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| number = ML17277A365
| number = ML17277A365
| issue date = 10/04/2017
| issue date = 10/04/2017
| title = 2017/10/04 NRR E-mail Capture - Final Request for Additional Information - Duane Arnold - Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" - CAC No. MF9829
| title = NRR E-mail Capture - Final Request for Additional Information - Duane Arnold - Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control - CAC No. MF9829
| author name = Chawla M L
| author name = Chawla M
| author affiliation = NRC/NRR/DORL/LPLIII
| author affiliation = NRC/NRR/DORL/LPLIII
| addressee name = Davis J M
| addressee name = Davis J
| addressee affiliation = NextEra Energy Duane Arnold, LLC
| addressee affiliation = NextEra Energy Duane Arnold, LLC
| docket = 05000331
| docket = 05000331
Line 13: Line 13:
| document type = E-Mail, Request for Additional Information (RAI)
| document type = E-Mail, Request for Additional Information (RAI)
| page count = 5
| page count = 5
| project = CAC:MF9829
| stage = RAI
}}
}}
=Text=
{{#Wiki_filter:NRR-PMDAPEm Resource From:                              Chawla, Mahesh Sent:                              Wednesday, October 04, 2017 11:17 AM To:                                Davis, J.Michael (J.Michael.Davis@nexteraenergy.com); Catron, Steve (Steve.Catron@fpl.com); Kilby, Gary; Probst, Jim; laura.swenzinski@nexteraenergy.com; Murrell, Bob (Bob.Murrell@nexteraenergy.com)
==Subject:==
Final Request for Additional Information - Duane Arnold Energy Center (DAEC) -
Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" - CAC No. MF9829 By application dated June 9, 2017 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML17164A076), NextEra Energy, LLC (NextEra), (the licensee) requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2, which changes the Technical Specifications (TSs) for Duane Arnold Energy Center (DAEC).
Traveler TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (ADAMS Accession No. ML16343B008). The U.S. Nuclear Regulatory Commission staff has reviewed the NextEra submittal and determined that following additional information is required in order to complete the review.
Request for Additional Information:
DAEC-RAI-1:
==Background:==
DAEC TS Section 2.0, Safety Limits, TS 2.1.1.3 states; Reactor Vessel Water Level - Reactor vessel water level shall be greater than 15 inches above the top of active irradiated fuel. [emphasis added]. Safety Limit (SL) 2.1.1.3 is maintained through the TS Limited Condition of Operation (LCO), applicability, actions, and notes. The DAEC TSs require certain safety systems to be OPERABLE during operations with a potential for draining the reactor vessel (OPDRVs). The proposed changes would replace existing TS requirements associated for OPDRVs with revised TSs providing an alternative requirement for Reactor Pressure Vessel (RPV) Water Inventory Control (WIC). These alternative requirements are intended to protect Safety Limit 2.1.1.3. The NRCs regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR) at 10 CFR 50.36.
DAEC TS Bases 2.1.1.3 states, in part:
The reactor vessel water level SL has been established at 15 inches above the top of the active irradiated fuel to provide a point that can be monitored and to also provide adequate SLs for affective action.
From Page 1 of 7 of the License Amendment Request (LAR):
NextEra Energy Duane Arnold, LLC (NextEra) has reviewed the safety evaluation provided to the Technical Specifications Task Force (TSTF) on December 20, 2016, as well as the information provided in TSTF-542. NextEra has concluded that the justifications presented in TSTF-542 and the safety evaluation prepared by the NRC staff are applicable to the Duane Arnold Energy Center (DAEC) and justify this amendment for incorporation of the changes to the DAEC TS. [emphasis added].
From the (LAR), Page 5 of 7.
1
3.1 No Significant Hazards Consideration Analysis NextEra Energy Duane Arnold, LLC (NextEra) requests adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control," which is an approved change to the Standard Technical Specifications (STS), into the Duane Arnold Energy Center Technical Specifications (TS). The proposed amendment replaces the existing requirements in the TS related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel. [emphasis added]. NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below.:
DAECs Safety Limit, Reactor vessel water level shall be greater than 15 inches above the top of active irradiated fuel, is different than the SL stated in the approved TS Change Traveler, TSTF-542 which assumes the Safety Limit is the top of active fuel. This difference between the DAEC SL and the TSTF-542 SL is not identified as a variation and is considered a significant change. Because of the differing SLs it is not clear how the proposed TS changes in TSTF-542 would protect DAECs SL.
This has global effects on the LAR including.
: 1. Regulatory Analysis, response to questions 1, 2, and 3.
: 2. Drain time definition, TS 1.1.
