ML25013A301
| ML25013A301 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/13/2025 |
| From: | Perry Buckberg Plant Licensing Branch II |
| To: | Mack J Florida Power & Light Co |
| Buckberg, P. NRR/DORL 415-1383 | |
| References | |
| EPID L-2024-LLR-0059 | |
| Download: ML25013A301 (1) | |
Text
From:
Perry Buckberg To:
Mack, Jarrett (Jarrett.Mack@fpl.com)
Subject:
Request for Additional Information Related to Turkey Point Nuclear Plant Relief Request VR MOVs biennial leakage test requirement (EPID L-2024-LLE-0059)
Date:
Monday, January 13, 2025 10:50:00 AM Attachments:
External_Sender RE Draft Request for Additional Information Related to Turkey Point Nuclear Plant Relief Request VR MOVs biennial leakage test requirement (EPID L-2024-LLE-0059).msg Final RAIs - Turkey Point Alternative VR-02 for 5th and 6th IST for Various MOVs L-2024-LLR-0059 1-13-25.pdf Good morning Jarrett,
By letter dated August 12, 2024, (ML24225A100), Florida Power and Light Company (FPL),
requested an alternative applicable to the Turkey Point Nuclear Plant, Units 3 and 4. FPL requested relief from the biennial leakage test requirement of ASME OM Code, Section ISTC-3630.
By email dated December 5, 2024, I transmitted a draft request for additional information (RAI) to you. A record of that draft RAI e-mail exchange is attached. Also attached is the final RAI.
FPL has agreed to respond to the attached final RAI within 30 days. The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact Perry Buckberg at (301) 415-1383 or via email at Perry.Buckberg@nrc.gov.
- Thanks, Perry Buckberg Senior Project Manager / Agency 2.206 Petition Coordinator U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation office: (301)415-1383 perry.buckberg@nrc.gov Mail StopO-8B1a, Washington, DC, 20555-0001
REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TURKEY POINT MOV ALTERNATIVE VR-02 FOR 5TH AND 6TH IST FLORIDA POWER & LIGHT COMPANY TURKEY POINT, UNITS 3, 4 DOCKET NO. 05000250, 05000251 ISSUE DATE: 1/13/2025
=
Background===
By letter dated August 12, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24225A100), Florida Power and Light Company (FPL) (the licensee) submitted Alternative Request VR-02 to the U.S. Nuclear Regulatory Commission (NRC) for both the current Fifth Interval Inservice Testing (IST) Program and the Sixth Interval IST Program proposing the use of an alternative to specific requirements in the 2004 Edition through the 2006 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) and the 2020 Edition of the ASME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) at Turkey Point Nuclear Plant (Turkey Point), Units 3 and 4. In Alternative Request VR-02, the licensee proposes to perform periodic internal valve inspections for four Category A motor-operated valves (MOVs) in each Turkey Point unit every three refueling outages in lieu of leak testing of these valves every 2 years required by the ASME OM Code.
Regulatory Basis The NRC regulations in 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, state, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in paragraph 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The NRC regulations in 10 CFR 50.55a(z), Alternatives to codes and standards requirements, state:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Question 1 EMIB-RAI-VR-02-01 Alternative Request VR-02 relies on the past performance of the four MOVs in each Turkey Point unit to support the use of periodic internal inspections rather than 2-year leak testing required by the ASME OM Code. The licensee is requested to describe the performance of recent IST tests (exercise, stroke time, and diagnostic testing) for these MOVs, and the test results.
Question 2 EMIB-RAI-VR-02-02 Alternative Request VR-02 proposes to rely on the close capability of the MOV-856A/B 2-inch globe valves and MOV-864A/B 16-inch double-disk valves in each Turkey Point unit to achieve the leak tightness required for these valves. The licensee is requested to describe the diagnostic testing of the MOV-856A/B 2-inch globe valves and MOV-864A/B 16-inch double-disk valves (including torque or limit switch controls) to demonstrate the effectiveness of the diagnostic testing to provide sufficient closing thrust and torque to minimize seat leakage, and to avoid damage to the valve and actuator.
Question 3 EMIB-RAI-VR-02-03 Alternative Request VR-02 proposes periodic internal inspections rather than leak testing to assess the operational readiness of the applicable valves to perform their leak-tight safety function. The licensee is requested to describe its method to verify that the overall leakage limit is being met to support the implementation of the AST license amendment, and also to describe how this differs from the current requirements for leakage determination for these valves.
Question 4 EMIB-RAI-VR-02-04 Alternative Request VR-02 proposes that periodic internal inspections of each applicable valve be conducted every three refueling outages in lieu of 2-year leak testing of each valve. The licensee is requested to describe the sampling of valves for internal inspection each refueling outage to identify seat degradation prior to the sealing capability becoming unacceptable.
Question 5 EMIB-RAI-VR-02-05 Alternative Request VR-02 states:
In addition to the proposed alternative to conduct inspections of the valve seating surface every three refueling outages via performance of a disk-to-seating surface
blue check, and perform repairs as warranted, these additional, programmatic controls further assure cumulative leakage across MOV-856A, B and MOV-864A, B will not exceed the leakage quantities assumed in the safety analyses.
The licensee is requested to describe the actions required by Alternative Request VR-02 with respect to the reduction in inspection interval of the specific valve and the group of valves, if the proposed inspections or MOV diagnostics indicate that the leakage limits might be exceeded.
From:
Mack, Jarrett To:
Subject:
[External_Sender] RE: Draft Request for Additional Information Related to Turkey Point Nuclear Plant Relief Request VR MOVs biennial leakage test requirement (EPID L-2024-LLE-0059)
Date:
Tuesday, January 7, 2025 7:56:46 AM
- Perry,
A clarification call will not be necessary for the draft RAIs associated with FPLs proposed alternative to the biennial leakage test requirement of ASME OM Code, Section ISTC-3630 for Turkey Point.
Should you have any questions, please let me know.
Jarrett
From: Perry Buckberg <Perry.Buckberg@nrc.gov>
Sent: Thursday, December 5, 2024 3:30 PM To: Mack, Jarrett <Jarrett.Mack@fpl.com>
Subject:
Draft Request for Additional Information Related to Turkey Point Nuclear Plant Relief Request VR MOVs biennial leakage test requirement (EPID L-2024-LLE-0059)
- Jarrett,
By letter dated August 12, 2024, (ML24225A100), Florida Power and Light Company (FPL),
requested an alternative applicable to the Turkey Point Nuclear Plant, Units 3 and 4. FPL requested relief from the biennial leakage test requirement of ASME OM Code, Section ISTC-3630.
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the request and has identified an area where additional information is needed to complete its review. Attached, please find a draft request for additional information (RAI).
The draft RAI is being sent to ensure that the request is understandable and the regulatory basis for the request is clear. This email and the attachment do not convey or represent an NRC staff position regarding TVA's request.
Please let me know if TVA would like to schedule a clarification call to discuss the draft RAI.
- Thanks, Perry Buckberg Senior Project Manager / Agency 2.206 Petition Coordinator U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation office: (301)415-1383 perry.buckberg@nrc.gov Mail StopO-8B1a, Washington, DC, 20555-0001