ML19086A176
| ML19086A176 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/27/2019 |
| From: | NRC |
| To: | Division of Materials and License Renewal |
| References | |
| Download: ML19086A176 (3) | |
Text
1 TurkeyPoint34SLRPEm Resource From:
Comar, Manny Sent:
Wednesday, March 27, 2019 8:57 AM To:
TurkeyPoint34SLR Resource
Subject:
FW: QUESTION: Does the NRC regulate the CCS? Is the CCS a safety-related structure?
From: Folk, Kevin Sent: Tuesday, March 26, 2019 8:24 AM To: Comar, Manny
Subject:
FW: QUESTION: Does the NRC regulate the CCS? Is the CCS a safety-related structure?
From: Folk, Kevin Sent: Thursday, February 28, 2019 2:51 PM To: Drucker, David <David.Drucker@nrc.gov>
Cc: Ford, William <William.Ford@nrc.gov>; Beasley, Benjamin <Benjamin.Beasley@nrc.gov>
Subject:
RE: QUESTION: Does the NRC regulate the CCS? Is the CCS a safety-related structure?
Thanks. Bill F. and I have discussed this extensively.
Just for the record.previously, (after the scoping public meeting and since) I have asked Lois to engage with the safety side and with DORL on this point. I believe Mike Wentzel was asked about it. However, during last summers interagency meeting, we discussed this issue with the attendees but more focused on who is responsible for discharges from the CCS. We made it clear to the attendees that the NRC does not regulate the operational aspects of the CCS, which differs from Sheps concerns but which does align with those of petitioners.
There may now be an AMP being contemplated for it, but the safety boundary (as I understand it) ends at the intake canal and includes the intake cooling water pumps (which are safety related). However, Bill is more up on the AMP from a surface water perspective than I am for this review.
Bill is correct about the deep well (number F-1 I believe), which is otherwise used for CCS freshening.
However, I do not believe they (FPL) has taken credit for the well in its SAMA analysis. My recollection is that I discussed the latter issue with Bill Rogers.
Bill has a need to discuss the maintenance of the CCS as related to geology and soils (as he cites below), but we cannot let OGC push us into doing a de facto impacts analysis as part of the environmental review. This is because it would then need to extend to every resource area!
So, I agree we need the safety side to validate what we have stated in the SEIS.
Kevin From: Drucker, David Sent: Thursday, February 28, 2019 2:29 PM
2 To: Folk, Kevin <Kevin.Folk@nrc.gov>
Subject:
FW: QUESTION: Does the NRC regulate the CCS? Is the CCS a safety-related structure?
fyi From: Drucker, David Sent: Thursday, February 28, 2019 11:01 AM To: Rogers, Bill <Bill.Rogers@nrc.gov>
Cc: Ford, William <William.Ford@nrc.gov>
Subject:
QUESTION: Does the NRC regulate the CCS? Is the CCS a safety-related structure?
Hi Bill - - can you help with the following?
In Section 3.5.1.1, Surface Water Hydrology under the heading Potential for Flooding at the Turkey Point Site in the Turkey Point DSEIS, Bill Ford says:
For structures that are important to the safe operation of the nuclear units, the NRC requires that they be designed and operated in consideration of potential flooding. The NRC does not have similar requirements for nonsafety-related structures or for structures that it does not regulate. At the Turkey Point site, such structures include office buildings, Units 1, 2, and 5, cooling towers, and the CCS.
Shep asks the question: Does the CCS really have no safety-related function?
Bill Fords response: I believe the CCS is a structure the NRC does not regulate and it is not a safety structure.
During operations except for a ultimate heat sink temperature requirement, we do not regulate the operation of the CCS My understanding is that should the CCS cease to function, the reactor would be shut down, and well water would be used to cool the shutdown reactor. The well is safety related, is protected, and was included in the flooding safety analysis for the reactors.
My further understanding is that the CCS, like a cooling tower is used to cool the plant. From the subsequent renewal safety application The cooling water canals serve as the plant ultimate heat sink. The cooling canals constitute a closed-cooling system made up of earthen canals that provide cooling of discharged water prior to reuse at the intake structure. Structural failure of the cooling canals could impact safety-related equipment.
Therefore, my understanding is while in its self it is not a safety structure it operation can impact safety structures.
Because it can impact safety equipment it scope into the safety license renewal review and an aging management program (AMP) will be required. The AMP will be used to manage loss of material, loss of form due to erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, seepage for earthen water-control structures exposed to outdoor air and water -flowing or standing environments. The Turkey Point AMP will include special inspections after major storm events such as hurricanes.
It is my understanding that after they are implemented the NRC does not inspect AMP activities. That they are no looked at again until another license renewal.
Sheps follow on question/comment: Dave - Our safety folks (Eric, etc) need to look at this statement and Bills comments. Is the CCS safety-related? This statement needs to be correct.
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FW: QUESTION: Does the NRC regulate the CCS? Is the CCS a safety-related structure?
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