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Category:Letter
MONTHYEARML24023A0342024-02-0505 February 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0038 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML23341A2102024-01-22022 January 2024 LTR-23-0216-1 - Closure Letter - 2.206 Petition for License Renewal Plant Reactor Pressure Vessel Embrittlement ML23320A3062024-01-22022 January 2024 Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project L-2024-007, Inservice Inspection Program Owner'S Activity Report (OAR-1)2024-01-18018 January 2024 Inservice Inspection Program Owner'S Activity Report (OAR-1) L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-166, Turkey Points Units 3 and 4, Correction to the 2022 Annual Radioactive Effluent Release Report2023-12-0606 December 2023 Turkey Points Units 3 and 4, Correction to the 2022 Annual Radioactive Effluent Release Report ML23340A0332023-12-0101 December 2023 FPL to Fws, Comments Submitted by Florida Power and Light on the Species Status Assessment Accompanying the September 20, 2023 Proposed Threatened Species Status with Section 4(d) Rule for the Miami Cave Crayfish L-2023-172, Supplement to Exemption Request Regarding Enhanced Weapons. Firearms Background Checks. and Security Event Notifications Final Rule2023-11-29029 November 2023 Supplement to Exemption Request Regarding Enhanced Weapons. Firearms Background Checks. and Security Event Notifications Final Rule L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, ML23333A0152023-11-27027 November 2023 Attachment G - Arcadis Memo Re FPL Year 4 Raasr Final (June 2, 2023, Appended to Derm letter)-1 ML23333A0102023-11-27027 November 2023 Attachment B - 11/07/2022 - Waterkeeper Scoping Comments-1 L-2023-146, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles2023-11-15015 November 2023 License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles IR 05000250/20230032023-11-0909 November 2023 Integrated Inspection Report 05000250/2023003 and 05000251/2023003 ML23310A1342023-11-0404 November 2023 10 CFR 2.206 Petition - LTR-23-0216-1 Petition Amendment; Turkey Point Subsequent Renewal with Petitioner 11/04/2023 ML24016A2622023-10-25025 October 2023 Subsequent License Renewal Updated List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected Project L-2023-077, License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis2023-10-11011 October 2023 License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published IR 05000250/20230102023-09-29029 September 2023 Biennial Problem Identification and Resolution Inspection Report 05000250/2023010 and 05000251/2023010 ML23234A1922023-09-27027 September 2023 Issuance of Amendment Nos. 297 and 290 Regarding Conversion to Improved Standard Technical Specifications ML23265A5492023-09-22022 September 2023 Transmittal of WCAP-18830-P/NP Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles to Support a License Amendment Request from FPL - License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis ML23243A9522023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application ML23243A9542023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application ML23243A9532023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application ML23243A9552023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application - Tribe- Section 106 Letters ML23199A2352023-09-0505 September 2023 Letter to EPA-Turkey Point Nuclear Generating Station, Units 3 and 4 - Notice of Availability of Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal ML23199A2482023-09-0505 September 2023 Ltr to Florida Power and Light Co - Turkey Point Nuclear Generating Units 3 and 4 - Notice of Availability of Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal L-2023-110, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-08-25025 August 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project IR 05000250/20230052023-08-21021 August 2023 Updated Inspection Plan for Turkey Point, Units 3 & 4 (Report 05000250/2023005 and 05000251/2023005) L-2023-115, Inservice Inspection Program Owner'S Activity Report (OAR-1)2023-08-21021 August 2023 Inservice Inspection Program Owner'S Activity Report (OAR-1) L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update IR 05000250/20230022023-08-14014 August 2023 Integrated Inspection Report 05000250/2023002 