ML14079A413

Declaration of Mr. Rudy Gil in Support of Florida Power & Light Company'S Answer Opposing Sace Motion to Stay Restart. Attachment 2

ML14079A413
Person / Time
Site:	Saint Lucie
Issue date:	03/20/2014
From:	Gil R Florida Power & Light Co
To:	NRC/OCM
SECY RAS
Shared Package
ML14079A409	List: ML14079A410 ML14079A411 ML14079A412 ML14079A413
References
50-389-LA, License Amendment, RAS 25705
Download: ML14079A413 (7)

Text

ATTACHMENT 2 March 20, 2014 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission

In the Matter of

) ) Florida Power & Light Company

) Docket No.

50-389 ) (St. Lucie Plant, Unit 2

) ) DECLARATION OF MR. RUDY GIL IN SUPPORT OF FPL'S ANSWER OPPOSING SACE MOTION TO STAY RESTART

Mr. Rudy Gil states as follows under penalty of perjury:

I. INTRODUCTION A. Declarant Background

1. I am the Corporate Manager of Programs for the NextEra Energy, Inc. nucl ear fleet. My educational background and qualifications include receiving a Bachelor of Sc i-ence in Civil Engineering in 1978 from the University of Miami.

I have held a Pr o-fessional Engineer License from the State of Florida since 19 82 and received a Se n-ior Reactor Operator Management Certification in 2000. I have been employed by the Florida Power & Light Company ("FPL")

Nuclear Division since 1978. I have held various engineering positions with increasing responsibility, including Corp o-rate Chief Civil Engineer, Design Engineering Manager and Systems Engineering Manager for the St. Lucie Nuclear Plant; Assistant Maintenance Manager at the Turkey Point Nuclear Plant; and my current position as Corporate Programs Eng i-2 neering Manager. In my current position, which I have held since 1998, I am r e-sponsible for the health of the engineering programs for the NextEra Energy, Inc. nuclear fleet. This includes ownership of the steam generator program for each of our pressurized water reactor sites, including St. Lucie. I have been active in the resolution of various nuclear industry issues. Examples of significant industry committees include the Nuclear Energy Institute task forces for Reactor Head Drop Analysis, Buried Piping and Fukushima Flooding. In addition, I am a member of the Electric Power Research Institute Advisory Committee for Materials Manag e-ment and the Executive Oversight Committee for the Pressurized Water Reactor Materials Management Program.

These committees provide guidance and ove r-sight for industry initiatives related to reactor coolant system materials programs, including steam generator management.

B. SACE's Motion to Stay Restart of St. Lucie Unit 2

2. I have reviewed and am familiar with Southern Alliance for Clean Energy

's ("SACE") motion to stay the restart of the St. Lucie Unit 2 reactor, which was filed with the Secretary on March 10 , 2014.1 I am also familiar with the Declaration provided by Mr. Arnold Gundersen in support of SACE's motion for stay

.2 3. My Declaration addresses SACE's erroneous claim that the restart of the St. Lucie Unit 2 nuclear reactor without a hearing would pose an undue risk to public health

1 Southern Alliance for Clean Energy's Motion to Stay Restart of St. Lucie Unit 2 Pending Conclusion of Hearing Regarding De Facto Amendment of Operating License and Request for Expedited Consideration (Mar. 10, 2014) ("SACE Motion"). 2 Declaration of Arnold Gundersen (Mar. 9, 2014

), Attachment 1 to Southern Alliance for Clean Energy's Hearing Request Regarding De Facto Amendment of St. Lucie Unit 2 Operating License (Mar. 10, 2014)

("Gundersen Decl.").

3 and safety due to steam generator tube wear

. SACE Motion at 7.

As set forth in this Declaration , the tube wear at St. Lucie Unit 2 has been identified and studied, the root cause is well understood, and FPL (and the NRC) has taken the steps ne c-essary to ensure safe operation of the plant.

4. My Declaration also address es SACE's erroneous implication that the tube wear at St. Lucie is similar to tube wear that led to the shutdown of the San Onofre Nuclear Generating Station ("SONGS").

