L-2014-362, Request for Schedule Relaxation from NRC Order EA-12-049 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Request for Schedule Relaxation from NRC Order EA-12-049 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML15014A228
Person / Time
Site:	Turkey Point
Issue date:	12/19/2014
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2014-362
Download: ML15014A228 (5)

Text

0December FPL.

19, 2014 L-2014- 362 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Unit 3 Docket Nos. 50-250 Florida Power and Light Company's, Turkey Point Unit 3, Request for Schedule Relaxation from NRC Order EA-12-049 "Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"

References:

1. US. Nuclear Regulatory Commission, Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12056A045)

This letter transmits a request for relaxation of schedule requirements contained in the Nuclear Regulatory Commission (NRC) Order EA- 12-049.

By letter dated March 12, 2012, (Reference 1) the NRC ordered Florida Power & Light Company (FPL) to take certain actions at Turkey Point Units 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 (SFP) cooling capabilities during beyond-design-basis external events.

Section IV of the order states, "As applicable, the Director, Office of Nuclear Reactor Regulation or the Director, Office of New Reactors may, in writing, relax or rescind any of the above conditions upon demonstration by the Licensee or [construction permit] holder of good cause."

In accordance with Section IV of NRC Order EA-12-049, FPL, is requesting that the Director, Office of Nuclear Reactor Regulation, relax the requirement for completion of full implementation for Turkey Point Unit 3, as prescribed in Section IV A.2 of NRC Order EA 049 for reasons detailed in the attachment to this letter. 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. L.a, or December 31, 2016, whichever comes first."

Florida Power & Light Company 9760 S.W. 344 HStreet Homestead, FL 33035

Turkey Point Unit 3 L-2014-362 Docket No. 50-250 Page 2 of 2 The proposed schedule relaxation aligns the Turkey Point Unit 3 to Turkey Point Unit 4 schedule for full compliance with the NRC Order EA-12-049 requirements.

FPL considers that, upon approval by the NRC, the alternative full implementation date regarding NRC Order EA- 12-049 proposed in the attachment will constitute a condition of the NRC Order EA-12-049 for Turkey Point Unit 3.

There are no new regulatory commitments contained in this letter.

Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Turkey Point Licensing Manager, at 305-246-7327.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December /, 2014 Sincerely, 4<6 Michael Kiley Site Vice President Turkey Point Nuclear Plant Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant

ATTACHMENT to L-2014-362 REQUEST FOR SCHEDULE RELAXATION OF NRC ORDER EA-12-049 REQUIREMENT IV.A.2 FOR TURKEY POINT NUCLEAR PLANT UNIT 3 Relaxation Request:

Pursuant to Section IV of the Nuclear Regulatory Commission (NRC) Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Reference 1), Florida Power & Light Company's (FPL),

Turkey Point Unit 3, herby submits a request for schedule relaxation from the Order requirements for completion of full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan as required in Condition C. L.a of the Order, or December 31, 2016, whichever occurs first.

Order Requirement from Which Relaxation is Requested:

NRC Order EA-12-049,Section IV.A.2 requires completion of full implementation of the Order requirements no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C. 1.a of the Order, or December 31, 2016, whichever comes first.

In accordance with the requirements of the Order, FPL submitted the Turkey Point Units 3 and 4 Mitigation Strategies Overall Integrated Plan (Reference 2) on February 26, 2013. The first six-month status report (Reference 3) revised the milestones to show a change in the target completion date for full implementation due to the longer duration of the extended power uprate refueling outages. Accordingly, the second refueling outage is currently scheduled to commence in October 2015 for Unit 3 and in 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, and for Unit 4, prior to the startup from the March 2016 refueling outage.

Justification for Relaxation Request:

NRC Order EA- 12-049 requires the development, implementation, and maintenance of guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.Section II of this order dictates the need to have guidance and strategies available to prevent fuel damage in the reactor and spent fuel pit should the loss of power, motive force and normal access to the ultimate heat sink affect all units at a site simultaneously.

