NRC 2010-0097, Response to Request for Additional Information on License Amendment Request 261, Supplement 5, Extended Power Uprate

Response to Request for Additional Information on License Amendment Request 261, Supplement 5, Extended Power Uprate

ML101890785
Person / Time
Site:	Point Beach
Issue date:	07/08/2010
From:	Meyer L Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC 2010-0097
Download: ML101890785 (41)

Text

NEXBera TM POINT BEACH July 8, 2010 NRC 2010-0097 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units Iand 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 License Amendment Request 261, Sup~lement5 Extended Power Uprate

References:

(I) FPL Energy Point Beach, LLC letter to NRC, dated April 7, 2009, License Amendment Request 261, Extended Power Uprate (ML091250564)

(2) NRC electronic mail to NextEra Energy Point Beach, LLC, dated May 19, 2010, Draft - Request for Additional Information Re: AFW (MLI 01410232)

Pursuant to 10 CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby submits Supplement 5 to License Amendment Request (LAR) 261 (Reference I ) for Point Beach Nuclear Plant (PBNP) Units 1 and 2. This supplement provides responses to NRC questions transmitted via Reference (2). This supplement also provides revised proposed Technical Specification (TS) changes for the Auxiliary Feedwater (AFW) System TS 3.7.5 that were previously submitted in Reference (I). The proposed TS changes are required based on the NextEra response to NRC questions in Reference (2).

Enclosure Iprovides the NextEra responses to the NRC staff's questions from the Technical Specification Branch transmitted in Reference (2). NextEra responses to the NRC staff's questions from the Electrical and Balance of Plant Branches in Reference (2) will be provided by separate letter. contains an evaluation of the proposed TS changes, including a determination that the proposed TS changes involve no significant hazards as defined in 10 CFR 50.92. An evaluation concludes that this change satisfies the criteria of 10 CFR 51.22 for categorical exclusion from the requirements for an environmental assessment. contains a markup of proposed TS changes. These changes replace proposed TS 3.7.5 changes previously submitted in Reference (I), Attachment 2.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 contains a markup of proposed TS Bases changes. These changes replace the TS Bases B 3.7.5 changes previously submitted in Reference (I), Attachment 3. The TS Bases changes are provided for information only. NRC approval is not being requested.

This letter contains no new regulatory commitments and no revisions to existing commitments.

The proposed TS changes have been reviewed by the Plant Operations Review Committee.

In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 8, 2010.

Very truly yours, NextEra Energy Point Beach, LLC Larry Meyer Site Vice President Enclosures (4) cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE I NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 261, SUPPLEMENT 5 EXTENDED POWER UPRATE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION The NRC staff determined that additional information was required (Reference I ) to enable completion of the review of License Amendment Request (LAR) 261, Extended Power Uprate (EPU) (Reference 2). The following information is provided by NextEra Energy Point Beach, LLC (NextEra) in response to the NRC Technical Specifications Branch Staff's request.

RAI I In addition to the request for additional information in items 2 through 4 below, please provide a safety analysis to justify TS 3.7.5, Auxiliary Feedwater changes proposed by this license amendment request.

NextEra Response The safety analyses justifying the changes to Technical Specification (TS) 3.7.5 are provided in Reference (2),as supplemented by References (3)through (19), and support implementation under the current licensing bases andlor EPU conditions. Additional evaluation is also provided in Enclosure 2.

-RAI 2 For the proposed TS 3.7.5 Condition described as one motor-driven auxiliary feedwater (MDAFW) pump inoperable concurrent with the turbine driven auxiliary feedwater (TDAFW) pump inoperable due to one inoperable steam supply, show that the PBNP design still provides for 100% of the AFW flow rate required by the safety analysis for the Feed Line Break or Main Steam Line Break, assuming no additional single failure.

Background:

TS changes are proposed based on plant modifications that replace two shared unit MDAFW with unit-specific MDAFW pumps configured to operate with the unit-specific TDAFW pump as a single system. Currently, TS 3.7.5 Condition A for one steam supply inoperable to one TDAFW pump system the licensee must restore the steam supply to operable status in 7 days. Accordingly, Condition B requires the licensee to start a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time (CT) clock, when the MDAFWpump becomes inoperable.

The TS basis for a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT for a MDAFW pump credits the redundant train (TDAFW pump) being fully operable with redundant steam supplies. Therefore, for a Condition of the TDAFW pump in a degraded condition with one steam supply inoperable when the MDAFW pump is also inoperable, the plant is operating in a higher risk significant condition which cannot be justified with the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT, The proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT is not justified and a more restrictive CT should be applied.

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Technical Specifications Task Force (TSTF) traveler TSTF-412 (ML071230105) provides guidance for a typical Westinghousefour loop pressurized water reactor with two MDAFW pumps and one TDAFW pump. In the event one steam supply is operable to the TDAFW pump and one MDAFW pump is operable, then TSTF-412 directs the licensee to enter a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> LC0 depending on whether the design can provide 100% of the required flow with a remaining safety-related MDAFW pump. However, because the TSTF assumes there is a remaining motor driven train capable of feeding the remaining intact steam generator TSTF-412 is not directly applicable for a two loop design like Point Beach.

Regulatory Basis: Title 10 Code of Federal Regulations 50.36(~)(2)Limiting conditions for operation. (i) 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. When a limiting condition for op&ation of any process step in the system of a fuel reprocessing plant is not met, the licensee shall shut down that part of the operation or follow any remedial action permitted by the technical specifications until the condition can be met, NextEra Response As stated in LAR 261, Attachment 5, Section 2.5.4.5.2, Technical Evaluation, and Table 2.5.4.5-2, Auxiliary Feedwater Flow Rate Requirements, the limiting AFW transient is a loss of normal feedwater (LONF) without a loss of non-vital AC power (LOAC), since the reactor coolant pumps are not tripped. Redundancy is provided by two 100% pump systems from diverse power sources. The auxiliary feedwater (AFW) system starts automatically and delivers sufficient AFW flow to maintain adequate steam generator (SG) levels during accidents.

Revised proposed TS, TS Bases, and corresponding evaluation addressing the new Auxiliary Feedwater (AFW) System and TSTF-412, Revision 3 (Reference 20), are provided in Enclosures 2, 3, and 4 to this letter. The Point Beach Nuclear Plant (PBNP) AFW system is atypical of two-loop pressurized water reactors in that the unitized motor-driven AFW (MDAFW) pumps can be cross-tied to feed the opposite unit SGs. As such, the Completion Time for the Condition of a full-capacity turbine-driven AFW (TDAFW) pump system inoperable due to one inoperable steam supply AND one full-capacity MDAFW pump system inoperable allows for a Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if a safety-related, full-capacity MDAFW pump system is available from the opposite unit. If a safety-related, full-capacity MDAFW pump system is not available from the opposite unit, the Completion Time is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Please note that, although not credited, the standby steam generator pumps can be used to provide feedwater to the SGs.

