ML100890513

Summary of Meeting with FPL Energy Point Beach, LLC, on Outstanding Issues and Schedule Changes to the Alternate Source Term, Extended Power Uprate, and Auxiliary Feedwater Amendment Reviews

ML100890513
Person / Time
Site:	Point Beach
Issue date:	05/20/2010
From:	Justin Poole Plant Licensing Branch III
To:
Poole Justin/DORL/LPL3-1/ 301-415-2048
References
TAC ME0219, TAC ME0220, TAC ME1044, TAC ME1081, TAC ME1082, TAC NE1045
Download: ML100890513 (31)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 20, 2010 LICENSEE:

FPL Energy Point Beach, LLC FACILITY:

Point Beach Nuclear Plant, Units 1 and 2

SUMMARY

OF JANUARY 27,2010, MEETING WITH FPL ENERGY POINT BEACH, LLC, ON OUTSTANDING ISSUES AND SCHEDULE CHANGES TO THE ALTERNATE SOURCE TERM, EXTENDED POWER UPRATE, AND AUXILIARY FEEDWATER AMENDMENT REVIEWS (TAC NOS. ME0219, ME0220, ME1044, ME1045, ME1081, AND ME1082)

On January 27,2010, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of FPL Energy Point Beach, LLC, at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss the outstanding issues on the Alternative Source Term (AST),

Extended Power Uprate (EPU), Auxiliary Feedwater (AFW) amendments. Also, the licensee planned to discuss a change in schedule and how this was to effect these reviews.

A list of attendees is attached as Enclosure 1. The licensee presentation is attached as.

Discussion The licensee started off the presentation by talking about their revised implementation schedules for the AST and EPU amendment request. The licensee stated that following the fall 2009 outage on Unit 2, they re-evaluated their implementation schedules and realized they could no longer be met. During the fall 2009 outage, a number of modifications and improvements were made, but the work took longer than planned, specifically on the AFW modifications. The new schedule will conduct work on Unit 1 over an additional cycle, and Unit 2 is now scheduled to be the lead unit. The licensee is now requesting that the NRC staff complete the AST, AFW, non-conservative setpoints, and EPU amendments on a schedule to support implementation during the spring 2011 outage on Unit 2. The licensee stated although they do not need the AST, AFW, and non-conservative setpoint amendments prior to spring of 2011, they would like the ability to implement these, if possible, prior to this outage to resolve long standing safety issues. The NRC staff agreed these items will continue to be worked on a schedule that would allow irnplementatic-i prior to the spring 2011 outage.

The next portion of the meeting focused on the AST amendment and the licensee's proposed responses to Requests for Additional Information (RAls) from the NRC staff. The licensee presented a draft version of proposed technical specifications (TSs) to the control room emergency filtration system (CREFS) system. The NRC staff mentioned that for one portion of the proposed TSs, the licensee still had not resolved the NRC staff's concern that the TS allowed for the possibility of the CREFS system being out of service during an accident with no compensatory measures in place. Following the discussion that took place between the licensee and the NRC staff, the licensee said they now understood the NRC staff's concern and would incorporate that into their formal response.

- 2 Following the discussion on AST, the meeting moved on to discuss outstanding issues with the AFW review. The first part of the AFW discussion was focused on RAI questions issued to the licensee by the NRC Electrical Engineering Branch. The licensee discussed how they intended to answer these questions. The NRC staff provided some clarifying feedback. The remainder of the AFW discussion focused on the staff asking clarifying questions on the systems design, mostly dealing with the service water suction cross over.

A member of the public was in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-2048, or Justin.Poole@nrc.gov.

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

Enclosures:

1. List of Attendees

2. Licensee Handout cc w/encls: Distribution via Listserv

LIST OF ATTENDEES FOR MEETING WITH POINT BEACH NUCLEAR PLANT REGARDING EPU/AST/AFW FOR UNITS 1 AND 2 NAME TITLE ORGANIZATION Stanley Gardocki Reactor System Eng.

NRC/DSS/BOP Harold Walker Sr. Reactor System Engr.

NRC/DSS/SCVB Nageswara R. Karipineni Reactor Systems Eng.

NRC/DSS/SCVB Bruce Heida Reactor System Eng.

NRR/DSS/SCVB Kamal Manoly Sr. Technical Advisor DE/NRR Benjamin Parks Reactor Systems Engr.

NRR/DSS/SRXB Samuel Miranda Reactor Systems Engr.

