NRC 2009-0105, License Amendment Request 241, Alternative Source Term, Response Clarification Request
| ML092750348 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/02/2009 |
| From: | Meyer L Point Beach |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC 2009-0105 | |
| Download: ML092750348 (10) | |
Text
October 2,2009 NEXTera TM ENERGVQ POINT BEACH 7
N RC 2009-01 05 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 License Amendment Reauest 241 Alternative Source Term Res~onse to Clarification Reauest
References:
(1)
FPL Energy Point Beach, LLC letter to NRC, dated December 8, 2008, License Amendment Request 241, Alternative Source Term (ML083450683)
(2)
FPL Energy Point Beach, LLC Letter to NRC, dated January 27,2009, Supplement to License Amendment Request 241, Transmittal of Proposed License Conditions (ML090280348).
(3)
NRC letter to NextEra Energy Point Beach, LLC, dated August 7, 2009, Point Beach Nuclear Plant, Units 1 and 2 - Request for Additional lnformation from Electrical Engineering Branch Re: Alternate Source Term (TAC Nos. ME021 9 and ME0220) (ML092150092)
(4)
NextEra Energy Point Beach, LLC letter to NRC, dated September 4, 2009, License Amendment Request 241, Alternative Source Term, Response to Request for Additional lnformation (ML092510118)
(5)
NRC electronic mail to NextEra Energy Point Beach, LLC, Draft - RAI Questions from the Electrical Engineering Regarding the Alternate Source Term Round 2, dated September 21,2009 (ML092640514)
NextEra Energy Point Beach, LLC (NextEra) submitted License Amendment Request (LAR) 241 (Reference 1) and transmitted proposed License Conditions related to LAR 241 (Reference 2),
to the NRC pursuant to 10 CFR 50.90. The license amendment would revise the current licensing basis to implement the alternative source term (AST) through reanalysis of the radiological consequences of the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR) Chapter 14 accidents.
The NRC staff determined that additional information was required via Reference (3) to enable the staff's review of the amendment request. NextEra provided responses to the request for NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241
Document Control Desk Page 2 additional information in Reference (4). In Reference (5), the NRC staff requested additional clarification for two of the responses provided in Reference (4). provides the NextEra response to the NRC staff's clarification request. provides the list of proposed AST license conditions. One additional License Condition in support of the AST LAR has been added to the list. The Plant Operating Review Committee has reviewed this change.
The information contained in this letter does not alter the no significant hazards consideration contained in Reference (1) and continues to satisfy the criteria of 10 CFR 51.22 for categorical exclusion from the requirements for an environmental assessment.
Summaw of Reaulatow Commitments The following new Regulatory Commitment is proposed:
Modifications will be completed prior to implementation of LAR-241 to reduce the limiting design basis emergency diesel generator loading on Train B to less than or equal to 2877 kW.
In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 2,2009.
Very truly yours, NextEra Energy Point Beach, LLC Larry Meyer Site Vice President Enclosures cc:
Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW
ENCLOSURE 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 241 ALTERNATIVE SOURCE TERM RESPONSE TO CLARIFICATION REQUEST The NRC staff requested additional information (Reference 1) to complete the staff's review of License Amendment Request (LAR) 241, Alternative Source Term (AST) (Reference 2).
NextEra Energy Point Beach, LLC (NextEra) provided responses to the request for additional information (RAI) via Reference 3. Electronic mail dated September 21, 2009, from the NRC staff to NextEra requested additional clarification for two of the responses provided in Reference 3. The following information is provided by NextEra in response to the NRC staff's clarification request.
Question 1 Provide additional details describing the testing of the EDGs to ensure the EDGs are capable to handle the AST loading, as provided in the response to RAI #1 (Sept 4, 2009 letter).
NextEra Response During a teleconference between NextEra and the NRC on September 22, 2009, the NRC asked whether the containment spray (CS) pumps are accounted for in the current emergency diesel generator (EDG) loading. As noted in NextEra's response to Question 1 of Reference 3, the CS pumps are currently automatically loaded on the EDGs. Therefore, the EDG loading summarized in NextEra's response to Question 2 of Reference 3 included the loads associated with the CS pumps.
Additionally, the NRC staff asked whether the current EDG load testing will address the additional loads as a result of the AST modifications. The current EDG margin and endurance testing addresses and bounds the additional loads as a result of the AST modifications as follows:
For the A Train EDGs (G-01 and G-02), margin load testing is based on the 2000-hour rating of the EDG (2850 kW) rather than the specific load. The worst case design basis accident Train A loading of 2779 kW is well within the 2000-hour rating of the Train A EDGs. This includes the 25 kW for the additional automatic loads associated with AST.
Current margin load testing is performed over a range of 2835-2970 kW at rated power factor and accounts for the additional automatic loads for AST.