RAI 3

Proposed TS 3.7.5 Actions Note is revised from "LC0 3.0.4.b is not applicable" to "LC0 3.0.4.b is not applicable when entering MODE I." Please evaluate the proposed change. Explain why this change is an appropriate limit for when either the AFW pumps or the standby steam generator pumps (SSGs) are depended on for MODE transition from hot standby to entry into MODE I. Describe any changes to the PBNP current licensing basis SE for incorporating TSTF-359 (Agencywide Document and Management System (ADAMS) Accession No. ML030900056) that would result from incorporating this change. Identify the use and application of the Actions Note concurrent with the Note to SR 3.7.5. I, which allows the AFW pump system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable.

Page 2 of 6

Background:

The key issue is if a licensee has additional startup pump(s) to supplement the auxiliary feedwater pumps in MODES 2, 3, and 4, then they can limit the non-applicability using the Note "LC0 3.0.4.b is not applicable when entering MODE I J1allowingperformance of risk assessments to enter MODE 2 - 4. If an additional startup pump is not available, and AFW is being used for startup, then the Note should be "LC0 3.0.4.b is not applicableJ1forall MODES.

Background:

Current TS 3.7.5, LC0 3.0.4.b Note prohibits application of the LC0 3.0.4. b exception when entering any MODE of TS 3.7.5 Applicability, TSTF-359 guidance is that if the plant does depend on AFW for startup, the Note should state, 'LC0 3.0.4.b is not applicable. '

However, if the plant does not depend on AFW for startup the Note should state 'LC0 3.0.4.b is not applicable when entering MODE I.' 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 LC0 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LC0 not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance SR 3.7.5.1 contains a Note is related to the LC0 3.0.4.b Actions Note which allows the AFW system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. This SR Note permits the AFW system to be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW System, OPERABILITY (i.e., the intended safety function) continues to be maintained. This SR Note is only applicable to Actions Note 'LC0 3.0.4. b is not applicable. " It is unclear why the proposed Actions Note should be permitted as a remedial action for inoperable AFW equipment when the standby steam generator pumps (SSGs), which were the former auxiliary feedwater pumps, are used for startup.

Section 2.5.4.5 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."

Regulatory Basis: 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."

NextEra Response The proposed TS change to insert the note'bvhen entering MODE I"has been withdrawn and is no longer part of the proposed AFW TS.

Current TS 3.7.5 Required Action D.2 Note "Entry into MODE 4 is not required unless the MDAFWP is operable when the TDAFW pump is fully capable of performing its function while in MODE 4" is retained as a Note to Required Action C.2. This Note results in delayed entry into Page 3 of 6

MODE 4. Pleasejustify retaining this Note is an appropriate allowance for the PBNP AFW System.

Background:

Proposed TS 3.7.5 Condition "C" requires if Condition "A" or "B" is not met then Required Action C. Irequires be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Required Action C.2 requires be in MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. Required Action C.2 is modified by a Note 'Entry into MODE 4 is not required unless the motor driven AFW pump is operable." As proposed if the one MDAFW pump becomes inoperable, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to restore the pump. If not restored, then Condition "C" would require entry into MODE 3, not MODE 4, even though the AFW pumps has a 100% operable TDAFW pump. Topical Repon' WCAP- 16294, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs" has determined that operation in MODE 4 is acceptable because of the availability of the TDAFW pump in the upper range. Therefore, the proposed TS note restricting entry into MODE 4 when the MDAFW pump is not operable is not an acceptable remedial action when the TDAFW pump is available for use.

NextEra Response The revised A M TS included in Enclosures 2, 3 and 4 to this letter proposes to delete the note described above.

References (1) , NRC electronic mail to NextEra Energy Point Beach, LLC, dated May 19, 2010, Draft-Request for Additional lnformation Re: AFW (MLI 01410232)

(2) FPL Energy Point Beach, LLC letter to NRC, dated April 7, 2009, License Amendment Request 261, Extended Power Uprate (ML091250564)

(3) NextEra Energy Point Beach, LLC letter to NRC, dated June 17,2009, License Amendment Request 261, Supplement 1, Extended Power Uprate (ML091690090)

(4) NextEra Energy Point Beach, LLC letter to NRC, dated June 17,2009, License Amendment Request 261, Supplement 2, Extended Power Uprate (ML091690087)

(5) NextEra Energy Point Beach, LLC letter to NRC, dated September II,2009, License Amendment Request 261, Extended Power Uprate, Expedited Review Request (ML092570205)

(6) NextEra Energy Point Beach, LLC letter to NRC, dated September 25, 2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML092750395)

(7) NextEra Energy Point Beach, LLC letter to NRC, dated October 9, 2009, License Amendment Request 261, Extended Power Uprate, Response to Acceptance Review Questions (ML092860098)

(8) NextEra Energy Point Beach, LLC letter to NRC, dated November 20,2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML093270030)

Page 4 of 6

NextEra Energy Point Beach, LLC letter to NRC, dated November 20, 2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML093270079)

NextEra Energy Point Beach, LLC letter to NRC, dated November 21,2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML093270032)

NextEra Energy Point Beach, LLC letter to NRC, dated November 21,2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML093270035)

NextEra Energy Point Beach, LLC letter to NRC, dated January 7,2010, License Amendment Request 261, Extended Power Uprate, Clarification of Response to Request for Additional lnformation (MLI 00080013)

NextEra Energy Point Beach, LLC letter to NRC, dated January 8,2010, License Amendment Request 261, Extended Power Uprate, Auxiliary Feedwater System Pipe Stress Analysis lnformation (MLI 00110037)

NextEra Energy Point Beach, LLC letter to NRC, dated January 13,201 0, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (MLI 00140163)

NextEra Energy Point Beach, LLC letter to NRC, dated January 22, 2010, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (MLI 00250011)

NextEra Energy Point Beach, LLC letter to NRC, dated February II,2010, License Amendment Request 261, Extended Power Uprate, Withdrawal of Expedited Review Request (MLI 00470786)

NextEra Energy Point Beach, LLC letter to NRC, dated March 3, 2010, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (MLI 00630133)

NextEra Energy Point Beach, LLC letter to NRC, dated April 15, 2010, License Amendment Request 261, Supplement 4, Extended Power Uprate (MLI 01050357)

NextEra Energy Point Beach, LLC letter to NRC, dated April 22, 2010, License Amendment Request 261, Extended Power Uprate, Implementation of New Auxiliary Feedwater System at Current Licensed Power Level (MLI 01130030)

Nuclear Regulatory Commission, Notice of Availability of Model Application Concerning Technical Specifications Task Force (TSTF) Traveler to Provide Actions for One Steam Supply to Turbine Driven AFWIEFW Inoperable Using the Consolidated Line Item Improvement Process, dated July II, 2007 (ML071230105)

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ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 261, SUPPLEMENT 5 EXTENDED POWER UPRATE EVALUATION OF PROPOSED CHANGES TO TECHNICAL SPECIFICATION 3.7.5, AUXILIARY FEEDWATER (AFW)

I.O

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Proposed Changes

4.0 REGULATORY EVALUATION

4. I Applicable Regulatory Requirementslcriteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions 5.0 ENVIRONMENTAL CONSIDEMTION

6.0 REFERENCES

11 pages follow

1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90,"Application for amendment of license or construction permit,"

NextEra Energy Point Beach, LLC, (NextEra) proposes additional changes to Technical Specifications (TS) for Point Beach Nuclear Plant (PBNP) Units 1 and 2, in support of License Amendment Request (LAR) 261 (Reference I).

