Text

Request for Extension of Completion Date of Generic Letter 2004-02 Actions
	ML083190054
Person / Time
Site:	Turkey Point
Issue date:	10/31/2008
From:	Jefferson W; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-04-002, L-2008-226
	Download: ML083190054 (13)
	v • d • e

OCT 3 12008 POWERING TODAY.

0 EMPOWERING TOMORROW.

L-2008-226 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Re: Florida Power & Light Company Turkey Point Unit 3 Docket No. 50-250 Request for Extension of Completion Date of the Turkey Point Unit 3 Generic Letter 2004-02 Actions

References:

(1) Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design.Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004 (2) Letter L-2005-034 from J. A. Stall (FPL) to U. S. Nuclear Regulatory Commission "NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated March 4, 2005 (ML050670429)

(3) Letter from E. A. Brown (U. S. Nuclear Regulatory Commission) to J. A.

Stall (FPL), "Turkey Point Plant, Units 3 and 4 - Request for Additional Information. (RAI) Related to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," dated June 2, 2005 (ML051520202)

(4) Letter L-2005-145 from J. A. Stall (FPL) to U. S. Nuclear Regulatory Commission "NRC Generic Letter 2004-02, Request for Additional Information - Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated. July,20, 2005 (ML052080038)

(5) Letter L-2005-181 from J. A. Stall (FPL) to U. S. Nuclear Regulatory Commission ."NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation at Pressurized Water Reactors -

Second Response," dated September 1, 2005 (ML052490339)

(6) Letter from B. T. Moroney (U. S. Nuclear Regulatory Commission) to J. A.

Stall (FPL) "Turkey. Point, Units 3 and 4, Request for Additional Information Re: Response to Generic letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized-Water Reactors," dated February 8, 2006 (ML060370438)

(7) Letter from C. Haney (U. S. Nuclear Regulatory Commission) to Holders of Operating Licensees for Pressurized Water Reactors, "Alternative an FPL Group company

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Page 2 of 5 Approach for Responding to the Nuclear Regulatory Commission Request for Additional Information RE: Generic Letter 2004-02," dated March 28, 2006 (ML060870274)

(8) Letter from C. Haney (U. S. Nuclear Regulatory Commission) to Holders of Operating Licenses for Pressurized-Water Reactors, "Alternative Approach for Responding to the Nuclear Regulatory Commission Request for Additional Information Letter Regarding Generic Letter 2004-02," dated January 4, 2007 (ML063460258)

(9) Letter from W. H. Ruland (U. S. Nuclear Regulatory Commission) to A.

Pietrangelo (Nuclear Energy Institute), "Content Guide for Generic Letter 2004-02 Supplemental Responses," dated August 15, 2007 (ML071060091)

(10) Letter from W. H. Ruland (U. S. Nuclear Regulatory Commission) to A.

Pietrangelo (Nuclear Energy Institute), "Revised Content Guide for Generic Letter 2004-02 Supplemental Responses," dated November 21, 2007 (ML073110269)

(11) Letter from W. H. Ruland (U. S. Nuclear Regulatory Commission) to A.

Pietrangelo (Nuclear Energy Institute), "Supplemental Licensee Responses to Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated November 30, 2007 (ML073320176)

(12) Letter L-2007-155 from J. A. Stall (FPL) to U. S. Nuclear Regulatory Commission "Request for Extension of Completion Date of the St. Lucie Unit 1, St. Lucie Unit 2 and Turkey Point Unit 3 Generic Letter 2004-02 Actions," dated December 7, 2007 (ML073450338)

(13) Letter L-2007-194 from J. A. Stall (FPL) to U. S. Nuclear Regulatory Commission "Response to Questions Regarding Request for Extension of Completion Date of the St. Lucie Unit 1, St. Lucie Unit 2 and Turkey Point Unit 3 Generic Letter 2004-02 Actions," dated December 20, 2007 (ML080090147)

(14) Letter from T. H. Boyce (U. S. Nuclear Regulatory Commission) to J. A.

