NRC 2011-0010, Plan for Completion of Actions for Generic Letter 2004-02 Potential Impact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors

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Plan for Completion of Actions for Generic Letter 2004-02 Potential Impact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
ML110350515
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 02/04/2011
From: Meyer L
Point Beach
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, NRC 2011-0010, TAC MC4705, TAC MC4706
Download: ML110350515 (3)
v • d • e


Text

February 4,201 1 NRC 2011-0010 GL 2004-02 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units Iand 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Plan for Completion of Actions for Generic Letter 2004-02 Potential Impact for Debris Blockage in Emergencv Recirculation Durinq Design Basis Accidents at Pressurized-Water Reactors

{TAC No. MC4705lMC4706)

References:

See Below Via Reference (I), the Commission granted a request submitted and subsequently supplemented by NextEra Energy Point Beach, LLC (NextEra) (References 2 and 3) for an extension to achieve compliance with the provisions of Generic Letter (GL) 2004-02 for Point Beach Nuclear Plant (PBNP), Unit 1.

The Regulatory Commitment made by NextEra in Reference (3), and reiterated in Reference (I), states the following:

Within 60 days following establishment of sufficient Commission direction to resolve the remaining GSI-I 91 issues, PBNP will submit to the NRC a plan with milestones to achieve final resolution.

The extension was approved until 90 days following Commission direction to the NRC staff to address the NRC Staff Requirements Memorandum dated May 17, 2010. The Commission provided the stated direction to the NRC staff via Reference (4).

With respect to PBNP Unit 2, the extension was approved by the NRC in a letter dated June 30, 2009 (Reference 5). Unit 2, therefore, was not addressed in References (1) and (3).

The Regulatory Commitment made in Reference (6) states that NextEra will complete modifications to resolve GSI-191 for Unit 2 by June 30, 2011.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 I

Document Control Desk Page 2 Subsequent to the above correspondence, Reference (4) was issued by the Commission to the NRC staff on December 23,2010. This document acknowledges that stakeholders and the Staff have agreed upon tests and analyses that remain to be completed regarding in-vessel effects, which could be the controlling factor in resolving GSI-191. It further acknowledges the prudence of deferring further plant modification actions, such removal of fibrous insulation, until tests and analyses are complete.

A path forward is uncertain, pending completion of testing and analyses, and completion of NRC staff evaluations of Options Iand 2, which are expected to occur over the next 18-month period and will culminate with a report to the Commission. Accordingly, it would be premature for NextEra to provide a detailed milestone schedule and activities for resolution and closure of GL 2004-02 at this time, pending further direction from the NRC staff.

The deterministic justification for continued operation provided to the Commission by NextEra for the previously requested extensions for resolution and closure of GL 2004-02 remain unchanged. In Reference (4), the Commission further validates NRC staff and licensee conclusions to date by stating, "...the vastly enlarged advanced strainers installed, compensatory measures already taken, and the low probability of challenging pipe breaks, adequate defense-in-depth is currently being maintained."

NextEra has established and implemented mitigating measures and physical improvements such as a new strainer design installed on both Units Iand 2 which significantly increases the available flow area from approximately 21 ft2 to 1,900 ft2. The amount of fibrous insulation inside containment on both Units has been significantly reduced. In addition to the physical modifications that have taken place at PBNP, inspections of the protective coatings in containment are performed on a refueling outage frequency, in accordance with the PBNP protective coatings program. Procedural controls have been established to limit potential debris sources in containment and emergency procedures have been revised to direct operators to monitor sump performance.

Therefore, the above Regulatory Commitments for Units 1 and 2 are revised as follows:

e NextEra shall develop a plan to achieve final resolution of GSI-191 for PBNP, Units 1 and 2, consistent with future industry guidance and the Reference (4) Staff Requirements Memo, by June 30, 2012.

If you have questions or require additional information, please contact Mr. James Costedio at 9201755-7427.

In accordance with the provisions of 10 CFR 50.91, a copy of this submittal has been provided to the designated Wisconsin Official.

Document Control Desk Page 3 Very truly yours, NextEra Energy Point Beach, LLC site-vice-president cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

References:

( 1 NRC letter to NextEra Energy Point Beach, LLC, dated June 30, 2010, Point Beach Nuclear Plant, Unit I- Generic Letter 2004-02 Extension Request Approval (TAC No. MC4705) (MLI 01800052)

(2) NextEra Energy Point Beach, LLC letter to NRC, dated February 19, 2010, Request for Extension of Completion Date for Generic Letter 2004-02, Potential lmpact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC No.

MC4705lMC4706) (MLI 00500632)

(3) NextEra Energy Point Beach, LLC letter to NRC, dated June 11, 2010, Supplemental Response for Extension Request for Completion of Actions for Generic Letter 2004-02, Potential lmpact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC No. MC4705lMC4706) (MLI 01650080)

(4) U.S. Nuclear Regulatory Commission, "Staff Requirements -

SECY-10-0113 - Closure Options for Generic Safety Issue - 191, Assessment of Debris Accumulation on Pressurized Water Reactor Sump Performance," Commission Staff Requirements Memo SECY-10-0113, December 23,201 0 (MLI 03570354)

(5) NRC letter to NextEra Energy Point Beach, LLC, dated June 30, 2009, Point Beach Nuclear Plant, Units Iand 2 - GSI-191IGL 2004-02 Additional Extension Request Approval (TAC Nos. MC4705 and MC4706)

(ML091800430)

(6) NextEra Energy Point Beach, LLC letter to NRC, dated June 12, 2009, Request for Extension of Unit 1 and 2 Completion Dates for Generic Letter 2004-02, Potential Impact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC Nos. MC4705lMC4706) (ML091660326)

Text

February 4,201 1 NRC 2011-0010 GL 2004-02 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units Iand 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Plan for Completion of Actions for Generic Letter 2004-02 Potential Impact for Debris Blockage in Emergencv Recirculation Durinq Design Basis Accidents at Pressurized-Water Reactors

{TAC No. MC4705lMC4706)

References:

See Below Via Reference (I), the Commission granted a request submitted and subsequently supplemented by NextEra Energy Point Beach, LLC (NextEra) (References 2 and 3) for an extension to achieve compliance with the provisions of Generic Letter (GL) 2004-02 for Point Beach Nuclear Plant (PBNP), Unit 1.