This supplement proposes revised TS changes for TS 3.7.5, Auxiliary Feedwater (AFW), that were previously submitted in Reference (I). The proposed TS changes are required based on the NextEra responses to NRC requests for additional information (Reference 2) provided in Enclosure Ito this letter.

2.0 DETAILED DESCRIPTION PBNP Units Iand 2 are being modified to include a unitized motor-driven AFW (MDAFW) pump system. Details of the system are contained in Section 2.5.4.5, Auxiliary Feedwater, of LAR 261, Attachment 5 (Reference I), as supplemented by References (3) through (19). The new MDAFW pump system for each unit will have increased flow capacity to ensure adequate margin is available for removal of decay heat from the core. The AFW system will be upgraded to install a new full-capacity unitized MDAFW pump on each unit and add AFW pump suction auto-switchover to safety-related service water upon loss of the condensate storage tank (CST) water source. The construction of the system may proceed under 10 CFR 50.59. The final physical tie-in and implementation require Commission approval.

A detailed description of the associated proposed TS changes is provided below for each change. Proposed markups for TS 3.7.5 are provided in Enclosure 3. Additionally, proposed markups for the Bases for Section 3.7.5 are provided in Enclosure 4 for NRC staff information.

2.1 Proposed Changes:

Replace:

"The AFW System shall be OPERABLE with; one turbine driven AFW pump system and two motor driven AFW pump systems" With:

"The AFW System shall be OPERABLE with; one turbine driven AFW pump system and one motor driven AFW pump system" Basis for the chanae: PBNP Units Iand 2 are being modified to include a unitized full-capacity MDAFW pump system. Each full-capacity MDAFW and full-capacity turbine-driven AFW (TDAFW) pump system will automatically start and deliver adequate flow to maintain steam generator (SG) levels during anticipated transients that result in a loss of the main feedwater system. As a result of the modification, the AFW system for each unit will consist of one full-capacity MDAFW pump system and one full-capacity TDAFW pump system.

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2. LC0 3.7.5 Note Replace:

'Only the motor driven AFW pump systems associated with steam generators relied upon for heat removal are required to be OPERABLE in MODE 4."

With:

'Only the motor driven AFW pump system is required to be OPERABLE in MODE 4."

Basis for the change: The Note is being revised to delete the requirement that the MDAFW pump system and its associated SG be OPERABLE, since the MDAFW pump system can be aligned to either or both SGs.

3. Condition A Replace:

'One steam supply to turbine driven AFW pump system inoperable."

With:

'One steam supply to turbine driven AFW pump system inoperable.

OR

............................................. NOTE.......................................

Only applicable if MODE 2 has not been entered following refueling.

The turbine driven AFW pump system inoperable in MODE 3 following refueling."

Basis for the chanse: This change is consistent with NUREG-1431, Revision 3, Standard Technical Specifications, Westinghouse Plants (Reference 23). The Note and Condition being added allow for a longer Completion Time due to the reduced decay heat following refueling.

4. Required Action A.1 Replace:

'Restore steam supply to OPERABLE status."

With:

'Restore affected equipment to OPERABLE status."

Basis for the change: The Required Action is changed to be consistent with the change in Condition A, that now address both an inoperable steam supply to the TDAFW pump system and an inoperable TDAFW pump system.

Page 2 of 14

5. Condition B Replace:

'One turbine driven AFW pump system inoperable in MODE 1, 2, or 3 for reasons other than Condition A."

With:

'One AFW pump system inoperable in MODE I, 2, or 3 for reasons other than Condition A" Basis for the chanqe: The condition is changed to account for either the MDAFW pump system or the TDAWF pump system being INOPERABLE in MODE I, 2, or 3.

6. Required Action B.1 Replace:

'Restore turbine driven AFW pump system to OPERABLE status."

With:

'Restore AFW pump system to OPERABLE status."

Basis for the chan~e:The required action is changed to be consistent with Condition B, which addresses both the MDAFW and TDAFW pump systems.

7. Condition C Replace:

'One motor driven AFW pump system inoperable in MODE 1, 2, or 31' With:

'Turbine driven AFW pump system inoperable due to one inoperable steam supply.

AND One motor driven AFW pump system inoperable."

Basis for the chanqe: The new Condition C is revised to address Technical Specification Task Force (TSTF)-412, Revision 3 (Reference 20). The new Condition C addresses the ability of the AFW system to mitigate the most limiting design basis events, excluding a single failure with an inoperable steam supply to a TDAFW pump system and an inoperable MDAFW pump system.

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8. Required Action C.1 Replace:

"C.1 Restore motor driven AFW pump system to OPERABLE status."

With:

'C.1 Restore the steam supply to the turbine driven pump system to OPERABLE status.

C.2 Restore the motor driven AFW pump system to OPERABLE status1' Basis for the channe: The Required Action is consistent with Condition C to re-establish redundancy by restoring either the inoperable steam supply to the TDAFW pump system to OPERABLE or restore the MDAFW pump system to OPERABLE status.

9. Completion Time for Required Action C.1 and new Required Action C.2 Replace:

'7 days 10 days from Discovery of Failure to meet the L C 0 With:

'r48hours if motor driven AFW pump system is available from the opposite unit Basis for the channe: The new Completion Time is consistent with TSTF-412, Revision 3 (Reference 20). Although the Completion Time stated in TSTF-412 is not directly applicable to two-loop pressurized water reactors, PBNP is atypical in that the MDAFW pump systems for each unit can be cross-tied to feed the SGs on the opposite unit. As such, the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time with the MDAFW pump system available on the opposite unit is appropriate.

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10. Condition D Replace:

'Required Action and associated Completion Time of Condition A, B, C not met.

Two AFW pump systems inoperable in MODE 1,2, or 3."

With:

'Required Action and associated Completion Time of Condition A, B, C not met1' Basis for the chanse:

Condition D is revised to delete the Condition of two AFW pump systems since the modified AFW system consists of only two pump systems (MDAFW and TDAFW pump systems) per unit. Loss of both AFW pump systems results in a loss of the AFW function and is covered by Limiting Condition for Operation (LCO) 3.0.3, which requires commencing a reactor shutdown within one hour.