NRRIDSS/SRXB Alexander Tslriqotis Mech. Engineer NRRIDE/EMCB Meena Khanna Branch ChieflDE/EMCB NRRIDE/EMCB Edward Smith Reactor Enqr.

NRRIDSS/SNPB Evan Davidson General Eingineer NRRIDSS/SNPB Greg Casto Branch Chief, Bal. of Pit NRRIDSS/SBPB Subinoy Mazumdai EICB Engineer NRR/DE/EICB Samir Darbali I&C Engineer NRRIDE/EICB Dylanne Duvigneaud Reactor Engineer NRRIDR/AADB Danielle Burgoyne Nuclear Specialist American Electric Power Tom Alexion Sr. Proiect Manager NRC/NRR/DPR G. Singh Matharu Sr. Elect. Eng.

NRC/NRR/DE/EEEB Gerald Waig Sr. Reactor Sys Eng.

NRRIDIRS/ITSB James Connolly FPL-St. Lucie EPU LAR Mgr.

FPLlSt. Lucie Jim Peschez FPL & NextrEra Energy Licensing Manager FPLlNextEra Aleem Boatright Nuclear Engineer NRRIDRNAADB Justin Poole Project Manager NRRIDORULPL3-1 Robert Pascarelli Branch Chief NRR/DORULPLlII-1 ENCLOSURE 1

Point Beach Extended Power Uprate Alternate Source Term NRC Meeting January 27, 2010

Point Beach - Agenda

• Opening

• Purpose

• Alternate Source Term (AST) and Extended Power Uprate (EPU) Schedules

• AST Ventilation System Technical Specifications

• Electrical Branch Auxiliary Feedwater (AFW) RAI Response Clarifications

• BOP Branch RAI Response Clarifications

• Clarifying Questions Related to AFW and Reactor Protection System/Engineered Safety Features Actuation System (RPS/ESFAS) RAls and RAI Responses

• Closing/Action Items I'JEXTera ENERGVe 2

Point Beach - Opening

• FPL has worked cooperatively and successfully with key stakeholders to make improvements at Point Beach When NextEra acquired Point Beach, we worked with NRC staff to fully understand concerns with longstanding equipment and margin issues at the site NextEra proposed a plan to address concerns and improve overall margin through EPU NextEra developed an aggressive schedule to make improvements

-- Improve design basis

-- Improve licensing basis

-- Improve overall safety margin

- We have been able to make progress where it hadn't previously been made We appreciate the support and work of the NRC staff.

f'JEXTera ENERGYfa 3

Point Beach - Opening

• The Point Beach EPU project has proven to be very complex The project team recognized that they might uncover issues that would impact the ability to achieve project milesfones The scope of the project has grown from somewhat limited to complex modifications

• Recent Unit 2 outage provided additional insight A number of modifications and improvements were made during the outage Work took longer than originally planned to ensure quality and no challenge to operational safety

• We are revising the schedule:

- NextEra will conduct work on Unit 1 over an additional cycle Will ?i!lo~ for greater organizational focus on safety improvement modifications

- Will allow more planning time for EPU modifications I'JEXrera ENERGye 4

Point Beach - Purpose

• Summarize the revised implementation schedules for the AST and EPU LARs

• Discuss potential solutions to the remaining technical issue on the AST LAR

- Proposed Auxiliary Building Ventilation (VNPAB) and Control Room Emergency Filtration (CREFS) System TSACs

• Technical Discussion Regarding Electrical Branch AFW RAI Response Clarifications

• Technical Discussion Regarding BOP Branch RAI Response Clarifications

• Provide Clarifications Regarding Other RAls and RAI Responses for AFW and RPS/ESFAS Mechanical/Civil Branch I&C Branch Tech. Spec. Branch Reactor Systems Branch 5

Point Beach - AST Schedule

• Resolve remaining technical issue January/February 2010

• Issue SE - April 2010

• Implement Spring 2011 vs. Spring 2010 (targeting end of 2010 for actual completion if possible) 6

Point Beach - EPU Schedule Non-EPU RPS/ESFAS RAls issued NextEra to identify which setpoints to be approved Need agreement on interim form of RPS/ESFAS tables before balance of EPU approved Anticipated NRC Approval - First Quarter 2010 Implement on both units within 180 days of NRC approval AFW RAls issued Technical Issues associated with Electrical Branch clarifications to RAI responses Anticipated NRC Approval - Second Quarter 2010 Will issue letter requesting approval under either current licensing basis orEPU AFW-Implement Spring 2011 vs. Spring 2010 (targeting end of 2010 for actual completion if possible) 7

