ML18318A433
| ML18318A433 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/19/2018 |
| From: | Michael Wentzel Plant Licensing Branch II |
| To: | Nazar M Florida Power & Light Co |
| Wentzel M DORL/LPL2-2 301-415-6459 | |
| References | |
| EPID L-2018-LLA-0280 | |
| Download: ML18318A433 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 Mr. Mano Nazar President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop EX/JB 700 Universe Blvd.
Juno Beach, FL 33408 November 19, 2018
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF LICENSE AMENDMENT REQUEST TO REVISE NFPA 805 LICENSE CONDITION FOR REACTOR COOLANT PUMP SEALS (EPID L-2018-LLA-0280)
Dear Mr. Nazar:
By letter dated October 17, 2018 (Agencywide Documents Access and Management System Accession No. ML18292A842), as supplemented by letter dated October 24, 2018 (Agencywide Documents Access and Management System Accession No. ML18297A032), Florida Power &
Light Company (the licensee) requested amendments to Renewed Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Unit Nos. 3 and 4. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this license amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50. 90 of Title 10 of the Code of Federal Regulations ( 10 CFR ),
whenever a holder of a license desires to amend the license, an application for an amendment must be filed with the Commission, as specified in 10 CFR 50.4, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that the licensee supplement the application to address the information requested in the enclosure within 13 working days of the date of this letter. This will enable the NRC staff to begin its detailed technical review. If the
information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
The information requested and the associated timeframe in this letter were discussed in a conference call with Ms. Olga Hanek on November 19, 2018.
If you have any questions, please contact me at (301) 415-6459 or Michael.Wentzel@nrc.gov.
Docket Nos. 50-250 and 50-251
Enclosure:
Supplemental Information Needed cc: Listserv Sincerely, Michael J. Wentz, reject Manager Plant Licensing Br h 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
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Background===
SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT REQUEST FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251 By letter dated October 17, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18292A842), as supplemented by letter dated October 24, 2018 (ADAMS Accession No. ML18297A032), Florida Power & Light Company (FPL, the licensee) submitted a license amendment request (LAR) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 to remove reliance on the Nuclear Regulatory Commission (NRC) staff's approval of the Flowserve Reactor Coolant Pump (RCP) Seal Topical Report (TR) as a condition of transition to National Fire Protection Association Standard (NFPA) 805. Instead, FPL proposes to apply the guidance outlined in WCAP-16175-P-A, Revision 0, "Model for Failure of RCP Seals Given Loss of Seal Cooling in CE [Combustion Engineering] NSSS [Nuclear Steam Supply System] Plants,"
March 2007 (a non-proprietary version of this report is available at ADAMS Accession No. ML071130383), as discussed in "Final Safety Evaluation for Pressurized Water Reactor Owners Group (PWROG) Topical ReportWCAP-16175-P, Revision 0, (CE NPSD-1199, Revision 1) 'Model for Failure of RCP Seals Given Loss of Seal Cooling in CE NSSS Plants' (TAC No. MB5803)" (ADAMS Accession No. ML070240429). The NRC staff has reviewed the information in FPL's submittals and has determined that additional information is needed in order for the NRC staff to reach a conclusion regarding acceptability of the LAR.
Supplemental Information Needed In Attachment W of the LAR, the licensee indicated that the change in risk for its transition to NFPA 805 continues to be representative of the risk in the proposed subsequent NFPA 805 LAR, after the addition of two analysis changes that include changing the RCP seal model from the Flowserve RCP TR to WCAP-16175-P-A, Revision O (which provides less time to trip the RCP pumps on loss of seal cooling), and reducing a screening human error failure probability for the ability to cross-tie Unit 4 Safety Injection pumps to Unit 3. The licensee further indicated that the numerical risk values for the post-transition plant for its transition to NFPA 805 (referred to as the baseline risk in the current NFPA 805 LAR), either bounds or is close to the values for the current LAR, and thus the current LAR is acceptable from a risk perspective.
The NRC staff notes that the numerical change in risk presented in Attachment W Section 2 of the current LAR does not meet the guidance in Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" (ADAMS Accession No. ML17317A256). One of the reasons the NRC staff approved the licensee's transition to NFPA 805 was because the licensee credited planned modifications for Fire Area CC, which resulted in a negative change in risk, as discussed later in the section.
Enclosure Although the NRC staff notes that the addition of RCP seals can play a large role in risk reduction, the risk reduction from the proposed \\/yCAP model is less than that for the original proposed Flowserve model, and therefore, the risk reduction from the RCP seal model in this current LAR is less than that credited in the original NFPA 805 LAR.
The licensee provides the results of their quantification of the updated post-transition model in Attachment W and concludes the impact of replacing the original RCP seal model with the WCAP model on core damage frequency (CDF) and large early release frequency (LERF) is small. However, the NRC staff recognizes that the impact on the compliant model, which includes risk reductions and the risk reduction credit, can be different from that of the post transition model, since the compliant model and risk reduction credit consider different conditions than the post transition model.
The NRC staff notes that the updated post-transition risk provided in this current LAR is only part of the equation needed to properly calculate the change in risk, and that the licensee has not provided updates to the compliant plant risk and credit for risk reduction modifications. As a result, the NRC staff requests that the licensee provide the results of a quantitative analysis that includes the updated numerical change in risk (i.e., Delta CDF/LERF) for the proposed changes described in the current LAR, including the additional risk of recovery actions, and whether RG 1.17 4 risk guidelines are met for this LAR.
In addition, the NRC staff identified potentially conflicting information in LAR Section 3.3 where the licensee indicated that the change in risk due to use of the proposed RCP seal model is in Region 11 of RG 1.17 4, but did not provide the numerical change in risk. The NRC staff identified that Region 11 of RG 1.17 4 corresponds to an increase in CDF in the range of 1 E-6 per reactor year to 1 E-5 per reactor year and an increase of LERF in the range of 1 E-7 per reactor year to 1 E-6 per reactor year, which appears to disagree with the information provided in Attachment W of the current LAR that the change in risk is comparable to the original NFPA 805 LAR. As a result, the NRC staff also requests that the licensee indicate whether the change in risk in the current LAR is comparable to the change in risk described in the original NFPA 805 LAR.
M.Nazar
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 -
SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF LICENSE AMENDMENT REQUEST TO REVISE NFPA 805 LICENSE CONDITION FOR REACTOR COOLANT PUMP SEALS (EPID L-2018-LLA-0280)
DATED NOVEMBER 19, 2018 DISTRIBUTION:
PUBLIC PM Reading File RidsNrrDorlLpl2-2 Resource RidsNrrLABClayton Resource RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrTurkeyPoint Resource RidsNrrDraAplb Resource RidsNrrDeEmib Resource JHyslop, NRR JRobinson, NRR ADAMS A ccess1on N o.: ML18318A433
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- 1 1ve-ma1 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DRA/APLB/BC NAME MWentzel BClayton GCasto DATE 11/16/18 11/16/18 11/19/18 OFFICE NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME UShoop (RSchaaf for)
MWentzel DATE 11/19/18 11/19/18 OFFICIAL RECORD COPY