and 05000251/2023002 L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 ML23242A0922023-08-0606 August 2023 Request for Withholding Information from Public Disclosure for Turkey Point Nuclear Generating Unit Nos. 3 and 4 ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment ML23198A2702023-08-0303 August 2023 Issuance of the Site-Specific Environmental Impact Statement Scoping Process Summary Report Associated with the Turkey Point Nuclear Generating Unit Numbers 3 and 4, Subsequent License Renewal Application, Environmental Report Supplement 2 L-2023-094, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-07-27027 July 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project ML23178A1872023-07-25025 July 2023 Review of the Spring 2022 Steam Generator Tube Inspections During Refueling Outage No. 33 ML23188A1242023-07-20020 July 2023 Acknowledgment of Temporary Suspension Request for License Request for License Amendment Request Reactor Protection System, Engineered Safety Features System, and Nuclear Instrumentation System ML23200A0672023-07-18018 July 2023 Tp 2023 RQ Inspection Notification Letter ML23173A0812023-07-17017 July 2023 Supplement to Regulatory Audit Plan in Support of Review of License Amendment Request Supporting Digital Instrumentation & Control Modernization Project (EPID L-2022-LLA-0105) - Non-Proprietary L-2023-087, Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452)2023-06-29029 June 2023 Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452) 2024-02-05
[Table view] Category:Safety Evaluation
MONTHYEARML23320A3062024-01-22022 January 2024 Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project ML23234A1922023-09-27027 September 2023 Issuance of Amendment Nos. 297 and 290 Regarding Conversion to Improved Standard Technical Specifications ML22307A1152022-11-28028 November 2022 Authorization of Relief Request No. 10 Part II Related to Repair of Intake Cooling Water Discharge Piping (EPID L-2022-LLR-0032) (Non-Proprietary) ML22028A0662022-05-24024 May 2022 Issuance of Amendment Nos. 296 and 289 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology (EPID L-2021-LLA-0070)- Non-Proprietary ML22123A1922022-05-10010 May 2022 Authorization of Relief Request Nos. 8 and 9 Regarding Extension of Inspection Interval for Reactor Pressure Vessel Welds ML22069A7112022-03-16016 March 2022 Authorization of Relief Request No. 10 Regarding Use of ASME Code Case N-513-4 for Extended Period for Intake Cooling Water Discharge Piping ML21032A0202021-02-26026 February 2021 Issuance of Amendment Nos. 295 and 268 Concerning Extension of Containment Leak Rate Testing Frequency ML20198M4982021-01-27027 January 2021 Issuance of Amendment Nos. 294 and 267 Regarding Emergency Action Level Scheme Upgrade (EPID L-2019-LLA-0271) (L-2019-203) ML20287A5512020-11-0606 November 2020 Approval of Alternative to Use ASME Code Section XI IWA-4340 - for Repairs of Component Cooling Water System Piping ML20237F3852020-10-20020 October 2020 Issuance of Amendment Nos. 293 and 286 Regarding Containment Atmospheric Radioactivity Ventilation Isolation and Leakage Detection System ML20104B5272020-04-16016 April 2020 Issuance of Exigent Amendment No. 291 Concerning the Deferral of Steam Generator Inspections ML19357A1952020-02-10010 February 2020 Unit No.1; & Turkey Point Nuclear Generating Unit Nos. 3 & 4 - Issuance of Amendments Nos. 265, 268, 164, 290, and 284 Revise Technical Specifications to Adopt TSTF-563 ML20015A1232020-02-0606 February 2020 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19266A5852019-12-17017 December 2019 Issuance of Amendment Nos. 289 and 283 Technical Specification Applicability to Equipment Shared Between Units and Exception to Technical Specification 4.0.4 ML19031C8912019-08-15015 August 2019 Issuance of Amendment Nos. 288 and 282 Regarding Revised Reactor Core Safety Limit to Reflect WCAP-17642-PA Revision 1 ML19148A7442019-07-31031 July 2019 Issuance of Amendment Nos. 161, 249, 200, 287, and 281 to Add Technical Specification Limiting Condition for Operation 3.0.6 ML19064A9032019-03-27027 March 2019 Issuance of Amendments Regarding Transition License Conditions for Reactor Coolant Pump Seals ML18354A6732019-03-18018 March 2019 Issuance of Amendments Regarding Technical Specifications Changes to Modify Emergency Diesel Generator Partial-Load Rejection