L-2025-028, Unit 4, Response to Request for Additional Information License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement
| ML25049A133 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/18/2025 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2025-028 | |
| Download: ML25049A133 (1) | |
Text
l=PL.
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE:
Turkey Point Nuclear Generating Station, Unit 4 Docket No. 50-251 Renewed Facility Operating License DPR-41 February 18, 2025 L-2025-028 10 CFR 50.90 Response to Request for Additional Information RE: License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project References:
- 1.
Florida Power & Light Company letter L-2025-019, License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, February 4, 2025 (ADAMS Accession No. ML25036A099)
- 2.
Nuclear Regulatory Commission electronic memorandum dated February 13, 2025, Request for Additional Information by the Office of Nuclear Reactor Regulation Regarding License Amendment Request to Extend the Implementation Date for Amendment 291 in Support of Reactor Coolant Pump Seal Replacement Project, Turkey Point Nuclear Generating Station, Unit 4, Florida Power and Light Company Docket No. 50-251, EPID No. L-2025-LLA-0026 (ADAMS Accession No. ML25044A247)
In Reference 1, Florida Power & Light Company (FPL) requested an extension of the implementation date specified in Amendment 291 to Subsequent Renewed Facility Operating License (SRFOL) DPR-41 from refueling outage (RFO) 4R35 (spring 2025) to RFO 4R36 (spring 2027) for Turkey Point Nuclear Generating Station (Turkey Point), Unit 4.
In Reference 2, the NRG staff requested additional information deemed necessary to complete its review.
The enclosure to this letter provides FPL's response to the NRG request for information (RAI). The information in this RAI response provides additional information that clarifies the application, does not expand the scope of the application as originally noticed, and should not change the NRG staffs originally proposed notice of determination of no significant hazards as published in the Federal Register.
This letter contains no new or revised regulatory commitments.
Should yciu have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 181h day of February 2025,
~~;:;:~
Ke A.Mac Director, Licensing and Regulatory Compliance Florida Power & Light Company Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035
Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health
Enclosure:
L-2025-028 Page 2 of 2
Turkey Point Nuclear Plant, Unit 4 Docket No. 50-251 L-2025-028 Enclosure Page 1 of 1 In Reference 1, Florida Power & Light Company (FPL) requested an extension of the implementation date specified in Amendment 291 to Subsequent Renewed Facility Operating License (SRFOL) DPR-41 from refueling outage (RFO) 4R35 (spring 2025) to RFO 4R36 (spring 2027) for Turkey Point Nuclear Generating Station {Turkey Point), Unit 4.
In Reference 2, the NRC staff requested additional information deemed necessary to complete its review, as indicated below. FPL's response follows..
NRC Staff Request for Additional Information (RAI):
The licensee stated that the conversion to the new RCP seal design is a complex modification necessitating, amongst other changes, replacement of the rotating assembly seal housing and seal water injection piping, thereby requiring detailed planning, scheduling and equipment staging and that due to unforeseen circumstances, vendor fabrication of the seal conversion equipment is delayed.
The licensee stated that it chooses to complete the scheduled "rotating assembly replacements" but install another set of Flowserve NX seals during the Unit 4 spring 2025 outage and that the "rotating assembly replacements" will serve to reduce the installation scope and duration for the new RCP seal conversion during the following spring 2027 outage and that since the current Fire Protection Program reflects the current seal design, operating for an additional cycle will not present new or heightened operational risk.
Explain what equipment is included in the "rotating assembly replacements" that will be completed during the Unit 4 spring 2025 outage and whether or not the equipment is considered like for like replacements or is considered new equipment needed to support the Framatome RCP hydrostatic seal package equipped with the Passive Shutdown Seal (PSDS). If the latter, explain how this new equipment will properly work with the Flowserve NX seals and not increase risk during the time it is installed.
FPL Response:
The plan to convert to the Framatome OEM style seal relies upon restoring the rotating assemblies to original design condition some time prior to the conversion. During the Unit 4 Spring 2025 outage, the last Reactor Coolant Pump (RCP) Rotating Assembly will be replaced like for like with a refurbished rotating element as an overall preventive maintenance type task. The refurbished Rotating Assemblies include a new shaft with integral sleeve and a new lower bearing, both considered key elements to improving the operation and expected life of the seals. It is not a design change from the currently installed rotating assembly and can operate with either seal design. Therefore, there is no new or heightened risk associated with the rotating assembly replacement for use with the Flowserve NX seals.
References:
- 1.
Florida Power & Light Company letter L-2025-019, License Amendment Request 280, Extend Implementation Date for Amendment No. 291 Regarding Revised Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, February 4, 2025 (ADAMS Accession No. ML25036A099)
- 2.
Nuclear Regulatory Commission electronic memorandum dated February 13, 2025, Request for Additional Information by the Office of Nuclear Reactor Regulation Regarding License Amendment Request to Extend the Implementation Date for Amendment 291 in Support of Reactor Coolant Pump Seal Replacement Project, Turkey Point Nuclear Generating Station, Unit 4, Florida Power and Light Company Docket No. 50-251, EPID No. L-2025-LLA-0026 (ADAMS Accession No. ML25044A247)