ML081200606

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Approval of Extension Request for GL 2004-02
ML081200606
Person / Time
Site: Turkey Point NextEra Energy icon.png
Issue date: 04/29/2008
From: Mozafari B
NRC/NRR/ADRO/DORL/LPLII-2
To: Stall J
Florida Power & Light Co
Mozafari B, NRR/ADRO/DORL, 415-2020
References
GL-04-002, TAC MC4726
Download: ML081200606 (6)


Text

April 29, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT NUCLEAR PLANT, UNIT 4 - APPROVAL OF EXTENSION REQUEST FOR GENERIC LETTER 2004-02 "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED WATER REACTORS" (TAC NO. MC4726)

Dear Mr. Stall:

By letter dated April 14, 2008, Florida Power and Light Company (FPL) requested an extension of the date for completing sump clogging corrective actions at Turkey Point Unit 4, as specified in the U.S. Nuclear Regulatory Commission (NRC) letter dated April 13, 2006. Specifically, FPL requested an extension until June 30, 2008, for completing the ex-vessel downstream effects evaluations that support high head safety injection pump acceptance. The NRC staff has evaluated the FPL request and concluded that it is acceptable to extend the due date for completing these evaluations at Turkey Point Unit 4 until June 30, 2008.

If the evaluations completed by June 30, 2008, are satisfactory, the results are to be submitted with the updated supplemental report to Generic Letter 2004-02, which FPL has committed to submit within three months following the spring 2008 outage. FPL will contact the NRC if these evaluations do not demonstrate acceptable results and additional corrective actions are required.

The NRC staff evaluation is enclosed. If you have any questions, please contact me at 301-415-2020.

Sincerely,

/RA by BMoroney Acting for?

Brenda L. Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No: 50-251

Enclosure:

As stated

April 29, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT NUCLEAR PLANT, UNIT 4 - APPROVAL OF EXTENSION REQUEST FOR GENERIC LETTER 2004-02 "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED WATER REACTORS" (TAC NO. MC4726)

Dear Mr. Stall:

By letter dated April 14, 2008, Florida Power and Light Company (FPL) requested an extension of the date for completing sump clogging corrective actions at Turkey Point Unit 4, as specified in the U.S. Nuclear Regulatory Commission (NRC) letter dated April 13, 2006. Specifically, FPL requested an extension until June 30, 2008, for completing the ex-vessel downstream effects evaluations that support high head safety injection pump acceptance. The NRC staff has evaluated the FPL request and concluded that it is acceptable to extend the due date for completing these evaluations at Turkey Point Unit 4 until June 30, 2008.

If the evaluations completed by June 30, 2008, are satisfactory, the results are to be submitted with the updated supplemental report to Generic Letter 2004-02, which FPL has committed to submit within three months following the spring 2008 outage. FPL will contact the NRC if these evaluations do not demonstrate acceptable results and additional corrective actions are required.

The NRC staff evaluation is enclosed. If you have any questions, please contact me at 301-415-2020.

Sincerely,

/RA by BMoroney Acting for/

Brenda L. Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No: 50-251

Enclosure:

As stated Distribution:

PUBLIC LPL2-2 R/F RidsNrrPMBMozafari RidsNrrDorlLpl2-2 RidsNrrLABClayton (Hard copy)

RidsNrrDssSsib RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn2MailCenter JGolla, NRR/SSIB LWhitney, NRR/SSIB RTorres, NRR/SSIB ML081200606 OFFICE LPL2-2/PM LPL2-2/LA SSIB/BC LPL2-2/BC NAME Bmoroney for BMozafari RSola for BClayton MScott By memo TBoyce DATE 04/21/08 04/29/08 4/29/08 04/29/08 OFFICIAL RECORD COPY

GENERIC LETTER 2004-02 CORRECTIVE ACTIONS EXTENSION REQUEST APPROVAL FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNIT 4 In a January 27, 2006, supplemental response to U.S. Nuclear Regulatory Commission (NRC)

Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors (Agencywide Documentation and Management System (ADAMS) Accession No. ML060310245), Florida Power and Light (FPL) described its activities directed at resolution of the Generic Safety Issue (GSI)-191 containment sump issue. In Attachment 1 to the January 27, 2006, letter, FPL provided bases for a conclusion that it was acceptable to extend the completion of the corrective actions for the issues discussed in GL 2004-02 until the Turkey Point Unit 4 spring 2008 refueling outage, which was scheduled to begin on April 27, 2008.

In a letter dated April 13, 2006 (ADAMS Accession No. ML060950574), the NRC approved an extension for completion of GL 2004-02 corrective actions for Turkey Point Unit 4 until the completion of the spring 2008 refueling outage. Specifically, FPL was to complete final modifications, which include replacement of interim sump strainers with the final/permanent sump strainer system, replacement of existing reactor coolant pump insulation with reflective metallic insulation, and replacement of mechanical seals and removal of the cyclone separators on the containment spray pumps.