Surveillance Requirement ML18270A4292018-12-0303 December 2018 Issuance of Amendments Nos. 284 and 278 Regarding Adoption of Risk-Informed Completion Times in Technical Specifications (CAC Nos. MF5455 and MF5456; EPID L-2014-LLA-0002) ML18255A3602018-11-14014 November 2018 Issuance of Amendments Regarding Technical Specifications Changes to Address Non-Conservative Actions for Containment and Control Room Ventilation Functions ML18130A4662018-06-12012 June 2018 Amendments Regarding Technical Specifications Pertaining to IST Program and ISI Program Requirements and Surveillance Frequency Control Program Applicability ML18106B1212018-04-25025 April 2018 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML18071A0802018-04-0606 April 2018 Correction to Safety Evaluation for Amendment Nos. 278 and 273 Regarding the Technical Specification Requirements Pertaining to Mode Change Limitations (CAC Nos. MF9903 and MF9904; EPID L-2017-LLA-0254) ML18019A0782018-03-19019 March 2018 Issuance of Amendments Regarding the Elimination of Certain Technical Specification Reporting Requirements (CAC Nos. MF9601 and MF9602; EPID L-2017-LLA-0213) ML18018A5592018-02-20020 February 2018 Issuance of Amendments Regarding the Technical Specification Requirements Pertaining to Mode Change Limitations (CAC Nos. MF9903 and MF9904; EPID L-2017-LLA-0254) ML17228A5632017-10-26026 October 2017 Issuance of Amendments Regarding Technical Specifications for High-Range Noble Gas Effluent Monitors ML17209A3192017-09-28028 September 2017 Issuance of Amendments Regarding Technical Specifications for Auxiliary Feedwater Actuation ML17213A8632017-08-29029 August 2017 Safety Evaluation for Relief Request No. PR-03, for the Fifth 10 Year Inservice Testing Interval Regarding Boric Acid Transfer Pump Testing Instrumentation ML17172A1152017-08-0303 August 2017 Turkey Point Nuclear Plant Generating Unit Nos. 3 and 4 - Issuance of Amendments Regarding Technical Specifications for Control Room Emergency Ventilation System (CAC Nos. MF8221 and MF8222) ML17122A1402017-05-10010 May 2017 Safety Evaluation for Relief Request No. 5 for Fifth 10-Year Inservice Inspection Interval ML17027A0782017-04-0707 April 2017 Issuance of Amendments Regarding Technical Specifications for Inservice Testing Programs (CAC Nos. MF8202 Through MF8209) ML16335A1952017-02-14014 February 2017 Issuance of Amendments Regarding Technical Specifications for Auxiliary Feedwater Pumps ML17004A2922017-02-0909 February 2017 Issuance of Amendments Regarding Technical Specifications for Snubbers ML16330A1182016-12-15015 December 2016 NextEra Fleet - Safety Evaluation for Proposed Alternative to the American Society of Mechanical Engineers Operation and Maintenance Code by Adoption of Approved Code Case OMN-20, Inservice Test Frequency (CAC Nos. MF8195 Through MF8201) ML16279A4552016-10-28028 October 2016 Turkey Point Nuclear Generating Station Units 3 & 4 - Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 ML16293A7782016-10-26026 October 2016 Turkey Point Nuclear Generating, Unit Nos. 3 and 4 - Safety Evaluation for Relief Request No. 4 for Fifth 10 Year Inservice Inspection Interval - Risk-Informed Inservice Inspection Program (CAC Nos. MF7277 and MF7278) ML16120A4732016-06-20020 June 2016 Issuance of Amendments Regarding Technical Specifications for Moderator Temperature Coefficient Measurements ML16004A0192016-04-26026 April 2016 Issuance of Amendments Regarding Technical Specification Figure for the Boric Acid Tank Minimum Volume ML16040A3732016-03-29029 March 2016 Issuance of Amendments Regarding Technical Specifications for Communications and the Manipulator Crane ML16047A1182016-03-0909 March 2016 Safety Evaluation for Relief Request No. 3 for Fifth 10-Year Inservice Inspection Interval - Alternative for Examination of Snubbers (CAC Nos. MF6386 and MF6387) ML16008B0722016-02-25025 February 2016 Issuance of Amendments Regarding Technical Specifications for Facility Staff Qualifications for Licensed Operators ML16011A4402016-02-0101 February 2016 Safety Evaluation for Relief Request No. 2 for the Fifth 10-Year Inservice Inspection Interval Regarding the Amount of Coverage Obtained During Specific Examinations of the Regenerative Heat Exchanger Welds (MF6384-MF6385) ML16011A2052016-01-22022 January 2016 Safety Evaluation for Relief Request No. PR-02, for the Fifth 