NRC 2009-0125, License Amendment Request 261 Re Extended Power Uprate, Response to Request for Additional Information on Auxiliary Feedwater System

License Amendment Request 261 Re Extended Power Uprate, Response to Request for Additional Information on Auxiliary Feedwater System

ML093270079
Person / Time
Site:	Point Beach
Issue date:	11/20/2009
From:	Meyer L Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC 2009-0125
Download: ML093270079 (4)

Text

POINT BEACH November 20,2009 NRC 2009-0125 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 261 Extended Power U ~ r a t e Response to Reauest for Additional lnformation

References:

(1) FPL Energy Point Beach, LLC letter to NRC, dated April 7,2009, License Amendment Request 261, Extended Power Uprate (ML091250564)

(2) NRC letter to NextEra Energy Point Beach, LLC, dated November 6, 2009, Point Beach Nuclear Plant, Units 1 and 2 - Request for Additional lnformation From Technical Specifications Branch Re:

Auxiliary Feedwater (TAC Numbers ME1081 and ME1082)

(ML093060301)

NextEra Energy Point Beach, LLC (NextEra) submitted License Amendment Request (LAR) 261 (Reference I ) to the NRC pursuant to 10 CFR 50.90. The proposed amendment would increase each unit's licensed thermal power level from 1540 megawatts thermal (MWt) to 1800 MWt, and revise the Technical Specifications to support operation at the increased thermal power level.

Via Reference (2), the NRC staff determined that additional information is required to enable the staff's continued review of the request. Enclosure 1 provides the NextEra response to the NRC staff's request for additional information.

This letter contains no new Regulatory Commitments and no revisions to existing Regulatory Commitments.

The information contained in this letter does not alter the no significant hazards consideration determination contained in Reference (1) and continues to satisfy the criteria of 10 CFR 51.22 for categorical exclusion from the requirements of an environmental assessment.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 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 November 20,2009.

Very truly yours, NextEra Energy Point Beach, LLC JJ-.4-Site Vice President Enclosure 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 261 EXTENDED POWER UPRATE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION The NRC staff determined that additional information is required (Reference 1) to enable the Technical Specifications Branch to complete its review of the auxiliary feedwater system portion of License Amendment Request (LAR) 261, Extended Power Uprate (EPU) (Reference 2). The following information is provided by NextEra Energy Point Beach, LLC (NextEra) in response to the NRC staff's request.

Explain why the proposed Actions Note in Technical Specification (TS) 3.7.5 is an appropriate remedial action for inoperable auxiliary feedwater (AFW) equipment that is normally used during plant startup.

Background:

TS 3.7.5, Wuxiliary Feedwater (AFW)," contains an Actions Note that states limiting condition for operation (LCO) 3.0.4.b is not applicable. The proposal revises this Note to state LC0 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

[STS], Westinghouse Plants," contains STS 3.7.5, "Auxiliary Feedwater (AFW), " with a similar Actions Note that states LC0 3.0.4.b is not applicable [when entering MODE I.] The Bases contains a reviewer's note that states "The LC0 3.0.4.b Note prohibits application of the LC0 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, 'LC0 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 LC0 3.0.4.bJ which allow entry into a Mode or other specified condition in the Applicability with the LC0 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."

The regulation at 10 CFR 50.36(c)(Z)(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 Page 1 of 2

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.

NextEra Response As identified in the question above, the following statement regarding the auxiliary feedwater (AFW) system is presented on Page 2.5.4.5-5 of the EPU LAR:

"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."

This statement is in the EPU LAR as part of the Point Beach Nuclear Plant (PBNP) description of the current licensing basis for the AFW system.

This licensing basis will change with implementation of modifications to the AFW system. With the new AFW system, the standby steam generator (SSG) pumps will be utilized for normal startup and shutdown. The SSG pumps are the former shared 480 V AC motor-driven auxiliary feedwater (MDAFW) pumps. These pumps are being retained after installation of the new unitized MDAFW pumps and 4160 V AC motors.

Since the SSG pumps will be used for normal startups and shutdowns following implementation of the AFW system modifications, the AFW pumps will not normally be relied upon for startup.

Accordingly, the Technical Specification 3.7.5 associated note for the provisions of LC0 3.0.4 applies only to entry into MODE 1 per the guidance provided in NUREG-1431, Revision 3, Volume 1.

References (1) NRC letter to NextEra Energy Point Beach, LLC, dated November 6, 2009, Point Beach Nuclear Plant, Units 1 and 2 - Request for Additional Information From Technical Specifications Branch: Re: Auxiliary Feedwater (TAC Numbers ME1081 and ME1082)

(ML093060301)

(2) FPL Energy Point Beach, LLC letter to NRC, dated April 7, 2009, License Amendment Request 261, Extended Power Uprate (ML091250564)

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