L-2014-020, Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments

Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments

ML14036A069
Person / Time
Site:	Saint Lucie
Issue date:	01/27/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-020
Download: ML14036A069 (4)

Text

0 January 27, 2014 FPL. L-2014-020 10 CFR 50.54(0 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Re: St. Lucie Units I and 2 Docket Nos. 50-335 and 50-389 Renewed Facility Operating License Nos. DPR-67 and NPF-16 Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments

References:

(1) NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(0 Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated March 12, 2012, Accession No. ML12073A348.

(2) NRC Letter to Nuclear Energy Institute, "Endorsement of Nuclear Energy Institute (NEI) 12-07,

'Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features,"' dated May 31, 2012, Accession No. MLI 2144A 142.

(3) Florida Power & Light (FPL) Letter L-2012-428, dated November 27, 2012, "Response to NRC 10 CFR 50.54(0 Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding, St. Lucie Plant Units 1 and 2, Flooding Walkdown Report FPL060-PR-001, Rev.0" (4) NRC Letter, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns," dated December 23, 2013, Accession No. MLI 3325A891 (5) St. Lucie Corrective Action Program (CAP) Action Request (AR) 1748014, Assignment 04, Small APM Justification.

(6) St. Lucie Corrective Action Program (CAP) Action Request (AR) 1931279, Assignment 01, Penetration Seal APM Justification.

On March 12, 2012, the N RC staff issued Reference I requesting information pursuant to Title 10 of the Code of Federal Regulations 50.54(0. Enclosure 4 of that letter contains specific Requested Information associated with Near-Term Task Force Recommendation 2.3 for Flooding. Per Reference 2, the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012. By Reference 3, Florida Power & Light (FPL) submitted the final report in response to the request for information.

One of the requirements of NEI 12-07 is to identify the available physical margin (APM) associated with each applicable flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. The results of this effort were to be maintained on site for future NRC audits.

Florida Power &Ught Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2014-020 Page 2 Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow them to complete its assessments. Accordingly, by Reference 4 the NRC staff has issued a request for additional information (RAI). The attachment to this letter provides FPL's responses for the St. Lucie Plant.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact Eric S. Katzman, St. Lucie Licensing Manager, at 772-467-7734.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Executed on January 2 -- ,2014 Very Joseph Jensen Site Vice President St. Lucie Plant Attachment

L-2014-020 Attachment Page I of 2 Per (4) NRC Letter, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns," dated December 23, 2013, Accession No. ML13325A891, FPL provides the following responses.

RAI Number 1: Confirmation that the processfor evaluatingAPM was reviewed Response: FPL has completed a review of the process used at the St. Lucie Plant to evaluate APMs.

RAI Number 2: Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI.

Response: The APM process used at St. Lucie Plant followed the guidance provided in NEI 12-07, including a definition for a small margin. Additional actions have been taken to make the process consistent with the information provided in this RAI.

RAI Number 3: If changes are necessary, a general descriptionof any process changes to establish this consistency.

Response: As stated above, the APM process used at St. Lucie Plant followed the guidance provided in NEI 12-07, including a definition for a small margin (AR 1748014, Reference 5). However, a specific APM had not been assigned to the seals associated with flood protection features. These items have now been addressed in accordance with the guidance provided in this RAI and entered into the corrective action process (AR 1931279, Reference 6), as appropriate, for further evaluation.

RAI Number 4: As a result of the audits and subsequent interactionswith industry duringpublic meetings, NRC staff recognized that evaluation ofAPMfor seals (e.g., flood doors, penetrations,floodgates, etc.)

was challengingfor some licensees. Generally, licensees were expected to use either Approach A or Approach B (describedbelow) to determine the APMfor seals.-

a) If sealpressure ratings were known, the seal ratings were used to determine APM (similarto example 2 in Section 3.13 ofNEI12-07). A numericalvalue for APM was documented No further action was performed if the APM value was greater than the pre-establishedsmall-margin threshold value. If the APM value was small, an assessment of "significantconsequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed b) If the seal pressure ratingwas not loiown, the APMfor seals in aflood barrieris assumed to be greater than the pre-establishedsmall-marginthreshold value if the following conditions were met:

(1) the APMfor the barrierin which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured,installed,and controlled as flooding seals in accordancewith the flooding licensing basis. Note that in order to determine that the seal has been controlledas afloodingseal, it was only necessary to determine that the seal conifigurationhas been governed by the plant's design controlprocess since installation. In this case, the APMfor the seal could have been documented as "not small ".

L-2014-020 Attachment Page 2 of 2 As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additionalactions are necessary if either Approach A or B was used.

If neitherApproach A or B was used to determnine the APM values for seals (eitheras part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:

• Enter the condition into the CAP (note: it is acceptableto utilize a single CAP entry to capture this issuefor multiple seals). CAP disposition of "undetermined" APM valuesfor seals should consider the guidanceprovided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safetyfunction againstfloods up to the currentlicensing basisflood height.

Disposition may occur as part of the IntegratedAssessment. If an IntegratedAssessment is not performed,determine whether there are significant consequences associatedwith exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes. These actions do not need to be complete prior to the RAI response.

• Report the APMas "undetermined" andprovide the CAP reference in the RAI response.

Response: Neither Approach A or B, as described above, were used to determine the APM values for seals. As part of the actions taken to address this RAI, the seals have been assigned an APM value of "undetermined" and have been entered into the CAP process (ARs 1748014 and 1931279, References 5 and 6) for further evaluation of their available physical margin. The disposition of the Action Requests will determine the APM and implementation of interim actions will be pursued, if necessary.

In addition, the original walkdown record forms issued as Attachment C to Reference 3 assigned an APM value of"N/A" for features (seals) located below the plant flood level. St. Lucie's intent is to not revise Attachment C to reflect the change in APM value from "N/A" to "undetermined," rather justification for the use of APM valve "N/A" will be included as part of the CAP entry (Reference 6).