ML15013A498

Relaxation of the Scheduler Requirements of Order EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events

ML15013A498
Person / Time
Site:	Turkey Point
Issue date:	03/13/2015
From:	Bill Dean Office of Nuclear Reactor Regulation
To:	Nazar M Nextera Energy
Paige J, NRR/JLD, 415-5888
References
EA-12-049, TAC MF0982
Download: ML15013A498 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P. 0. Box 14000 Juno Beach, FL 33408-0420 March 13, 2015

SUBJECT:

TURKEY POINT NUCLEAR GENERATING, UNIT 3 - RELAXATION OF THE SCHEDULE REQUIREMENTS OF ORDER EA-12-049, "ISSUANCE OF ORDER TO MODIFY LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" (TAC NO. MF0982)

Dear Mr. Nazar:

By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A735), the U.S. Nuclear Regulatory Commission (NRC) ordered Florida Power & Light Company (FPL, the licensee), to take certain actions at Turkey Point Nuclear Generating, Units 3 and 4 (Turkey Point 3 and 4), associated with the Fukushima Near-Term Task Force Recommendations. Order EA-12-049 directed that actions be taken by licensees to develop and implement strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities during beyond-design-basis external events.

Section IV of the order states that licensees proposing to deviate from requirements contained in NRC Order EA-12-049 may request that the Director, Office of Nuclear Reactor Regulation, relax or rescind certain conditions. By letter dated December 19, 2014 (ADAMS Accession No. ML15014A228), FPL submitted a request for relaxation of the schedule requirement for full implementation for Turkey Point 3, as prescribed in Section IV A.2 of NRC Order EA-12-049.

That requirement states, in part, "All holders of operating licenses issued under Part 50... shall complete full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a, or December 31, 2016, whichever comes first."

The licensee stated in its request that the second refueling outage will commence in October 2015 for Unit 3 and March 2016 for Unit 4. Therefore, consistent with the schedule requirements of Order EA-12-049, full implementation of the mitigating strategies for Unit 3 must be completed prior to startup from the October 2015 refueling outage. FPL requested that the required date for full implementation for Unit 3 be relaxed until restart from the Unit 4 Cycle 29 refueling outage, which is forecasted for May 2016. The requested schedule relaxation for Unit 3 would allow Turkey Point 3 and 4 to be in compliance with the Order EA-12-049 requirements at the same time.

In its December 19, 2014, letter, FPL provided several reasons in support of its relaxation request for Unit 3. The licensee indicated that Turkey Point is a two unit site with significant physical and procedural interdependencies, including the sharing of the auxiliary feedwater system. The current schedule requirements for compliance with Order EA-12-049 for Unit 3 would result in an interim period of approximately six months that the two units would not be consistently configured for responding to a beyond-design-basis event at the site. For example, the low leakage reactor coolant pump seals would not yet have been replaced on Unit 4, resulting in different cooldown requirements between the units and conflicting demands on how to use the shared supply of the emergency feedwater make-up water.

In light of the facts presented, the NRC staff has determined that the licensee has presented good cause for a relaxation of the order implementation date. The NRC staff agrees that compliance to the Unit 3 schedule requirements of Order EA-12-049 would create a hardship without a compensating increase in the level of safety. The NRC staff also considered that, following the accident at Fukushima Dai-ichi, the NRC concluded that a sequence of events such as the Fukushima Dai-ichi accident is unlikely to occur in the United States, based on the current regulatory requirements and existing plant capabilities. Therefore, the extension of time (approximately six months) for Unit 3 to achieve full implementation of the requirements of the mitigation strategies order until restart of the Unit 4 Cycle 29 refueling outage (May 2016) is ju?tified. Given the plant-specific circumstances at Turkey Point 3, and that the proposed completion date is prior to the December 2016 implementation date of the order, the NRC staff approves the relaxation request.

Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of the order for full order implementation for Turkey Point 3 is relaxed until the completion of the Unit 4 Cycle 29 refueling outage scheduled in May 2016.

The licensee did not request relaxation of the requirement for full order implementation for Turkey Point 4, so that requirement, for full implementation by the completion of the Unit 4 March 2016 refueling outage, is unchanged.

If you have any questions, please contact Jason Paige, at 301-415-5888.

Sinc,erely,

~~----

illiam M. Dean, Director Office of Nuclear Reactor Regulation Docket No. 50-250 cc: Listserv

ML15013A498 OFFICE NRR/JLD/JOMB/PM NRR/JLD /LA NAME JPaige Slent DATE 01/14/15 01/14/15 OFFICE OE OGC NAME RFretz DCylkowski*

DATE 01/15/15 02/24/15 Sincerely, IRA/

William M. Dean, Director Office of Nuclear Reactor Regulation RidsNrrLASLent Resource RidsOgcMailCenter Resource RidsOeMailCtr RidsN rrMailCenter RidsRgn2MailCenter Resource

• via email NRR/DORL/LPL2-2/PM NRR/JLD/JOMB/BC (A)

AKlett (w/comments)

MHalter 01/23/15 01/23/15 NRR/JLD/D NRR/D JDavis BDean 03/04/15 03/13/15