ML100740720

Summary of Meeting with Florida Power & Light, on the Proposed License Amendment Request Regarding Taking Credit for Boraflex in the Spent Fuel Pool

ML100740720
Person / Time
Site:	Turkey Point
Issue date:	07/23/2010
From:	Jason Paige Plant Licensing Branch II
To:	Office of Nuclear Reactor Regulation
Paige, Jason C, NRR/DORL,301-415-5888
Shared Package
ML100740721	List: ML100740720 ML100740722
References
TAC ME3443
Download: ML100740720 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 23, 2010 FLORIDA POWER & LIGHT FACILITY: TURKEY POINT UNIT 3

SUMMARY

OF JANUARY 21, 2010, MEETING WITH FLORIDA POWER &

LIGHT, ON THE PROPOSED LICENSE AMENDMENT REQUEST REGARDING TAKING CREDIT FOR BORAFLEX IN THE SPENT FUEL POOL (TAC NO. ME3443)

On January 21,2010, Florida Power & Light Company (FPL, the licensee) and the Nuclear Regulatory Commission (NRC) held a public meeting regarding Turkey Point, Unit 3 spent fuel pool (SFP) issue at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of this meeting was to discuss Turkey Point's proposed license amendment request (LAR) to update its Unit 3 SFP licensing basis. A list of attendees is provided as an Enclosure.

The licensee presented information (See Agencywide Documents Access and Management System Accession No. ML100740722).

By letter dated May 16, 2001, the licensee performed an analysis to predict the approximate date the degradation of any Boraflex panel will exceed the assumed degradation values for each SFP region. The licensee concluded that the average areal density in the dissolved region is projected to fall below the maximum degradation assumed in the updated final safety analysis report (UFSAR) approximately in November 2006. To mitigate this degradation, the licensee put in place administrative controls and submitted a LAR, referred to as the Boraflex Remedy LAR. on January 27,2006. The LAR proposed to use metamic inserts, reactivity control cluster assemblies (RCCAs), and water holes. The NRC approved this LAR July 17. 2007 (license amendments 234 and 229). The implementation date of this LAR was prior to the end of the Turkey Point Unit 4 Cycle 24.

By letter dated September 1, 2009, the licensee stated that the Boraflex Remedy LAR would not be able to be implemented by the implementation date due to the vendor's inability to fabricate the metamic inserts within the maximum specified dimensions. The licensee requested an implementation date extension to September 30, 2012. By letter dated November 13, 2009, the NRC approved an extension to "no later than February 28, 2011" with license conditions for Unit 4 only. The NRC believed that Turkey Point Unit 3 was outside of its design basis and could not approve the extension request. FPL withdrew its September 1, 2009, application by letter dated November 9, 2009, and committed to submit a LAR for Unit 3 to revise its SFP licensing basis. This commitment was made by the licensee by letter dated December 31, 2009.

The licensee stated that they have been using NRC-approved methodologies to satisfy criticality design basis requirements for keff* The NRC questioned the NRC-approved methodologies and what approved methods were used. The licensee specifically stated that they used methodologies as described in Westinghouse report WCAP-14416-NP-A. The NRC stated that

-2 the methodologies specified in WCAP-14416-NP-A were nonconservative in many instances, and by letter dated July 27,2001, the NRC stated its position on the non-conservatisms.

The licensee acknowledged that given the length of time the administrative controls have been in place, Turkey Point's UFSAR should have been updated but they believed they were in compliance with Technical Specifications (TSs) 5.5.1.1 a and 5.5.1.1 b. The NRC questioned how can Turkey Point not be in conformance with its UFSAR but be in compliance with its TSs?

The licensee stated that they are in compliance with its TSs by using the compensatory measures that were approved by the NRC in the July 17, 2007, safety evaluation. The NRC stated its position that the licensee is not in compliance with its TSs because Turkey Point Unit 3 did not fully implement license amendment 234. A licensee cannot pick and choose sections to use from an approved license amendment. A licensee can only take credit for a license amendment after it has been fully implemented and Turkey Point did not fully implement license amendments 234 and 229, hence the September 1, 2009, extension implementation date request. Also, the NRC stated that Turkey Point's criticality analysis only takes credit for Boraflex and not the administrative controls (RCCAs, water holes, etc.).

The licensee also provided discussions on the programs RACKLIFE and BADGER. RACKLIFE is used to predict the varying degraded conditions of the areal density for each of the Boraflex panels. BADGER measures the actual degraded conditions of the Boraflex panels. The licensee provided information on Turkey Point's Boraflex management program and how FPL predicts degradation of the Boraflex. The NRC provided feedback on Turkey Point's program that the BADGER test should be performed on the same panels every 3 years so FPL doesn't have to predict or assume panel degradation.

FPL concluded that Turkey Point's Unit 3 SFP remains in a safe configuration with the actions taken specified in the December 31 commitment letter. Some of the commitments are as follows: increase the boron concentration of the Unit 3 SFP; administratively restrict the use of storage cells that have degraded below a specified limit; and load additional fuel assemblies in the Unit 3 SFP only into storage cells for which the presence of Boraflex is not credited. The proposed Unit 3 LAR will address SFP conditions until the Boraflex Remedy Amendment can be implemented. The NRC believes that with the actions that FPL is taking, Turkey Point's Unit 3 SFP is safe and no safety significant issue is present.

A member of the public was a participant in the teleconference. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-5 8, or ~e@nrc.gov.

ason C. Paige, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-250

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv

LIST OF ATTENDEES JANUARY 21, 2010, MEETING WITH FLORIDA POWER & LIGHT PRE-APPLICATION MEETING RE SPENT FUEL POOL U.S. NUCLEAR REGUALTORY COMMISSION V. Cusumano M. Yoder K. Wood D. Cunanan T. Nakanishi T. Boyce R. Taylor M. Sykes P. Higgins FLORIDA POWER & LIGHT C.O'Farrili J. Peschel J. Garcia B. Tomonto E. Fuentes C. Villard NETCO DIVISION OF SCIENTECH K. Leuenroth WESTINGHOUSE K. Cummings PUBLIC K. Halloran Enclosure 1

PKG ML100740721 Mtg Summary* ML100740720 Handouts* ML100740722 OFFICE DORULPL2-2/PM DORULPL2-2/LA DORULPL2-2/BC DORULPL2-2/PM NAME JPaige BClayton DBroaddus by (EBrown) JPaige DATE 3/18/2010 3/18/2010 7/23/10 7/23/10