SBK-L-04077, Letter from FPL Energy Seabrook Station - Response to Request for Additional Information, Inspection Report 50-443/2004-003/Predecisional Enforcement Conference. with Slide Attachment

Letter from FPL Energy Seabrook Station - Response to Request for Additional Information, Inspection Report 50-443/2004-003/Predecisional Enforcement Conference. with Slide Attachment

ML043230440
Person / Time
Site:	Seabrook
Issue date:	10/08/2004
From:	Warner M Florida Power & Light Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-04-003, SBK-L-04077 RGN-001
Download: ML043230440 (13)

Text

FPL Energy Seabrook Station ocr 12 p

FPL Energy Seabrook Station

"" '2h"0. Box 300 Seabrook, NH 03874 (603) 773-7000 October 8,2004 Docket No. 50-443 SBK-L-04077 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 205 5 5-000 1 Seabrook Station Response to Request for Additional Information Inspection Report 50-0443/2004003/Predecisional Enforcement Conference FPL Energy Seabrook, LLC (FPL Energy Seabrook) provides in the enclosure the additional information requested by the Region I staff during the September 23, 2004 predecisional enforcement conference to discuss an apparent violation identified in Inspection Report 50-443/2004003. The additional information addresses questions regarding the manual operation of the turbine building rollup doors, rollup door operation during flooding and a review of expansion joint operating experience. As noted in the attached slides, the additional information supports our position that the operators will be able to open the rollup door in a timely manner in all conditions and there is no industry operating experience of a catastrophic failure of an expansionjoint of the type used at Seabrook Station.

The inclusion of the additional information does not change our conclusions, as presented during the predecisional enforcement conference, regarding the results of the 1 OCFR50.59 Evaluation performed under the new rule or the significance of the apparent violation.

Copies of the attached slides were provided to Region I by fax on October 4,2004.

U.S. Nuclear Regulatory Commission SBK-L-04077 / Page 2 Very truly yours, FPL Energy Seabrook, LLC I

Site Vice President cc.

S. J. Collins, NRC Region I Administrator S. P. Wall, NRC Project Manager, Project Directorate 1-2 G. T. Dentel, NRC Resident Inspector Dr. R. R. Bellamy, Region I Branch Chief

ENCLOSURE TO SBK-L-04077 Presentation ( 1 0 s l i d e s )

Manual Operation of Rollup Doors Reviewed original NSO timing sheets.

- 3 NSO's unfamiliar w/ manual operation, I familiar

- I NSO (unfamiliar) not given opportunity to open door

- 3 NSO's successful Effect of manual door operation on timing

- First rollup door adds 2.1 5 minutes

- Second rollup door adds 1.2 minutes

- Total time from start of scenario to manually open doors is 7.96 minutes

- Opening doors within 8 minutes approximately doubles FPL Energy Seabrook Station 1

Manual Operation of Rollup Doors (Continued)

Res u Its HEP assumption of NSOs not trained to open doors yields minimal impact on CDF increase Therefore, no impact on original conclusions FPL Energy Seabrook Station 2

Expansion Joint Operating Experience Reviewed rubber expansion joint failure data referred by N RC Reviewed EPRIINMAC Report 1008635, Ex pa n s i o n J o i n t M a i n t e n a n ce G u id e

- Most failures in systems w/ different operating parameters than

- No indication of gross failures that resulted in leakage

- No circumferential tears identified

- EPDM material, as used at Seabrook Station, our Circulating Water system approaching the 56,000 gpm design Will not age rapidly when exposed to low temperature Deterioration of reinforcing rings and cord delamination will FPL Energy Seabrook Station progress slowly, allowing detection before failure S

3

Expansion Joint Operating Experience (Continued)

Res u Its No impact on initiating event frequency No impact on risk increase.

