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{{Adams
#REDIRECT [[L-2014-020, Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments]]
| number = ML14036A069
| issue date = 01/27/2014
| title = Florida Power & Light Co. - Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments
| author name = Jensen J
| author affiliation = Florida Power & Light Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000335, 05000389
| license number = DPR-067, NPF-016
| contact person =
| case reference number = L-2014-020
| document type = Letter
| page count = 4
| project =
| stage = RAI
}}
 
=Text=
{{#Wiki_filter:0 January 27, 2014FPL. L-2014-020 10 CFR 50.54(0U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555Re: St. Lucie Units I and 2Docket Nos. 50-335 and 50-389Renewed Facility Operating License Nos. DPR-67 and NPF-16Update to Response to NRC 10 CFR 50.54(f)
Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding  
-Review of Available Physical Margin(APM) Assessments
 
==References:==
 
(1) NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(0 Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review ofInsights from the Fukushima Dai-Ichi Accident,"
dated March 12, 2012, Accession No.ML 12073A348.
(2) NRC Letter to Nuclear Energy Institute, "Endorsement of Nuclear Energy Institute (NEI) 12-07,'Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features,"'
datedMay 31, 2012, Accession No. MLI 2144A 142.(3) Florida Power & Light (FPL) Letter L-2012-428, dated November 27, 2012, "Response to NRC10 CFR 50.54(0 Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding, St. Lucie Plant Units 1 and 2, Flooding Walkdown Report FPL060-PR-001, Rev.0"(4) NRC Letter, "Request for Additional Information Associated with Near-Term Task ForceRecommendation 2.3, Flooding Walkdowns,"
dated December 23, 2013, Accession No.MLI 3325A891(5) St. Lucie Corrective Action Program (CAP) Action Request (AR) 1748014, Assignment 04,Small APM Justification.
(6) St. Lucie Corrective Action Program (CAP) Action Request (AR) 1931279, Assignment 01,Penetration Seal APM Justification.
On March 12, 2012, the N RC staff issued Reference I requesting information pursuant to Title 10 of theCode of Federal Regulations 50.54(0.
Enclosure 4 of that letter contains specific Requested Information associated with Near-Term Task Force Recommendation 2.3 for Flooding.
Per Reference 2, the NRCendorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns ofPlant Flood Protection Features,"
dated May 31, 2012. By Reference 3, Florida Power & Light (FPL)submitted the final report in response to the request for information.
One of the requirements of NEI 12-07 is to identify the available physical margin (APM) associated witheach applicable flood protection
: feature, determine if the margin provided is small, and evaluate anysmall margins that have potentially significant consequences through the corrective action process.
Theresults of this effort were to be maintained on site for future NRC audits.Florida Power & Ught Company6501 S. Ocean Drive, Jensen Beach, FL 34957 L-2014-020 Page 2Following the NRC staff's initial review of the walkdown
: reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow them to complete its assessments.
Accordingly, by Reference 4the NRC staff has issued a request for additional information (RAI). The attachment to this letterprovides FPL's responses for the St. Lucie Plant.This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.
Should you have any questions regarding this submittal, please contact Eric S. Katzman, St. LucieLicensing
: Manager, at 772-467-7734.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Executed on January 2 -- ,2014VeryJoseph JensenSite Vice President St. Lucie PlantAttachment L-2014-020 Attachment Page I of 2Per (4) NRC Letter, "Request for Additional Information Associated with Near-Term Task ForceRecommendation 2.3, Flooding Walkdowns,"
dated December 23, 2013, Accession No. ML13325A891, FPL provides the following responses.
RAI Number 1: Confirmation that the process for evaluating APM was reviewedResponse:
FPL has completed a review of the process used at the St. Lucie Plant to evaluate APMs.RAI Number 2: Confirmation that the APM process is now or was always consistent with the guidance inNEI 12-0 7 and discussed in this RAI.Response:
The APM process used at St. Lucie Plant followed the guidance provided in NEI 12-07,including a definition for a small margin. Additional actions have been taken to make the processconsistent with the information provided in this RAI.RAI Number 3: If changes are necessary, a general description of any process changes to establish thisconsistency.
Response:
As stated above, the APM process used at St. Lucie Plant followed the guidance provided inNEI 12-07, including a definition for a small margin (AR 1748014, Reference 5). However, a specificAPM had not been assigned to the seals associated with flood protection features.
These items have nowbeen addressed in accordance with the guidance provided in this RAI and entered into the corrective action process (AR 1931279, Reference 6), as appropriate, for further evaluation.
RAI Number 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation ofAPMfor seals (e.g., flood doors, penetrations, floodgates, etc.)was challenging for some licensees.
Generally, licensees were expected to use either Approach A orApproach B (described below) to determine the APMfor seals.-a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example2 in Section 3.13 ofNEI12-07).
A numerical value for APM was documented No further action wasperformed if the APM value was greater than the pre-established small-margin threshold value. Ifthe APM value was small, an assessment of "significant consequences" was performed and theguidance in NEI 12-07 Section 5.8 was followedb) If the seal pressure rating was not loiown, the APMfor seals in aflood barrier is assumed to begreater than the pre-established small-margin threshold value if the following conditions were met:(1) the APMfor the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled asflooding seals in accordance with the flooding licensing basis. Note that in order to determine thatthe seal has been controlled as aflooding seal, it was only necessary to determine that the sealconifiguration has been governed by the plant's design control process since installation.
In this case,the APMfor the seal could have been documented as "not small ".
L-2014-020 Attachment Page 2 of 2As part of the RAI response, state if either Approach A or Approach B was used as part of the initialwalkdowns or as part of actions taken in response to this RAI. No additional actions are necessary ifeither Approach A or B was used.If neither Approach A or B was used to determnine the APM values for seals (either as part of thewalkdowns or as part of actions taken in response to this RAI), then perform the following two actions:* Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture thisissue for multiple seals). CAP disposition of "undetermined" APM values for seals should considerthe guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals canperform their intended safety function against floods up to the current licensing basis flood height.Disposition may occur as part of the Integrated Assessment.
If an Integrated Assessment is notperformed, determine whether there are significant consequences associated with exceeding thecapacity of the seals and take interim action(s),
if necessary, via the CAP processes.
These actionsdo not need to be complete prior to the RAI response.
* Report the APMas "undetermined" andprovide the CAP reference in the RAI response.
Response:
Neither Approach A or B, as described above, were used to determine the APM values forseals. As part of the actions taken to address this RAI, the seals have been assigned an APM value of"undetermined" and have been entered into the CAP process (ARs 1748014 and 1931279, References 5and 6) for further evaluation of their available physical margin. The disposition of the Action Requestswill determine the APM and implementation of interim actions will be pursued, if necessary.
In addition, the original walkdown record forms issued as Attachment C to Reference 3 assigned an APMvalue of"N/A" for features (seals) located below the plant flood level. St. Lucie's intent is to not reviseAttachment C to reflect the change in APM value from "N/A" to "undetermined,"
rather justification forthe use of APM valve "N/A" will be included as part of the CAP entry (Reference 6).}}

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