Stall (FPL) "St. Lucie Nuclear Plant, Units 1 and 2, and Turkey Point Nuclear Plant, Unit 3 - Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized Water Reactors, Extension Request Evaluation," dated December 28, 2007 (ML073610401)

(15) Letter L-2008-033 from W. Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter.

2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated February 28, 2008 (ML080710429)

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Page 3 of 5 (16) Letter L-2008-138 from W. Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated June 30, 2008 (ML081960386)

(17) Letter from B. L. Mozafari (U. S. Nuclear Regulatory Commission) to J. A.

Stall (FPL), "Turkey Point Nuclear Plant, Unit 3 - Request for Additional Information (RAI) Related to Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," September 17, 2008 (ML082610705)

(18) SECY-06-0078, "Status of Resolution of GSI-191, Assessment of [Effect of]

Debris Accumulation on PWR Sump Performance," dated March 31, 2006.

(ML053620174)

The purpose of this submittal is to request an extension for Turkey Point Unit 3 to July 30, 2009 for full implementation of the regulatory requirements of Generic Letter (GL) 2004-02 (Reference 1).

The U. S. Nuclear Regulatory Commission (NRC) issued Reference 1 to request that addressees perform an evaluation of the emergency core cooling system (ECCS) and containment spray system (CSS) recirculation functions in light of the information provided in the GL and, if appropriate, take additional actions to ensure system functions.

Additionally, the GL requested addressees to provide the NRC with a written response in accordance with 10 CFR 50.54(f). The request was based on identified potential susceptibility of the pressurized water reactor (PWR) recirculation sump screens to debris blockage during design basis accidents requiring recirculation operation of ECCS or CSS and on the potential for additional adverse effects due to debris blockage of flowpaths necessary for ECCS and CSS recirculation and containment drainage.

Reference 2 provided the initial Florida Power and Light Company (FPL) response to the GL for Turkey Point Units 3 and 4. Reference 3 requested additional information regarding the Reference 2 response to the GL for Turkey Point Plant Units 3 and 4. Reference 4 provided the FPL response to Reference 3. Reference 5 provided the second of two responses requested by the GL. Reference 6 requested FPL to provide additional information for Turkey Point Units 3 and 4 to support the NRC staff's review of Reference 2, as supplemented by References 4 and 5.

Reference 7 provided an alternative approach and timetable that licensees may use to address outstanding requests for additional information. Reference 8 supplemented Reference 7 with the NRC expectation that all GL 2004-02 responses will be provided no later than December 31, 2007. For those licensees granted extensions to allow installation of certain equipment in spring 2008, the NRC staff expected that the facility response will be appropriately updated with any substantive GL corrective action analytical results or technical detail changes within 90 days of the change or outage completion. As further described in Reference 8, the NRC

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Page 4 of 5 expected that all licensees will inform the NRC, either in supplemental GL 2004-02 responses or by separate correspondence as appropriate, when all GS-1 91 actions are complete.

Reference 9 describes the content to be provided in a licensee's final GL 2004-02 response that the NRC staff believes would be sufficient to support closure of the GL. Reference 10 revised the guidance provided in Reference 9 by incorporating minor changes which were viewed by the NRC as clarifications.

Reference 11 authorized all PWR licensees up to two months beyond December 31, 2007 (i.e.,

to February 29, 2008) to provide the supplemental responses to the NRC.

In Reference 12, FPL requested an extension for completing Turkey Point Unit 3 chemical effects testing and analysis activities until June 30, 2008, and in-vessel and ex-vessel downstream effects evaluations until March 31, 2008. Reference 13 provided FPL's response to NRC questions regarding Reference 12. The request for an extension was approved in the Reference 14 evaluation for Turkey Point Unit 3.

