ML093060301

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Request for Additional Information from Technical Specifications Branch Regarding Auxiliary Feedwater
ML093060301
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 11/06/2009
From: Justin Poole
Plant Licensing Branch III
To: Meyer L
Point Beach
Poole Justin/DORL/LPL3-1/ 301-415-2048
References
TAC ME1081, TAC ME1082
Download: ML093060301 (2)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 6, 2009 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 TECHNICAL SPECIFICATIONS BRANCH RE: AUXILIARY FEEDWATER (TAC NOS. I\\IIE1081 AND IVIE1082)

Dear Mr. Meyer:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 7, 2009, as supplemented by two letters dated June 17, and September 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML091250564, ML091690087, ML091690090, and ML092750395, respectively), FPL Energy Point Beach, LLC, submitted a request to change technical specifications due to modifications to the auxiliary feedwater system. This was originally part of the extended power uprate request but was separated out by the NRC staff.

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 October 27, 2009, 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. 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

REQUEST FOR ADDITIONAL INFORMATION POINT BEACH NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 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, "Auxiliary Feedwater (AFW)," contains an Actions Note that states limiting condition for operation (LCO) 3.004.b is not applicable. The proposal revises this Note to state LCO 3.004.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 LCO 3.004.b is not applicable [when entering MODE 1.] The Bases contains a reviewer's note that states "The LCO 3.004.b Note prohibits application of the LCO 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, ILCO 3.004.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 LCO 3.004.b, which allow entry into a Mode or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

Section 2.504.5 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)(2)(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 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.

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 TECHNICAL SPECIFICATIONS BRANCH RE: AUXILIARY FEEDWATER (TAC NOS. ME1081 AND ME1082)

Dear Mr. Meyer:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated April 7, 2009, as supplemented by two letters dated June 17, and September 25,2009 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML091250564, ML091690087, ML091690090, and ML092750395, respectively), FPL Energy Point Beach, LLC, submitted a request to change technical specifications due to modifications to the auxiliary feedwater system. This was originally part of the extended power uprate request but was separated out by the NRC staff.

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 October 27, 2009, 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, IRA!

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 RidsNrrLATHarris Resource LPL3-1 r/f RidsNrrPMPointBeach Resource RidsNrrDorlLpl3-1 Resource REIliott, NRR RidsRgn3MailCenter Resource RidsOgcRp Resource CShulten, NRR RidsAcrsAcnw_MailCTR Resource RidsNrrDirsltsb Resource RidsNrrDorlDpr Resource ADAMS Accession Number: ML093060301

  • oer memo dated June 12, 2009 OFFICE LPL3-1/PM LPL3-1/LA NRR/SBPB/BC LPL3-1/BC NAME JPoole THarris RElliott*

RPascarelli DATE 11/05/09 11/05/09 6/12/09 11/06/09 OFFICIAL RECORD COpy