Point Beach - EPU Schedule

• Balance of EPU Expedited Review Request (TS for Unit 1 Modifications) Submitted 9/09 LAR Accepted November 2009 Anticipated NRC RAls per LIC-112 - March 2010 Anticipated NRC Approval - November 2010 EPU-Implement Fall 2011 vs. Spring 2010 for Unit 1, Spring 2011 for Unit 2 (no change)

• Will issue letter withdrawing the Expedited Review Request and requesting change to schedule, commitments, and licensing conditions reflecting the above implementation schedules NEXTera ENERGY~

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Point Beach - Schedule I

NRC Time Line I

Point Beach EPU Time Line January 27,2010 12108 2: 3 4

LAR Approval Window 12/7/08 AST LAR Submitted 12/11 4/7/09 11/4/09 3/10 4/10 5/10 11/2010 EPU LAR EPU LAR NRC Approves NRC Approves NRC Approves NRC Approves Submitted Accepted Non EPU AST LAR AFW EPU LAR RPS/ESFAS Complete I AST/EPU Time Line I Unit 2 EPU Implementation 12/10 Complete AST Implementation (both units)

Complete AFW Implementation (both units)

Complete Non-EPU RPS/

Today IESFAS Implementation (both units)

Complete Unit 1 EPU Implementation f'JEXTera ENERGVe 9

Point Beach - AST Ventilation System Technical Specifications

• Auxiliary Building Ventilation System (VNPAB)

Proposed 7 day TSAC System configuration

-- See handout

-- Redundant active components

-- Certain maintenance work could require redundant portions of the system to be taken Qut of service Example: Filter Fans are located inside the plenum to the Stack Fans Maintenance

-- Filter and Stack fans, preventative maintenance every 6 months

-- Filter maintenance/testing every 18 months

-- Maintenance history past 6 years W-21A & B - 12 work orders on each, minor support modifications, fan guard repairs/adjustments, belt replacements, fan balancing, minor frame repairs W-30A & B - 6 work orders on one, 4 on the other, install vibration pads, minor duct repairs 10

Point Beach - AST Ventilation System Technical Specifications

• VNPAB Performed dose analysis without credit for VNPAB for LBLOCA

-- Using flashing fractions based on sump temperature Control Room TEDE dose is 4.2 Rem Methodology has been accepted by NRC at other sites as part of the AST licensing basis calculation

-- Using actual ECCS leakage limit and % unfiltered in-leakage test limit (bounds actual tested value)

Control Room TEDE dose is 4.3 Rem

-- Combining both of the above Control Room TEDE dose is 2.1 Rem Analysis provides basis for 7 day TSAC 11

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Point Beach - AST Ventilation System Technical Specifications Control Room Emergency Filtration System (CREFS)

Proposed 7 day TSAC System configuration

-- See handout

-- Redundant active components

-- Certain maintenance work could require redundant portions of the system to be taken out of service Maintenance

-- Emergency fans, preventative maintenance every 12 months

-- Recirculation fans, preventative maintenance every 6 months

-- Filter maintenance/testing every 18 months

-- Fan/Filter cubicle general inspection every 12 months

-- Maintenance Rule Performance over 2 year period from 10/1/07 to 9/30/09 1 Fan component failure 111 total equipment unavailable hours Analysis without credit for CREFS will result in control room doses> 5 Rem even with KI Probability of a DBE at the same time CREFS is out of service is very low 15

Point Beach - AST Ventilation System Technical Specifications

• CREFS Prepared proposed Technical Specifications

-- Reviewed Technical Specifications of other older plants with approved AST having similar Control Room ventilation system configuration as Point Beach

-- Drafted Point Beach version based on this review

-- Separate TSACs for active and passive components

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Point Beach - AST Ventilation System Technical Specifications 3.7 PLANT SYSTEMS 3.7.9 Control Room Emergency Filtration System (CREFS)

LCO 3.7.9 CREFS shall be OPERABLE with:

a. Two control room recirculation fans,

b. Two control room emergency fans,

c. One filter train

d. Two control room emergency fan control dampers, and

e. Two isolation dampers in the kitchen area exhaust duct NOTE The control room envelope boundary may be opened intermittently under administrative control.