In Reference 15, FPL provided a GL 2004-02 supplemental response using the content guide provided in Reference 9 (dated August 15, 2007). Reference 16 provided an updated supplemental response, as discussed in References 12, 13, 14, and 15, using the NRC Revised Content Guide for GL 2004-02 Supplemental Responses, dated November 21, 2007, that was provided by the NRC in Reference 10.

In Reference 16, the response included the results of Alion Science and Technology chemical testing at the VUEZ facility, and responses to remaining NRC RAI's. In Reference 17, the NRC stated that they had issues with the testing protocol of the VUEZ testing and included a group of RAI's pertaining to the chemical test program. This letter also recommended that FPL request an extension using the SECY-06-0078 process provided in Reference 18.

As requested in Reference 17, FPL held a teleconference with the NRC on October 3, 2008.

FPL provided an overview of Turkey Point Unit 3's alternative approach for responding to NRC's concern regarding the VUEZ test results in Reference 16, and stated that an extension

.request to July 30, 2009 will be submitted for Turkey Point Unit 3 to complete the alternative approach demonstration. of this letter provides an overview of the schedule for FPL's alternative approach for resolving NRC concerns with the VUEZ chemical testing and the use of these results in validating final GL 2004-02 compliance for Turkey Point Unit 3. Attachment 1 also provides the basis for supporting the FPL conclusion that it is acceptable to extend completion of full compliance with Generic Letter 2004-02 for Turkey Point Unit 3 until July 30, 2009. This attachment discusses the mitigative measures and permanent modifications that are in place at Turkey Point Unit 3 and how they support the criteria contained in SECY-06-0078, Reference 18.

FPL concluded that the chemical results from the VUEZ test program were correctly applied to the Turkey Point Unit 3 strainer design, and that the resulting potential impacts on ECCS NPSH, as provided in Reference 16, are appropriately conservative. FPL is in a unique position to support this assertion, based on comparisons between the Turkey Point Unit 3 and Unit 4 test programs and results. Although the strainers for Unit 3 and Unit 4 were manufactured by

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Page 5 of 5 different vendors, they are both vertical plate strainers with 3/32 inch holes. Both nuclear units have similar chemistry conditions, similar levels of aluminum, and both use sodium tetraborate to buffer post accident pH. The Unit 4 strainers were flume tested by AREVA at Alden Labs, including integrated chemical effects testing, and resulted in a much lower head loss than the final calculated head loss reported for Unit 3 in Reference 16. While there may remain NRC concerns relative to the VUEZ test protocols, the comparison between Unit 3 and Unit 4 strainer test parameters will validate and affirm the conservatism of the results provided to NRC for Turkey Point Unit 3 in Reference 16.

This information is being provided in accordance with 10 CFR 50.54(f).

Please contact Robert J. Tomonto, at (305) 246-7327, if you have any questions regarding this extension request.

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

Executed on October 2008.

yo 7 incerely Turkey Point Nuclear Plant Attachments: (1) cc: NRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 1 of 8 Attachment 1 Basis for Acceptability of Request for Extension of Completion-Date of Turkey Point Unit 3 GL 2004-02 Actions

1. Background

The U. S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors, (Reference 1) to request that licensees perform an evaluation of the emergency core cooling system (ECCS) and containment spray system (CSS) recirculation functions in light of the information provided in the GL and, if appropriate, take additional actions to ensure system function. In the GL, the staff determined that a written response, in accordance with 10 CFR 50.54(f), was due no later than December 31, 2007, and that continued operation through this period was justified. In Reference 2, an extension request for Turkey Point Unit 3 completion of GL 2004-02 activities was requested to June 30, 2008 based on the criterion contained in SECY-06-0078, Reference 3, and was granted by the NRC in Reference 4. FPL submitted the final Turkey Point Unit 3 supplemental submittal for GL 2004-02 on June 30, 2008, Reference 5. Plant specific strainer testing and analysis confirmed that the new strainers are of sufficient size to demonstrate acceptable ECCS pump NPSH margin when fully loaded with debris only, and then evaluated for potential chemical impacts based on results of the Alion Science and Technology chemical testing at the VUEZ facility.

