ML081360263
| ML081360263 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 09/25/2008 |
| From: | Lois James Plant Licensing Branch III |
| To: | Meyer L Florida Power & Light Energy Point Beach |
| Cushing, J S, NRR/DORL/LPLIII-1,415-1424 | |
| References | |
| TAC MD7864, TAC MD7865 | |
| Download: ML081360263 (4) | |
Text
September 25,2008 Mr. Larry Meyer Site Vice President FPL Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241
SUBJECT:
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2-RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7864 AND MD7865)
Dear Mr. Meyer:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated May 12, 2008, FPL Energy Point Beach, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Point Beach Nuclear Plant, Units 1 and 2. The NRC staffs assessment of the responses for Point Beach Nuclear Plant, Units 1 and 2 is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance. For Point Beach, Unit 1, the NRC staff noted the licensee did not discuss the reason or basis for the acceptability for why it cannot not meet the requested 9-month response date for the detailed walkdowns of GL piping sections at Unit 1 that are readily accessible while at power. The NRC staff requests that the licensee submit a 3-month supplemental response to revise its proposed alternative course of action for Point Beach, Unit 1, related to its 9-month initial response and its 9-month supplemental (post-outage) response as described in the enclosure.
The NRC staff concluded that for Point Beach, Unit 2, with the exception of the clarifications and associated requests discussed in the enclosure, the licensees proposed alternative course of action is acceptable. This letter allows the licensee to implement its proposed alternative course of action for Point Beach, Unit 2, provided that, implementation is consistent with the clarifications and associated requests discussed in the enclosure.
If you have any questions regarding this letter, please feel free to contact Jack Cushing at (301) 415-1424.
Sincerely,
/RA/
Lois James, Chief Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
As stated cc w/encl: See next page
The NRC staff concluded that for Point Beach, Unit 2, with the exception of the clarifications and associated requests discussed in the enclosure, the licensees proposed alternative course of action is acceptable. This letter allows the licensee to implement its proposed alternative course of action for Point Beach, Unit 2, provided that, implementation is consistent with the clarifications and associated requests discussed in the enclosure.
If you have any questions regarding this letter, please feel free to contact Jack Cushing at (301) 415-1424.
Sincerely,
/RA/
Lois James, Chief Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsOgcRp Resource LPL3-1 R/F RidsAcrsAcnw_MailCTR Resource RidsNrrLATHarris Resource RidsNrrLABTully Resource RidsNrrPMJCushing Resource RidsRgn3MailCenter Resource RidsNRrrDorlLpl3-1Resource RidsNrrDorlDPR DBeaulieu, DPR/PGCB SSun, DSS/SRX WLyon, DSS/SRXB ADAMS Accession Number: ML081360263 NRR-106 OFFICE NRR/LPL3-1:PM NRR/LPL3-1:LA NRR/DPR:BC NRR/DSS:DD NRR/LPL3-1:BC NAME JCushing THarris BT for MMurphy JWermiel LJames DATE 09/22/08 09/23/08 09/15/08 09/09/08 09/25/08 OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 POINT BEACH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-266 AND 50-301
- 1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated May 12, 2008, FPL Energy Point Beach, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Point Beach Nuclear Plant, Units 1 and 2. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of some segments of piping in the GL subject systems, including the high and low pressure safety injection systems, the shutdown system and the containment spray system cannot be completed for the following reasons: (1) walkdowns of these systems would require entry into areas of high radiation; (2) erection of some scaffolding is impractical due to locations in high radiation areas, or near sensitive or safety related equipment; and, (3) removal of insulation from piping of the GL subject systems may be needed.
The licensee also stated that the evaluation results for the completed licensing and design basis reviews, the operating and test procedure reviews, evaluations of accessible piping for Unit 2, as well as the schedule for corrective actions that may be required based on these evaluations will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008).
As an alternative course of action, the licensee plans to complete walkdowns of inaccessible subject system piping during the next scheduled refueling outages, which are presently scheduled for fall 2008 for Unit 1 and fall 2009 for Unit 2. The licensees letter dated May 12, 2008, listed the following commitments:
- 1. Provide an initial GL 2008-01 submittal by October 11, 2008, which includes the evaluation results for the completed licensing and design basis reviews, the operating and test procedure reviews, and evaluations of the accessible GL piping for Unit 2, as well as the schedule for corrective actions that may be required based on these evaluations.
