ML22111A178
| ML22111A178 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/26/2022 |
| From: | Florida Power & Light Co |
| To: | Michael Mahoney, Moul D NRC/NRR/DORL/LPL2-2 |
| Mahoney M | |
| References | |
| Download: ML22111A178 (13) | |
Text
1 Turkey Point Unit 3 and Unit 4 License Amendment Request: Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project Non-proprietary information suitable for public disclosure April 26, 2022 OPEN SESSION
2 Florida Power & Light Contract and Support Introductions - On the Call today
- FPL Nuclear Fleet Licensing
- Jarrett Mack - Fleet Licensing Lead
- Michael Davis - Nuclear Fleet Licensing Manager
- Steve Catron - Fleet Director of Regulatory Affairs
- FPL Nuclear Engineering
- Phil Barnes - Nuclear Engineering Manager
- Stet Hindes - Lead Nuclear Engineer
- Anil Julka - Nuclear Reliability and Risk Manager
- Phil Opsal - Licensing Lead
- Stuart Brown - Project Manager
- Garrett Snedeker - PRA
- Jensen Hughes
- Usama Farradj - Fire PRA
- Andy Ratchford - NSCA/Licensing
- Vinny Rubano - Consultant
- Enercon
3 Agenda - Open and Closed Sessions Open Session
- Background/Purpose
- License Amendment Request (LAR)
- Impact on Probabilistic Risk Assessment (PRA)
- Fire PRA Refinements
- PRA Quality
- Defense in Depth/Safety Margin
- Schedule
- Questions and Comments Closed Session Reserved for proprietary questions/responses Non-proprietary information suitable for public disclosure
4 Background/Purpose History of Reactor Coolant Pump (RCP) Seal Configuration
- NFPA 805 submittal committed to replacement of the original RCP seals with a seal capable of minimizing RCP seal leakage and supporting a longer period of no RCP seal cooling/seal injection prior to the need for an RCP trip. (Amendments 262/257 - ML15061A237)
- Business strategy - elected to install alternate seal design with longer service life
- Framatome RCP Hydrostatic Seal Package equipped with the Framatome Passive Shutdown Seal (PSDS) chosen.
Non-proprietary information suitable for public disclosure
5 Background/Purpose Initial Approach
- On January 13, 2022, FPL held a drop-in meeting with NRC in preparation for a public meeting to discuss the replacement of the existing RCP seal with the Framatome RCP Hydrostatic Seal Package equipped with the Framatome PSDS.
- Since that meeting the licensing strategy has been revised to develop a site-specific analysis based on accepted industry practices.
- The revised licensing approach includes a LAR to address the impact of the RCP seal replacement on the Fire Protection Program as discussed in this meeting.
Non-proprietary information suitable for public disclosure
6 License Amendment Request License Condition
- The license condition related to the Fire Protection Program established at PTN Units 3 and 4 is listed below. This condition allows some risk-informed changes to be made to the Fire Protection Program without prior NRC approval, provided certain limits are met.
D. Fire Protection Risk-Informed Changes that May Be Made Without Prior NRC Approval (b)
Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1 x 10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Non-proprietary information suitable for public disclosure
7 License Amendment Request Reason for the LAR
- The revised risk values are expected to exceed the NFPA 805 self-approval limit listed in the license condition.
LAR to be submitted in accordance with 10 CFR 50.90
- Content of the LAR includes:
Reason for revised PRA values Fire PRA refinements PRA quality Defense in depth Safety margins Non-proprietary information suitable for public disclosure
8 Impact on PRA Reason for Revised PRA Values
- Change in RCP seal failure probabilities
- Change in time available for RCP trip Non-proprietary information suitable for public disclosure
9 Fire PRA Refinements The latest NRC guidance on interruptible fires and transient fire size was incorporated.
Refinements of existing scenarios to incorporate fire modeling similar to that used elsewhere in the Fire PRA.
Non-proprietary information suitable for public disclosure
10 PRA Quality Peer Review Facts & Observation (F&O) Status
- PRA Quality conforms to Regulatory Guide 1.200, Rev. 2
- Risk informed applications currently in effect at Turkey Point include:
Surveillance Frequency Control Program (SFCP, TSTF-425, RITS initiative 5b)
Risk Informed Completion Time (RICT, TSTF-505, RITS initiative 4b)
- Four F&Os not formally closed via the Independent Assessment of F&O Closure review performed by the PWROG in 2019 (which included NRC and PWROG observers)
- Basis for open F&Os not impacting this LAR will be addressed as part of the submittal Sources of Uncertainty
- Will address uncertainty in accordance with NUREG-1855 Non-proprietary information suitable for public disclosure
11 Defense in Depth/Safety Margin As stated in the license condition and industry guidance both defense in depth and safety margin considerations must be addressed.
Non-proprietary information suitable for public disclosure
12 Schedule LAR submittal scheduled for July 2022
- Request standard one year review period Installation scheduled for Unit 4 fall 2023 outage and Unit 3 fall 2024 outage Non-proprietary information suitable for public disclosure
13 Questions and Comments Non-proprietary information suitable for public disclosure