10-Year Inservice Testing Interval Regarding Requirements for the Quarterly Testing of the Residual Heat Removal Pumps (CAC Nos. MF6388 & MF6389) ML15350A2032015-12-23023 December 2015 Safety Evaluation for Relief Request No. 16, for the Fourth 10-Year Inservice Inspection Interval Regarding the Amount of Coverage Obtained During Specific Examinations ML15352A1622015-12-23023 December 2015 Safety Evaluation for Relief Request No. 17, for the Fourth 10-Year Inservice Inspection Interval Regarding the Amount of Coverage Obtained During Specific Examinations ML15328A2402015-12-11011 December 2015 Safety Evaluation for Relief Request No. 15, for the Fourth 10-Year Inservice Inspection Interval Regarding the Amount of Coverage Obtained During Specific Examinations ML15328A1082015-12-0909 December 2015 Safety Evaluation for Relief Request No. PR-01, for the Fifth 10-Yeaer Inservice Testing Interval Regarding Requirements for the Quarterly Testing of the Boric Acid Transfer Pumps ML15294A4432015-11-0909 November 2015 Issuance of Amendments Regarding Emergency Core Cooling System Technical Specifications ML15271A3252015-10-14014 October 2015 Safety Evaluation for Relief Request No. 1, Revision 1 for Fifth 10-Year Inservice Inspection Interval - Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal ML15233A3792015-09-28028 September 2015 Issuance of Amendments Regarding Cyber Security Milestone 8 Completion Date in the Renewed Facility Operating Licenses 2024-01-22
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 9, 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 - SAFETY EVALUATION FOR RELIEF REQUEST NO.3 AND RELIEF REQUEST NO.4 FOR THE USE OF A RISK-INFORMED INSERVICE INSPECTION PROGRAM (TAC NOS. MD7740 AND MD8875)
Dear Mr. Stall:
By letters L-2007-204 and L-2007-205 to the U.S. Nuclear Regulatory Commission (NRC) dated December 7,2007, as supplemented in letter L-2008-181 dated August 22,2008, Florida Power and Light submitted Relief Requests Number 3 and 4 for the fourth 1O-year inservice inspection (lSI) interval for Turkey Point Units 3 and 4, respectively. The submittals request relief from American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements for the selection and examination of Class 1 piping welds. The relief requests propose to use a risk-informed lSI (RI-ISI) program developed based on the methodology contained in Westinghouse Owners Group (WOG) Topical Report WCAP-14572, Revision 1-NP-A, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report," instead of a program developed according to the ASME Code requirements for Class 1 piping welds. The NRC endorsed the WOG RI-ISI methodology in its safety evaluation dated December 15, 1998.
The NRC staff has reviewed the licensee's proposed alternative and has concluded that the licensee's proposed alternative as specified in Relief Request Nos. 3 and 4 may be authorized pursuant to Title 10 of the Code of Federal Regulations Section 50.55a(a)(3)(i) on the basis that it provides an acceptable level of quality and safety. Further details on the bases for the NRC staff's conclusions are contained in the enclosed safety evaluation. If you have any questions regarding this issue, please feel free to contact Brenda Mozafari at (301) 415-2020.
Sincerely, l~;S;PJ~
Thomas H. Boyce, Chief I tf\
Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Safety Evaluation cc: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCEAR REACTOR REGULATION RISK-INFORMED INSERVICE INSPECTION PROGRAM RELIEF REQUEST NUMBERS 3 AND 4 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 INTRODUCTION
By letters dated December 7, 2008 (Reference 1 and 2), as supplemented in letter dated August 20, 2008 (Reference 3), Florida Power and Light (FPL) requested Nuclear Regulatory Commission (NRC) approval of alternate risk-informed inservice inspection (RI-ISI) selection and examination criteria to be used during Turkey Pont's Unit 3 (TP3) and Unit 4 (TP4) fourth 1O-year inspection interval (the fourth interval). The licensee's proposed RI-ISI programs are an alternative pursuant to Section 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR). The scope of the alternate RI-ISI programs are applicable to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2001 Edition through the 2003 Addenda, Class 1 piping, Categories B-F and B-J piping welds.