Required Action D. 1 Replace:

I1 NOTE------------------------------------------------------------

Each unit may be sequentially placed in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when both units are in Condition C concurrently.

Be in MODE 3."

With:

'Bein MODE 3.

Basis for the chanqe: This Note is no longer applicable to the unitized AFW system.

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12. Required Action D.2 Replace:

'I

........................................... NOTE............................................................

Entry into MODE 4 is not required unless on motor driven AFW pump is OPERABLE.

Be in MODE 4."

With:

'Bein MODE 4."

Basis for the change: This change is consistent with TSTF-412, Revision 3 (Reference 20) and Condition C of NUREG-1431 (Reference 23), which do not allow the exception from entering MODE 4 when in Condition D.

13. Condition E Replace:

'Three AFW pump systems inoperable in MODE I, 2, or 3."

With:

'Two AFW pump systems inoperable in MODE I, 2, or 3 for reasons other than Condition C."

Basis for the chanse: The modified AFW system consists of only two AFW pump systems per unit.

14. Condition F Replace:

'One or more required AFW pump systems inoperable in MODE 4."

With:

'Required motor driven AFW pump system inoperable in MODE 4."

Basis for the chanae: There is only one MDAFW pump system per unit.

15. Required Action F.1 Replace:

Initiate action to restore AFW pump system(s) to OPERABLE status."

With:

'Initiate action to restore the motor driven AFW pump system to OPERABLE status."

Basis for the chanse: This is consistent with Condition F in that there is only one MDAFW pump system per unit.

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3.0 TECHNICAL EVALUATION

PBNP Units 1 and 2 are being modified to include a unitized MDAFW pump system. Details of the system are contained in Section 2.5.4.5, Auxiliary Feedwater, of LAR 261, Attachment 5 (Reference I), as supplemented by References (3) through (19). New MDAFW pump systems are being installed to increase the capability of the AFW system. The safety-related portions of each unit-specific AFW system are designed as Seismic Class I, and are capable of withstanding design basis earthquake accelerations without a loss of system performance capability.

Each new unit-specific MDAFW pump system and current TDAFW pump system are designed such that a single active failure will not disable more than one MDAFW or TDAFW pump system in each unit. Each of the MDAFW and TDAFW pump systems in each unit has some shared discharge piping with independent instrumentation and controls necessary for operation. The unit-specific MDAFW pump systems share a CST suction header. The unit-specific TDAFW pump systems share a second CST suction header. Each AFW pump suction will automatically transfer from the non-safety related CST to safety-related service water on low suction pressure, reducing required operator actions.

Each MDAFW and TDAFW pump system will automatically start and deliver adequate AFW flow to maintain adequate SG levels during anticipated plant transients that result in a loss of the main feedwater system. These transients include loss of normal feedwater (LONF) and loss of non-vital AC power (LOAC) events. The limiting transient with respect to AFW is a LONF without a concurrent LOAC, since the reactor is not immediately tripped, continuing to add 100% power to the reactor coolant, until a low-low SG level reactor trip occurs. Redundancy is provided by full-capacity MDAFW and full-capacity TDAFW pump systems using different power sources. The design capacity of each pump system ensures that on the limiting LONF event, with a failure of one AFW system, adequate RCS heat removal will be maintained to prevent the pressurizer from going water solid.

The unit-specific MDAFW pump systems eliminate the current manual operator action on dual unit AFW actuations (e.g., LOAC) to balance the MDAFW pump flows between the units. The AFW pump systems will automatically start and deliver sufficient AFW flow to maintain adequate SG levels for other accidents such as the steam generator tube rupture (SGTR) and main steam line break (MSLB). Although operator action is required to isolate the AFW lines to a faulted SG following a MSLB, the addition of flow control valves on the individual MDAFW pump SG discharge headers automatically decreases the maximum flow to the faulted SG, while increasing the flow to the non-faulted SG relative to the pre-EPU system configuration.

The new Condition C of TS 3.7.5 is being revised to address TSTF-412, Revision 3 (Reference 20). The proposed new Condition C addresses the ability of the AFW system to mitigate the most limiting design basis events, excluding a single failure, with one inoperable steam supply to the TDAFW pump system and an inoperable MDAFW pump system. The allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is appropriate, if the full-capacity MDAFW pump system from the opposite unit is available to meet the required design basis AFW flow. If the full-capacity MDAFW pump system from the opposite unit is not available, the allowed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is appropriate.

Page 7 of 14

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirementslcriteria NextEra submitted LAR 261 (Reference I ) to the NRC pursuant to 10 CFR 50.90. The proposed license amendment would increase each unit's licensed thermal power level from 1540 megawatts thermal (MWt) to 1800 MWt, and revise the Technical Specifications to support operation at the increased thermal power level. NextEra has determined that the proposed TS changes do not require any exemptions or relief from regulatory requirements and do not affect conformance with any GDC differently than described in the PBNP Final Safety Analysis Report (FSAR).

PBNP was licensed prior to the 1971 publication of 10 CFR 50 Appendix A, General Design Criteria for Nuclear Power Plants (GDC) (ML003674718). As such, PBNP is not licensed to Appendix A GDCs. PBNP FSAR Section I.3 lists the plant-specific GDCs to which the plant was licensed. The PBNP GDCs are similar in content to the draft GDCs proposed for public comment in 1967. The following discussion addresses the proposed change with respect to meeting the requirements of the applicable draft design criteria to which PBNP is licensed.

PBNP GDC 1 - Quality Standards. Those systems and components of reactor facilities which are essential to the prevention, or the mitigation of the consequences, of nuclear accidents which could cause undue risk to the health and safety of the public shall be identified and then designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed. Where generally recognized codes and standards pertaining to design, materials, fabrication, and inspection are used, they shall be identified. Where adherence to such codes or standards does not suffice to assure a quality product in keeping with the safety function, they shall be supplemented or modified as necessary. Quality assurance programs, test procedures, and inspection acceptance criteria to be used shall be identified. An indication of the applicability of codes, standards, quality assurance programs, test procedures, and inspection acceptance criteria used is required. Where such items are not covered by applicable codes and standards, a showing of adequacy is required.

PBNP GDC 2 - Performance Standards. Those systems and components of reactor facilities which are essential to the prevention or to the mitigation of the consequences of nuclear accidents which could cause undue risk to the health and safety of the public shall be designed, fabricated, and erected to performance standards that enable such systems and components to withstand, without undue risk to the health and safety of the public, the forces that might reasonably be imposed by the occurrence of an extraordinary natural phenomenon such as earthquake, tornado, flooding condition, high wind, or heavy ice. The design bases so established shall reflect: (a) appropriate consideration of the most severe of these natural phenomena that have been officially recorded for the site and the surrounding area and (b) an appropriate margin for withstanding forces greater than those recorded to reflect uncertainties about the historical data and their suitability as a basis for design.

