Text

Revised Response to NRC Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity
	ML042110162
Person / Time
Site:	Turkey Point
Issue date:	07/27/2004
From:	Stall J; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BL-03-002, L-2004-144
	Download: ML042110162 (5)
	v • d • e

&I P.O. Box 14000, Juno Beach, FL 33408-0420 FPL L-2004-144 U.S. Nuclear Regulatory Commission 10 CFR 50.54(f)

Attn: Document Control Desk Washington DC 20555 JUL 2 7 2004 RE: Florida Power and Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Revised Response to NRC Bulletin 2003-02 Leakage From Reactor Pressure Vessel Lower Head Penetrations And Reactor Coolant Pressure Boundary Integritv On August 21, 2003, the Nuclear Regulatory Commission (NRC) issued Bulletin 2003-02, "Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity." The Bulletin requested that specific information be provided to the NRC within 30 days of the date of the bulletin. By letter L-2003-234, dated September 19, 2003, Florida Power & Light Company (FPL) provided the requested information, including a commitment to perform a visual examination (VT-2) of all 50 reactor pressure vessel (RPV) lower head penetrations, at Turkey Point Units 3 and 4, during the next and subsequent refueling outages.

The initial Turkey Point Unit 4 visual examinations were performed during the refueling outage in October 2003. These bare-metal visual examinations (VT-2 examinations) included 100% of the circumference of each of the 50 RPV lower head (referred to as bottom mounted instrument (BMI)) penetrations where they enter the RPV lower head. Examination results were submitted to the NRC by letter L-2003-307, dated December 19, 2003. Due to the high radiation dose associated with performing visual examinations of BMI penetrations at this time, FPL is changing its commitment from a bare metal visual examination (VT-2) to an ultrasonic testing (UT) method, for examinations performed during the October 2004, Turkey Point Unit 3 refueling outage and the March 2005, Turkey Point Unit 4 refueling outage. The UT examinations will provide additional confidence in the integrity of the reactor pressure vessel (RPV) lower head penetrations as the Bulletin requests, while minimizing radiation exposure to plant personnel.

The basis for this change is provided Inthe attachment to this letter.

The attached information is provided pursuant to the requirements of Section 182a of the Atomic Energy Act of 1954, as amended and 10 CFR 50.54(f).

Please contact Rajiv S. Kundalkar at (561) 694-4848 if you have any questions regarding the information provided.

incerely yours, kcJ. A. al Senior Vice President, Nuclear and Chief Nuclear Officer Attachment an FPL Group company

Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251 L-2004-144, Page 2 STATE OF FLORIDA

)Ss.

COUNTY OF PALM BEACH R. S. Kundalkar being first duly sworn, deposes and says:

That he is Vice President, Nuclear Engineering of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, Information and belief, and that he is authorized to execute the document on behalf of said Licensee.

R. S. Kundalkar Subscribed and sworn to before me this Z7.*ray of 2004

-me of otary Public (Type of Print)

OFFICIALNOTARY SEAL JUDITH ANN CREASMAAN NxwCARY PUBUC ST ATE OF FLORIDA COMMISSION NO. CC980677 MYCOMMISSIONEXP. DEC. 5XN R. S. Kundalkar is personally known to me.

I Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251 L-2004-144 Attachment, Page 1 of 3 ATTACHMENT REVISED RESPONSE FOR TURKEY POINT UNITS 3 AND 4, TO NRC BULLETIN 2003-02: "LEAKAGE FROM REACTOR PRESSURE VESSEL LOWER HEAD PENETRATIONS AND REACTOR COOLANT PRESSURE BOUNDARY INTEGRITY,"

REQUESTED INFORMATION ITEMS 1(b) and 1(c)

On August 21, 2003, the Nuclear Regulatory Commission (NRC) issued Bulletin 2003-02, "Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity." The NRC requested that specific information be provided within 30 days of the date of the Bulletin. Florida Power and Light Company (FPL) provided the 30-day information request set forth In the Bulletin by letter dated September 19, 2003.1 FPL is changing the examination method for the bottom head penetrations from a bare metal visual (VT-2) to an ultrasonic testing (UT) method for Turkey Point Units 3 and 4. The basis for the change is provided in the following revised response to NRC Requested Information Items 1(b)and 1(c):

NRC Request 1(b): A description of the RPV lower head penetration inspection program that will be implemented at your plant during the next and subsequent refueling outages. The description should include the extent of the inspections which will be conducted with respect to the areas and penetrations to be inspected, inspection methods to be used, qualification standards for the inspection methods, the process used to resolve the source of findings of boric acid deposits or corrosion, the inspection documentation to be generated, and the basis for concluding that your plant will satisfy applicable regulatory requirements related to the structural and leakage integrity of the RPV lower head penetrations.