For the Train B EDGs (G-03 and G-04), AST modifications will result in a net decrease in the worst case design basis accident loading. Certain non-essential loads which are currently automatically loaded will be removed. The worst case design basis accident Page 1 of 3
Train B loading considering AST loads is 2877 kW. This value supersedes the 2890 kW value provided in Reference 3. The 200-hour rating for B-train EDGs is 2951 kW. A License Condition (Enclosure 2) is proposed that requires the current margin load testing for Train B EDGs to be performed over a range of 2877-2950 kW at rated power factor.
This range will account for the automatic loads for AST. The License Condition will remain in effect until the implementation of LAR 261 (Reference 4) for Unit 1. New EDG TS were submitted for approval in Supplement 2 to LAR 261 (Reference 5).
Question 2 For the components listed in response to RAI#6, are these existing cables, motors, and motor terminations?
NextEra Response The components listed in response to Question 6 of Reference 3 that will be added to the PBNP 10 CFR 50.49 program environmental qualification (EQ) will be a combination of replacement and existing components. The EQ evaluation for these components has been completed. The results are summarized in the table below. Although the mission time for these components following design basis accidents is 30 days, the EQ qualification is based on the worst-case one year integrated post accident dose.
The addition of these components to the 10 CFR 50.49 EQ program and the installation of the replacement motors and cables are being implemented as part of the AST modifications.
Addition of the components to the 10 CFR 50.49 EQ program ensures that they are qualified for design basis accident harsh environmental conditions.
Replacement Qualification Power cables for exhaust stack fan motor Replacement 1. 1 6 ~ 1 0 ~
(W-2 1 A-M)
Power cables for exhaust stack fan motor Replacement 1. 1 6 ~ 1 0 ~
(W-21 B-M)
Page 2 of 3 Exhaust filter fan motor (W-30A-M) and motor terminations Exhaust filter fan motor (W-BOB-M) and motor terminations Power cables for W-30A-M and W-30B-M Power and control cables for control room recirculation fan motor (W-13B1 -M)
Replacement P
Replacement Existing Existing Power and control cables for control room Existing P
1x105 1. 1 6 ~ 1 0 ~
1. 1 6 ~ 1 0 ~
P 1. 1 6 ~ 1 0 ~
2x1 o7 3.89~1 o7 3.89~1 o7 3.89~1 o7 1x105 1. 1 6 ~ 1 0 ~
1. 1 6 ~ 1 0 ~
4. 3 ~ 1 0 ~
3.89~1 o7
References (1)
NRC letter to NextEra Energy Point Beach, LLC, dated August 7,2009, Point Beach Nuclear Plant, Units 1 and 2 - Request for Additional lnformation from Electrical Engineering Branch Re: Alternate Source Term (TAC Nos. ME0219 and ME0220)
(2)
FPL Energy Point Beach, LLC letter to NRC, dated December 8, 2008, License Amendment Request 241, Alternative Source Term (ML083450683)
(3)
NextEra Energy Point Beach, LLC letter to NRC, dated September 4, 2009, License Amendment Request 241, Alternative Source Term, Response to Request for Additional Information (ML092510118)
(4)
FPL Energy Point Beach, LLC letter to NRC, dated April 7, 2009, License Amendment Request 261, Extended Power Uprate (ML091250564)
(5)
NextEra Energy Point Beach, LLC letter to NRC, dated June 17,2009, License Amendment Request 261 Supplement 2, Extended Power Uprate (ML091690087)
Page 3 of 3
ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 241 ALTERNATIVE SOURCE TERM RESPONSE TO CLARIFICATION REQUEST PROPOSED LICENSE CONDITIONS TO APPENDIX C FOR OPERATING LICENSES DPR-24 AND DPR-27 4 Pages Follow
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE DPR-24 NextEra Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:
Amendment Addltlonal Conditions Implementation w
rn NextEra Enerav Point Beach will modifv the PBNP control room (CR) radi at io n s h ~ e
' Id' ~ n a to ensure CR habitabilitv reauirements are maintained.
This modification is scheduled to be comaleted followina Nuclear Reaulatory Commission (NRC) approval of LAR 241. "Alternative Source Term." duri~q the Unit 1 (201 0) refuelina outaae.
NextEra Enerav Point Beach will modifv the containment sprav (CS) and resid ua I he at removal (RHR) svstems to provide thr o ttl in a c aaa bili tv o f CS an d RHR durina the emeraencv core coolina svstem (ECCS) recirculation phase.
These modifications will be completed on a unit-saecific basis at the next Unit 1 (2010) refuelina outaae.