PBNP GDC 4 - Sharing of Systems. Reactor facilities may share systems or components if it can be shown that such sharing will not result in undue risk to the health and safety of the public.

PBNP GDC 1I- Control Room. The facility shall be provided with a control room from which actions to maintain safe operational status of the plant can be controlled. Adequate radiation protection shall be provided to permit continuous occupancy of the control room under any credible post-accident condition or as an alternative, access to other areas of the facility as necessary to shut down and maintain safe control of the facility without excessive radiation exposures of personnel.

PBNP GDC 12 - Instrumentation and Control Systems. Instrumentation and controls shall be provided as required to monitor and maintain within prescribed operating ranges essential reactor facility operating variables.

PBNP GDC 37 - Engineered Safety Features Basis for Design. Engineered safety features shall be provided in the facility to back up the safety provided by the core design, the reactor coolant pressure boundary, and their protection systems. Such engineered safety features shall be designed to cope with any size reactor coolant piping break up to and including the equivalent of a circumferential rupture of any pipe in that boundary, assuming unobstructed discharge from both ends.

PBNP GDC 38 - Reliability and Testability of Engineered Safety Features. All engineered safety features shall be designed to provide such functional reliability and ready testability as is necessary to avoid undue risk to the health and safety of the public.

PBNP GDC 40 - Missile Protection. Adequate protection for those engineered safety features, the failures of which could cause an undue risk to the health and safety of the public, shall be provided against dynamic effects and missiles that might result from plant equipment failures other than a rupture of the Reactor Coolant System piping. An original design basis for protection of equipment against the dynamic effects of a rupture of the Reactor Coolant System piping is no longer applicable.

PBNP GDC 41 - Engineered Safety Features Performance Capability. Engineered safety features, such as the emergency core cooling system and the containment heat removal system, shall provide sufficient performance capability to accommodate the failure of any single active component without resulting in undue risk to the health and safety of the public.

PBNP GDC 42 - Engineered Safety Features Components Capability. Engineered safety features shall be designed so that the capability of these features to perform their required function is not impaired by the effects of a loss-of-coolant accident to the extent of causing undue risk to the health and safety of the public.

4.2 Precedent Proposed changes to TS 3.7.5 reflect the new unit-specific MDAFW pump system design. The changes to TS 3.7.5 are consistent with TS 3.7.5, Auxiliary Feedwater (AFW) System, contained in NUREG-1431, Revision 3, Standard Technical Specifications, Westinghouse Plants (Reference 23). The terminology "pump systems" contained in the existing PBNP TS has been retained, rather than adopting the term "train" when referring to the new pumps.

During the conversion from PBNP Custom TS to Improved TS, Justification for Deviation (JFD)-01 was submitted to the Commission for review in this regard. The rationale for use of the term "pump systems" versus "trains" was that "pump systems" is a more accurate description of the PBNP AFW system, since the flow paths associated with the AFW pumps are not associated with a specific engineered safety feature safety train. "Pump systems" and Page 9 of 14

"trains" both represent the valves and piping which support the ability of an AFW pump to provide the required accident analysis flow rates. Pump systems more aptly describe the AFW system at two-loop pressurized water reactor plants. The Commission approved this JFD, as documented in the safety evaluation approving the new Improved TS (ML012250504).

In addition, similar TS for the Prairie Island Nuclear Plant AFW System have been approved (ML022210054).

4.3 Significant Hazards Consideration NextEra has evaluated whether or not a significant hazard is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"lssuance of Amendment:' as discussed below:

1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed auxiliary feedwater (AFW) system design will provide additional capacity and reliability for the system. In addition, an automatic switchover from a condensate storage tank (CST) suction source of water to a safety-related service water source will be installed for actuation based upon the loss of suction pressure from the CST. A low suction pressure trip of the AFW pumps will be maintained to ensure pump protection, if the automatic suction transfer does not occur. Implementation of the new AFW system design and the proposed changes to Technical Specification (TS) 3.7.5, Auxiliary Feedwater (AFW), were evaluated against the current analysis of record for the current licensed power level of Point Beach Nuclear Plant (PBNP), Units 1 and 2. The current analyses remain applicable or are unaffected by implementation of the new AFW system and associated TS changes, with the exception of the steam line break containment response and steam generator tube rupture (SGTR) radiological consequences. These two accidents were reanalyzed with the current licensing basis for the AFW modifications and the results are acceptable with the revised minimum and maximum AFW flow rates and pump start timing.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 10 of 14

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed AFW system design will provide additional capacity and reliability for the system. In addition, an automatic switchover from a CST suction source of water to a safety-related service water source will be installed for actuation based upon the loss of suction pressure from the CST. A low suction pressure trip of the AFW pumps will be maintained to ensure pump protection, if the automatic suction transfer does not occur.

lmplementation of the AFW system design and the proposed changes to TS 3.7.5, Auxiliary Feedwater (AFW), are not significant accident initiators or precursors. These proposed changes will not create the possibility of a new or different kind of accident or event.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed AFW system design will provide additional capacity and reliability for the system. In addition, an automatic switchover from a CST suction source of water to a safety-related service water source will be installed for actuation based upon the loss of suction pressure from the CST. A low suction pressure trip of the AFW pumps will be maintained to ensure pump protection, if the automatic suction transfer does not occur.

lmplementation of the new AFW system design and the proposed changes to TS 3.7.5, Auxiliary Feedwater (AFW), were evaluated against the current analysis of record for the current licensed power level of PBNP Units Iand 2. The current analyses remain applicable or are not affected by implementation of the new AFW system and associated TS changes, with the exception of the steam line break containment response and SGTR radiological consequences. These two accidents were reanalyzed using the current licensing basis for the AFW modifications. The results are acceptable with the revised minimum and maximum AFW flow rates and pump start timing. Thus, the margin to safety in the accident analysis for the current licensed power level is not significantly reduced by these proposed changes.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NextEra concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of'ho significant hazards consideratiori'is justified.

