L-2019-125, Flooding Protection Features Planned Changes Implementation Plan Commitment Update Notification

Flooding Protection Features Planned Changes Implementation Plan Commitment Update Notification

ML19204A179
Person / Time
Site:	Turkey Point
Issue date:	06/27/2019
From:	Hess R Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-125
Download: ML19204A179 (4)

Text

June 27, 2019 L-2019-125 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555 Re: Turkey Point Unit 3 and Unit 4 Docket Nos. 50-250 and 50-251 Flooding Protection Features Planned Changes Implementation Plan Commitment Update Notification

References:

1. NRC Request for Information Pursuant to 10 CFR 50.54(f) 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, ADAMS Accession Number ML12056A046.

2. FPL Letter, L-2014-087, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flood Hazard Reevaluations for Recommendation 2.1, dated March 11, 2013, ADAMS Accession Number ML13095A216.

3. NRC Letter, Turkey Point Nuclear Generating, Unit Nos. 3 and 4 - Staff Assessment of Response to Title 10 CFR 50.54(f), Information Request -

Flood Causing Mechanism Reevaluation (TAC NOS MF1114 and MF1115),"

dated December 4, 2014, ADAMS Accession Number ML14324A816.

4. NRC Letter, Turkey Point Nuclear Generating, Unit Nos. 3 and 4 -

Supplement to Staff Assessment of Response to 10 CFR 50.54(f) Information Request-Flood-Causing Mechanisms Reevaluation (CAC Nos. MF1114 and MF1115), dated November 4, 2015, ADAMS Accession Number ML15301A200.

5. NRC Staff Requirements Memoranda to COMSECY-14-0037, "Integration of Mitigating Strategies for Beyond Design-Basis External Events and Reevaluation of Flooding Hazards," dated March 30, 2015.

6. NRC Letter, Coordination of Requests for Information Regarding Flooding Hazard Reevaluations and Mitigating Strategies for Beyond-Design-Basis External Events, dated September 1, 2015.

7. NEI 16-05, Revision 1, External Flooding Assessment Guidelines, dated June 2016, ADAMS Accession Number ML16165A178.

9760 S.W. 344 Street Homestead, FL 33 035

Turkey Point Units 3 and 4 L-2019-125 Docket Nos. 50-250 and 50-251 Page 2 of 3

8. U.S. Nuclear Regulatory Commission, JLD-ISG-2016-01, Guidance for Activities Related to Near-Term Task Force Recommendation 2.1, Flood Hazard Reevaluation; Focused Evaluation and Integrated Assessment, Revision 0, dated July 11, 2016, ADAMS Accession Number, ML16162A439.

9. FPL Letter, L-2017-124, Flooding Focused Evaluation Summary, dated June 29, 2017, ADAMS Accession Number ML17212B180.

On March 12, 2012, the NRC issued Reference 1 to request information associated with Near Term Task Force (NTTF) Recommendation 2.1 for Flooding . Enclosure 2 of Reference 1, requested that licensees reevaluate flood hazards using present day methods and regulatory guidance and to submit the Flood Hazard Reevaluation Report (FHRR) . For Turkey Point Units 3 and 4, the FHRR was submitted on March 11, 2013, Reference 2, and supplemented by FPL letters dated January 31, 2014, February 26, 2014, and April 25, 2014, and August 7, 2014, ADAMS Accession Numbers ML14055A365, ML14073A065, ML14149A479 and ML14234A085, respectively. The NRC Staff completed its review as documented in the Staff Assessment, Reference 3, and in the Supplement of the Staff Assessment, Reference 4.

Following the Commission's directive to NRC Staff in Reference 5, the NRC issued a letter to industry (Reference 6) indicating that new guidance is being prepared to replace instructions in Reference 5 and provide for a "graded approach to flooding reevaluations" and "more focused evaluations of local intense precipitation and available physical margin in lieu of proceeding to an integrated assessment."

NEI prepared the new "External Flooding Assessment Guidelines" in NEI 16-05 (Reference 7), which was endorsed by the NRC in Reference 8. NEI 16-05 indicates that each flood-causing mechanism not bounded by the design basis flood (using only stillwater and/or wind-wave runup level) should follow one of the following five assessment paths:

• Path 1: Demonstrate Flood Mechanism is Bounded Through Improve Realism

• Path 2: Demonstrate Effective Flood Protection

• Path 3: Demonstrate a Feasible Response to LIP

• Path 4: Demonstrate Effective Mitigation

• Path 5: Scenario Based Approach Non-bounded flood-causing mechanisms in Paths 1, 2, or 3 would only require a Focused Evaluation (FE) to complete the actions related to external flooding required by the March 12, 2012 10 CFR 50 .54(f) letter. Mechanisms in Paths 4 or 5 require an Integrated Assessment Turkey Point Units 3 and 4 followed Path 2, Demonstrate Effective Flood Protection, in accordance with NEI 16-05, Rev. 1, and utilized Appendices B and C to that document for guidance on evaluating the site strategy.

Turkey Point Units 3 and 4 L-2019-125 Docket Nos. 50-250 and 50-251 Page 3 of 3 On June 29, 2017, FPL submitted the Flooding Focused Evaluation for Turkey Point Units 3 and 4 (Reference 9), which included a list of planned changes (Reference 9, Table 2) to be implemented to ensure adequate Available Physical Margin (APM) and reliability of flood protection features credited for the reevaluated le'(els during a Probable Maximum Storm Surge (PMSS). The planned changes included changes to the manholes and conduit penetrations, which support the Local Intense Precipitation (LIP).

Based on the discussions with NRC Staff on May 22, 2019, FPL documents herein a commitment update by providing in the Enclosure the implementation plan for completing the planned changes for the identified (Reference 9, Table 2) flood protection features.

Should you have any questions regarding this submittal, please contact Mr. Robert J.

Hess, Turkey Point Licensing Manager, at 305-246-4112.

Si ess Licensing anager 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

Enclosure to L-2019-125 Turkey Point Units 3 and 4 Flooding Focused Evaluation Protection Feature Planned Changes Implementation Plan Flooding Implementation Planned Changes Protection Complete (Reference 9, Table 2)

Feature Due Date (Tracked via condition report AR 01977 483-03)

(Reference 9)

Install a removable 4 ft concrete block barrier at Stoplogs 1, 06/01 /21 Jersey Barriers 2, 16, 17, 18, 19, 20, 21, 22, 23, 24, SL-1, SL-2, and SL-4.

06/01/21 Flood Barrier Replace the existing CMU wall with a stronger/taller CMU Wall wall.

06/01/21 Stop logs Add additional weld metal to Stoplogs 16-22.

06/01/21 Stop logs Add reinforcing stiffeners to Stoplogs 16-24.

06/01/21 Replace existing anchors on Stoplogs 23 and 24 with Stop logs higher capacity mechanical/epoxy anchors.

06/01/21 Reinforce the CMU flood wall with rebar around Stoplogs 1 Stop logs and 15.

06/01/21 Stop logs Caulk/seal the identified Stoplogs before a flooding event.

06/01/21 Procure a new 12 in. drain plug rated for at least 10 ft of Drain Plug back pressure.

06/01/21 Install watertight sealing solution on the 23 manholes Manholes identified in NEE016-PR-001.

06/01/21 Conduit Install watertight seals on the 209 conduits identified in the Penetrations Flooding Hazards Modifications