SBK-L-04077, Letter from FPL Energy Seabrook Station - Response to Request for Additional Information, Inspection Report 50-443/2004-003/Predecisional Enforcement Conference. with Slide Attachment

Letter from FPL Energy Seabrook Station - Response to Request for Additional Information, Inspection Report 50-443/2004-003/Predecisional Enforcement Conference. with Slide Attachment

ML043230440
Person / Time
Site:	Seabrook
Issue date:	10/08/2004
From:	Warner M Florida Power & Light Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-04-003, SBK-L-04077 RGN-001
Download: ML043230440 (13)

Text

FPL Energy ocr 12 p FPL Energy Seabrook Station Seabrook Station "" '2h"0. Box 300 Seabrook, NH 03874 (603) 773-7000 October 8,2004 Docket No. 50-443 SBK-L-04077 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D .C. 20555-0001 Seabrook Station Response to Request for Additional Information Inspection Report 50-0443/2004003/Predecisional Enforcement Conference FPL Energy Seabrook, LLC (FPL Energy Seabrook) provides in the enclosure the additional information requested by the Region I staff during the September 23, 2004 predecisional enforcement conference to discuss an apparent violation identified in Inspection Report 50-443/2004003.The additional information addresses questions regarding the manual operation of the turbine building rollup doors, rollup door operation during flooding and a review of expansion joint operating experience. As noted in the attached slides, the additional information supports our position that the operators will be able to open the rollup door in a timely manner in all conditions and there is no industry operating experience of a catastrophic failure of an expansionjoint of the type used at Seabrook Station.

The inclusion of the additional information does not change our conclusions, as presented during the predecisional enforcement conference, regarding the results of the 10CFR50.59 Evaluation performed under the new rule or the significance of the apparent violation. Copies of the attached slides were provided to Region I by fax on October 4,2004.

U.S. Nuclear Regulatory Commission SBK-L-04077 / Page 2 Very truly yours, FPL Energy Seabrook, LLC

-- I Site Vice President cc. S . J. Collins, NRC Region I Administrator S. P. Wall, NRC Project Manager, Project Directorate 1-2 G. T. Dentel, NRC Resident Inspector Dr. R. R. Bellamy, Region I Branch Chief

ENCLOSURE TO SBK-L-04077 Presentation (10 s l i d e s )

Manual Operation of Rollup Doors Reviewed original NSO timing sheets.

- 3 NSO's unfamiliar w/ manual operation, Ifamiliar

- INSO (unfamiliar) not given opportunity to open door

- 3 NSO's successful Effect of manual door operation on timing

- First rollup door adds 2.15 minutes

- Second rollup door adds 1.2 minutes

- Total time from start of scenario to manually open doors is 7.96 minutes

- Opening doors within 8 minutes approximately doubles FPL Energy Seabrook Station 1

Manual Operation of Rollup Doors (Continued)

ResuIts HEP assumption of NSOs not trained to open doors yields minimal impact on CDF increase Therefore, no impact on original conclusions FPL Energy Seabrook Station 2

Expansion Joint Operating Experience Reviewed rubber expansion joint failure data referred by NRC Reviewed EPRIINMAC Report 1008635, Expansion Joint Maintenance Guide

- Most failures in systems w/ different operating parameters than our Circulating Water system

- No indication of gross failures that resulted in leakage approaching the 56,000 gpm design

- No circumferential tears identified

- EPDM material, as used at Seabrook Station, Will not age rapidly when exposed to low temperature Deterioration of reinforcing rings and cord delamination will progress slowly, allowing detection before failure S

FPL Energy Seabrook Station 3

Expansion Joint Operating Experience (Continued)

ResuIts No impact on initiating event frequency No impact on risk increase.

FPL Energy Seabrook Station

Expansion Joint Operating Experience Additional Information From EPRIINMAC Report 1008635

- 15 of 31 events: smaller (241,301,3411) expansion joints less robust consfrucfion and less force fo deflecf joint

- I 5 of 31 events: condensate pump expansion joints, higher temperature, more rapid aging

- 20 of 31 events: expansion joints on suction or discharge of pumps - higher stresses and pressure surges

- Ievent: 108 expansion joint, 2000 gpm leak- Water Hammer initiated FPL Energy Seabrook Station 5

Expansion Joint Operating Experience EPRI Failure Data for Rubber Expansion Joints Plant &E Event Description AN0 2 18 30-in. expansion joint condensate pump.

Expansion joint inspected and found to have pinholes because of aging Beaver Valley Expansion joint collapsed Beaver Valley I I9 24-in. SW expansion joint ruptured because of erosion of tube (replaced in 1985)

Beaver Valley 2 4 30-in. condensate pump suction expansion joint deformed and partially collapsed, no leakage Beaver Valley 2 10 30-in. suction expansion joint for condensate pump found to have pinhole leak Brunswick 1 14 Rupture of screen wash pump expansion joint Byron I 7 Condensate pump expansion joint cover found torn 180 degrees Calvert Cliffs I 3 24-in.suction side of condensate pump expansion joint-tube imploded and core of joint visible FPL Energy Seabrook Station 6

Expansion Joint Operating Experience EPRl Failure Data for Rubber Expansion Joints Plant  !!!!E Event DescriDt ion Clinton 1 4 Condenser water box over-pressurized, damage to water box expansion joint, no leakage Clinton 1 3 Inlet expansion joint to condenser leaking (Icup/hr)

Comanche Peak I 8 Circulation pump expansion joint ruptured because of normal aging Cook I 15 8-in. SW header expansion joint leaked because of 4-in. gash in the joint, cause unknown Cook 2 9 Expansion joint in discharge header of essential service water pump ruptured because of degradation Crystal River 3 8 IO-in. SW pump suction expansion joint failed - hole in joint Diablo Canyon 1,2 13 Two cooling system synthetic expansion joints experienced catast rophic fa iIures Ft. St. Vrain I 14 CCW expansion joint failed because of degradation FPL Energy Seabrook Station 7

Expansion Joint Operating Experience EPRI Failure Data for Rubber Expansion Joints Plant &E Event Description Indian Pt. 3 12 30-in. condensate pump expansion joint leaking Indian Pt. 3 I1 Expansion joint on suction side of condensate pump deformed and leaked because of degradation Indian Pt. 3 16 30-in. expansion joint on suction side of condensate pump had minor leakage (excessive forces)

Indian Pt. 3 17 Expansion joint on suction side of condensate pump deformed and leaked because of degradation LaSalle 1&2 I 108-in. circ water pump expansion joint failed resulting in flooding (2000 gpm) water hammer Limerick 1 12 Leak in expansion joint on suction side of condensate Pump Limerick 2 Leak on ESW expansion joint Millstone 2 2 Main feedwater pump turbine condensor pump expansion joint developed leak because of high temperature FPL Energy Seabrook Station 8

Expansion Joint Operating Experience EPRl Failure Data for Rubber Expansion Joints Plant &E! Event Description Sequoyah 1 13 Main feedwater pump turbine condenser pump expansion joint developed leak because of high temperature St. Lucie I IO 30-in. SW system, rubber expansion joint ruptured because of aging and cyclic fatigue St. Lucie I 14 Intake 30-in. cooling water expansion joint had through wall leak, aging VC Summer 11 36-in. expansion joint on suction side of condensate pump had a hole in liner with no leakage VC Summer 9 36-in. expansion joint on suction side of condensate pump developed leak, cyclic fatigue VC Summer 9 36-in. expansion joint on suction side of condensate pump developed leak, cyclic fatigue Turkey Point 3 16 30-in. suction expansion joint for condensate pump leaked Seabrook Station 9

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