L-2012-004, Response to NRC Request for Additional Information Regarding Bulletin 2011-011, Mitigating Strategies

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Response to NRC Request for Additional Information Regarding Bulletin 2011-011, Mitigating Strategies
ML12018A240
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 01/04/2012
From: Kiley M
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-11-001, L-2012-004, TAC ME6494, TAC ME6495
Download: ML12018A240 (4)


Text

Florida Power and Light Company, 9760 SW 3 4 4th St., Homestead, FL 33035 0

IPL.

POWERING TODAY.

EMPOWERING TOMORROW.'

10 CFR 50.4 L-2012-004 January 4, 2012 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to NRC Request for Additional Information Regarding Bulletin 2011-01, Mitigating Strategies

References:

1) NRC Bulletin 2011-01, Mitigating Strategies, dated May 11, 2011
2) FPL Letter L-2011-261 dated July 8, 2011, 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies
3) NRC Letter dated December 5, 2011: Turkey Point, Units 3 and 4 -

Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" (TAC Nos. ME6494 and ME6495)

The Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, Mitigating Strategies, dated May 11, 2011 (Reference 1), to request each licensee to provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).

In Bulletin 2011-01, the NRC requested each licensee to submit written responses within 30 and 60 days of the date of the Bulletin. Florida Power and Light Company (FPL) provided the 60-day response for Turkey Point Units 3 and 4 in FPL Letter L-2011-261 dated July 8, 2011 (Reference 2).

The attachment to this letter forwards FPL's reply to the NRC request for additional information (Reference 3) regarding FPL's 60-day Bulletin response. The attachment contains information that addresses measures that are currently in place. There are no new regulatory commitments contained in this letter.

an FPL Group company

Florida Power and Light Company L-2012-004 Response to NRC Request for Additional Information Regarding Bulletin 2011-01 Page 2 of 2 If there are any questions, or if additional information is required, please contact Robert J.

Tomonto, Licensing Manager, at 305-246-7327.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant

Attachment:

Response to NRC Request for Additional Information Regarding Bulletin 2011-01, Mitigating Strategies cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant

Florida Power and Light Company L-2012-004 Turkey Point Nuclear Plant Attachment Response to NRC Request for Additional Information Regarding Bulletin 2011-01 Page 1 of 2 Response to NRC Request for Additional Information Regarding BuHletin 2011-01, Mitigating Strategies Turkey Point Nuclear Plant On May 11, 2011, the NRC issued Bulletin 2011-01 'Mitigating Strategies' (Reference 1). In Bulletin 2011-01, the NRC requested each licensee to submit written responses within 30 and 60 days of the date of the Bulletin. Florida Power and Light Company (FPL) provided the 60-day response for Turkey Point Units 3 and 4 in FPL Letter L-2011-261 dated July 8, 2011 (Reference 2).

By letter dated December 5, 2011 (Reference 3), the NRC requested additional information regarding FPL's 60-day Bulletin response. FPL's reply to the NRC request for additional information is contained below.

NRC Request

1. Describe in detail the maintenance or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

The bulletin requested that each licensee describe in detail the maintenance and testing on equipment supporting the mitigating strategies to ensure that it will be functional when needed. In the context of the mitigating strategies, these devices are commonly used for firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product releases. The U. S. Nuclear Regulatory Commission (NRC) staff could not determine if you performed maintenance and testing activities to ensure that these devices will be functional when needed.

FPL Response Monitor and spray nozzles are passive components and are checked quarterly for evident signs of corrosion or damage. Testing is not routinely performed.

Other equipment supporting mitigating strategies include hand loaders for valve operators, flange adapters and flow instruments. These are checked quarterly for evident signs of corrosion or damage. Instruments are routinely calibrated. Testing is not routinely performed.

NRC Request

2. Describe in detail the testing of radio communications equipment to ensure that it is functional when needed.

Florida Power and Light Company L-2012-004 Turkey Point Nuclear Plant Attachment Response to NRC Request for Additional Information Regarding Bulletin 2011-01 Page 2 of 2 The bulletin requested that each licensee describe in detail the maintenance and testing of equipment supporting the mitigating strategies to ensure that it will be functional when needed. Communications equipment needed to support the mitigating strategies was described in the NRC Safety Evaluation (SE) documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026). The SE states that you installed and tested an Interoperability Radio System and that radios are maintained and tested using plant procedures. However, based upon your response to the bulletin, the NRC staff could not determine if you continue to perform activities to ensure that radio communications equipment will be functional when needed.

FPL Response Radios are stored on charge and are functionally tested quarterly, consistent with emergency preparedness guidance.

NRC Request

3. Describe in detail how you assure the availability of Homestead Air Reserve Base to provide offsite support in response to a B.5.b event.

The bulletin requested that each licensee describe in detail how it assures the availability of offsite support, including a listing of offsite organizations relied upon for emergency response. The NRC Safety Evaluation documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026) states that the Homestead Air Reserve Base has the required knowledge, skills, and abilities to support response actions and that you were pursuing a letter of agreement. Homestead Air Reserve Base was not listed in your response to Question 5 of the bulletin.

FPL Response The response to Question 5 of the bulletin only listed those outside organizations that were identified in earlier correspondence and from whom formal mutual aid agreements had been obtained. The pursuit to obtain a Letter of Agreement or other formal confirmation of mutual aid with Homestead Air Reserve Base has been unsuccessful.

