ML22111A178

April 26, 2022 Public Meeting on Reactor Coolant Pump Seal Replacement - Florida Power and Light Slides

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

Turkey Point Unit 3 and Unit 4 License Amendment Request: Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project April 26, 2022 OPEN SESSION 1 Non-proprietary information suitable for public disclosure

Introductions - On the Call today Florida Power & Light Contract and Support

• FPL Nuclear Fleet Licensing

• Framatome

• Jarrett Mack - Fleet Licensing Lead

• Phil Opsal - Licensing Lead

• Michael Davis - Nuclear Fleet

• Stuart Brown - Project Manager Licensing Manager

• Garrett Snedeker - PRA

• Steve Catron - Fleet Director of Regulatory Affairs

• FPL Nuclear Engineering

• Jensen Hughes

• Phil Barnes - Nuclear Engineering

• Usama Farradj - Fire PRA Manager

• Andy Ratchford - NSCA/Licensing

• Stet Hindes - Lead Nuclear Engineer

• Vinny Rubano - Consultant

• FPL Nuclear Fleet PRA

• Enercon

• Anil Julka - Nuclear Reliability and

• Pat Furio - LAR Lead Risk Manager

• Keith Vincent - Lead PRA Engineer 2 Non-proprietary information suitable for public disclosure

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 3 Non-proprietary information suitable for public disclosure

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.

4 Non-proprietary information suitable for public disclosure

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.

5 Non-proprietary information suitable for public disclosure

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.

6 Non-proprietary information suitable for public disclosure

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 7 Non-proprietary information suitable for public disclosure

Impact on PRA

• Reason for Revised PRA Values

- Change in RCP seal failure probabilities

- Change in time available for RCP trip 8 Non-proprietary information suitable for public disclosure

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.

9 Non-proprietary information suitable for public disclosure

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 10 Non-proprietary information suitable for public disclosure

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.

11 Non-proprietary information suitable for public disclosure

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 12 Non-proprietary information suitable for public disclosure

Questions and Comments 13 Non-proprietary information suitable for public disclosure