NextEra Enerav Point Beach will revise PBNP Emeraencv Operating Procedures (EOPs) to direct continued containment sarav while on sump recircul ion. p approval of LAR 241. "Alternative Source Term." and followina the completion of chuni-ecific' odifications to provide throttlina capability durina the ECCS recirculation ahase.
NextEra Enerav Point Beach will modifv the control room emeraencv filtration svstem (CREFS) to create a new alianment for the accident mode that provides a combination of filtered outside air and filtered recirculation air. The mod~f~cat~ons
.. will include redundancv for all CREFS active components that mu p r
on loss of off s' rte power in conjunction with a containment isolation or hiah con rol room r d
source for h RE d
modific io ill be c d*
11 rnative Source Term." durina the second site refuelina outaae that completes installation of the CS and RHR svstem modifications to provide throttlina ca~abilitv durina the ECCS recirculation phase. thus completing installation for both units.
NextEra Enerav Point Beach will modifv the primarv auxiliarv buildina (PAB) ventilation svstem (VNPAB) to ensure redundancv of active comaonents needed to operate the PAB exhaust svstem. VNPAB comoonents
.. credited for AST will be upqr a ded t o a n auamented aualitv status. No credlt IS taken bv AST for the PAB charcoal filters. NextEra Enerav-e PBNP EOPs to address startina the VNPAB fans. This modification is S s lear Reaulatorv Com approval of LAR 241. "Alternative Source Term." durina the Unit 1 (2010) refuelina outaae.
Point Beach Unit 1 Amendment No. 22%
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE DPR-24 NextEra Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:
Amendment Add~tlonal Condlt~ons Implementatior-t Number Date NextEra Enerav Point Beach. LLC will perform Train B Emeraency Diesel Generator load testina over a ranae of 2877 to 2950 kW at rated Dower factor followina implementation of LAR-241 in accordance with the testina schedule. This license condition will remain in effect until implementation of LAR-261 for Unit 1, Point Beach Unit 1 Amendment No. 2-28
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE DPR-27 NextEra Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:
Amendm en1 A dditional Conditions Jmplementation Number I2Bk2 NextEra
.. Enerav Point Beach will modifv the PBNP control room (C R) r?ad~atlon shieldina to ensure CR hab~tabll~tv requirements are ma This mod~f~cation intained.
is scheduled to be completed followina Nuclear Reaulatory R
s u
m I1 the Unit 1 (2010) refuelina outaae.
NextEra Enerav Point Beach will modifv the containment sorav (CS) and residual heat removal (RHR) svstems to orovide throttlina capabilitv of CS and RHR durina the emeraencv core coolina svstem (ECCS) re These circulation ohase.
modifications will be completed on a unit-soecific basis at the next Unit 2 (2009) refuelina outaae..
NextEra Enerav Point Beach will revise PBNP Emeraencv Ooerating Procedures (EOPs) to direct continued containment sprav while on sumo recirculation. These orocedure chanaes will be implemented followina NRC approval of LAR 241. "Alternative Source Term." and followina the comoletion of each unit-specific installation of the CS and RHR svstem modifications to provide throttlina capabilitv durina the ECCS recirculation phase.
svstem (CREFS) to create a new alianment for the accident mode that provides a combination of filtered outside air and filtered recirculation air. The modifications will include redundancv for all CREFS active comoonents that us re osi io f m t p
t n rom their normal operatina position. and auto-start capabilitv on loss of offsite oower in coniunction with a containment isolation or hiah control room radiation sianal from an emeraencv diesel aenerator suoplied source for the CREFS fans required for the new svstem alianment. This modification will be comoleted followina NRC aoproval of LAR 241.
"Alternative Source Term." durina the second site refuelina outaae that comoletes installation of the CS and RHR svstem modifications to orovide throttlina caoabilitv durina the ECCS recirculation ohase. thus comoleting
~nstallation for both units.
1 1
ventilation svstem (VNPAB) to ensure redundancv of active comoonents e the PAB exhaust svstem. VNPAB comoonents credited fo needed to operat r
AST will be uparaded to an auamented aualitv status. No credit is taken by AST for the PAB charcoal filters. NextEra Enerav Point Beach will revise PBNP EOPs to address startina the VNPAB fans. This modification is scheduled to be completed followina Nuclear Reaulatorv Commission iNRCI approval of LAR 241. "Alternative Source Term." durina the Unit 1 (201 0) refuelina outam Point Beach Unit 2 Amendment No. 2%
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE DPR-27 NextEra Energy Point Beach, LLC shall comply with the following conditions and the schedules noted below:
Amendment Additional Cond~tions.
Implementation Number
&Zi&
NextEra Enerav Point Beach. LLC will perform Train B Emeruencv D '
e t
W w with the test ina schedule. This license condition will remain In effect untll implementation of LAR-261 for Unit 1.
Point Beach Unit 2 Amendment No. 283