Page I 1 of 14

4.4 Conclusions In conclusion, based on the considerations discussed above, ( I ) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. The Plant Operations Review Committee has reviewed the proposed changes and concurs with this conclusion.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(~)(9).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

(I) FPL Energy Point Beach, LLC letter to NRC, dated April 7, 2009, License Amendment Request 261, Extended Power Uprate (ML091250564)

(2) NRC electronic mail to NextEra Energy Point Beach, LLC, dated May 19,2010, Draft-Request for Additional lnformation Re: AFW (MLI 01410232)

(3) NextEra Energy Point Beach, LLC, letter to NRC, dated June 17,2009, License Amendment Request 261, Supplement 1, Extended Power Uprate (ML091690090)

(4) NextEra Energy Point Beach, LLC letter to NRC, dated June 17, 2009, License Amendment Request 261, Supplement 2, Extended Power Uprate (ML091690087)

(5) NextEra Energy Point Beach, LLC letter to NRC, dated September 11, 2009, License Amendment Request 261, Extended Power Uprate, Expedited Review Request (ML092570205)

(6) NextEra Energy Point Beach, LLC letter to NRC, dated September 25,2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML092750395)

(7) NextEra Energy Point Beach, LLC letter to NRC, dated October 9,2009, License Amendment Request 261, Extended Power Uprate, Response to Acceptance Review Questions (ML092860098)

(8) NextEra Energy Point Beach, LLC letter to NRC, dated November 20, 2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML093270030)

Page 12 of 14

(9) NextEra Energy Point Beach, LLC letter to NRC, dated November 20, 2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional Information (ML093270079)

NextEra Energy Point Beach, LLC letter to NRC, dated November 21,2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (ML093270032)

NextEra Energy Point Beach, LLC letter to NRC, dated November 21,2009, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional Information (ML093270035)

NextEra Energy point Beach, LLC letter to NRC, dated January 7, 2010, License Amendment Request 261, Extended Power Uprate, Clarification of Response to Request for Additional Information (MLI 00080013)

NextEra Energy Point Beach, LLC letter to NRC, dated January 8, 2010, License Amendment Request 261, Extended Power Uprate, Auxiliary Feedwater System Pipe Stress Analysis Information (MLI 00110037)

NextEra Energy Point Beach, LLC letter to NRC, dated January 13, 2010, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (MLI 00140163)

NextEra Energy Point Beach, LLC letter to NRC, dated January 22, 2010, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional lnformation (MLI 00250011)

NextEra Energy Point Beach, LLC letter to NRC, dated February 11, 2010, License Amendment Request 261, Extended Power Uprate, Withdrawal of Expedited Review Request (MLI 00470786)

NextEra Energy Point Beach, LLC letter to NRC, dated March 3, 2010, License Amendment Request 261, Extended Power Uprate, Response to Request for Additional Information (MLI 00630133)

NextEra Energy Point Beach, LLC letter to NRC, dated April 15, 2010, License Amendment Request 261, Supplement 4, Extended Power Uprate (MLl01050357)

NextEra Energy Point Beach, LLC letter to NRC, dated April 22, 2010, License Amendment Request 261, Extended Power Uprate, Implementation of New Auxiliary Feedwater System at Current Licensed Power Level (MLI 01130030)

Nuclear Regulatory Commission, Notice of Availability of Model Application Concerning Technical Specifications Task Force (TSTF) traveler to Provide Actions for One Steam Supply to Turbine Driven AFWIEFW Inoperable Using the Consolidated Line Item Improvement Process, dated July II,2007 (ML071230105)

U. S. Nuclear Regulatory Commission, Seismic Qualifications for Auxiliary Feedwater Systems, Generic Letter 81-14, February 1981 (ML031210309)

Page 13 of 14

(22) NRC Safety Evaluation, Seismic Qualification of the Auxiliary Feedwater, Point Beach Nuclear Plants Units Iand 2, dated September 16, 1986 (23) NUREG-1431, Revision 3, dated June 30,2004, Standard Technical Specifications Westinghouse Plants June 2004 (ML041830612 and ML041830205)

Page 14 of 14

ENCLOSURE 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 261 SUPPLEMENT 5 EXTENDED POWER UPRATE PROPOSED TECHNICAL SPECIFICATION 3.7.5 CHANGES 3 pages follow

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW)

LC0 3.7.5 The AFW System shall be OPERABLE with; one turbine driven AFW pump system and twe one motor driven AFW pump systems:

...................................... NOTE...................................................

Only the motor driven AFW pump systems is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1,2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

............................................................ NOTE---........................................................

LC0 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One steam supply to turbine A.1 Restore 7 days driven AFW pump system affected equipment to inoperable. OPERABLE status.

10 days from Discovery of Failure to meet the LC0 not been entered following refuelinq The turbine driven AFW Dump svstem inoperable in MODE 3 followinp refuelina.

B. One k;H"t3jfte$fjfFeft AFW pump B.l Restore 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> system inoperable in MODE 1, 2, AFW pump system to or 3 for reasons other than OPERABLE status. AND Condition A.

10 days from Discovery of Failure to meet the LC0 (continued)

Point Beach Unit I- Amendment No. 224 Unit 2 - Amendment No. 2%

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. * -

1=1 9

' 3 - 3 C.1 a 3 Turbine driven AFW pump system inoperable due to one Restore the steam s u ~ p l v inooerable steam supplv. to the turbine driven Dumo svstem to OPERABLE status.

One motor driven AFW pump system inoperable. 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if motor C.2 Restore the motor driven driven AFW pump AFW pump svstem to svstem is available OPERABLE status from the opposite unit 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> D. Required Action and associated D.1 _hlnTE Completion Time of Condition A, B, or C not met.

Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> (continued)

Point Beach Unit I- Amendment No. 224 Unit 2 - Amendment No. 233

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

-AFW pump systems E. rFkFee TLvo E.1 ---------- NOTE-----------

inoperable in MODE I,2, or 3 for L C 0 3.0.3 and all other reasons other than Condition C. L C 0 Required Actions requiring MODE changesare suspended until one AFW pump system is restored to OPERABLE status..

Initiate action to restore Immediately AFW pump system to OPERABLE status.

F. Brte-cH-FFter-e Required F.1 Initiate action to restore Immediately motor driven AFW pump systems the motor driven AFW inoperable in MODE 4. pump system@ to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 NOTE................................

AFW pump system(~)may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW manual, power operated, and 31 days automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed or otherwise secured in position, is in the correct position.

(continued)

Point Beach Unit 1 - Amendment No. 224 Unit 2 - Amendment No. 2%

ENCLOSURE 4 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS I AND 2 LICENSE AMENDMENT REQUEST 261, SUPPLEMENT 5 EXTENDED POWER UPRATE PROPOSED TECHNICAL SPECIFICATION 3.7.5 BASES CHANGES (FOR INFORMATION ONLY) 14 pages follow

AFW System B 3.7.5 B 3.7 PLANT SYSTEMS B 3.7.5 Auxiliary Feedwater (AFW) System BASES BACKGROUND The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW pumps provide cooling water to the steam generator secondary side via connections to the main feedwater (MFW) piping inside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LC0 3.7.1) or atmospheric dump valves (LC0 3.7.4). If the main condenser is available, steam may be released. via the steam bypass valves and recirculated to the CST.