FPL Revised Response to NRC Request 1(b): FPL performed a 100% bare metal visual examination (VT-2) of the bottom mounted instrument (BMI) penetrations at Turkey Point Unit 4 in the fall of 2003. The Insulation was lowered to facilitate the direct and remote visual examination. The high radiation dose rates In the vicinity of the bottom head resulted in an exposure of 29.7 REM to perform the visual exam. Due to the actual accumulated dose for the Turkey Point Unit 4 Inspection, and identical work scope and similar radiological conditions near the reactor vessel bottom head at Turkey Point Unit 3, additional planning is necessary to develop an ALARA efficient insulation modification package to facilitate a long term periodic visual inspection plan. Therefore, FPL is changing its examination method to perform ultrasonic testing (UT) of the BMI penetrations at the next refueling outage for Turkey Point Unit 3 (Fall 2004). In addition, FPL will perform a UT examination of the BMI penetrations at Turkey Point Unit 4 (Spring 2005). These UT examinations are planned during scheduled reactor vessel in-service Inspections with the lower core barrel removed. The UT examinations will be performed in lieu of the previously committed bare metal visual examinations (VT-2) during the next refueling outage for each unit. The UT examinations will provide additional confidence in the integrity of the reactor pressure vessel (RPV) lower head penetrations as the Bulletin requests, while minimizing radiation exposure to plant personnel. This Inspection alternative will also allow additional time to plan an ALARA efficient insulation modification to support future bare metal visual examinations. The information gathered from the UT examinations will be reported to the EPRI Material

I Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251 L-2004-144 Attachment, Page 2 of 3 Reliability Program (MRP) to support the development of a long term industry inspection plan 2 In addition to the NRC reporting requirements of the Bulletin.

Extent of the Inspections: The UT examination scope for the next Turkey Point Unit 3 RFO (fall 2004) is planned to include all 50 BMI penetrations. The exam volume is planned from a horizontal plane 2 inches above the weld toe to a horizontal plane 2 inches below the weld root. If this exam volume cannot be achieved, the exam will be to the maximum extent possible for this first time Turkey Point Unit 3 examination, and alternate justification will be provided. Such alternate justification may include an analysis of the stress levels in the BMI nozzle relative to the distance above or below the J-groove weld.

The UT examination scope for the next Turkey Point Unit 4 refueling outage (spring 2005) is planned to Include all 50 BMI penetrations. The exam volume, like that described above for Unit 3, is planned from a horizontal plane 2 inches above the weld toe to a horizontal plane 2 Inches below the weld root. If this exam volume can not be achieved, the exam will be to the maximum extent possible for this first time Turkey Point Unit 4 UT examination, and alternate justification will be provided.

The examination scope for subsequent refueling outages, at Turkey Point Units 3 and 4, will include bare metal visual (VT-2) of all 50 BMI penetrations Including 100% of the circumference of each penetration as it enters the RV lower head. Modifications will be implemented at future outages, as necessary, to enable a 100% bare metal visual examination of the BMIs. The boric acid inspection program will be modified to include VT-2 bare metal examination of the BMIs at a frequency determined by the EPRI MRP, ASME Code changes, or Regulatory action.

Examination methods: The UT examination method will be used for the BMI penetrations at both Turkey Point Units 3 and 4 at the refueling outages identified above.

Qualification standards: The UT examination equipment and procedures will be demonstrated in accordance with the EPRI MRP BMI inspection demonstration program and the vendor's written practice.

Personnel utilized to perform these supplemental examinations will be certified in accordance with the vendors written practices. FPL will review and approve all NDE personnel certifications and procedures prior to examinations being performed.

If visual examination is necessary, personnel and procedures will be qualified as identified in FPL's original response to the Bulletin.'

Process used to resolve the source of findings: FPL will use the condition report process to evaluate UT indications. Any potential flaw will be evaluated using a flaw tolerance approach and may be supplemented by bare metal visual examinations of the suspect BMI penetration.

When visual findings are evaluated, the process will be as identified in FPL's original response to the Bulletin.'

Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251 L-2004-144 Attachment, Page 3 of 3 Documentation of the examinations: The examinations will be documented in a report. Digital results of the examination will be recorded. UT scan images may be used to support the examination findings and supplement the report.

Basis for concluding that your plant will satisfy applicable regulatory requirements: The response to this request remains unchanged from FPL's original response to the Bulletin,' except that the UT method will be used to inspect the BMI penetrations during the October 2004, Turkey Point Unit 3 refueling outage and the March 2005, Turkey Point Unit 4 refueling outage. The UT method provides a more thorough determination of BMI penetration structural integrity since it has the ability to detect both through-wall and part through-wall flaws in the penetration.

NRC Request 1(c): If you are unable to perform a bare-metal visual inspection of each penetration during the next refueling outage because of the inability to perform the necessary planning, engineering, procurement of materials, and implementation, are you planning to perform bare-metal visual inspections during subsequent refueling outages?

If so, provide a description of the actions that are planned to enable a bare-metal visual inspection of each penetration during subsequent refueling outages. Also, provide a description of any penetration inspections you plan to perform during the next refueling outage. The description should address the applicable items in paragraph (b).

FPL Revised Response to NRC Request 1(c): FPL performed a bare metal visual examination (VT-2) of all 50 BMI penetrations at Turkey Point Unit 4 during the refueling outage following the issuance of the Bulletin (fall 2003). FPL Is planning to perform a UT examination of the BMI penetrations at both Turkey Point Units 3 and 4 during the next refueling outages as identified in the response to 1(b) above. FPL is planning to modify the reactor vessel lower head insulation design, as necessary, to accommodate a complete bare metal visual examination (VT-2) of all 50 BMI penetrations for future refueling outages, while minimizing the radiation exposure to the plant personnel.

FPL letter L-2003-234, "Florida Power and Light Company, St. Lucie Units 1 and 2, Docket Nos. 50-335 and 50-389, Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-25 1, FPL Energy Seabrook, LLC, Seabrook Station, Docket No. 50-443, NRC Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity:' J. A. Stall to NRC, September 19,2003.

2 MRP Letter 2004-04, "BMI Integrated Industry Inspection Plan:' Leslie Hartz, Chair of the MRP Senior Representatives, Dominion Generation to PWR Owners with Bottom Mounted Instrument Nozzles, May 14,2004.