ML11105A011

Withdrawal of an Amendment Request (Tac Nos. ME5775 and ME5776)

ML11105A011
Person / Time
Site:	Turkey Point
Issue date:	04/15/2011
From:	Paige J C Plant Licensing Branch II
To:	Nazar M Florida Power & Light Co
Paige J C
References
TAC ME5775, TAC ME5776
Download: ML11105A011 (4)

Text

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<t 0 ... ;;: '" April 15, 2011 flj "'" ....0****....Mr. Mano Executive Vice President Chief Nuclear Florida Power and Light P.O. Box Juno Beach, Florida TURKEY POINT UNITS 3 AND 4 -WITHDRAWAL OF AN AMENDMENT REQUEST (TAC NOS. ME5775 AND ME5776)

Dear Mr. Nazar:

By letter dated March 3, 2011, Florida Power &Light Company (FPL, the licensee) applied for an amendment to the Turkey Point, Units 3 and 4 Operating Licenses No. DPR-31 and DPR-41, respectively.

The proposed change would have modified the facility technical specifications surveillance requirements 4.8.2.1 pertaining to periodic verification of battery bank capacity and intercell and connection resistance.

While the Nuclear Regulatory Commission (NRC) staff was completing its acceptance review, three draft acceptance review questions were sent to you via email. See Enclosure for the draft acceptance review questions.

On April 5, 2011, the NRC staff and FPL held a teleconference to discuss the draft acceptance review questions.

During the call, the NRC staff categorized item 1 as an acceptance review question and items 2 and 3 as nonconservatisms identified by the staff while reviewing the application and the associated licensing basis. In its draft acceptance review questions for item 1, the NRC staff provided two options to the licensee, either, supplement the license amendment request or withdraw and resubmit.

In regards to items 2 and 3, the licensee stated during the teleconference that they would follow-up with the items by entering them into Turkey Point's corrective action program, and notify the NRC staff of its conclusions.

Subsequently, by letter dated April 13, 2011, FPL withdrew the amendment request. The purpose of this letter is to advise that the above-cited application is being treated as withdrawn.

Notice of Consideration of Issuance of the proposed amendment had not been published in the Federal Register. C. Paige, Project Manager t Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

Draft Acceptance Review Questions cc w/encl: Distribution via Listserv DRAFT ACCEPTANCE REVIEW QUESTIONS DC SOURCES SURVEILLANCE REQUIREMENTS LICENSE AMENDMENT REQUEST FLORIDA POWER & LIGHT CO. TURKEY POINT, UNITS 3 AND 4 DOCKET NOS. 50-250 AND 50-251 Deletion of measurement of battery cell connection resistances from TS (SRs 4.B.1.b.2 and c.3) and move to plant battery maintenance procedures CDBI inspection, in 200B, identified that the battery cell interconnection resistance values ::;150 micro-ohms in technical specification (TS) surveillance requirements (SRs) 4.B.1.b.2 and c.3 do not match with the values used in safety related battery voltage drop calculation.

The calculation considered much lower values of cell interconnection resistance (30-40 micro-ohms) based on plant maintenance procedures.

In the license amendment request (LAR), the licensee proposed to delete measurement of battery cell connection resistances from the TSs (SRs 4.B.1.b.2 and c.3) and move to plant battery maintenance procedures.

The licensee stated in the LAR that TS SR battery discharge and capacity demonstrate the battery is capable of meeting the design basis requirements.

The licensee cited NUREG-1431 as part of its basis for relocating the battery resistance SR criteria to a battery monitoring and maintenance program based on the parameters of IEEE Standard 450-1995.

Technical Specification Task Force (TSTF)-360, "DC Sources Rewrite," which was incorporated into NUREG-1431, was the initial step by the NRC, and the industry/utility group to collectively address DC battery SRs for disseminating between operability issues versus maintenance issues. However, after TSTF-360 was issued, many deficiencies and issues were identified (these issues and industry response can be found in meeting summaries dated July 21, 2006, Agencywide Document and Management System (ADAMS) Accession No. ML062200549 and Augusr15, 2006, ADAMS Accession No. ML062060207).

As such, the TSTF working group decided to perform a comprehensive review to resolve the past deficiencies and to incorporate the lessons learned from TSTF-360 into a new TSTF (TSTF-500).

At the same time, it was also decided to continue reviewing the in-house amendment requests at that time. Since the TSTF working group initiated the TSTF-500, the Nuclear Regulatory Commission (NRC) staff has not approved any amendment requests based on TSTF-360 (Le., NUREG-1431).

This includes not approving the relocation of battery resistance measurements (see recent precedents for Catawba/McGuire, Cooper, and Wolf Creek). Furthermore, TSTF-360 and 500 were both written from a holistic standpoint and were not intended to allow partial implementation.