FPL Energy Seabrook Station

Expansion Joint Operating Experience Additional Information From EPRIINMAC Report 1008635

- 15 of 31 events: smaller (241,301,3411) expansion joints less robust consfrucfion and less force fo deflecf joint

- I 5 of 31 events: condensate pump expansion joints, higher temperature, more rapid aging

- 20 of 31 events: expansion joints on suction or discharge of pumps - higher stresses and pressure surges

- I event: 108 expansion joint, 2000 gpm leak-Water Hammer initiated FPL Energy Seabrook Station 5

Expansion Joint Operating Experience EPRI Failure Data for Rubber Expansion Joints Plant AN0 2 Beaver Valley Beaver Valley I Beaver Valley 2 Beaver Valley 2 Brunswick 1 Byron I Calvert Cliffs I

&E 18 I 9 4

10 14 7

3 Event Description 30-in. expansion joint condensate pump.

Expansion joint inspected and found to have pinholes because of aging Expansion joint collapsed 24-in. SW expansion joint ruptured because of erosion of tube (replaced in 1985) 30-in. condensate pump suction expansion joint deformed and partially collapsed, no leakage 30-in. suction expansion joint for condensate pump found to have pinhole leak Rupture of screen wash pump expansion joint Condensate pump expansion joint cover found torn 180 degrees 24-in.suction side of condensate pump expansion joint-tube imploded and core of joint visible FPL Energy Seabrook Station 6

Expansion Joint Operating Experience EPRl Failure Data for Rubber Expansion Joints Plant

!!!!E Clinton 1 4

Clinton 1 3

Comanche Peak I 8 Cook I 15 Cook 2 9

Crystal River 3 8

Diablo Canyon 1,2 13 Ft. St. Vrain I 14 Event Descri D t i o n Condenser water box over-pressurized, damage to water box expansion joint, no leakage Inlet expansion joint to condenser leaking (I cup/hr)

Circulation pump expansion joint ruptured because of normal aging 8-in. SW header expansion joint leaked because of 4-in. gash in the joint, cause unknown Expansion joint in discharge header of essential service water pump ruptured because of degradation IO-in. SW pump suction expansion joint failed - hole in joint Two cooling system synthetic expansion joints experienced ca tast ro p h ic fa i I u res CCW expansion joint failed because of degradation FPL Energy Seabrook Station 7

Expansion Joint Operating Experience EPRI Failure Data for Rubber Expansion Joints Plant Indian Pt. 3 Indian Pt. 3 Indian Pt. 3 Indian Pt. 3 LaSalle 1&2 Limerick 1 Limerick 2 Millstone 2 FPL Energy Seabrook Station

&E 12 I 1 16 17 I

12 2

Event Description 30-in. condensate pump expansion joint leaking Expansion joint on suction side of condensate pump deformed and leaked because of degradation 30-in. expansion joint on suction side of condensate pump had minor leakage (excessive forces)

Expansion joint on suction side of condensate pump deformed and leaked because of degradation 108-in. circ water pump expansion joint failed resulting in flooding (2000 gpm) water hammer Leak in expansion joint on suction side of condensate Pump Leak on ESW expansion joint Main feedwater pump turbine condensor pump expansion joint developed leak because of high temperature 8

Expansion Joint Operating Experience EPRl Failure Data for Rubber Expansion Joints Plant Sequoyah 1 St. Lucie I St. Lucie I VC Summer VC Summer VC Summer Turkey Point 3

&E!

13 I O 14 11 9

9 16 Event Description Main feedwater pump turbine condenser pump expansion joint developed leak because of high temperature 30-in. SW system, rubber expansion joint ruptured because of aging and cyclic fatigue Intake 30-in. cooling water expansion joint had through wall leak, aging 36-in. expansion joint on suction side of condensate pump had a hole in liner with no leakage 36-in. expansion joint on suction side of condensate pump developed leak, cyclic fatigue 36-in. expansion joint on suction side of condensate pump developed leak, cyclic fatigue 30-in. suction expansion joint for condensate pump leaked Seabrook Station 9

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