References

1. NRC Bulletin 2011-01, Mitigating Strategies, dated May 11,2011
2. FPL Letter L-2011-261 dated July 8, 2011, 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies
3. NRC Letter dated December 5, 2011: Turkey Point, Units 3 and 4 -Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" (TAC Nos. ME6494 and ME6495)

Text

Florida Power and Light Company, 9760 SW 3 4 4th St., Homestead, FL 33035 0

IPL.

POWERING TODAY.

EMPOWERING TOMORROW.'

10 CFR 50.4 L-2012-004 January 4, 2012 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to NRC Request for Additional Information Regarding Bulletin 2011-01, Mitigating Strategies

References:

1) NRC Bulletin 2011-01, Mitigating Strategies, dated May 11, 2011
2) FPL Letter L-2011-261 dated July 8, 2011, 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies
3) NRC Letter dated December 5, 2011: Turkey Point, Units 3 and 4 -

Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" (TAC Nos. ME6494 and ME6495)

The Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, Mitigating Strategies, dated May 11, 2011 (Reference 1), to request each licensee to provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).

In Bulletin 2011-01, the NRC requested each licensee to submit written responses within 30 and 60 days of the date of the Bulletin. Florida Power and Light Company (FPL) provided the 60-day response for Turkey Point Units 3 and 4 in FPL Letter L-2011-261 dated July 8, 2011 (Reference 2).

The attachment to this letter forwards FPL's reply to the NRC request for additional information (Reference 3) regarding FPL's 60-day Bulletin response. The attachment contains information that addresses measures that are currently in place. There are no new regulatory commitments contained in this letter.

an FPL Group company

Florida Power and Light Company L-2012-004 Response to NRC Request for Additional Information Regarding Bulletin 2011-01 Page 2 of 2 If there are any questions, or if additional information is required, please contact Robert J.

Tomonto, Licensing Manager, at 305-246-7327.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant

Attachment:

Response to NRC Request for Additional Information Regarding Bulletin 2011-01, Mitigating Strategies cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant

Florida Power and Light Company L-2012-004 Turkey Point Nuclear Plant Attachment Response to NRC Request for Additional Information Regarding Bulletin 2011-01 Page 1 of 2 Response to NRC Request for Additional Information Regarding BuHletin 2011-01, Mitigating Strategies Turkey Point Nuclear Plant On May 11, 2011, the NRC issued Bulletin 2011-01 'Mitigating Strategies' (Reference 1). In Bulletin 2011-01, the NRC requested each licensee to submit written responses within 30 and 60 days of the date of the Bulletin. Florida Power and Light Company (FPL) provided the 60-day response for Turkey Point Units 3 and 4 in FPL Letter L-2011-261 dated July 8, 2011 (Reference 2).

By letter dated December 5, 2011 (Reference 3), the NRC requested additional information regarding FPL's 60-day Bulletin response. FPL's reply to the NRC request for additional information is contained below.

NRC Request

1. Describe in detail the maintenance or testing of monitor nozzles, spray nozzles, or similar devices to ensure that they will be functional when needed.

The bulletin requested that each licensee describe in detail the maintenance and testing on equipment supporting the mitigating strategies to ensure that it will be functional when needed. In the context of the mitigating strategies, these devices are commonly used for firefighting, spent fuel pool spray strategies, and as a means to reduce the magnitude of fission product releases. The U. S. Nuclear Regulatory Commission (NRC) staff could not determine if you performed maintenance and testing activities to ensure that these devices will be functional when needed.

FPL Response Monitor and spray nozzles are passive components and are checked quarterly for evident signs of corrosion or damage. Testing is not routinely performed.

Other equipment supporting mitigating strategies include hand loaders for valve operators, flange adapters and flow instruments. These are checked quarterly for evident signs of corrosion or damage. Instruments are routinely calibrated. Testing is not routinely performed.

NRC Request

2. Describe in detail the testing of radio communications equipment to ensure that it is functional when needed.

Florida Power and Light Company L-2012-004 Turkey Point Nuclear Plant Attachment Response to NRC Request for Additional Information Regarding Bulletin 2011-01 Page 2 of 2 The bulletin requested that each licensee describe in detail the maintenance and testing of equipment supporting the mitigating strategies to ensure that it will be functional when needed. Communications equipment needed to support the mitigating strategies was described in the NRC Safety Evaluation (SE) documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026). The SE states that you installed and tested an Interoperability Radio System and that radios are maintained and tested using plant procedures. However, based upon your response to the bulletin, the NRC staff could not determine if you continue to perform activities to ensure that radio communications equipment will be functional when needed.

FPL Response Radios are stored on charge and are functionally tested quarterly, consistent with emergency preparedness guidance.

NRC Request

3. Describe in detail how you assure the availability of Homestead Air Reserve Base to provide offsite support in response to a B.5.b event.

The bulletin requested that each licensee describe in detail how it assures the availability of offsite support, including a listing of offsite organizations relied upon for emergency response. The NRC Safety Evaluation documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026) states that the Homestead Air Reserve Base has the required knowledge, skills, and abilities to support response actions and that you were pursuing a letter of agreement. Homestead Air Reserve Base was not listed in your response to Question 5 of the bulletin.

FPL Response The response to Question 5 of the bulletin only listed those outside organizations that were identified in earlier correspondence and from whom formal mutual aid agreements had been obtained. The pursuit to obtain a Letter of Agreement or other formal confirmation of mutual aid with Homestead Air Reserve Base has been unsuccessful.

References

1. NRC Bulletin 2011-01, Mitigating Strategies, dated May 11,2011
2. FPL Letter L-2011-261 dated July 8, 2011, 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies
3. NRC Letter dated December 5, 2011: Turkey Point, Units 3 and 4 -Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" (TAC Nos. ME6494 and ME6495)