In Reference 6, the NRC stated that they have identified several critical issues with the test protocol used in the chemical effects testing at VUEZ, as reflected in the NRC request for additional information (RAI). The NRC stated that an alternative approach to demonstrate adequate performance of the containment sump may need to be considered by FPL; however, should an alternate approach be utilized, response to the specific RAIs is not necessary. The NRC requested that FPL communicate their plan for demonstrating adequate sump performance by October 3, 2008, and stated that they expect that a public meeting with FPL will be needed to discuss the plan in more detail. Finally, the NRC stated that FPL will need to submit an extension request in accordance with the established process from SECY 06-0078 (Reference 3); and that a description of FPL's plans and schedule will need to be included in the extension request.

On October 3, 2008 a telephone conference was held between FPL and NRC representatives to discuss the Turkey Point Unit 3 alternative approach for demonstrating compliance with GL 2004-02. An alternate approach to validate adequate performance of the containment sump will be provided for Turkey Point Unit 3. FPL has concluded that the chemical results from the VUEZ test program were conservatively applied to the Turkey Point Unit 3 strainer design, and that the resulting potential impacts on ECCS NPSH are appropriately conservative.

The Unit 4 strainers were flume tested by AREVA at Alden Labs, which included integrated chemical effects testing, and as provided in Turkey Point Unit 4 final supplemental response on GL 2004-02, Reference 7, adequate ECCS NPSH margin is available. Hence, FPL is in a unique position to demonstrate that the Unit 3 ECCS NPSH results are conservative, based on comparisons between the Turkey Point Unit 3 and Unit 4 strainer test programs. An overview of some of the comparison items in the alternative approach include:

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 2 of 8

Although the strainers for Unit 3 and Unit 4 were manufactured by different vendors, they are both vertical plate strainers with 3/32 inch holes and utilize manifolds and piping connected to the sump.

Unit 3 has approximately 50% more sump screen surface area than Unit 4.

Unit 3 has significantly less fiber reaching the screens than Unit 4, i.e. not enough to calculate the formation of a thin bed on Unit 3.

Unit 3 and Unit 4 have similar particulate loadings, however the particulate loading on Unit 3 is less than Unit 4 on a per square foot basis at the sump.

The units have slightly different chemical and cal-sil loadings (Unit 3 is less than Unit 4 at the sump screens on a per square foot basis).

Both nuclear units have similar aluminum masses and areas, above and below the post LOCA flood level.

Both nuclear units use sodium tetraborate to buffer post accident pH.

FPL also indicated that a Computational Fluid Dynamics (CFD) analysis would be performed on Unit 3 to assure that Unit 4 strainer tested velocity profiles are bounding. NRC was also informed that FPL would file for an extension request for Turkey Point Unit 3 to July 30, 2009 using this alternative approach, and that at this time, there would likely be no need to respond to the RAI's included in NRC's September 17, 2008 letter, Reference 6.

In GL 2004-02, the NRC Staff summarized their reasoning and assessment to conclude that existing pressurized water reactors (PWRs) may continue to operate through December 31, 2007 while responding to the GL and implementing the required corrective actions. The requested extension, for full GSI-191 implementation to July 30, 2009, does not impact the NRC Staff's original conclusions summarized in GL 2004-02, wherein the staff concluded that it is acceptable to operate until the corrective actions are completed. An estimate of the potential additional risk for the requested extension period is provided. The following sections will also address the three criteria specified in SECY-06-0078 (Reference 3) that the NRC Staff expects to be satisfactorily addressed in an extension request.

2. Risk Estimate Introduction This section summarizes the calculation of the risk impact of extending the completion of Generic Letter 2004-02 actions at Turkey Point Unit 3, until July 30, 2009.

Backgqround NRC Generic Issue GSI-191 identifies that the current design basis methodology for assessing the potential for debris-induced sump blockage may not be conservative.