By letters dated January 19,2000 (Reference 4) and July 8, 2002 (Reference 5), FPL submitted similar requests for relief to implement an RI-ISI program for the remainder of TP3's and TP4's third 10-year interval (the third interval) respectively. The NRC staff approved FPL's RI-ISI programs for use during the third intervals by letters dated November 30, 2000 (Reference 6) and August 1,2003 (Reference 7). The licensee is proposing to use RI-ISI programs based on the same methodology for the fourth intervals that began February 22, 2004, and ends February 22,2014 for TP3 and April 15, 2004, and ends April 14,2014 for TP4.
2.0 REGULATORY EVALUATION
Regulation 10 CFR 50.55a(g) requires that lSI of the ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Code, "Rules for Inservice Inspection of Nuclear Power Plant Components" (hereinafter called Code) and applicable addenda, except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
The regulation 10 CFR 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that the proposed alternatives would provide an acceptable level of quality and safety, or if the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Enclosure
-2 The licensee stated that the proposed RI-ISI programs are developed consistent with the staff approved RI-ISI process and methodology delineated in Westinghouse Owners Group Topical Report WCAP-14572, Revision 1-NP-A, 'Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report," (WCAP-TR)
(ML042610469). The staff reviewed the proposed RI-ISI program based on guidance and acceptance criteria provided in the following documents:
- NRC Regulatory Guide 1.178, Revision 1, An Approach for, Plant-Specific, Risk-Informed Decisionmaking for Inservice Inspection of Piping, U.S. NRC, September 2003.
- NUREG-0800, Chapter 3.9.8, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Risk-Informed Inservice Inspection of Piping, U.S. NRC, September 2003.
3.0 TECHNICAL EVALUATION
The licensee is requesting relief that would permit continued use of the RI-ISI programs for the fourth 10-year lSI intervals instead of the ASME Section XI program. A RI-ISI program is acceptable and provides an acceptable level of quality and safety if it meets the five key principles of risk-informed decisionmaking, discussed in RGs 1.174 and 1.178. These principles are:
- 1) The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.
- 2) The proposed change is consistent with the defense-in-depth philosophy.
- 3) The proposed change maintains sufficient safety margins.
- 4) When proposed changes result in an increase in core damage frequency and/or large early release frequency, the increases should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.
- 5) The impact of the proposed change should be monitored by using performance measurement strategies.
The first principle is met in these relief requests because an alternative lSI program may be authorized pursuant to 10 CFR 50.55a(3)(i) and, therefore, an exemption request is not required.
The second and third principles require assurance that the alternative program is consistent with the defense-in-depth philosophy and that sufficient safety margins are maintained, respectively.
The licensee stated in References 1 and 2 that the methodology used to develop the fourth interval RI-ISI programs is identical to the risk-informed processes approved by the staff for use
-3 at TP3 and TP4 in References 6 and 7. Assurance that the second and third principles are met is based on the application of the approved methodology and not on the particular inspection locations selected. Therefore, the staff concludes that the FPL's application of the methodology approved for use in the third interval to develop its proposed programs for the fourth interval provides assurance that the second and third principles are met.
The fourth principle requires an estimate of the change in risk. The change in risk is dependent on the number and location of inspections in the proposed lSI program compared to the number and location of inspections that would be performed using the requirements of ASME Section IX. In References 1 and 2, the licensee reported that a new change in risk evaluation was performed and the risk from the revised RI-ISI programs for TP3 and TP4 continue to remain lower when compared to the last deterministic Section XI inspection program. Relief was granted in References 6 and 7 from selected requirements in the 1989 edition of Section XI, which was the licensee's code of record when relief was requested. The licensee stated in Reference 1 that its code of record for the fourth interval is the ASME Section XI 1998 through 2000 Addenda. This change in the code of record might require changes to a few inspection locations for the fourth interval ASME inspection program from which the licensee is requesting relief. Minor changes in ASME locations may affect the risk calculation required by the RI-ISI methodology. However, the change in risk calculation uses simple bounding calculations to provide a concluding check of the acceptability of the proposed program. The accuracy of the change in risk calculations does not warrant developing a new ASME inspection program to be used briefly as a baseline program for the change in risk calculation and then discarded.