Turkey Point Nuclear Plant is a two unit site with significant physical and procedural interdependencies. The two units share certain common structures, systems and components (such as auxiliary feedwater cross connections, and DC buses), common control room, and common Operational Staff resources.

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ATTACHMENT to L-2014-362 Compliance to NRC Order EA-12-049 schedule requirements for full implementation for Turkey Point Unit 3 would result in an interim period (for approximately six months) that the two units would not be consistently configured for responding to the beyond design basis event at the site. For example, the low leakage reactor coolant pump seals would not have been replaced on Unit 4 yet. This inconsistency in plant design configuration would complicate the cooldown requirements and it would result in conflicting demands on how to use the limited supply of the emergency feedwater make-up water during the event mitigation philosophy for both Turkey Point units.

The physical modifications for Unit 3 will be completed prior to restart from the second refueling outage, currently scheduled for November 2015. While most of the physical modifications are unit specific, due to the interdependency of needed systems and structures, the interim period would require special procedures and training that would create operational challenges on both units with respect to external event mitigation philosophy. As such, compliance to the Unit 3 schedule requirements of the NRC Order EA-12-049 would create a considerable hardship without a compensating increase in the level of safety.

FPL is requesting herein that the Director, Office of Nuclear Reactor Regulation, relax the requirement for full implementation for the Turkey Point Unit 3 as prescribed in Section IV.A.2 of NRC Order EA-12-049 schedule requirements. Specifically, FPL proposes to defer the full implementation of the Order requirement for Turkey Point Unit 3 to align with the implementation of Turkey Point Unit 4 to meet the NRC Order EA- 12-049 requirements.

Accordingly, FPL requests that the NRC Order EA-12-049,Section IV.A.2 requirements for full implementation date for the Turkey Point Unit 3 be relaxed to the following milestone:

Turkey Point Unit 3 - Restart from the scheduled Unit 4 Cycle 29 refueling outage (Forecasted for May 2016)

The requested schedule relaxation to the alternative full implementation date for Unit 3 would allow both Turkey Point Units 3 and 4 to be in compliance with the NRC Order EA-12-049 requirements at the same time.

The justification for this relaxation is based on a reduced risk to safety through the implementation of a more consistent and overall site response to a beyond design basis event through the use of a consistent and unified approach to procedural development and training.

From a natural hazard risk perspective, the Turkey Point seismic reanalysis has determined that the maximum potential seismic activity that could affect the site is significantly less than the current licensing basis. The reevaluated flood hazards events that are not bounded by the current licensing basis are: the hurricane storm surge and the local intense precipitation. In the case of the hurricane storm surge event, the proposed schedule relaxation of approximately six months spans the calendar during the lowest probable hurricane activity (Hurricane season is June 1st through November 30th in the Eastern US). For the local intense precipitation, the Page 2 of 3

ATTACHMENT to L-2014-362 potential flooding levels do not adversely affect the equipment important to safety.

Accordingly, the risk of these natural hazard events during the six months relaxation period is considered negligible.

FPL considers that upon approval by the NRC, the alternative full implementation date, proposed above, will constitute a condition of the NRC Order EA-12-049 for Turkey Point Unit 3.

==

Conclusion:==

As described above, compliance with the Unit 3 NRC Order EA-12-049 schedule requirements for full implementation of the mitigation strategies would result in hardship or unusual difficulty without a compensating increase in the level of safety. Therefore, in accordance with the provisions of Section IV of the Order, we request relaxation of the requirement described in Section IV.A.2 of the NRC Order Ea- 12-049.

References:

I. US. Nuclear Regulatory Commission, Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12056A045)

2. L-2013-061, Florida Power and Light Company's Overall Integrated Plan in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 26, 2013 ( ML13072A038)

3. L2013-249, Florida Power and Light Company's First Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 21, 2013 (ML13248A311)

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