Michigan and its normal water level (approximately 23 feet below the plant elevation) no flooding of Lake Michigan from a combination of rain collection and runoff will ever endanger Kewaunee." But this is not the issue. The issue is whether ponding on the site can affect safety-related equipment, and whether roof ponding can fail roofs, with attendant failure of safety-related equipment. The roof ponding issue is adequately addressed, in a response dated August 29,1995, to a request for additional information.
' However, the site ponding issue is not addressed adequately. Moreover, the runoff was calculated with a runoff coefficient of 0.15. ConsMering the fact that the soil has high clay conter,t (see p. F-6 of the Point Beach A-45 study, NUREG/CR-4458, and see also baction 3.1.3.6 of the Kewaunee IPEEE submittal), and that the ground may be frozen in the spring (when it is most likely the PMP event would occur), the runoff coefficient should likely be considerably higher. We note that the U.S. Army Corps of Engineers Engineer Manual, EM 1110-2-1417, Flood-Runoff Analysis, p.13-7, states that for Probable Maximum Storms (PMSs), ground conditions that affect losses should be the most severe that can reasonably exist in conjunction with a PMS, and that, where it is possible for the ground to be frozen, zero or near zero loss rates should be used.
Accordingly, a runoff coefficient C= 0.9 may be more appropriate. Moreover the PMP estimates in the submittal were based on a 10 sq. mi area; a 1 sq. mi area would give a greater depth. From Fig. 24 of HMR 52, a 1 hr,1 sq. mi PMP corresponds to a rainfall intensity l=16.5 in/hr, as opposed to the 13 in/hr used in the IPEEE submittal (for a 10
=___
d t mir area). The drainage area A is stated to be not greater than 640 acres (=1 sq. mi)in Rev.12 of the Kewaunee Updated Final Safety Analysis Report (UFSAR), on p. 2.6-8.
Using the rational formula, the peak flow Q is given by Q= CIA, with C=0.9, l=16.5 in/hr, and A= 1 mi2, from which one obtains Q=9583 cubic feet per sec. But the peak flow that the drainage ditch can handle is 467 cubic feet per sec, from the UFSAR, p. 2.6-9. Thus the drainage ditch does not appear to be able to handle the runoff, and there may be some site flooding and ponding, from a PMP event.
Furthermore, it should be noted that one cannot determine the level of flooding at the site from computing a rate ofincrease of water level from Q/A= CIA /A, as is done on
- p. 5-29 of the IPEEE submittal. Here, A is the drainage area; the water from this area collects on the site, but the amount of water that collects in a particular area on the site depends on the topography of the site. Portions of the area A may not be on the site, but the water from these portions can runoff onto the site. Some areas of the site may experience sheet runoff and there may be ponding of water in other areas.
Please address the issue of site flooding and ponding from the PMP. Please provide an analysis of the PMP which demonstrates the extent to which site flooding and ponding from the PMP results in wateringress into buildings housing safety-related equipment.
Have any storms that have occurred resulted in water ingress into buildings housi.m safety-related squipment?
_