ML092110111: Difference between revisions

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| issue date = 07/30/2009
| issue date = 07/30/2009
| title = Draft RAI on Response to GL 2008-01
| title = Draft RAI on Response to GL 2008-01
| author name = Tam P S
| author name = Tam P
| author affiliation = NRC/NRR/DORL/LPLIII-1
| author affiliation = NRC/NRR/DORL/LPLIII-1
| addressee name = Breene T L, Gadzala J, Sly C
| addressee name = Breene T, Gadzala J, Sly C
| addressee affiliation = Dominion Energy Kewaunee, Inc
| addressee affiliation = Dominion Energy Kewaunee, Inc
| docket = 05000305
| docket = 05000305
| license number = DPR-043
| license number = DPR-043
| contact person = Tam P S
| contact person = Tam P
| case reference number = TAC MD7847, GL-08-001
| case reference number = TAC MD7847, GL-08-001
| document type = E-Mail
| document type = E-Mail
Line 28: Line 28:


The NRC staff is reviewing your 9-month response to GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."  Guidance on NRC staff expectation is provided by an NRC letter to J. H. Riley of NEI, 5/28/09 (Accession NO.
The NRC staff is reviewing your 9-month response to GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."  Guidance on NRC staff expectation is provided by an NRC letter to J. H. Riley of NEI, 5/28/09 (Accession NO.
ML091390637), which is generally consistent With NEI guidance provided to Industry (letter, J. H. Riley, 3/20/08)  as clarified in later NEI communications. We recommend that the licensee consult NRC's 5/28/09 letter when responding to the following RAIs:  
ML091390637), which is generally consistent With NEI guidance provided to Industry (letter, J. H. Riley, 3/20/08)  as clarified in later NEI communications. We recommend that the licensee consult NRC's 5/28/09 letter when responding to the following RAIs:
: 1. GL is intended for addressing all modes and all operating conditions, and it is not limited to events and accidents evaluated in the UFSAR. Please confirm that all subject systems are evaluated for all modes and all operating conditions. Justify why CVCS is not included in the subject systems. (Page 1, 21)  
: 1. GL is intended for addressing all modes and all operating conditions, and it is not limited to events and accidents evaluated in the UFSAR. Please confirm that all subject systems are evaluated for all modes and all operating conditions. Justify why CVCS is not included in the subject systems. (Page 1, 21)
: 2. Please provide a summary of Technical Requirements Manual/ Technical Requirements Bases section similar to NUREG -1431 SR 3.5.2.3 and LCO 3.6.6. Confirm that these TRM requirements are currently implemented and provide the results of this approach for the subject systems.  (Page 8)  3. Please summarize the methodology and applicable limits for gas accumulation in the discharge piping of the LHSI (RHR) and ICS systems for Kewaunee.  (Page 13)  
: 2. Please provide a summary of Technical Requirements Manual/ Technical Requirements Bases section similar to NUREG -1431 SR 3.5.2.3 and LCO 3.6.6. Confirm that these TRM requirements are currently implemented and provide the results of this approach for the subject systems.  (Page 8)  3. Please summarize the methodology and applicable limits for gas accumulation in the discharge piping of the LHSI (RHR) and ICS systems for Kewaunee.  (Page 13)
: 4. DEK performed calculations to identify the maximum potential void volumes at local high point locations and in valve bonnets in the SI, RHR and ICS systems.  (Page 15)
: 4. DEK performed calculations to identify the maximum potential void volumes at local high point locations and in valve bonnets in the SI, RHR and ICS systems.  (Page 15)
Please summarize the results of these calculations and how it is going to be used for future modifications.  
Please summarize the results of these calculations and how it is going to be used for future modifications.
: 5. Please demonstrate that adequate NPSH margin exist when air ingestion effects are considered in the revised calculations for SI, RHR and ICS pumps and also provide the revised calculations.
: 5. Please demonstrate that adequate NPSH margin exist when air ingestion effects are considered in the revised calculations for SI, RHR and ICS pumps and also provide the revised calculations.
(Page 15)      
(Page 15)
: 6. Please summarize the following procedures briefly:  
: 6. Please summarize the following procedures briefly:
: a. Fill and vent procedures with acceptance criteria to assure that piping is sufficiently full after system fill and vent activity. Also provide the details of confirmatory testing followed by fill procedures. (Page 23/24)  
: a. Fill and vent procedures with acceptance criteria to assure that piping is sufficiently full after system fill and vent activity. Also provide the details of confirmatory testing followed by fill procedures. (Page 23/24)
: b. The procedures for periodic monitoring for gas accumulation at Kewaunee. Discuss future modifications to allow monitoring in the locations which are currently inaccessible and other compensatory measures as part of monitoring program. Justify that quarterly monitoring would be adequate to assure operability of the subject systems. (Page 36)  
: b. The procedures for periodic monitoring for gas accumulation at Kewaunee. Discuss future modifications to allow monitoring in the locations which are currently inaccessible and other compensatory measures as part of monitoring program. Justify that quarterly monitoring would be adequate to assure operability of the subject systems. (Page 36)
: c. Revised In-service testing procedures to provide dynamic sweeping as part of the filling of the systems where needed to assure systems are sufficiently full. (Page 43)  
: c. Revised In-service testing procedures to provide dynamic sweeping as part of the filling of the systems where needed to assure systems are sufficiently full. (Page 43)
: d. Discuss various surveillance procedures applicable to subject systems.  
: d. Discuss various surveillance procedures applicable to subject systems.
: 7. Please summarize briefly the resolution of completed corrective actions as identified in Section II, A and B of the submittal as appropriate and identify any adverse conditions that were discovered.  (Page 41-43)  
: 7. Please summarize briefly the resolution of completed corrective actions as identified in Section II, A and B of the submittal as appropriate and identify any adverse conditions that were discovered.  (Page 41-43)
: 8. Training was not identified in the GL but it is considered to be a necessary part of applying procedures and other activities when addressing issues identified in the GL.
: 8. Training was not identified in the GL but it is considered to be a necessary part of applying procedures and other activities when addressing issues identified in the GL.
Please discuss training briefly.  
Please discuss training briefly.  