Westinghouse developed a report, WCAP-16362, "PRA Modeling Template for Sump Blockage" (Reference 8) that addresses the implications of sump blockage on risk. This WCAP provides a general model for sump blockage but did not produce quantitative values. The WCAP modeling approach was used in this simplified evaluation.

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 3 of 8 Evaluation The risk impact is limited to large-break LOCAs, since only these LOCAs are large enough to create enough debris to clog the containment sump. The frequency of a large-break LOCA is 1.33E-06 per year (NUREG/CR-6928, "Industry-Average Performance for Components and Initiating Events at U.S. Commercial Nuclear Power Plants" (Reference 9). Minimal credit is taken for mitigation of sump blockage given a large-break LOCA. At Turkey Point Unit 3, mitigation includes making up to the refueling water storage tank (RWST) to allow extended injection and starting the Unit 4 SI pumps for injection from the Unit 4 RWST. These actions are based on steps in the emergency procedures. For these recovery actions, a screening value of 0.2 was used for the probability of failing to successfully perform these mitigating activities.

Conclusion The increase in the core damage frequency due to clogging of the sump is therefore (1.33E-06 per year) * (0.2) = 2.66E-07 per year.

This calculated increase in the core damage frequency is well below the Regulatory Guide 1.174 (Reference 10) definition of less than 1E-06 per year for a "very small change" in core damage frequency. Therefore, extending the completion of Generic Letter 2004-02 Actions at Turkey Point Unit 3, until July 30, 2009, does not pose a significant increase in risk.

3. SECY-06-0078 Criteria SECY-06-0078 (Reference 3) specifies three criteria that should be addressed in GL 2004-02 licensee extension requests. These criteria and the FPL responses are provided below:

a. SECY-06-0078 Criterion 1 "The licensee has a plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties."

FPL Response:

As earlier described in the Background, FPL has a plan for resolving NRC concerns related to the testing protocols used by Alion Science and Technology at the VUEZ facility, by using an alternative approach that compares AREVA testing conducted on the Unit 4 strainers to Unit 3 strainers. This will validate that the available ECCS NPSH in the Turkey Point Unit 3 June 30, 2008 submittal, Reference 5, is conservative. The elements of the current alternative approach include:

Description of Plan Milestone Target Completion Date Conduct a Computational Fluid Dynamics (CFD) analysis January 30, 2009 for Unit 3 and compare with Unit 4 tested velocity profile Perform detailed engineering evaluation and prepare critical parameters comparison between Unit 3 and Unit 4, February 27, 2009 including incorporating the CFD results

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 4 of 8 Meet with NRC to provide presentation of results and obtain feedback By March 16, 2009 Submittal to NRC to address Turkey Point Unit 3 chemical effects testing (This date allows for contingency actions if July 30, 2009 required)

In order to assure completion of the above analysis for Turkey Point Unit 3, an extension is requested for Generic Letter 2004-02 to July 30, 2009. It is further noted that this extension is based on successful validation that Unit 4 strainer testing bounds the Unit 3 strainer system. In the event that this analysis is unsuccessful, additional Unit 3 strainer testing may be required.

Further, reexamination of original assumptions and bases of other calculations, or potentially, additional outage related plant modifications may be required.

b. SECY-06-0078 Criterion 2 "The licensee identifies mitigative measures to be put in place prior to December 31, 2007, and adequately describes how these mitigative measures will minimize the risk of degraded ECCS and CSS functions during the extension period."

FPL Response The following mitigative measures have been implemented and will minimize the risk of degraded ECCS and CSS functions during the extension period.

Leak-Before-Break Turkey Point Unit 3 has NRC approval (Safety Evaluation Report attached to NRC letter dated June 23, 1995) (Reference 11) to invoke the leak-before-break methodology to eliminate the dynamic effects (pipe whip and jet impingement) of postulated reactor coolant piping (hot leg, cold leg, and cross-over piping) ruptures from the design basis of the plant. The approval was based on the conclusion that the probability of a pipe failure before noticeable leakage could be detected and the plant brought to a safe-shutdown condition, is negligibly small. While leak-before-break is not being used to establish the design basis load on the sump strainer, it does provide a basis for safe continued operation until the completion of the GL 2004-02 actions.