- 2. Provide a complete Unit 1 GL 2008-01 submittal 90 days after the end of the next refueling outage that is planned for the fall of 2008. This submittal will include the complete design evaluation reviews based on the detailed both accessible and inaccessible GL piping section walkdowns performed.
- 3. Provide a complete Unit 2 GL 2008-01 submittal 90 days after the end of the next refueling outage that is planned for the fall of 2009. This submittal will complete the design evaluation review based on detailed walkdowns of previously inaccessible GL piping sections performed during the Unit 2 outage.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. The preliminary walk downs of Unit 2 found no issues that would raise a question as to the operability of the subject systems.
- 2. The emergency core cooling system, residual heat removal and containment systems are routinely tested in accordance with the technical specifications and in-service testing (IST) programs.
- 3. The on-line tests and the routine evolutions during plant shutdowns (decay heat removal operation) involve most of the design basis piping alignments of these systems for both the suction and the discharge piping and have consistently demonstrated their operability.
Based on the above considerations, the licensee concluded that completing performance of the preliminary and final walkdowns and subsequent complete evaluations of the subject piping outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment Point Beach Unit 1 The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance. The NRC staff noted the licensee did not discuss the reason or basis for the acceptability for why it cannot not meet the requested 9-month response date for the detailed walkdowns of GL piping sections at Unit 1 that are readily accessible while at power.
The NRC staff requests that the licensee submit a 3-month supplemental response for Point Beach, Unit 1, to revise its proposed alternative course of action related to its 9-month initial and supplemental response. The NRC staff requests the licensee to submit the information requested in GL 2008-01 for Point Beach, Unit 1, as follows:
- 1. 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Point Beach, Unit 1, fall 2008 refueling outage, provide all GL requested information to the NRC by October 11, 2008.
- 2. 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days after the end of the fall 2008 refueling outage at Point Beach, Unit 1.
Point Beach Unit 2 For Point Beach Unit 2, the NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described testing associated with managing gas accumulation at Point Beach Nuclear Plant, Unit 2. The NRC staff notes examples where the licensees 3-month submittal dated May 12, 2008, does not clearly describe the content for the 9-month submittals for Unit 2. Specifically, it is unclear whether the licensees 9-month initial response for Point Beach, Unit 2, will include all GL requested information for accessible GL piping. The NRC staff requests the licensee to submit the information requested in GL 2008-01 for Point Beach, Unit 2, as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Point Beach Nuclear Plant, Unit 2, fall 2009 refueling outage, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittals - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days after the end of the fall 2009 refueling outage at Point Beach Nuclear Plant, Unit 2, respectively.
Point Beach Units 1 and 2 For Point Beach, Units 1 and 2, for each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated May 12, 2008, did not mention certain potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.
Point Beach Nuclear Plant, Units 1 and 2 cc:
Licensing Manager FPL Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Ken Duveneck Town Chairman Town of Two Creeks 13017 State Highway 42 Mishicot, WI 54228 Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, WI 54241 Chairman Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Mr. J. A. Stall Executive Vice President, Nuclear and Chief Nuclear Officer FPL Group P. O. Box 14000 Juno Beach, FL 33408-0420 T. O. Jones Vice President, Nuclear Operations Mid-West Region Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Peter Wells Acting Vice President, Nuclear Training and Performance Improvement Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 John Bjorseth Plant General Manager Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241 Mark E. Warner Vice President, Nuclear Plant Support Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. Antonio Fernandez Senior Attorney FPL Energy, LLC P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. Mano Nazar Senior Vice President and Nuclear Chief Operating Officer FPL Energy, LLC P. O. Box 14000 Juno Beach, FL 33408-0420 Abdy Khanpour Vice President Engineering Support FPL Energy, LLC P. O. Box 14000 Juno Beach, FL 33408-0420 J. Kitsembel Electric Division Public Service Commission of Wisconsin P. O. Box 7854 Madison, WI 53707-7854 Mr. M. S. Ross Managing Attorney FPL Energy, LLC P. O. Box 14000 Juno Beach, FL 33408-0420