Therefore, the staff finds the comparison of the risk estimate between the proposed RI-ISI program and the ASI\I1E program based on the code of record from which relief was granted in Reference 6 and 7 appropriate and acceptable. The reported result obtained by using the methodology in the WCAP-TR satisfies the change in risk guidelines in the WCAP-TR and, therefore, the fourth principle is met.
The fifth principle of risk-informed decisionmaking requires that the impact of the proposed change should be monitored by using performance measurement strategies. In References 1 and 2, the licensee stated that periodic evaluation and update of its RI-ISI programs were performed in conjunction with the end of the third interval. The licensee also described briefly the changes to each RI-ISI program and summarized the changes at the plants that caused the changes to the proposed programs. In Reference 3, the licensee indicated that it used Revision 7 of its dual unit PRA model in March 2007, and summarized several updates that had been made to this PRA model. These evaluations are consistent with FPL's description of its living program approved by the staff in References 6 and 7 and demonstrate that the RI-ISI program is being periodically updated which satisfies the fifth principle's primary goal to ensure that no adverse safety degradation occurs because of the changes to the licensing basis.
Based on the above discussion, the staff concludes that the five key principles of risk-informed decision making are satisfied by the licensee's proposed third 1O-year RI-ISI programs, and, therefore, concludes that the proposed program for the fourth 1O-year lSI interval is acceptable.
4.0 CONCLUSION
S Based on the information provided in the licensee's submittals, the staff has determined that the proposed alternative satisfies the five key principles of risk-informed decisionmaking. Satisfying these principles demonstrates that the proposed alternative provides an acceptable level of
-4 quality and safety, and therefore the proposed alternatives may be authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 1O-year lSI inspection interval at Turkey Point Unit 3 and Unit 4.
5.0 REFERENCES
- 1. Letter from William Jefferson, Jr. (FPL), to NRC, dated December 17,2007, transmitting
Turkey Point Unit 3, Docket No. 50-250, Relief Request NO.3 Risk-Informed Inservice Inspection Program."
- 2. Letter from William Jefferson, Jr. (FPL), to NRC, dated December 17,2007, transmitting
Turkey Point Unit 4, Docket No. 50-251, Relief Request No.4 Risk-Informed Inservice Inspection Program."
- 3. Letter from William Jefferson, Jr. (FPL), to NRC, dated August 22, 2008, transmitting "Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251, Fourth 10 Year Interval Inservice Inspection Program, Response to Request for Additional Information for Risk-Informed Inservice Inspection (RI-ISI) Relief requests 3 and 4."
- 4. Letter from R. J. Hovey (Turkey Point Plant), to NRC, dated January 19, 2000, transmitting "Turkey Point Unit 3, Docket No. 50-250 Risk-Informed Inservice Inspection Program."
- 5. Letter from J. P. McElwain (Turkey Point Plant), to NRC, dated July 08,2002, transmitting Turkey Point Unit 4 Docket No. 50-251 Risk-Informed Inservice Inspection Program."
- 6. Letter from Richard P. Correia (NRC) to Thomas F. Plunkett (FPL), dated November 30,2000, transmitting "Turkey Point Plant, Unit 3 - Relief Request Regarding Safety Evaluation of Risk-Informed Inservice Inspection Program (TAC No. MA8111 )."
- 7. Letter from Allen G. Howe (NRC) to Thomas F. Plunkett (FPL), dated August 1,2003, transmitting "Turkey Point Nuclear Plant, Unit 4 - Evaluation of Relief Request Concerning Risk-Informed Inservice Inspection (TAC No. MB5551).
Principle Contributor: Stephen Dinsmore Date: December 9, 2008
ML083250173 NRR-028 OFFICE LPL2-2/PM LPL2-2/PM LPL2-2/LA DRNAPLA OGC NLO LPL2-2/BC w/comments NAME JPaige BMozafari BClayton MRubin EWiliiamson BMoroney forTBoyce DATE 11/21/08 11/24/08 11/21/08 By Memo dtd. 12/03/08 12/09/08 10/27/08