: 3. All places that relates TAF and the Safety Limit since the safety limit is TAF plus 15 inches (for example, but not limited to; TS LCO 3.5.2 and LCO 3.5.2 Required Action D.1).
: 4. New variation to describe these differences between TAF and the DAEC safety limit.
: 5. TS Bases Question: Justify the applicability of TSTF-542 to DAEC given that the DAEC SL 2.1.1.3 is different than TSTF-542.
DAEC-RAI-2:
==Background:==
Red line strike-out appears to be in error for LAR, Attachment 2, TS page 3.3-46. For 3.3.5.2 (top left of the page), being corrected to 3.3.5.3, there is a 3 missing for the 3.3.5.3 title.
Question: Provide a corrected page for 3.3-46.
DAEC-RAI-3
==Background:==
LAR, Attachment 1, Page 4 describes variation i related to TS 3.3.5.2. This variation states, in part;
        ..TS 3.3.5.2 does not include a surveillance requirement (SR) for a logic system functional test since the SR applies only to the manual initiation function. Likewise, the changes to TS 3.5.2, RPV Water Inventory Control, do not include SR 3.5.2.8, which demonstrates ECCS injection/ spray actuation on a manual initiation signal.
Traveler TSTF-542, SR 3.5.2.8 states, in part; Verify the required ECCS injection/spray subsystem actuates on a manual initiation signal.
2
An alternative SR appears to be missing that tests the capability that the associated ECCS injection/spray pumps and valves can be manually operated to provide additional RPV inventory. This SR ensures that the required ECCS injection/spray subsystem can be manually operated for Modes 4 and 5.
Question: Provide additional justification that an alternative SR is not needed to test the capability of the pumps/valves as stated above or provide new TS SR 3.5.2.8 markup.
DAEC-RAI-4
==Background:==
LAR, Attachment 2, TS page 3.5-10 describes the changes to SR 3.5.2.4 (new 3.5.2.5), which states, Verify for the required ECCS subsystem each power operated and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. Per the TSTF-542 traveler, the wording should be: Verify, for the required ECCS subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.
Question: Provide justification for the difference between the submittal and the traveler or provide a correction to TS SR 3.5.2.4. Also consider adding a comma between Verify and for, per the traveler.
DAEC-RAI-5
==Background:==
to the LAR (Mark-up DAEC TS page 3.5-11) contains proposed SR 3.5.2.6, Operate the required ECCS injection/spray subsystem through the recirculation line for  10 minutes. The Frequency is listed as, In accordance with the Inservice Testing Program. The equivalent in TSTF-542, STS SR 3.5.2.6, states the associated Frequency as [92 days OR In accordance with the Surveillance Frequency Control Program].
Question: Provide a technical justification for this variation from TSTF-542.
DAEC-RAI-6
==Background:==
Page 3.5-8 of the LAR describes the proposed LCO 3.5.2. The proposed wording is: One low pressure ECCS subsystem shall be OPERABLE.
TSTF-542 wording is: One low pressure ECCS injection/spray subsystem shall be OPERABLE.
In addition, in several places of the LAR injection/spray is missing after ECCS.
* LCO 3.5.2 Condition A
* LCO 3.5.2 A.1 Required Actions
* SR 3.5.2.5 Question: Provide justification for the difference between the submittal and the traveler TSTF-542 or provide a correction to proposed LCO 3.5.2 and SR 3.5.2.5.
A teleconference was held with the NRC staff on September 26, 2017, to discuss the above information. On October 3, 2017, Michael Davis of the Duane Arnold Energy Center (the licensee) agreed via email sent by Jim Probst to provide a written response to the requested information within 30 days (prior to November 3, 2017).
3
Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 4
Hearing Identifier:    NRR_PMDA Email Number:          3753 Mail Envelope Properties      (Mahesh.Chawla@nrc.gov20171004111700)
==Subject:==
Final Request for Additional Information - Duane Arnold Energy Center (DAEC) -
Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" - CAC No. MF9829 Sent Date:              10/4/2017 11:17:24 AM Received Date:          10/4/2017 11:17:00 AM From:                  Chawla, Mahesh Created By:            Mahesh.Chawla@nrc.gov Recipients:
"Davis, J.Michael (J.Michael.Davis@nexteraenergy.com)" <J.Michael.Davis@nexteraenergy.com>
Tracking Status: None "Catron, Steve (Steve.Catron@fpl.com)" <Steve.Catron@fpl.com>
Tracking Status: None "Kilby, Gary" <Gary.Kilby@fpl.com>
Tracking Status: None "Probst, Jim" <Jim.Probst@nexteraenergy.com>
Tracking Status: None "laura.swenzinski@nexteraenergy.com" <laura.swenzinski@nexteraenergy.com>
Tracking Status: None "Murrell, Bob (Bob.Murrell@nexteraenergy.com)" <Bob.Murrell@nexteraenergy.com>
Tracking Status: None Post Office:
Files                          Size                      Date & Time MESSAGE                        8286                      10/4/2017 11:17:00 AM Options Priority:                      Standard Return Notification:            No Reply Requested:                No Sensitivity:                    Normal Expiration Date:
Recipients Received:}}