The NRC staff review finds that the amendment request does not contain sufficient information based on the above referenced past precedents.

Based on the above, the NRC staff finds this portion of the license amendment request unacceptable with the opportunity to supplement.

Therefore, the licensee can either supplement the amendment request to provide specific battery resistance values (in lieu of relocating to a administrative program) or withdraw and

-2 resubmit the license amendment request in accordance with TSTF-500 (when approved).

Currently, TSTF-500 is in the review stage and is expected to be issued by the middle of 2011. TS SR 4.8.2.1.e reads: "At least once per 18 months during shutdown**, by giving performance discharge tests ...... " While reviewing the subject LAR, the NRC staff identified that TS SR 4.8.2.1.e provides a surveillance requirement of 18 months instead of 12 months for completing the performance discharge tests. It is the NRC staff's position that SR 4.8.2.1.e should be consistent with industry standard IEEE 450-1995 Section 5.2.c which recommends "Annual performance tests of battery capacity should be made on any battery that shows signs of degradation or has reached 85% of the service life expected for the application.

Degradation is indicated when the battery capacity drops more than 10% from its capacity on the previous performance test, or is below 90% of the manufacturer's rating." The NRC staff requests that you provide the technical basis for why an18 month surveillance requirement is acceptable as opposed to "at least once per 12 months." 3. Service and Performance Tests Duration According to the Final Safety Analysis Report (Section 8.2.2.3.1): "Each battery has been sized to support operation of its required loads for two hours without terminal voltage falling below its minimum required value. The capability of the safety related batteries to provide required power is demonstrated by the performance of 30 minute service and performance tests in accordance with the plant's Technical Specifications.

This service testing time of 30 minutes is conservatively based on the time required to manually load a charger during a station blackout event." According to the LAR (Page 9 of the enclosure): "Each battery shall be sized to provide power to its loads for two hours during a design basis accident concurrent with a Loss of Offsite Power (LOOP) ... " It is the NRC staff's position that the service test duration should match the designed duty cycle (two hours) of safety-related loads. The performance discharge test to verify the battery capacity is typically more than 30 minutes. Provide justification why the service test is not performed for two hours to match the designed duty cycle of safety-related loads of batteries.

Provide justification for duration of the performance discharge test to verify the battery capacity.

April 15, 2011 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 TURKEY POINT UNITS 3 AND 4 -WITHDRAWAL OF AN AMENDMENT REQUEST (TAC NOS. ME5775 AND ME5776)

Dear Mr. Nazar:

By letter dated March 3, 2011, Florida Power &Light Company (FPL, the licensee) applied for an amendment to the Turkey Point, Units 3 and 4 Operating Licenses No. DPR-31 and DPR-41, respectively.

The proposed change would have modified the facility technical specifications surveillance requirements 4.8.2.1 pertaining to periodic verification of battery bank capacity and intercell and connection resistance.

While the Nuclear Regulatory Commission (NRC) staff was completing its acceptance review, three draft acceptance review questions were sent to you via email. See Enclosure for the draft acceptance review questions.

On April 5, 2011, the NRC staff and FPL held a teleconference to discuss the draft acceptance review questions.

During the call, the NRC staff categorized item 1 as an acceptance review question and items 2 and 3 as nonconservatisms identified by the staff while reviewing the application and the associated licensing basis. In its draft acceptance review questions for item 1, the NRC staff provided two options to the licensee, either, supplement the license amendment request or withdraw and resubmit.

In regards to items 2 and 3, the licensee stated during the teleconference that they would follow-up with the items by entering them into Turkey Point's corrective action program, and notify the NRC staff of its conclusions.

Subsequently, by letter dated April 13, 2011, FPL withdrew the amendment request. The purpose of this letter is to advise that the above-cited application is being treated as withdrawn.

Notice of Consideration of Issuance of the proposed amendment had not been published in the Federal Register.

Sincerely, IRA! Jason C. Paige, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

Draft Acceptance Review Questions cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL2-2 R/F RidsNrrDorlLpl2-2 RidsAcrsAcnw MailCTR Resource RidsNrrLABClayton RidsNrrPMTurkeyPoint RidsNrrDorlDpr RidsRgn2MailCenter Resource RidsNrrDeEeeb RidsOgcRp Resource MMcConnell, NRR VGoel, NRR PSahay, NRR ADAMS Accession No. ML 111 05A011 E NRRlLPL2-21PM NRRlLPL2-21LA NRRlLPL2-2/BC JPaige BClayton DBroaddus 04/15/11 04/15/11 04/15/11 NRRlLPL2-2/PM JPaige 04/15/11 OFFICIAL AGENCY RECORD