NRC 2008-0038, Supplemental Response to Generic Letter 2004-02, Potential Lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors

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Supplemental Response to Generic Letter 2004-02, Potential Lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
ML081620337
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 06/09/2008
From: Mccarthy J
Florida Power & Light Energy Point Beach
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, NRC 2008-0038
Download: ML081620337 (3)
v • d • e


Text

FPL Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 FPL E m e ~ g y Point Beach Nuclear Plarlt June 9,2008 NRC 2008-0038 GL 2004-02 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Unit 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Supplemental Response to Generic Letter 2004-02, Potential lmpact of Debris Blockaae on Emeraencv Recirculation Durina Desian Basis Accidents at Pressurized-Water Reactors

References:

(1) NRC Generic Letter (GL) 2004-02 dated September 13, 2004, "Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors?(ML042360586)

(2) Nuclear Management Company, LLC Letter to NRC dated September 1, 2005,

'Nuclear Management Company Response to GL 2004-02: Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactor$ (ML052500302)

NRC Letter to Nuclear Management Company, LLC dated February 9,2006,

'Point Beach Nuclear Plant, Units 1 and 2: Request For Additional Information Re: Response to GL 2004-02: Potential lmpact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized-Water Reactors?(ML060370491)

NMC Letter to NRC dated October 3, 2006, "Supplemental Response to GL 2004-02, Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water ReactorS'(ML062850105)

FPL Energy Point Beach Letter to NRC dated November 16,2007,"Response to GL 2004-02, Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water ReactorS(ML073230345)

FPL Energy Point Beach Letter to NRC dated February 29, 2008,"Supplemental Response to Generic Letter 2004-02, Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactor$ (ML080630613)

Telephone Conference with NRC on February 26, 2008, regarding Point Beach Nuclear Plant Resolution of GL 2004-02 Telephone Conference with NRC on May 20, 2008, regarding Point Beach Nuclear Plant Resolution of GL 2004-02 An FPL Group company

Document Control Desk Page 2 This letter documents the discussions between representatives of the NRC Staff and FPL Energy Point Beach regarding extension of the June 30, 2008, completion of activities required via Generic Letter 2004-02. The discussions are identified as References (7) and (8) above.

FPL Energy Point Beach has not been able to conduct the confirmatory head loss testing of the replacement emergency core cooling system (ECCS) sump screens as a result of limited test facility availability. Therefore, a final submittal containing the information requested in References (I) and (3) will be delayed beyond June 30, 2008, as previously committed to in Reference (6).

The remaining areas to be addressed to complete GL 2004-02 are head loss testing (including potential chemical effects), analysis of potential chemical precipitants, and evaluation of both in-vessel and ex-vessel downstream effects. While the analyses and evaluations of chemical effects and downstream effects have been completed, these results will be submitted with the head loss test results so the final submittal is complete.

FPL Energy Point Beach has been actively engaged in monitoring and evaluating the test results and experiences of other pressurized water reactors (PWR) testing of similar ECCS strainers. As a result of some of the test results obtained by the contractors performing tests for other PWRs, FPL Energy Point Beach is revisiting the debris generation analyses and exploring other areas where excessive conservatisms could cause head loss test failures when actual screen performance is expected to be fully acceptable.

Earlier tests performed for FPL Energy Point Beach used the default zone of influence (ZOI) values stated in NEI 04-07 Volume I and accepted in Volume II. This resulted in a very large volume of generated debris. Industry testing has demonstrated that actual ZOls (specifically the ZOI for NUKON insulation) are substantially smaller. Therefore, FPL Energy Point Beach is revising the debris generation analyses to reflect these later test results and reduce the total quantity of fibrous debris from NUKON. Changes from the methodology previously submitted will be discussed in the final submittal.

As a result of these supporting analytical changes, the scheduled large flume testing for FPL Energy Point Beach at Alden Laboratories has been delayed to the week of July 7, 2008.

The testing contractors have indicated that the preparation, review and approval of the final test reports and supporting calculations will require six weeks following completion of testing.

FPL Energy Point Beach intends to develop the final submittal to the NRC in parallel, and to provide that submittal by September 30, 2008. This new date represents a three-month delay in transmittal of the final response to GL 2004-02 from that previously committed in Reference (6).

Transmittal of the test results to NRC can be provided, if desired, within a week following completion of testing.

The planned testing will be performed in accordance with the protocol previously established by PCI, AREVA, and Alden Laboratories for the demonstration testing of"SureFld'strainers.

The replacement screens have been installed, the affected procedures have been revised to reflect the operating requirements of the screens, and there are no remaining modifications or changes planned.

Document Control Desk Page 3 The bases for a reasonable assurance of operability with the installed replacement strainers is unchanged from that detailed in Reference (5),and is further substantiated by the information provided in Reference (6). In addition, the mitigative measures that were described in Reference (5) remain in effect.

Summary of Resulatory Commitments This letter revises the following Regulatory Commitment stated in Reference (6):

The final submittal of the testing and analyses demonstrating acceptable long-term ECCS performance in the areas of downstream and chemical effects will be made by September 30, 2008.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 9.2008.