The AFW System consists of #wee independent pump systems; lwe one motor driven AFW pumps S ,

and one c k k a k d steam turbine driven pump per unit. a& The motor driven and turbine driven pumps are pump& capable of providing 100%

of the design AFW flow rate assumed in the accident analvsis+vMe&e

1. levwe&. Each pump is provided with a recirculation line to maintain pump discharge flow above the minimum required flow rate for pump cooling. bc The normal source of water to the AFW pumps is the Condensate Storage Tank (CST) and the safety related supply is the Service Water (SW) System. The pump suctions are automaticallv transferred to the service water svstem if the AFW low suction pressure set~ointis reached. CST low level alarms alert personnel that the AFW pump suction supplv must be monitored and transferred to the service water svstem before the low suction pressure setpoint is reached. Motor operated valves are provided to allow the suction supply for the AFW pumps to be maweky automaticallv transferred to the SW system. For an AFW pump system to be considered OPERABLE, its associated service water suction supply valve must be operable.

Point Beach Unit 1 - Amendment No. 2Q4 Unit 2 - Amendment No. 236

AFW System B 3.7.5 BASES Point Beach Unit I- Amendment No. Z W Unit 2 - Amendment No. 236

AFW System B 3.

7.5 BACKGROUND

(continued)

Althouah the AFW svstem is capable of supplvina feedwater to the steam aenerators durina non-emeraencv conditions. its ~rimaryfunction is to allow safe shutdown followina an accident or plant trip. The AFW motor driven AFW pump svstem is powered from safeauards Dower.

The pump's discharae header splits into two branch lines to the unit's two steam aenerators. The flow control valves on the branch lines are set so each steam aenerator is provided with approximatelv one-half of the unit's total required flow. This feature precludes the motor driven AFW pump from trippina on an overcurrent condition at low steam generator pressure.

The motor driven AFW pump systems actuates automatically on steam generator water level (low-low) in either steam aenerator and upon receipt of a safety injection (SI) signal. If offsite power is available, the motor driven AFW pump systems actuates immediately. If offsite power is not available, the safeguards buses shed their normal operating loads and are connected to the emergency diesel generators (EDGs). The motor driven AFW pump systems a w then actuated per tbek &

programmed time sequence. While not credited in any DBA analysis, the motor driven AFW pump systems also actuates on; a trip of all MFW pumps, and by the Anticipated Transient Without Scram Mitigating System Actuation Circuit.

Each unit's turbine driven AFW pump receives steam from both steam generator main steam lines upstream of the main steam isolation valves. Each of the two steam fee$ smgm!~ lines can supply 100% of the required steam flow to the turbine driven AFW pump. Both steam supply lines must be OPERABLE to consider the turbine driven AFW pump OPERABLE. All power-operated valves associated with the turbine driven AFW pump system are DC-powered-The turbine driven AFW pump system actuates automatically on a steam generator water level Illow-low1in bet4 either steam generators.

While not credited in any DBA analysis, the turbine driven AFW pump system also actuates on; a trip of all MFW pumps, undervoltage on both main feedwater pump buses, and by the Anticipated Transient Without Scram Mitigating System Actuation Circuit.

Point Beach Unit 1 - Amendment No. 204-Unit 2 - Amendment No. 2 2 5

ARN System B 3.7.5 Qt7e-13Wr)/3 Either of the pumps at full flow is sufficient to remove decay heat and cool the unit to residual heat removal (RHR) entry conditions.

Thus, the requirement for diversity in motive power sources for the AFW System is met.

The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies Point Beach Unit I- Amendment No. 204-Unit 2 - Amendment No. 206

AFW System B 3.7.5 BASES BACKGROUND sufficient water to cool the unit to RHR entry conditions, with steam (continued) released through the ADVs.

The AFW System is discussed in the FSAR, Section 10.2 (Ref. I).

APPLICABLE The AFW System mitigates the consequences of any event with loss of SAFETY ANALYSES normal feedwater.

The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures in excess of the steam generator safety valve set pressure.

In addition, the AFW System must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to MODE 4 conditions.

The AFW system is assumed to function in the mitigation of Design Basis Accidents (DBAs) and transients 4 s include; Steam Generator Tube Rupture (SGTR), main steam line break, loss of normal feedwater, and loss of all AC power to the station auxiliaries.

The AFW system must be capable of isolating AFW to the ruptured steam generator following a SGTR in addition to isolating the steam supply to turbine driven AFW pump associated with the ruptured steam generator. Although the AFW System will be initiated during the Small Break LOCA, the event has been analyzed with no credit for AFW. The Small Break LOCA was analyzed without AFW to be conservative and to limit the modeling required to address all possible combinations and time delays for various AFW system configurations.

The ESFAS automatically actuates the AFW pump2 and associated power operated valves and controls when required to ensure an adequate feedwater supply to the steam generators dwmg A safetv function determination proaram (SFDP) review per TS 3.0.6 and TS 5.5.14 must be ~erformedfor the supported function of Containment Operability if a motor driven AFW (MDAFW) pump discharae valve is inoperable: The review must consider the Operabilitv of Containment Sprav and Containment Fan Coolers per the reauirements of TS 3.6.6.

The AFW system satisfies the requirements of Criterion 3 of #w&4%2 10 CFR 50.36(c)2(ii).

Point Beach

AFW System B 3.7.5 This LC0 provides assurance that the AFW System will perform its design safety function to mitigate the consequences of Design Basis Accidents and transients. Thee AFW pump systems, consisting of 4vw+kw& one motor driven pump systems and one c k d k a b d turbine driven pump system are required to be OPERABLE to ensure the availability of RHR capability for all events

. . accompanied by a loss of offsite power and a single failure.

This is accomplished bv powerina the motor driven pump from an emeraencv AC bus. The other AFW pump system does not relv on AC power. It relies on a steam turbine driven pump with a steam source that is not isolated bv closure of the MSlVs and valves ower red from DC sources.

The AFW System is configured into #wee pump systems. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE, and the components required to FFEHNH&

automatically transfer AFW pump suction supply to the service water system are OPERABLE. This requires that the 4we motor driven AFW pumps be OPERABLE, eask and capable of supplying AFW 4s-a

. - The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each main steam line upstream of the MSIVs, and shall be capable of supplying AFW to both &the steam generators. The piping, valves, instrumentation, and controls in the required flow paths also are required to be OPERABLE.

For an AFW pump system to be considered OPERABLE, a minimum recirculation flow path must be available, and the backup pneumatic supply for the minimum recirculation air-operated valve must be OPERABLE.

The LC0 is modified by a Note indicating that only the motor driven AFW pump6 6 duced heat removal requirements and short period of time in MODE 4 during which the AFW is required and the insufficient steam available in MODE 4 to power the turbine driven AFW pump.

APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.

Point Beach B 3.7.5-4 4-(M&mB

AFW System B 3.7.5 BASES In MODE 4 the AFW System may be used for heat removal via the steam generators.

In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.