APPLICABI L1TY:

MODES 1,2,3,4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room recirculation fan, one control room emergency fan, and/or one control room emergency fan control damper inoperable A.1 Restore inoperable fan and/or damper to OPERABLE status 7 days B. One isolation damper in the kitchen area exhaust duct inoperable B.1 Restore isolation damper to OPERABLE status OR 7 days B.2 Place and maintain the other isolation damper in the same duct in the closed position.

7 days 18

Point Beach - AST Ventilation System Technical Specifications 3.7.9 CREFS C. With the filter train inoperable for reasons other than an inoperable Control Room Envelope boundary C.1 Restore filter train to OPERABLE status 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> D. With the filter train inoperable due to an inoperable Control Room Envelope boundary D.1 Initiate actions to implement mitigating actions, and D.2 Verify mitigating actions to ensure Control Room Envelope occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, and D.3 Restore Control Room Envelope boundary to OPERABLE status Immediately 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> 90 days E. Required Action and associated Completion Time of Condition A, B, C, or D not met.

E.1. Be in MODE 3 AND 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> E.2. Be in MODE 5 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> 19

Point Beach - AST Ventilation System Technical Specifications 3.7.9 CREFS APPLICABILITY:

During movement of irradiated fuel assemblies ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room recirculation fan, one control room emergency fan, and/or one control room emergency fan control damper inoperable A.1 Restore inoperable fan and/or damper to OPERABLE status 7 days B. One isolation damper in the kitchen area exhaust duct inoperable B.1 Restore isolation damper to OPERABLE status OR B.2 Place and maintain the other isolation damper in the same duct in the closed position.

7 days 7 days C. With the filter train inoperable C.1 Suspend movement of irradiated fuel assemblies Immediately D. Required Action and associated Completion Time of Condition A, or B not met.

E.1. Suspend movement of irradiated fuel assemblies Immediately 20

Point Beach - Technical Discussion Regarding Electrical Branch RAI Response Clarifications

1.

In response to staff's RAI dated August 26, 2009, regarding the EDG voltage dip below the acceptance limit of 75 percent nominal voltage during motor start, the licensee stated that the EDGs are capable of starting safeguard loads and the voltage recovers quickly to the acceptable level. Based on staff's review of the dynamic loading calculations, the staff notes that under certain loading conditions for Train "A" EDG, the frequency is outside 2 percent margin, the worst-case voltage dip is 45-48 percent and the voltage overshoot is 129.5 percent. Train "A" voltage and frequency variations are outside the industry accepted standards and guidance Provide detailed analyses regarding the downstream effects on components such as contactors, control fuses, inverters, battery chargers, solenoids, MOVs, solid state devices, etc., and the basis to show that all required loads will start and continue to run with sufficient margins after accounting for any uncertainties. Provide justification for the performance capabilities of the EDG "A" regulator and excitation systems to support shutdown equipment within design basis requirements during a DBA. The staff notes that Train "B" EDG bus voltages remain above 75°k of nominal voltage, consistent with NRC Regulatory Guide 1.9, throughout the motor starting sequence in all postulated loading conditions. Provide a summary of all bus voltages for the 'B' train distribution system.

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Point Beach - Technical Discussion Regarding Electrical Branch RAI Response Clarifications

2.

The cables for new AFW pump motors are planned to be routed through the existing duct banks and manholes which are susceptible to moisture, wet or flooding conditions. The staff's review of Point Beach's operating experience indicates that, since 1997, numerous corrective action documents were generated to capture concerns associated with cable submergence and water ingress through underground cableways and manholes. Provide cable design specifications and manufacturer's certification to provide assurance that these cables are designed for the environment they will be subjected to. Also, provide details of the proposed initial tests and periodic tests for these cables including the type of tests and the frequency.

3.

In response to staff's RAI dated August 26, 2009, regarding EDG/loss of voltage relay time delays, the licensee stated that the EDG output breaker closure within 14 seconds is consistent with accident analysis. The staff notes that this is inconsistent with the design/licensing basis for the EDGs. Specifically, FSAR Section 8.8.1, Design Basis, states that the EDGs are required to start and be ready for loading within 10 seconds after receiving a start signal. In addition, Section 8.8.3 states that the time from receipt of start signal to EDG ready to accept load shall not exceed 10 seconds (reaches its rated speed and voltage and the associated breaker closes automatically to reenergize the safeguard buses). The staff notes that the existing EDG design (time delays for output breaker closure is 14 seconds) is inconsistent with chapter 8 design basis requirements. Explain the inconsistency and identify all the loads that are started on the safety bus at 10 seconds in accordance with Chapter 8 design basis.