Latest revision as of 04:37, 4 December 2019

NRR E-mail Capture - Final Request for Additional Information - Duane Arnold - Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control - CAC No. MF9829
ML17277A365
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 10/04/2017
From: Mahesh Chawla
Plant Licensing Branch III
To: Jennifer Davis
NextEra Energy Duane Arnold
References
MF9829
Download: ML17277A365 (5)
v • d • e


Text

NRR-PMDAPEm Resource From: Chawla, Mahesh Sent: Wednesday, October 04, 2017 11:17 AM To: Davis, J.Michael (J.Michael.Davis@nexteraenergy.com); Catron, Steve (Steve.Catron@fpl.com); Kilby, Gary; Probst, Jim; laura.swenzinski@nexteraenergy.com; Murrell, Bob (Bob.Murrell@nexteraenergy.com)

Subject:

Final Request for Additional Information - Duane Arnold Energy Center (DAEC) -

Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" - CAC No. MF9829 By application dated June 9, 2017 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17164A076), NextEra Energy, LLC (NextEra), (the licensee) requested to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2, which changes the Technical Specifications (TSs) for Duane Arnold Energy Center (DAEC).

Traveler TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (ADAMS Accession No. ML16343B008). The U.S. Nuclear Regulatory Commission staff has reviewed the NextEra submittal and determined that following additional information is required in order to complete the review.

Request for Additional Information:

DAEC-RAI-1:

Background:

DAEC TS Section 2.0, Safety Limits, TS 2.1.1.3 states; Reactor Vessel Water Level - Reactor vessel water level shall be greater than 15 inches above the top of active irradiated fuel. [emphasis added]. Safety Limit (SL) 2.1.1.3 is maintained through the TS Limited Condition of Operation (LCO), applicability, actions, and notes. The DAEC TSs require certain safety systems to be OPERABLE during operations with a potential for draining the reactor vessel (OPDRVs). The proposed changes would replace existing TS requirements associated for OPDRVs with revised TSs providing an alternative requirement for Reactor Pressure Vessel (RPV) Water Inventory Control (WIC). These alternative requirements are intended to protect Safety Limit 2.1.1.3. The NRCs regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR) at 10 CFR 50.36.

DAEC TS Bases 2.1.1.3 states, in part:

The reactor vessel water level SL has been established at 15 inches above the top of the active irradiated fuel to provide a point that can be monitored and to also provide adequate SLs for affective action.

From Page 1 of 7 of the License Amendment Request (LAR):

NextEra Energy Duane Arnold, LLC (NextEra) has reviewed the safety evaluation provided to the Technical Specifications Task Force (TSTF) on December 20, 2016, as well as the information provided in TSTF-542. NextEra has concluded that the justifications presented in TSTF-542 and the safety evaluation prepared by the NRC staff are applicable to the Duane Arnold Energy Center (DAEC) and justify this amendment for incorporation of the changes to the DAEC TS. [emphasis added].

From the (LAR), Page 5 of 7.

1

3.1 No Significant Hazards Consideration Analysis NextEra Energy Duane Arnold, LLC (NextEra) requests adoption of TSTF-542, "Reactor Pressure Vessel Water Inventory Control," which is an approved change to the Standard Technical Specifications (STS), into the Duane Arnold Energy Center Technical Specifications (TS). The proposed amendment replaces the existing requirements in the TS related to "operations with a potential for draining the reactor vessel" (OPDRVs) with new requirements on Reactor Pressure Vessel Water Inventory Control (RPV WIC) to protect Safety Limit 2.1.1.3. Safety Limit 2.1.1.3 requires reactor vessel water level to be greater than the top of active irradiated fuel. [emphasis added]. NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below.:

DAECs Safety Limit, Reactor vessel water level shall be greater than 15 inches above the top of active irradiated fuel, is different than the SL stated in the approved TS Change Traveler, TSTF-542 which assumes the Safety Limit is the top of active fuel. This difference between the DAEC SL and the TSTF-542 SL is not identified as a variation and is considered a significant change. Because of the differing SLs it is not clear how the proposed TS changes in TSTF-542 would protect DAECs SL.

This has global effects on the LAR including.