Procedural Guidance, Traininq and Actions As discussed in our responses to NRC Bulletin 2003-01, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," Turkey Point has implemented a number of interim corrective actions to assure core cooling and containment integrity (References 12 and 13). In the NRC letter of August 15, 2005 (Reference 14) the Staff concluded that FPL was responsive to and met the intent of Bulletin 2003-01 for Turkey Point Units 3 and 4.

Operators are trained and have guidance for continuously monitoring emergency core cooling system (ECCS) and containment spray system (CSS) pump parameters, including loss of net-positive suction head (NPSH) as indicated by erratic pump current or discharge flow. Training

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 5 of 8 briefs presented during operator requalification training have increased operations personnel awareness of the potential for the containment recirculation sump to become clogged during operation of the ECCS and CSS pumps in the recirculation cooling mode. Procedural actions are in place to provide additional injection sources by aligning the opposite unit's RWST and high head safety injection (HHSI) pumps to the accident unit, or aligning the accident unit's charging pump to drain the remaining inventory from the RWST.

Containment Cleanliness FPL has implemented a number of actions to enhance containment cleanliness as documented in the response to Bulletin 2003-01. Detailed containment cleanliness procedures exist for unit restart readiness and for containment entry at power. These procedures incorporate the industry guidance of Nuclear Energy Institute (NEI) 02-01, Revision 1 (Reference 15) to minimize miscellaneous debris sources within the containment. Detailed containment sump inspections are performed at the end of each outage. These visual inspections of the containment sump screens ensure that the suction inlets are not restricted by debris.

Specifically, the procedures require that no loose debris (rags, trash, clothing, etc) is present in the containment which could be transported to the containment recirculation sumps. In addition, the Plant General Manager and the Site Vice President are required to personally walk down the containment prior to the restart from an outage.

Information Notice 2005-26 On September 16, 2005, NRC issued Information Notice (IN) 2005-26, "Results of Chemical Effects Head Loss Tests in a Simulated PWR Sump Pool Environment" (Reference 16). The IN applies to plants that have calcium silicate (Cal-Sil) insulation and utilize trisodium phosphate (TSP) as a buffering agent in the containment sump. Both Turkey Point Units 3 and 4 use sodium tetraborate as a buffering agent, not TSP. Therefore, Turkey Point Unit 3 is not susceptible to the chemical effects issues delineated in the IN.

Permanent Modifications Our mitigative measures include the following permanent physical improvements to Turkey Point Unit 3 ECCS sump and materials inside containment that were implemented during the Fall 2007 refueling outage:

The sump screens have been completely replaced with a strainer system that has a total strainer surface area of approximately 5,500 ft2 with perforations of 3/32-inch. The new system consists of 12 strainer modules.with interconnecting piping, and is completely passive. The new strainers replaced the previous sump screens which had a combined total surface area of approximately 63 ft2 with a 1/4-inch screen mesh.

The existing calcium silicate insulation and insulation protective metal was removed from the PRT to reduce the quantity of insulation debris postulated for a loss-of-coolant accident.

The existing reactor coolant pump insulation has been replaced with reflective metal insulation (RMI) to reduce the quantity of insulation debris.

The existing pressurizer surge line insulation (consisting of NUKON and calcium silicate) was

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 6 of 8 also replaced with RMI.

The containment closeout inspection procedure was revised to verify removal of the refueling cavity drain covers prior to entry into Mode 4 to eliminate a potential recirculation flow path choke point.

c. SECY-06-0078 Criterion 3 "For proposed extensions beyond several months, a licensee's request will more likely be accepted if the proposed mitigative measures include temporary physical improvements to the ECCS sump or materials inside the containment to better ensure a high level of sump performance."