I'JEXTera ENERGY~

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Point Beach - Technical Discussion Regarding Electrical RAI Response Clarifications

4.

Explain how the EDG fuel oil consumption and volume calculation accounted for additional fuel oil requirements for AFW and other plant modifications. What is the basis for removing 10Dk margin from the original fuel oil consumption calculation? Provide details on how instrument uncertainties, instrument errors, temperature effects and specific gravity variations were accounted for in the calculation?

5.

In response to staff's RAI dated August 26, 2009, regarding environmental parameters for the AFW motor location, the licensee stated that the normal radiation level is 1300 RAD for 60-year TID and the AFW pumps and associated equipment will not be included in the EQ program since they are not credited in the accident analysis although they are sequenced loads used in a LOCA. Please identify all electronic components installed in this area and the effects of these components on other safety related components if they are not qualified in accordance with 10 CFR 50.49.

NEXTera ENERG..'Ca 23

Point Beach - Technical Discussion Regarding Electrical RAI Response Clarifications

6.

In response to staff's RAI dated June 2, 2009, regarding the surveillance tests for EDGs, the licensee proposed new TS surveillance SR 3.8.1.7 requirement (the performance of a 24-hour endurance and load margin test of each EDG). The staff notes that the proposed EDG endurance and margin test does not envelop the accident loads for the entire duration of the 24-hr run. Specifically, EDGs G-01 and G-02 are loaded to 98.2% to 100.9%) of the 2000-hour load rating for ~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 90 to 1000/0 of the 2000-hour load rating for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />; G-03 and G-04 EDGs are loaded to 97.4% to 100% of the 200-hour load rating for ~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 90 to 100% of the 2000-hour load rating for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> with EDGs operating at the highest end of the 2-hour load range for 5 minutes. This is not consistent with RG 1.9 recommendations. The intent of the 24-hr test is to demonstrate that the EDG can operate at maximum postulated accident loads for extended duration. The 2-hour test requirement at a higher loading demonstrates design margins. Therefore, staff requests the licensee to provide basis why the proposed loading ranges are adequate to demonstrate the capability of the EDGs to operate for its intended mission time. Also, explain why EDGs designated for each unit cannot be tested during modes other than modes 1 and 2 as recommended in NUREG-1431.

NEXTera ENERGY~

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Point Beach - Discussion of Clarifications Related to AFW and RPS/ESFAS RAls and Responses

• BOP Branch AFW

1. Licensee establishes 25.5 seconds as the max allowable time delay for the pump to trip. Provide the details on how 25.5 seconds was determined, Include such assumptions as pump flow, volume of water in piping, any confirmation from vendor that can support their premise that no damage will be done to the pump if tripped prior to some point.

(calculation).

2. The calculation is based upon keeping the suction to the pump covered with water. However, if the pump draws down water in the pumping from where the service water ties in, then a slug of air will be introduced into the pump ahead of the service water. Maybe the calculation needs to be based on keeping the tie in covered with water.

3. Is the signal to turn off the timers the same signal to turn on? Does it take the 3 seconds for pressure to be restored in the piping after Test Switchover is actuated (18.4)? Concern is there is only a 1/2 second margin until the pump trip signal would actuate (18.9 sec). Is there any significant delay from switch actuation to cancel timer?

4. At T=O, is the calculation based upon the lowest pressure to activate the switch.

HELB 25

Point Beach - Discussion of Clarifications Related to AFW and RPS/ESFAS RAls and Responses

• Mechanical/Civil Branch AFW

• I&C Branch AFW RPS/ESFAS

• Tech. Spec. Branch AFW RPS/ESFAS

• Reactor Systems Branch LOCA Non-LOCA f\\JEXTera ENERGXe 26

Point Beach - Summary SE for AST LAR - April 2010 Pending resolution of ventilation system technical specifications SE for non-EPU RPS/ESFAS - March 2010 SE for AFW - April/May 2010 Pending resolution of electrical clarifications Balance of EPU LAR Formal RAls by March 2010 ACRS in Summer 2010 Approval in November 2010 NextEra stands ready to support the staff in its review Prompt replies to RAls, tabletops, breakout meetings, etc.

Quick identification and resolution of technical issues Site audits, access to records 27

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