Also, as discussed in FPLs supplemental response to the NRC GL 2004-02 for Turkey Point Units 3 and 4, dated February 28, 2008 (ADAMS Accession No. ML080710429), other supporting activities including analysis, testing and administrative/procedural changes would be completed by the end of the spring 2008 outage. These include coating tests that support a qualified coating Zone Of Influence of 4.0D; integrated debris and chemical effects testing to validate the strainer design (large flume test); walkdowns to identify potential recirculation flow path chokepoints and quantities of latent and miscellaneous debris in the containment; programmatic activities to control the quantity of unqualified/degraded coatings in containment; assessment that current containment housekeeping procedures are acceptable; and configuration control of insulation within containment.

In a teleconference with the NRC staff on March 27, 2008, FPL stated that it had recently identified that the high head safety injection (HHSI) pumps do not meet the shaft stiffness acceptance criteria utilizing the methodology in Westinghouse topical report WCAP-16406-P, Revision 1. In accordance with the provisions (alternative analytical options) of WCAP-16406-P, Revision 1, a refined rotor dynamic analysis will be performed to determine if an increased wear limit is acceptable. In addition, a review of existing conservative margins may also be conducted to evaluate wear effects on the pumps. These two options are described in WCAP-16406-P, Revision 1. FPL plans to complete this analytical work by June 30, 2008; however, this date is later than the currently scheduled restart for Turkey Point Unit 4.

By letter dated April 14, 2008 (ADAMS Accession No. ML081070252), FPL requested an additional extension for Turkey Point Unit 4 in order to complete the ex-vessel downstream effects evaluations that support HHSI pump acceptance. If these evaluations are satisfactory, the results of the HHSI pump analyses will be provided to the NRC staff with the Turkey Point Unit 4 updated supplemental response to GL 2004-02. As stated in the February 28, 2008 supplemental response, FPL will submit a follow-up (updated) supplemental response to GL 2004-02 within three months following the spring 2008 refueling outage. FPL stated that if these evaluations do not demonstrate acceptable results and additional corrective actions are required, it will contact the NRC.

The NRC staff based its review of extension requests for the due date for completion of GL 2004-02 corrective actions on criteria stated in SECY-06-0078, Status of Resolution of GSI-191, Assessment of Debris Accumulation on PWR Sump Performance. Specifically, an extension may be granted if:

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, 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 emergency core cooling system (ECCS) and containment spray system (CSS) functions during the extension period, and For proposed extensions beyond several months, a licensees request will more likely be accepted if the proposed mitigative measures include temporary physical improvements to the ECCS sump or materials inside containment to better ensure a high level of ECCS sump performance.

With regard to the first extension criterion, FPL stated that with the exception of the requested analysis extension for the HHSI pumps to June 30, 2008, FPL will have completed all planned GL 2004-02 improvements to Turkey Point Unit 4 by the completion of the spring 2008 outage.

These improvements will result in significantly improved safety margins associated with the ECCS and CSS systems.

With regard to the second extension criterion, FPL stated that in addition to modifications made in the fall 2006 outage, walkdowns to identify potential recirculation flow path chokepoints and quantities of latent and miscellaneous debris in the containment; programmatic activities to control the quantity of unqualified/degraded coatings in containment; an assessment that current containment housekeeping procedures are acceptable; and procedures for configuration control of insulation within containment, are all scheduled to be complete before startup from the spring 2008 outage, as described in the February 28, 2008, supplemental response, thus minimizing the risk of degraded ECCS and CSS functions during the extension period.

With regard to the third extension criterion, the significant modifications discussed in the licensees April 14, 2008, extension request, in particular the replacement of interim sump strainers with the final/permanent sump strainer system, replacement of existing reactor coolant pump insulation with reflective metallic insulation, and replacement of mechanical seals and removal of the cyclone separators on the containment spray pumps, satisfy this extension criterion.

Based on the licensee having satisfactorily addressed the SECY-06-0078 due date extension criteria as discussed above, the NRC staff finds it is acceptable to extend the completion date for ex-vessel downstream effects evaluations and any associated corrective actions for Turkey Point Unit 4 until June 30, 2008. Should the time period for potential Turkey Point Unit 4 corrective actions be determined by FPL to extend beyond June 30, 2008, FPL will need to submit an additional extension request to the NRC.

J. Stall Florida Power and Light Company TURKEY POINT PLANT cc:

Mr. Mano Nazar Senior Vice President and Nuclear Chief Operating Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.

Suite 220 Washington, DC 20004 William Jefferson, Jr.

Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 County Manager Miami-Dade County 111 Northwest 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission 9762 SW. 344th Street Florida City, Florida 33035 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Michael Kiley Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Paul Infanger, Licensing Manager Florida Power and Light Company Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035 Don E. Grissette Vice President, Nuclear Training and Performance Improvement Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President, Nuclear Technical Services Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420