ML102440185

Draft RAIs Re AST LAR

ML102440185
Person / Time
Site:	Turkey Point
Issue date:	08/25/2010
From:	Paige J C Plant Licensing Branch II
To:	Franzone S, Tomonto B Florida Power & Light Co
Paige, Jason C, NRR/DORL,301-415-5888
References
Download: ML102440185 (3)

Text

From: Paige, Jason Sent: Wednesday, August 25, 2010 3:25 PM To: Franzone, Steve; Tomonto, Bob

Subject:

DRAFT RAIs RE AST LAR Steve, below are the draft RAIs that the containment ventilation branch (questions 1-8) and the mechanical engineering branch (question 9) generated from FPL's May 21, 2010 RAI responses. I suggest we have a call tomorrow, Thursday, August 26, 2010 to discuss. Also, we will discuss TSTF-448 during this call. Let me know if this works for you.

Jason By letter dated May 21, 2010 Florida Power and Light (FPL), licensee of Turkey Point Units 3 and 4, responded to the NRC staff's request for additional information (RAI). In response to RAI #20 it states that modifications are proposed to the control room emergency ventilation system (CREVS) to install a compensatory filter unit that may be manually placed in service in the event that the installed filter train becomes inoperable--.The proposed location is currently outside of the control room envelope (CRE) and post maintenance testing will assure the leak tightness of the system. It is also stated that the filtration unit design is currently planned to include a recirculation fan, charcoal and high efficiency particulate air filter (HEPA) and capable of being powered off of the swing bus from the emergency diesel generators (EDGs). The licensee's responses to the following RAIs will allow the staff to complete its review in a timely manner.

1. Will the stated post maintenance testing be conducted in accordance with an NRC accepted standard such as ASTM-E741? If not, what standard will be used?

2. In the May 21, 2010, letter you stated the proposed location of the compensatory filter unit is currently outside of the control room envelope (CRE) and post maintenance testing will assure the leak tightness of the system. How will leak tightness be assured?

3. The proposed location of the compensatory filtration unit is outside the CRE and will be manually placed into service. How can this be accomplished without invalidating the results of the current ASTM E741 tracer gas test?

4. Will the surveillance requirements for technical specification (TS) 3/4.7.5 be updated to include the compensatory filtration unit?

5. Will the charcoal in the compensatory filtration unit be tested in accordance with the testing methods and at the frequencies specified for the charcoal in the CREVS?

6. On page 6 of 24 under SURVEILLANCE REQUIREMENTS item c. states "At least once per 18 months or (1) after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal absorber housing, or (3) following operational exposure of the filters to effluents from painting, fire or chemical releases in any ventilation zone communicating with the system, or (4) after complete or partial replacement of a filter bank by:--". In this context, what is the meaning of "operational"? This appears to be inconsistent with the NRC staff's intent when discussing ventilation zones communicating with systems (see Regulatory Guide 1.52 revision 3, June 2001, Regulatory Position C.6.3 foot note 8).

7. To facilitate a more clear understanding, the NRC staff is requesting that the first sentence (page 7 of 24 item a.5.) be revised as follows: "With the filter train inoperable, e.g., an inoperable filter, and/or two inoperable recirculation fans, and/or two inoperable recirculation dampers, immediately suspend all movement of irradiated fuel, and immediately initiate action to implement mitigating actions, and, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure control room occupant radiological exposures will not exceed limits and, within 7 days, restore the filter train to OPERABLE status."

8. In the BASES on page 23 of 24, the second paragraph states that a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time (AOT) is reasonable based on the low probability of a---. This statement is not consistent with ACTION statement a.5 of TS 3/4.7.5, i.e., there is no 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT. The NRC staff requests that FPL revise this paragraph in accordance with the TS action statement.

9. In the attachment to the May 21, 2010, letter, page 4 of 24 indicates that the compensatory filtration unit will be designed as a safety-related, Seismic Class I backup to the installed system. a) Describe the methodology utilized to perform the seismic qualification of the compensatory filtration unit. Additionally, confirm that the methodology described is in accordance with the Turkey Point licensing basis. If the methodology is not in accordance with the Turkey Point licensing basis, provide justification for this deviation.

b) Provide a summary of the results of the seismic qualification of the compensatory filtration unit demonstrating that this unit, including the individual filtration unit components and all connected components, meets the acceptance criteria for Seismic Class I structures, systems, and components at PTN.

Jason Paige, Turkey Point Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-5888 E-mail Properties Mail Envelope Properties ()

Subject:

DRAFT RAIs RE AST LAR Sent Date: 8/25/2010 2:01:37 PM Received Date: 8/25/2010 3:25:00 PM From: Paige, Jason

Created By: Jason.Paige@nrc.gov

Recipients:

Steve.Franzone@fpl.com (Franzone, Steve)

Tracking Status: None Bob.Tomonto@fpl.com (Tomonto, Bob)

Tracking Status: None

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