ML12044A052

Pre-application Conference Call to Plan for Processing a Change to TS 3.8.4 DC Sources

ML12044A052
Person / Time
Site:	Duane Arnold
Issue date:	02/08/2012
From:	Feintuch K Division of Operating Reactor Licensing
To:	Matthew Mcconnell, Byrne T, Feintuch K Florida Power & Light Co, NextEra Energy Duane Arnold, Office of Nuclear Reactor Regulation
References
Download: ML12044A052 (6)

Text

{{#Wiki_filter:1 NRR-PMDA-ECapture Resource From:Feintuch, Karl Sent: Wednesday, February 08, 2012 3:56 PM To: Feintuch, Karl; McConnell, Matthew; Byrne, Thomas

Subject:

Duane Arnold Energy Center -Pre-application conference call to plan for processing a change to TS 3.8.4 DC Sources <ae> Attachments: oledata.mso; TS 3.8.4 markup.pdfThe conference call started at 3:30 PM and ended at 3:45 PM ET on 2/8/2012 Attending were: For NRC: Feintuch, McConnell For DAEC: Thomas Byrne, Dennis Pint, Steve Catron

Contemplated changes were discussed (see notes below). For planning purposes, DAEC (Byrne) will notify Karl Feintuch of the projected date of issuance of the amendment application. Karl Feintuch USNRC 301-415-3079

From: Feintuch, Karl Sent: Wednesday, February 08, 2012 1:00 PM To: 'Thomas.Byrne@nexteraenergy.com' Cc: McConnell, Matthew

Subject:

Pre-Application review - Notes for TS 3.8.4 DC Sources - TS change discussion Based on our (Catron, Byrne, Feintuch) phone conversation on 2/6/2012, I prepared these notes for Reviewer McConnell. They would color his perceptions in participating in the call scheduled for today. Please review them with the objective of clarifying or correcting what I wrote so all parties accurately understand what your are attempting. An accurate version of the notes will be a record of the call. (Undetected errors remain mine.)

Karl Feintuch USNRC 301-415-3079

================ begin notes ===========

Below is a challenge from Duane Arnold.

I requested this summary (below and attached) as the result of a call from Duane Arnold's licensing manager (Steve Catron) this afternoon. They have a project to increase the number of battery cells for the Division 1 and 2 -125 VDC batteries. However, their assigned project team did not complete the necessary calculation to support a licensing amendment until after the deadline for our one year metric, relative to their next refueling outage. Now it is a matter of practicality to accomplish the needed licensing amendment within our resources. I will list the constraints below that I drew from this first conversation and suggest a follow-up conversation to see if we can be responsive. Details follow as I know them at this time. I can open a pre-application review TAC if a cursory review of the licensee's impending application is encouraging.

1 - TS Changes to be requested: See attached TS pages 3.8-17, 3.8-18, and 3.8-19, as marked by hand. 2 - Reason for change: Increase capacity for Design Basis Accident and Fukushima response. 3 - Physical change: Add two cells to each 125 VDC source. 24 - Physical change schedule: Add cells during fall refueling outage (nominal 10/06/2012 to 12/06/2012); physically install the cell but not connect them without the amendment. 5 - Amendment issuance requested by: First week in December 2012 (corresponding to nominal 12/06/2012 end of outage.) 6 - Planned date to submit application: mid to late February 2012. 7 - Inferred [by PM] "SE to PM" date for issuance in Dec.2012: Late October to Early November 2012 [ We (DORL) typically need 6 weeks to issue the letter, and I am presuming seasonal stresses due to confluence of holidays, excess leave to be taken, rush because of end-of-year deadlines - kdf] 8 - Effective number of full months for Tech Branch to produce SE Memorandum

8 months = full March thru most of, or full, October 2012. 9 - Implementing strategy for issuance of SE Memorandum within 8 full months

A - Apply LIC-109 processes such that (1) the application is "perfect" (no RAI items are needed - for the entire project) or (2) RAI cycle time(s) are 7 calendar days throughout the entire project. These accelerated cycle times would be the "as mutually agreed" times that supersede the default 30 day intervals. [Make allowance for other compelling circumstances.- kdf 2/8/2012] B - Recommend an OGC Reviewer very experienced with TS 3.8.4 reviews.

C - Perceived benefit-to-cost: Benefit = Application of 9A and 9B can save about 2 months of processing time; if this strategy is practical for EEEB, then we brief the licensee on the Benefit to Cost considerations for achieving project goals. The licensee is expediting the application effort at this time. I believe that EEEB and ITSB are the only cognizant Technical Branches for this TS change.

Karl Feintuch

========== begin Duane Arnold TS 3.8.4 change executive summary ================

From: Byrne, Thomas [1] Sent: Monday, February 06, 2012 3:17 PM To: Feintuch, Karl Cc: Catron, Steve

Subject:

DAEC Summary of Amendment Request for TS 3.8.4, DC Sources Karl: The proposed amendment we discussed today would revise the DAEC TS by modifying existing Surveillance Requirements (SRs) regarding the battery terminal and charger voltages and amperage provided in SR 3.8.4.1 and SR 3.8.4.6. This amendment also deletes the one-time allowance provided in Amendment 247 (granted in 2002) to allow for online battery replacement. I figured I'd clean up the TS by removing this one-time allowance. See the attached pages for a markup of what will change. We're interested in getting approval by the first week of December 2012 if possible. Let me know if you require further information. Tom Thomas R. Byrne Thomas.Byrne@nexteraenergy.com Senior Licensing Engineer Duane Arnold Energy Center (319) 851-7929

==== end Duane Arnold TS 3.8.4 change executive summary ======

3 ======== end notes ===========}}