1. Regulatory Analysis, response to questions 1, 2, and 3.
2. Drain time definition, TS 1.1.
3. All places that relates TAF and the Safety Limit since the safety limit is TAF plus 15 inches (for example, but not limited to; TS LCO 3.5.2 and LCO 3.5.2 Required Action D.1).
4. New variation to describe these differences between TAF and the DAEC safety limit.
5. TS Bases Question: Justify the applicability of TSTF-542 to DAEC given that the DAEC SL 2.1.1.3 is different than TSTF-542.

DAEC-RAI-2:

Background:

Red line strike-out appears to be in error for LAR, Attachment 2, TS page 3.3-46. For 3.3.5.2 (top left of the page), being corrected to 3.3.5.3, there is a 3 missing for the 3.3.5.3 title.

Question: Provide a corrected page for 3.3-46.

DAEC-RAI-3

Background:

LAR, Attachment 1, Page 4 describes variation i related to TS 3.3.5.2. This variation states, in part;

..TS 3.3.5.2 does not include a surveillance requirement (SR) for a logic system functional test since the SR applies only to the manual initiation function. Likewise, the changes to TS 3.5.2, RPV Water Inventory Control, do not include SR 3.5.2.8, which demonstrates ECCS injection/ spray actuation on a manual initiation signal.

Traveler TSTF-542, SR 3.5.2.8 states, in part; Verify the required ECCS injection/spray subsystem actuates on a manual initiation signal.

2

An alternative SR appears to be missing that tests the capability that the associated ECCS injection/spray pumps and valves can be manually operated to provide additional RPV inventory. This SR ensures that the required ECCS injection/spray subsystem can be manually operated for Modes 4 and 5.

Question: Provide additional justification that an alternative SR is not needed to test the capability of the pumps/valves as stated above or provide new TS SR 3.5.2.8 markup.

DAEC-RAI-4

Background:

LAR, Attachment 2, TS page 3.5-10 describes the changes to SR 3.5.2.4 (new 3.5.2.5), which states, Verify for the required ECCS subsystem each power operated and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position. Per the TSTF-542 traveler, the wording should be: Verify, for the required ECCS subsystem, each manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Question: Provide justification for the difference between the submittal and the traveler or provide a correction to TS SR 3.5.2.4. Also consider adding a comma between Verify and for, per the traveler.

DAEC-RAI-5

Background:

to the LAR (Mark-up DAEC TS page 3.5-11) contains proposed SR 3.5.2.6, Operate the required ECCS injection/spray subsystem through the recirculation line for 10 minutes. The Frequency is listed as, In accordance with the Inservice Testing Program. The equivalent in TSTF-542, STS SR 3.5.2.6, states the associated Frequency as [92 days OR In accordance with the Surveillance Frequency Control Program].

Question: Provide a technical justification for this variation from TSTF-542.

DAEC-RAI-6

Background:

Page 3.5-8 of the LAR describes the proposed LCO 3.5.2. The proposed wording is: One low pressure ECCS subsystem shall be OPERABLE.

TSTF-542 wording is: One low pressure ECCS injection/spray subsystem shall be OPERABLE.

In addition, in several places of the LAR injection/spray is missing after ECCS.

A teleconference was held with the NRC staff on September 26, 2017, to discuss the above information. On October 3, 2017, Michael Davis of the Duane Arnold Energy Center (the licensee) agreed via email sent by Jim Probst to provide a written response to the requested information within 30 days (prior to November 3, 2017).

3

Mahesh Chawla Project Manager Phone: 301-415-8371 Fax: 301-415-1222 mahesh.chawla@nrc.gov 4

Hearing Identifier: NRR_PMDA Email Number: 3753 Mail Envelope Properties (Mahesh.Chawla@nrc.gov20171004111700)

Subject:

Final Request for Additional Information - Duane Arnold Energy Center (DAEC) -

Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, "Reactor Pressure Vessel Water Inventory Control" - CAC No. MF9829 Sent Date: 10/4/2017 11:17:24 AM Received Date: 10/4/2017 11:17:00 AM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:

"Davis, J.Michael (J.Michael.Davis@nexteraenergy.com)" <J.Michael.Davis@nexteraenergy.com>

Tracking Status: None "Catron, Steve (Steve.Catron@fpl.com)" <Steve.Catron@fpl.com>

Tracking Status: None "Kilby, Gary" <Gary.Kilby@fpl.com>

Tracking Status: None "Probst, Jim" <Jim.Probst@nexteraenergy.com>

Tracking Status: None "laura.swenzinski@nexteraenergy.com" <laura.swenzinski@nexteraenergy.com>

Tracking Status: None "Murrell, Bob (Bob.Murrell@nexteraenergy.com)" <Bob.Murrell@nexteraenergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 8286 10/4/2017 11:17:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

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