Very truly yours, FPL ENERGY-BEACH, LLC 2+-?P Site ice President McCarthy Enclosures CC: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

Text

FPL Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 FPL E m e ~ g y Point Beach Nuclear Plarlt June 9,2008 NRC 2008-0038 GL 2004-02 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Unit 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Supplemental Response to Generic Letter 2004-02, Potential lmpact of Debris Blockaae on Emeraencv Recirculation Durina Desian Basis Accidents at Pressurized-Water Reactors

References:

(1) NRC Generic Letter (GL) 2004-02 dated September 13, 2004, "Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors?(ML042360586)

(2) Nuclear Management Company, LLC Letter to NRC dated September 1, 2005,

'Nuclear Management Company Response to GL 2004-02: Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactor$ (ML052500302)

NRC Letter to Nuclear Management Company, LLC dated February 9,2006,

'Point Beach Nuclear Plant, Units 1 and 2: Request For Additional Information Re: Response to GL 2004-02: Potential lmpact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized-Water Reactors?(ML060370491)

NMC Letter to NRC dated October 3, 2006, "Supplemental Response to GL 2004-02, Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water ReactorS'(ML062850105)

FPL Energy Point Beach Letter to NRC dated November 16,2007,"Response to GL 2004-02, Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water ReactorS(ML073230345)

FPL Energy Point Beach Letter to NRC dated February 29, 2008,"Supplemental Response to Generic Letter 2004-02, Potential lmpact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactor$ (ML080630613)

Telephone Conference with NRC on February 26, 2008, regarding Point Beach Nuclear Plant Resolution of GL 2004-02 Telephone Conference with NRC on May 20, 2008, regarding Point Beach Nuclear Plant Resolution of GL 2004-02 An FPL Group company

Document Control Desk Page 2 This letter documents the discussions between representatives of the NRC Staff and FPL Energy Point Beach regarding extension of the June 30, 2008, completion of activities required via Generic Letter 2004-02. The discussions are identified as References (7) and (8) above.

FPL Energy Point Beach has not been able to conduct the confirmatory head loss testing of the replacement emergency core cooling system (ECCS) sump screens as a result of limited test facility availability. Therefore, a final submittal containing the information requested in References (I) and (3) will be delayed beyond June 30, 2008, as previously committed to in Reference (6).

The remaining areas to be addressed to complete GL 2004-02 are head loss testing (including potential chemical effects), analysis of potential chemical precipitants, and evaluation of both in-vessel and ex-vessel downstream effects. While the analyses and evaluations of chemical effects and downstream effects have been completed, these results will be submitted with the head loss test results so the final submittal is complete.

FPL Energy Point Beach has been actively engaged in monitoring and evaluating the test results and experiences of other pressurized water reactors (PWR) testing of similar ECCS strainers. As a result of some of the test results obtained by the contractors performing tests for other PWRs, FPL Energy Point Beach is revisiting the debris generation analyses and exploring other areas where excessive conservatisms could cause head loss test failures when actual screen performance is expected to be fully acceptable.

Earlier tests performed for FPL Energy Point Beach used the default zone of influence (ZOI) values stated in NEI 04-07 Volume I and accepted in Volume II. This resulted in a very large volume of generated debris. Industry testing has demonstrated that actual ZOls (specifically the ZOI for NUKON insulation) are substantially smaller. Therefore, FPL Energy Point Beach is revising the debris generation analyses to reflect these later test results and reduce the total quantity of fibrous debris from NUKON. Changes from the methodology previously submitted will be discussed in the final submittal.

As a result of these supporting analytical changes, the scheduled large flume testing for FPL Energy Point Beach at Alden Laboratories has been delayed to the week of July 7, 2008.

The testing contractors have indicated that the preparation, review and approval of the final test reports and supporting calculations will require six weeks following completion of testing.

FPL Energy Point Beach intends to develop the final submittal to the NRC in parallel, and to provide that submittal by September 30, 2008. This new date represents a three-month delay in transmittal of the final response to GL 2004-02 from that previously committed in Reference (6).

Transmittal of the test results to NRC can be provided, if desired, within a week following completion of testing.

The planned testing will be performed in accordance with the protocol previously established by PCI, AREVA, and Alden Laboratories for the demonstration testing of"SureFld'strainers.

The replacement screens have been installed, the affected procedures have been revised to reflect the operating requirements of the screens, and there are no remaining modifications or changes planned.

Document Control Desk Page 3 The bases for a reasonable assurance of operability with the installed replacement strainers is unchanged from that detailed in Reference (5),and is further substantiated by the information provided in Reference (6). In addition, the mitigative measures that were described in Reference (5) remain in effect.

Summary of Resulatory Commitments This letter revises the following Regulatory Commitment stated in Reference (6):

The final submittal of the testing and analyses demonstrating acceptable long-term ECCS performance in the areas of downstream and chemical effects will be made by September 30, 2008.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 9.2008.

Very truly yours, FPL ENERGY-BEACH, LLC 2+-?P Site ice President McCarthy Enclosures CC: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

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