ML082540437
| ML082540437 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/19/2008 |
| From: | Boyce T Plant Licensing Branch II |
| To: | Stall J Florida Power & Light Co |
| Paige, Jason, NRR,301-415-5888 | |
| References | |
| GL-08-001, TAC MD7890, TAC MD7891 | |
| Download: ML082540437 (7) | |
Text
September 19, 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 UNITS 3 AND 4 - 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. MD7890 AND MD7891)
Dear Mr. Stall:
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, 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 "L-2008-105, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated May 9, 2008]], Florida Power & Light (FPL), the licensee, submitted a 3-month response to GL 2008-01 for Turkey Point Units 3 and 4 (TP-3 and TP-4). The NRC staffs assessment of the licensees responses for TP-3 and TP-4 is enclosed.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis and concluded that for TP-3 and TP-4, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action at TP-3 and TP-4 provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure regarding the content of the reports and plans for tracking long-term actions.
If you have any questions regarding this letter, please feel free to contact Brenda Mozafari at (301) 415-2020.
Sincerely,
/RA/
Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-250 and 50-251
Enclosure:
NRC Assessment of 3-Month Response cc w/encl: See next page
If you have any questions regarding this letter, please feel free to contact Brenda Mozafari at (301) 415-2020.
Sincerely,
/RA/
Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-250 and 50-251
Enclosure:
NRC Assessment of 3-Month Response cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsOgcRp MMurphy LPL2-2R/F RidsAcrsAcnw&mMailCenter JPaige RidsNrrDorlLpl2-2 RidsRgn2MailCenter RidsNrrDss RidsNrrLABClayton DBeaulieu, DPR/PGCB RidsNrrPMBMozafari SSun, DSS/SRXB RidsNrrDorlDPR WLyon, DSS/SRXB ADAMS Accession Number: ML082540437 NRR-106 OFFICE LPL II-2/PE LPL II-2/PM LPL II-2/LA PGCB:BC DSS/DD LPL II-2/BC NAME JPaige (BMozafari for)
BMozafari BClayton MMurphy*
JWermiel*
TBoyce DATE 9/11/08 9/19/08 9/19/08 9/11/08 9/16/08 9/19/08 OFFICIAL RECORD COPY
Florida Power & Light Company 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 & 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 TURKEY POINT PLANT Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Michael Kiley Plant General Manager Turkey Point Nuclear Plant Florida Power & Light Company 9760 SW. 344th Street Florida City, FL 33035 Olga Hanek, Licensing Florida Power & Light Company Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035 Don E. Grissette Vice President, Nuclear Operations, South Region Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Abdy Khanpour Vice President, Engineering Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mark E. Warner Vice President, Nuclear Plant support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Peter Wells, Acting VP, Nuclear Training and Performance Improvement Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420
Enclosure NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 TURKEY POINT UNITS 3 AND 4 DOCKET NOS. 50-250 AND 251 1.0
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, 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.
2.0 Licensees Proposed Alternative Course of Action By "L-2008-105, Three Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated May 9, 2008]], Florida Power & Light (FPL), the licensee, submitted a 3-month response to GL 2008-01 for Turkey Point Units 3 and 4 (TP-3 and TP-4). FPL indicated that it would complete, within the requested 9 months, a significant amount of the requested actions for TP-3 and TP-4, including reviews of plant design, licensing basis documentation, and system operating and testing procedures. The only GL 2008-01 reporting request that would not be completed by the requested response time is walkdowns of some segments of piping of the subject systems, including the emergency core cooling (ECC), residual heat removal (RHR),
and containment spray (CS) systems. The licensee stated that it cannot complete the walkdowns because portions of the subject systems are inaccessible during power operation due to the need to enter into radiation environments, to remove insulation from piping of the subject systems, or to erect scaffolding to obtain adequate access for the requested detailed inspections.
The licensee stated that it performed the preliminary walkdown of TP-4 during the recently completed refueling outage to scope the scaffolding and insulation removal activities for detailed inspection walkdowns. The detailed inspection walkdowns will be performed during the next refueling outage for TP-4, which is planned in the fall of 2009. These walkdowns will confirm the acceptability of the installed piping, and implement any corrective actions necessary to maintain operability of the ECC, RHR, and CS systems. As an alternative course of action, the licensee proposed a three-part submittal, comprised of an initial 9-month submittal and two subsequent final submittals, one for TP-3 and one for TP-4.
The final TP-3 submittal will document the results of the detailed walkdowns of the remaining TP-3 piping and the closure of any outstanding TP-3 issues that were not complete at the time of the first submittal. The TP-3 submittal will be provided within 90 days of completion of the TP-3 spring 2009 refueling outage.
The final TP-4 submittal will document the results of the detailed walkdowns of the remaining TP-4 piping and the closure of any outstanding TP-4 issues that were not complete at the time of the first submittal. The TP-4 submittal will be provided within 90 days of completion of the TP-4 fall 2009 refueling outage.
The licensee proposed the following for completion of the GL 2008-01 response:
(1) Provide an initial submittal by October 11, 2008, that includes the evaluation results for the completed licensing and design basis reviews, the operating and test procedure reviews and the completed walkdown information for accessible areas, as well as the schedule for any corrective actions that may be required based on these evaluations.
(2) Provide for TP-3 a complete GL 2008-01 submittal 90 days after the end of the next refueling outage that is planned for the spring of 2009 for TP-3. This submittal will complete the design evaluation review based on the completed walkdowns of inaccessible area piping, completed evaluation results, and schedule for any additional corrective actions based on the completed evaluation for TP-3.
(3) Provide for TP-4 a complete GL 2008-01 submittal 90 days after the end of the next refueling outage that is planned for the fall of 2009 for TP-4. This submittal will complete the design evaluation review based on the completed walkdowns of inaccessible area piping, completed evaluation results, and schedule for any additional corrective actions based on the completed evaluation for TP-4.
The licensee stated that because of internal and industry operating experience issues, it conducted extensive plant walkdowns, as well as procedure, drawing, and operating history reviews to identify potential gas intrusion vulnerabilities and pathways, and to add high venting capability at key locations. These walkdown and review activities resulted in several modifications and programmatic enhancement. The plant procedures require venting the ECC and RHR systems piping on a 31-day frequency. The licensee has confidence that the GL subject systems can fulfill their required functions, based on its more than 35 years of operating and testing experiences.
3.0 NRC Staff Assessment The NRC staff finds that for TP-3 and TP-4, with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and modifications associated with managing gas accumulation at TP.
The NRC staff noted that the licensees 3-month submittal dated May 9, 2008, did not clearly describe the content for the 9-month submittals. The NRC staff requests that the licensee submit the information requested in the GL as follows:
(1)
Nine-Month Initial Submittal - For the portions of the subject systems that are accessible, prior to the spring 2009 and fall 2009 refueling outages for TP-3 and TP-4, respectively, provide all GL requested information to the NRC by October 11, 2008.
(2)
Nine-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 each of the spring 2009 and fall 2009 refueling outages for TP-3 and TP-4, respectively.
For both the 9-month initial and supplemental submittals, and consistent with the information requested in the GL, the licensees 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 9, 2008, did not mention other 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. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. 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.