L-2011-531, License Renewal Reactor Vessel Internals Inspection Program Implementation Commitment Revision Notification

License Renewal Reactor Vessel Internals Inspection Program Implementation Commitment Revision Notification

ML12020A247
Person / Time
Site:	Turkey Point
Issue date:	12/22/2011
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2011-531
Download: ML12020A247 (4)

Text

0 DEC 222011 L-2011-531 FPL.

POWERING TODAY.

EMPOWERING TOMORROW.

U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Docket Nos. 50-250 and 50-251 License Renewal (LR) Reactor Vessel Internals (RVI) Inspection Program Implementation Commitment Revision Notification

References:

1) Memorandum, USNRC to File, "Commitment Lists for Renewed Operating License (ROL) Plants with No Commitment Appendix Attached to Its ROL Safety Evaluation Reports/NUREGs for Use with IP-71003," Attachment 1.5, "Site Specific List of Commitments for Post-Renewal Inspection at Turkey Point Nuclear Plant," dated March 6, 2007

2) FPL letter L-2011-176 to the USNRC, "License Renewal (LR) Reactor Vessel Internals (RVI) Inspection Program, Letter of Intent to Adopt Materials Reliability Program (MRP) Report MRP-227, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines" and Revision of Commitments," dated May 11, 2011,

3) Final Safety Evaluation of EPRI Report, Materials Reliability Program Report 10 16596 (MRP-227), Revision 0, "Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines," issued June 22, 2011

4) NRC Regulatory Issue Summary 2011-07, "License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management," issued July 21, 2011 The original renewed license commitment (Outstanding Commitment No. 6 listed in Attachment 1.5 of Reference 1) required Turkey Point to implement the Reactor Vessel Internals (RVI) Inspection Program prior to the end of the initial operating term (July 19, 2012, and April 10, 2013 for Turkey Point Units 3 and 4, respectively). This commitment was based on the specific Turkey Point RVI Inspection Program that was previously approved by the Nuclear Regulatory Commission (NRC).

On May 11, 2011, Florida Power and Light Company (FPL) submitted letter L-2011-176, (Reference 2) to confirm FPL's intent to adopt and implement the NRC approved Reactor Vessel Internals (RVI) MRP-227 Guidelines for Turkey Point Units 3 and 4.

an FPL Group company

L-2011-531 Page 2 of 3 NRC approved and issued the Final Safety Evaluation for EPRI Report MRP-227 on June 22, 201 l(Reference 3). On July 21, 2011, NRC issued Regulatory Issue Summary (RIS) 2011-07, License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management (Reference 4). RIS 2011-07 states that Licensees with renewed licenses will be expected to submit AMPs/Inspection Plans in accordance with MRP-227-A and consistent with the timing requirements reflected in their LR commitments. Additionally, Licensees who would be required by their commitments to make their submittal prior to one year after the issuance of this RIS may modify their commitments to reflect a requirement to submit their AMPs/Inspection plans no later than October 1, 2012.

Prior to taking any action to modify the timing requirements for implementation of the RVI Inspection Program for Turkey Point, FPL held two telephone conferences on October 3, 2011 with Mr. Jason Paige, Turkey Point Project Manager and NRC License Renewal Staff Mr. James Medoff and Ms. Heather Jones, and again on October 26, 2011 with Mr. Paige to obtain a common understanding on Turkey Point Units 3 and 4 commitment revisions and required submittals.

The purpose of this letter is to notify the Commission of a revised renewed license commitment for Turkey Point Unit 3 and to document the FPL/NRC discussions addressing related required submittals for Units 3 and 4.

The original and revised RVI Inspection Program commitments associated with adopting and implementing MRP-227-A Guidelines are listed in Attachment 1.

Based on the discussions held with NRC Staff on October 3, 2011 and on October 26, 2011, it is our understanding that:

• FPL can evaluate and revise the previous NRC approved Turkey Point RVI Aging Management Program (AMP) to adopt NRC approved MRP-227-A Guidelines under the controls of the 10 CFR 50.59 rule.

" FPL can revise the original renewed license commitment (Reference 1) to defer implementation of the Unit 3 RVI Inspection Program to no later than December 31, 2012.

As discussed with the NRC Staff, adopting the NRC approved MRP-227 Guidelines impacts the timely implementation of the RVI Inspection Program for Turkey Point Unit 3, since the current commitment to implement the RVI Inspection Program is prior to July 19, 2012 (end of the initial operating license term). FPL explained that additional time is needed to address licensee actions identified in the final NRC Safety Evaluation for MRP-227-A (Reference 3).

Deferring implementation to no later than December 31, 2012, would allow FPL sufficient time to incorporate, in the RVI AMP, the latest NRC Staff guidance for implementing MRP-227-A.

L-2011-531 Page 3 of 3

• FPL is required to submit the Turkey Point Unit 3 RVI Inspection Plan no later than December 31, 2012 (consistent with the revised commitment).

" FPL will implement the Turkey Point Unit 4 RVI Inspection Program and will submit the RVI Inspection Plan prior to the end of the initial operating licensing term (i.e., April 10, 2013), which is consistent withthe timing requirements of the current Turkey Point Unit 4 commitment.

Should there be any questions, please contact Mr. Robert J. Tomonto, Licensing Manager at 305-246-7327.

Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant SM Attachment cc: Regional Administrator, USNRC Region II USNRC Senior Resident Inspector - Turkey Point Plant

L-2011-531 Attachment 1 Turkey Point Units 3 and 4 License Renewal Revised Commitment Original Outstanding Commitment for Turkey Point Units 3 and 4 (Reference 1, Attachment 1.5)

Prior to the end of the initial 6 Implement Reactor Vessel Internals Inspection Program operating license term Revised* Outstanding Commitment for Turkey Point Units 3 and 4 No later than December 31, 6 Implement Reactor Vessel Internals Inspection Program 2012 for Unit 3, and prior to the end of the initial operating license term for Unit 4 Notes:

• Additions are noted with bold and underlined text.