FPL Response There are no temporary physical improvements required for Turkey Point Unit 3 to support the requested extension to July 30, 2009. As discussed under criterion 2, the final sump strainers are installed, other supporting modifications have been completed, and appropriate mitigative measures have been implemented.

d. Conclusions An extension until July 30, 2009 for completing the requested GL 2004-02 actions and modifications is acceptable because:

1. The calculated increase in the core damage frequency is well below the RG 1.174 definition of less than 1E-06 per year for a "very small change" in core damage frequency. Therefore, extending the completion of the analyses and confirmation of the acceptability of the sump modifications for Turkey Point Unit 3 does not pose a significant increase in risk.

2. FPL has taken aggressive action including extensive analysis and testing, and has implemented physical improvements (including a new larger sump strainer) to ensure a high level of sump performance.

3. FPL has implemented mitigative measures that will minimize the risk of degraded ECCS/CSS functions during the extension period.

4. FPL has a plant-specific plan with milestones to address outstanding technical issues with margin to account for uncertainties.

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 7 of 8

4. References

1. Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004

2. Letter L-2007-155 from J. A. Stall (FPL) to U. S. Nuclear Regulatory Commission.

"Request for Extension of Completion Date of the St. Lucie Unit 1, St. Lucie Unit 2 and Turkey Point Unit 3 Generic Letter 2004-02 Actions," dated December 7, 2007 (ML073450338)

3. SECY-06-0078, "Status of Resolution of GSI-191, Assessment of [Effect of] Debris Accumulation on PWR Sump Performance," dated March 31, 2006. (ML053620174)

4. Letter from T. H. Boyce (U. S. Nuclear Regulatory Commission) to J. A. Stall (FPL) "St.

Lucie Nuclear Plant, Units 1 and 2, and Turkey Point Nuclear Plant, Unit 3 - Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized Water Reactors, Extension Request Evaluation,"

dated December 28, 2007 (ML073610401)

5. Letter L-2008-138 from W. Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated June 30, 2008 (ML081960386)

6. Letter from B. L. Mozafari (U. S. Nuclear Regulatory Commission) to J. A. Stall (FPL),

"Turkey Point Nuclear Plant, Unit 3 - Request for Additional Information (RAI) Related to Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," September 17, 2008 (ML082610705)

7. Letter L-2008-160 from W. Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Updated Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated August 11, 2008 (ML082380244)

8. Westinghouse WCAP-1 6362, PRA Modeling Template for Sump Blockage, April 2005

9. NUREG/CR-6928, "Industry-Average Performance for Components and Initiating Events at U.S. Commercial Nuclear Power Plants", February 2007, p. D-1 1.

10. Regulatory Guide 1.174, Rev. 1, "An Approach to for Using Probabilistic Risk Assessment in Risk Informed Decisions on Plant-Specific Changes to the Licensing Basis," November 2002

11. NRC Letter, from R. P. Croteau (NRC) to J.H. Goldberg (FPL), "Turkey Point Units 3 and 4 - Approval to Utilize Leak-Before-Break Methodology for Reactor Coolant System Piping (TAC M91494 and M91495)," dated June 23, 1995

Turkey Point Unit 3, Docket No. 50-250 L-2008-226, Attachment 1, Page 8 of 8

12. Letter L-2003-201 from J. A. Stall, "NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," August 8, 2003

13. Letter L-2004-255 from T. 0. Jones, "Response to Request for Additional Information Regarding NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," November 9, 2004

14. Letter from B. T. Moroney to J. A. Stall, "Turkey Point Nuclear Plant Units 3 and 4 -

Responses to NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors," (TAC Nos. MB9623 and MB9624), August 15, 2005

15. NEI 02-01, Rev. 1, "Condition Assessment Guidelines: Debris Sources Inside PWR Containments"

16. NRC Information Notice 2005-26, "Results of Chemical Effects Head Loss Tests in a Simulated PWR Sump Pool Environment," September 16, 2005