Point Beach B 3.7.5-4a -

AFW System B 3.7.5 ACTIONS A Note prohibits the application of LC0 3.0.4.b to an inoperable AFW pump system. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW pump system inoperable and the provisions of LC0 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LC0 not met after a performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

If one of the two steam sup~liesto the turbine driven AFW train is inoperable. or if the turbine driven pump is inoperable while in MODE 3 immediatelv followina refuelina. action must be taken to restore the inoperable equipment to an OPERABLE status within 7 davs. The 7 dav Completion Time is reasonable. based on the followina reasons:

a. For the inoperabilitv of a steam supplv to the turbine driven AFW pump. the 7 dav Completion Time is reasonable, since there is a redundant steam supplv to the turbine driven AFW purnD.

b. For inoperabilitv of a turbine driven pump while in MODE 3 immediatelv subseauent to a refuelina. the 7 dav Completion Time is reasonable due to the minimal decav heat in this situation.

c. For both the inoperabilitv of a steam s u ~ p l vline to the turbine driven pump and an inoperable turbine driven AFW pump while in MODE 3 immediatelv followina a refuelina outaae, the 7 dav Completion Time is reasonable due to the availabilitv of a redundant OPERABLE motor driven AFW pump. and due to the low probabilitv of an event reauirina the use of the turbine driven AFW pump.

Point Beach Unit I- Amendment No. 245 Unit 2 - Amendment No. 220

AFW System B 3.7.5 The second Completion Time for Required Action A.l establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which multiple Conditions are entered concurrently. The AND connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

With the -one AFW pump system {c.~.,

a4wbke) inoperable in MODE 1, 2, or 3, for reasons other than Condition A, action must be taken to restore the pump system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This includes loss of two steam supplv lines to the turbine driven AFW PumD. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable, based on redundant capabilities afforded by the remaining OPERABLE AFW pump systems, time needed for repairs, and the low probability of a DBA occurring during this time period.

Point Beach Unit I- Amendment No. 24-6 Unit 2 - Amendment No. 220

AFW System B 3.7.5 ACTIONS (continued) The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 10 day Completion Time provides a limitation on the time allowed in this specified Condition after discovery of failure to meet the LCO.

This limit is considered reasonable for situations in which multiple Conditions are entered simultaneously. The AND connector between the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 10 day Completion Times dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

With the turbine driven AFW Pump svstem inoperable due to one inoperable steam supplv and the motor driven AFW pump svstem inoperable. action must be taken to restore the affected eauipment to OPERABLE status within 48 or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as described below.

Assuminq no sinale active failures when in this condition. the accident

/MSLB) could result in the loss of the remainina steam supplv to the turbine driven AFW pump due to the faulted steam aenerator. In this condition, the AFW svstem mav no lonaer be able to meet the required flow to the SGs assumed in the safetv analvsis.

If the motor driven AFW pump svstem from the opposite unit is available. the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Completion Time is reasonable based on the fact that this motor driven AFW pumo svstem is capable of providinq Point Beach Unit 1 - Amendment No. 2%

Unit 2 - Amendment No. ZQ

AFW System B 3.7.5 BASES 100°/~of the AFW flow requirements, and the low probabilitv of an event occurrina that would challenge the AFW system.

If the motor driven AFW pump system from the opposite unit is not available, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the remaininq OPERABLE steam s u p ~ l vto the turbine driven AFW pump. and the low ~robabilitvof an event occurrina that would reauire the inoperable steam supply to be available for the turbine driven AFW puma D.l and 0.2 When Required Action A.1, B.1, # C.1, or C.2 cannot be completed within the required Completion Time, 7 I = + a , L ,3 #3g&

, the unit must be placed in a MODE in which the LC0 does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

Point Beach B 3.7.5-6a Unit 1 - Amendment No. 2%

Unit 2 - Amendment No. 220 I

AFW System B 3.7.5 ACTIONS (continued) The allowed Completion Timeg ' are reasonable, based on operating experience, to reachU T

-t conditions from full power conditions in an orderly manner and without challenging unit systems.

If aKUHee both AFW pump systems are inoperable in MODE 1,2, or 3 for reasons other than Condition C, the unit is in a seriously degraded condition with no automaticallv initiated safety related AFW pumP svstems s ,

and only limited means for conducting a cooldown with non-safety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW pump svstem &a&-+to OPERABLE status.

Required Action E.l is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW pump system is restored to OPERABLE status. In this case, LC0 3.0.3 is not applicable because it could force the unit into a less safe condition. This Note does not prohibit voluntary MODE changes that may be prudent for safe operation.

In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation. This is addressed in LC0 3.4.6, "RCS Loops-MODE 4." With the motor driven pump systems inoperable, a= ct immediately restore the inoperable pump system@ to OPERABLE status. The immediate Completion Time is consistent with LC0 3.4.6.

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and Point Beach Unit I- Amendment No. 24-45 Unit 2 - Amendment No. 2220

AFW System B 3.7.5 SURVEILLANCE the steam generators during pump testing. This Note allows suitable REQUIREMENTS test conditions to be established while allowing a reasonable time (continued) period to complete the SR during unit startups and low power operation.

This SR verifies that AFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates an ESFAS, by demonstrating that ea& the two motor driven AFW pump discharge flow control valves actuate to their correct positions on an actual or simulated actuation signal. This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

The 18 month Frequency is acceptable based on operating experience and the design reliability of the equipment.

The SR is modified by a Note that states one or more AFW &ahs pump svstems may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW system, OPERABILITY (i.e., the intended safety function) continues to be maintained.

This SR verifies that the AFW pumps will start in the event of any accident or transient that generates an ESFAS by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

The ability of the Main Steam supply valves for the turbine driven pump to actuate to the correct position on an actual or simulated actuation signal is verified by this SR. The ability of the motor driven AFW pump Point Beach Unit I- Amendment No. 24-45 Unit 2 - Amendment No. 220

AFW System B 3.7.5 SURVEILLANCE discharge flow control valves to actuate to the correct position on an REQUIREMENTS actual or simulated actuation signal is also tested by this SR. TkAWQ (continued)

This SR is modified by two Notes. Note 1 indicates that the SR may be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

Note 2 states one or more AFW kaiRs pump svstems may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the AFW mode of operation, provided it is not otherwise inoperable. This exception allows the system to be out of its normal standby alignment and temporarily incapable of automatic initiation without declaring the train(s) inoperable. Since AFW may be used during startup, shutdown, hot standby operations, and hot shutdown operations for steam generator level control, and these manual operations are an accepted function of the AFW system, OPERABILITY (i.e., the intended safety function) continues to be maintained.

This SR verifies that the AFW is properly aligned by verifying the flow paths from the CST to each steam generator supplied by the respective AFW pump system prior to exceeding 2% of RTP after more than 30 days in any combination of MODE 5 or 6 or defueled. OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgement and other administrative controls that that ensure that flow paths remain OPERABLE. To further ensure AFW System alignment, flow path OPERABILITY is verified following extended outages to determine no misalignment of valves has occurred. This SR ensures that the flow path from the CST to the steam generators is properly aligned.

REFERENCES 1. FSAR, Section 10.2.

2. ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants.

Point Beach B 3.7.5-1 0 42mxa%