Revision as of 21:12, 11 July 2019

Draft RAI on Response to GL 2008-01
ML092110111
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 07/30/2009
From: Tam P
Plant Licensing Branch III
To: Breene T, Gadzala J, Sly C
Dominion Energy Kewaunee
Tam P
References
TAC MD7847, GL-08-001
Download: ML092110111 (3)


Text

Accession No. ML092110111

From: Tam, Peter Sent: Thursday, July 30, 2009 7:39 AM To: Craig D Sly; 'Jack Gadzala'; Thomas L Breene Cc: Desai, Kulin

Subject:

Kewaunee - Draft RAI on Response to GL 2008-01 (TAC MD7847)

Craig:

The NRC staff is reviewing your 9-month response to GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." Guidance on NRC staff expectation is provided by an NRC letter to J. H. Riley of NEI, 5/28/09 (Accession NO.

ML091390637), which is generally consistent With NEI guidance provided to Industry (letter, J. H. Riley, 3/20/08) as clarified in later NEI communications. We recommend that the licensee consult NRC's 5/28/09 letter when responding to the following RAIs:

1. GL is intended for addressing all modes and all operating conditions, and it is not limited to events and accidents evaluated in the UFSAR. Please confirm that all subject systems are evaluated for all modes and all operating conditions. Justify why CVCS is not included in the subject systems. (Page 1, 21)
2. Please provide a summary of Technical Requirements Manual/ Technical Requirements Bases section similar to NUREG -1431 SR 3.5.2.3 and LCO 3.6.6. Confirm that these TRM requirements are currently implemented and provide the results of this approach for the subject systems. (Page 8) 3. Please summarize the methodology and applicable limits for gas accumulation in the discharge piping of the LHSI (RHR) and ICS systems for Kewaunee. (Page 13)
4. DEK performed calculations to identify the maximum potential void volumes at local high point locations and in valve bonnets in the SI, RHR and ICS systems. (Page 15)

Please summarize the results of these calculations and how it is going to be used for future modifications.

5. Please demonstrate that adequate NPSH margin exist when air ingestion effects are considered in the revised calculations for SI, RHR and ICS pumps and also provide the revised calculations.

(Page 15)

6. Please summarize the following procedures briefly:
a. Fill and vent procedures with acceptance criteria to assure that piping is sufficiently full after system fill and vent activity. Also provide the details of confirmatory testing followed by fill procedures. (Page 23/24)
b. The procedures for periodic monitoring for gas accumulation at Kewaunee. Discuss future modifications to allow monitoring in the locations which are currently inaccessible and other compensatory measures as part of monitoring program. Justify that quarterly monitoring would be adequate to assure operability of the subject systems. (Page 36)
c. Revised In-service testing procedures to provide dynamic sweeping as part of the filling of the systems where needed to assure systems are sufficiently full. (Page 43)
d. Discuss various surveillance procedures applicable to subject systems.
7. Please summarize briefly the resolution of completed corrective actions as identified in Section II, A and B of the submittal as appropriate and identify any adverse conditions that were discovered. (Page 41-43)
8. Training was not identified in the GL but it is considered to be a necessary part of applying procedures and other activities when addressing issues identified in the GL.

Please discuss training briefly.

If you so desire, you may set up a conference call with me to clarify, revise, or otherwise discuss the above questions. We request your formal response by 9/25/09, unless we agree on a different target date.

Peter S. Tam , Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Tel. 301-415-1451

E-mail Properties Mail Envelope Properties (C56E360E9D804F4B95BC673F886381E71FBC23C75A)

Subject:

Kewaunee - Draft RAI on Response to GL 2008-01 (TAC MD7896)

Sent Date: 7/30/2009 7:38:32 AM Received Date: 7/30/2009 7:38:00 AM From: Tam, Peter

Created By: Peter.Tam@nrc.gov

Recipients:

craig.d.sly@dom.com (Craig D Sly)

Tracking Status: None jack.gadzala@dom.com ('Jack Gadzala')

Tracking Status: None thomas.l.breene@dom.com (Thomas L Breene)

Tracking Status: None Kulin.Desai@nrc.gov (Desai, Kulin)

Tracking Status: None

Post Office:

HQCLSTR02.nrc.gov

Files Size Date & Time

MESSAGE 15452 7/30/2009

Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False

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