ML092950174
| ML092950174 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/22/2009 |
| From: | Justin Poole Plant Licensing Branch III |
| To: | Jim Costedio, Flentje F, Hale S Point Beach |
| Poole Justin/DORL/LPL3-1/ 301-415-2048 | |
| References | |
| Download: ML092950174 (2) | |
Text
From:
Poole, Justin Sent:
Thursday, October 22, 2009 9:46 AM To:
'Hale, Steve'; COSTEDIO, JAMES; 'Flentje, Fritzie'
Subject:
Draft - Request for Additional Information from Technical Specification Branch RE: Auxiliary Feedwater Modification
- Steve, By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 7, 2009, as supplemented by two letters dated June 17, and September 25, 2009, FPL Energy Point Beach, LLC, submitted a request to change technical specifications due to modifications to the auxiliary feedwater system (AFW). This was originally part of the extended power uprate request, but was separated out by the NRC staff.
The Technical Specification Branch has reviewed the information provided and determined that in order to complete its evaluation, additional information is required. We would like to discuss the questions, in draft form below, with you in a conference call.
This e-mail aims solely to prepare you and others for the proposed conference call. It does not convey a formal NRC staff position, and it does not formally request for additional information.
Justin C. Poole Project Manager NRR/DORL/LPL3-1 U.S. Nuclear Regulatory Commission (301)415-2048 email: Justin.Poole@nrc.gov
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DRAFT
- 1. Explain why the proposed Actions Note in TS 3.7.5 is an appropriate remedial action for inoperable AFW equipment that is normally used during plant startup.
Background:
TS 3.7.5, Auxiliary Feedwater (AFW), contains an Actions Note that states LCO 3.0.4.b is not applicable. The proposal revises this Note to state LCO 3.0.4.b is not applicable when entering Mode 1. However, no justification for this change appears to be provided in the submittal (page 1.0-28).
For comparison purposes, NUREG-1431, Revision 3.0, Standard Technical Specifications, Westinghouse Plants, contains STS 3.7.5, Auxiliary Feedwater (AFW), with a similar Actions Note that states LCO 3.0.4.b is not applicable [when entering MODE 1.] The Bases contains a reviewers note that states The LCO 3.0.4.b Note prohibits application of the LCO 3.0.4.b exception when entering MODE 1 if the plant does not depend on AFW for startup. If the plant does depend on AFW for startup, the Note should state, LCO 3.0.4.b is not applicable. This is due to the increased risk associated with entering a Mode or other specified condition in the Applicability with an AFW train inoperable. The provisions of LCO 3.0.4.b, which allow entry into a Mode or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
Section 2.5.4.5 of the Attachment 5 submittal (page 2.5.4.5-5) discusses the AFW system and states The auxiliary feedwater system has no functional requirements during normal, at power, plant operation. It is used during plant startup and shutdown and during hot shutdown or hot standby conditions when chemical additions or small feedwater flow requirements do not warrant the operation of the main feedwater and condensate systems.
10 CFR 50.36(c)(2)(i) states limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
Since the AFW system is used during plant startup, it is unclear why the proposed Actions Note should be permitted as a remedial action for inoperable AFW equipment.
DRAFT