ML100750685

Request for Additional Information, Extended Power Uprate

ML100750685
Person / Time
Site:	Point Beach
Issue date:	03/25/2010
From:	Justin Poole Plant Licensing Branch III
To:	Meyer L Point Beach
Poole Justin/DORL/LPL3-1/ 301-415-2048
References
TAC ME1044, TAC ME1045
Download: ML100750685 (4)

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Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241-9516

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION FROM FIRE PROTECTION BRANCH RE: EXTENDED POWER UPRATE (TAC NOS. ME1044 AND ME1045)

Dear Mr. Meyer:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 7, 2009, as supplemented by letters dated September 11 and October 9, 2009 (Agencywide Documents Access and Management System Accession Nos. ML091250564, ML092570205, and ML092860098), FPL Energy Point Beach, LLC, submitted a request to increase each unit's licensed core power level from 1540 megawatts thermal (MWt) to 1800 MWt reactor core power, and revise the technical specifications to support operation at this increased core thermal power level.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on March 16, 2010, it was agreed that you would provide the additional information within 30 days of the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2048.

Justin C. oole, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 Fire Protection RAI #1 In RS-001, Revision 0, Review Standard for Extended Power Uprates (EPUs), Attachment 1 to Matrix 5, "Supplemental Fire Protection Review Criteria," states that "Power uprates typically result in increases in decay heat generation following plant trips. These increases in decay heat usually do not affect the elements of a fire protection program related to (1) administrative controls, (2) fire suppression and detection systems, (3) fire barriers, (4) fire protection responsibilities of plant personnel, and (5) procedures and resources necessary for the repair of systems required to achieve and maintain cold shutdown. In addition, an increase in decay heat will usually not result in an increase in the potential for a radiological release resulting from a fire.

However, the licensee's application should confirm that these elements are not impacted by the extended power uprate."

The NRC staff note that license amendment request (LAR) 261, Attachment 5, Section 2.5.1.4.2.

"Technical Evaluations", on page 2.5.1.4-5, specifically addresses only items (1) and (4) above.

Provide statements to address items (2), (3), and (5).

Fire Protection RAI #2 LAR 261, Attachment 5, Section 2.5.1.4.2. "Technical Evaluations", on page 2.5.1.4-7, states that, "...The [Fire Protections Evaluation Report] FPER also addresses all required aspects of Separation Criteria for Safe Shutdown Capability. The separation criterion is not affected by the EPU unless a modification is created. As such, the modification process will control the changes to the alternative/dedicated or backup shutdown capability.

Other than modifications to the plant, governed by processes which assess the effect on Fire Protection Program, EPU does not affect the alternative shutdown methods. Modifications required as a result of EPU that modify the function of any mechanical component in the alternative safe shutdown flow paths, modify any components or circuits that provide power, control, or indication to components required for alternative safe shutdown, or introduce any plant equipment failure modes which will affect the ability to achieve any of the alternative shutdown functions, will be addressed as part of the plant modification process... "

It is unclear to the NRC staff whether there are fire protection program plant modifications planned (e.g., adding new cable trays, or re-routing of existing cables, or increases in combustible loading affecting fire barriers rating, or changes to administrative controls) at EPU conditions. Clarify whether this request involves plant modifications, or changes to the fire protection program, including any proposed modifications to implement transition to Title 10 "Energy" of the Code of Federal Regulations (10 CFR) 50.48(c). The NRC staff requests the licensee to identify proposed modifications, if any, and discuss the impact of these modifications on the plant's compliance with the fire protection program licensing basis, 10 CFR 50.48, or applicable portions of 10 CFR 50, Appendix R.

Enclosure

- 2 Fire Protection RAI #3 LAR 261, Attachment 5, Section 2.5.1.4.2. "Technical Evaluations", on page 2.5.1.4-11, states that, "... EPU Evaluation: The probability of a spurious [safety injection] SI pump start or spurious [containment spray] CS initiation is unchanged for EPU operations and the time required for mitigating actions as stated above is not changed. Pending LAR 241 (ML083450683) discusses modifications to the controls of these pumps and throttling the pump discharges, which may increase the time permissible prior to unacceptable consequences... "

The NRC staff notes that the LAR 241 evaluation has not yet been completed. To address the possible case where the Nuclear Regulatory Commission (NRC) disapproves LAR 241, discuss how results of LAR 241 would impact the fire protection program at the EPU conditions.

Further, the NRC staff notes that this request is based on a deterministic evaluation, not a probabilistic one; therefore, explain (1) the relevance of the probability of a spurious SI pump start or spurious CS initiation and (2), if relevant, why the probability and the time required for mitigating actions are unchanged for EPU operations.

Fire Protection RAI #4 LAR 261, Attachment 5, Section 2.5.1.4.2. "Technical Evaluations", on page 2.5.1.4-12, states that, "... EPU Evaluation: The time to [steam generator] SG dryout in case of a spurious opening of an SG [atmospheric dump valve] ADV has been verified for EPU to remain between 14 and 49 minutes, depending upon the unit involved and initial conditions and the time due to conservative assumptions in the original analysis... "

At EPU conditions with higher decay heat, why does the time to SG dryout in case of a spurious opening of an SG ADV still remain between 14 and 49 minutes. For example, was the original evaluation based on a range of possible conditions sufficiently conservative so as to bound even the range now possible under EPU conditions? Discuss how the assumptions in the original analysis remain valid for EPU conditions.

Fire Protection RAI #5 Some plants credit aspects of their fire protection system for other than fire protection activities, e.g., utilizing the fire water pumps and water supply as backup cooling or inventory for non primary reactor systems. If the Point Beach Nuclear Plant (PBNP) Units1 and 2, credits its fire protection system in this way, the EPU LAR should identify the specific situations and discuss to what extent, if any, the EPU affects these "non-fire-protection" aspects of the plant fire protection system. If the PBNP Units1 and 2, do not take such credit, the NRC staff requests that the licensee verify this as well.

March 25, 2010 Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241-9516

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION FROM FIRE PROTECTION BRANCH RE: EXTENDED POWER UPRATE (TAC NOS. ME1044 AND ME1045)

Dear Mr. Meyer:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 7, 2009, as supplemented by letters dated September 11 and October 9,2009 (Agencywide Documents Access and Management System Accession Nos. ML091250564, ML092570205, and ML092860098), FPL Energy Point Beach, LLC, submitted a request to increase each unit's licensed core power level from 1540 megawatts thermal (MWt) to 1800 MWt reactor core power, and revise the technical specifications to support operation at this increased core thermal power level.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on March 16, 2010, it was agreed that you would provide the additional information within 30 days of the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2048.

Sincerely, IRAJ Justin C. Poole, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ DISTRIBUTION PUBLIC RidsNrrLABTully Resource LPL3-1 rtf RidsNrrPMPointBeach Resource RidsNrrDorlLpl3-1 Resource Nlqbal, NRR RidsRgn3MailCenter Resource RidsOgcRp Resource AKlein, NRR RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr Resource RidsNrrDraAfpb Resource ADAMS Accession Number: ML100750685

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DATE 03/24/10 03/22/10 03/03/10 RPascarelli 03/25/10 OFFICIAL RECORD COpy