The Regulatory Commitment made by NextEra in Reference (3), and reiterated in Reference (I), states the following:

Within 60 days following establishment of sufficient Commission direction to resolve the remaining GSI-I 91 issues, PBNP will submit to the NRC a plan with milestones to achieve final resolution.

The extension was approved until 90 days following Commission direction to the NRC staff to address the NRC Staff Requirements Memorandum dated May 17, 2010. The Commission provided the stated direction to the NRC staff via Reference (4).

With respect to PBNP Unit 2, the extension was approved by the NRC in a letter dated June 30, 2009 (Reference 5). Unit 2, therefore, was not addressed in References (1) and (3).

The Regulatory Commitment made in Reference (6) states that NextEra will complete modifications to resolve GSI-191 for Unit 2 by June 30, 2011.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 I

Document Control Desk Page 2 Subsequent to the above correspondence, Reference (4) was issued by the Commission to the NRC staff on December 23,2010. This document acknowledges that stakeholders and the Staff have agreed upon tests and analyses that remain to be completed regarding in-vessel effects, which could be the controlling factor in resolving GSI-191. It further acknowledges the prudence of deferring further plant modification actions, such removal of fibrous insulation, until tests and analyses are complete.

A path forward is uncertain, pending completion of testing and analyses, and completion of NRC staff evaluations of Options Iand 2, which are expected to occur over the next 18-month period and will culminate with a report to the Commission. Accordingly, it would be premature for NextEra to provide a detailed milestone schedule and activities for resolution and closure of GL 2004-02 at this time, pending further direction from the NRC staff.

The deterministic justification for continued operation provided to the Commission by NextEra for the previously requested extensions for resolution and closure of GL 2004-02 remain unchanged. In Reference (4), the Commission further validates NRC staff and licensee conclusions to date by stating, "...the vastly enlarged advanced strainers installed, compensatory measures already taken, and the low probability of challenging pipe breaks, adequate defense-in-depth is currently being maintained."

NextEra has established and implemented mitigating measures and physical improvements such as a new strainer design installed on both Units Iand 2 which significantly increases the available flow area from approximately 21 ft2 to 1,900 ft2. The amount of fibrous insulation inside containment on both Units has been significantly reduced. In addition to the physical modifications that have taken place at PBNP, inspections of the protective coatings in containment are performed on a refueling outage frequency, in accordance with the PBNP protective coatings program. Procedural controls have been established to limit potential debris sources in containment and emergency procedures have been revised to direct operators to monitor sump performance.

Therefore, the above Regulatory Commitments for Units 1 and 2 are revised as follows:

e NextEra shall develop a plan to achieve final resolution of GSI-191 for PBNP, Units 1 and 2, consistent with future industry guidance and the Reference (4) Staff Requirements Memo, by June 30, 2012.

If you have questions or require additional information, please contact Mr. James Costedio at 9201755-7427.

In accordance with the provisions of 10 CFR 50.91, a copy of this submittal has been provided to the designated Wisconsin Official.

Document Control Desk Page 3 Very truly yours, NextEra Energy Point Beach, LLC site-vice-president cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

References:

( 1 NRC letter to NextEra Energy Point Beach, LLC, dated June 30, 2010, Point Beach Nuclear Plant, Unit I- Generic Letter 2004-02 Extension Request Approval (TAC No. MC4705) (MLI 01800052)

(2) NextEra Energy Point Beach, LLC letter to NRC, dated February 19, 2010, Request for Extension of Completion Date for Generic Letter 2004-02, Potential lmpact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC No.

MC4705lMC4706) (MLI 00500632)

(3) NextEra Energy Point Beach, LLC letter to NRC, dated June 11, 2010, Supplemental Response for Extension Request for Completion of Actions for Generic Letter 2004-02, Potential lmpact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC No. MC4705lMC4706) (MLI 01650080)

(4) U.S. Nuclear Regulatory Commission, "Staff Requirements -

SECY-10-0113 - Closure Options for Generic Safety Issue - 191, Assessment of Debris Accumulation on Pressurized Water Reactor Sump Performance," Commission Staff Requirements Memo SECY-10-0113, December 23,201 0 (MLI 03570354)

(5) NRC letter to NextEra Energy Point Beach, LLC, dated June 30, 2009, Point Beach Nuclear Plant, Units Iand 2 - GSI-191IGL 2004-02 Additional Extension Request Approval (TAC Nos. MC4705 and MC4706)

(ML091800430)

(6) NextEra Energy Point Beach, LLC letter to NRC, dated June 12, 2009, Request for Extension of Unit 1 and 2 Completion Dates for Generic Letter 2004-02, Potential Impact for Debris Blockage in Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors (TAC Nos. MC4705lMC4706) (ML091660326)

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