SACE Motion at 2; Gundersen Decl.

at ¶ 36. S i g-nificant differences between the design of the St. Lucie 2 and SONGS steam gene r-ators, as well as differences in the type of tube wear experience d, make such a co m-parison inappropriate and misleading.

II. TUBE WEAR AT ST. LUCIE UNIT 2 AND FPL'S RESPONSE 5. This section of my Declaration provides a brief history of tube wear in the St. Lucie Unit 2 replacement steam generators and the actions undertaken to ensure safe o p-eration of that Unit

. 6. Inspection s performed after the first cycle of operation for the St. Lucie 2 steam generators identified a number of tube

-to-anti-vibration bar ("AVB") wear indic a-tions in the U

-bend area. As required by FPL's Steam Generator Management pr o-gram and the Unit's technical specifications, operational assessments for the second

cycle of plan t operation were prepared. Based on those assessments, no tubes r e-quired plugging for the second cycle. However, FPL conservatively plugged all tubes (14) with a wear level greater than 25%.

7. Inspections performed after the second cycle of operation identified an increased number of tube wear indications, as predicted by the operational assessments. Wear 4 rates, however, decreased during the second cycle as also predicted. Based on the operational assessment prepared after the second cycle, one tube required plugging. FPL conservatively plugged an additional 20 tubes.

8. As predicted by the operational assessment performed after the second cycle, i n-spections performed after the third cycle again identified an increased number of indications. Wear rates, however, continued to decrease as also predicted. The i n-dications were limited to the same three regions of the tube bundle where indic a-tions were found after the first and second cycles. Seven tubes required pluggi ng during this inspection, and FPL conservatively plugged an additional 112 tubes.

9. These inspections found no tube

-to-tube wear in St. Lucie Unit 2's steam gener a-tors. Only tube-to-AVB wear occurred.

10. The root cause of the tube wear at St. Lucie Unit 2 is well understood. The co m-prehensive root cause evaluation conducted by AREVA for FPL

, and reviewed by an independent third party, concluded that the U

-tubes were not effectively suppor t-ed during the tubing installation process.

The tube bundle was allowed to sag, cau s-ing slight deformation of the AVBs, which in turn closed the tube

-to-AVB gap. This condition caused tubes to be in constant contact with AVBs at several loc a-tions, contrary to the design specification and models. The resulting tube-to-AVB contact allow ed tube wear in the affected tubes/areas.

However, a s expected based on this root cause, the tube wear has attenuated over time and is manageable under FPL's Steam Generator Management program. 11. On February 25, 2011

, FPL requested a license amendment to permit an extended power uprate at St. Lucie Unit 2.

Letter from Richard L. Anderson, Site Vice Pre s-5 ident, St. Lucie Plant, to NRC, L

-2011-021 (Feb. 25, 2011) (ADAMS Accession No. ML110730116).

At that time, and taking into account the root cause evalu a-tion, analyses were performed by AREVA for FPL that demonstrated acceptable tube wear at power uprate conditions

, the NRC considered the results of the se ana l-yses when it evaluated and approved the St. Lucie Unit 2 power uprate on Septe m-ber 2 4, 2012. Letter from J. Sam Armijo, Chairman, ACRS, to R.W. Borchardt, NRC Executive Director of Operations (Jul. 23, 2012), at 4 (ADAMS Accession No. ML12198A202); Letter from Tracy J. Orf, Project Manager, Plant Licensing Branch 11-2, to Mano Nazar, Executive Vice President and Chief Nuclear Officer, Florida Power and Light Company (Sept. 24, 2012) (ADAMS Accession No.

ML12235A463).

12. St. Lucie Unit 2's first cycle of operation under the power uprate conditions has been completed.

FPL is currently conducting an inspection of its steam generator tubes. The implementation of this inspection is being monitored by NRC represen t-atives on site as part of their normal oversight process.

III. THERE ARE SIGNIFICANT DESIGN DIFFERENCES BETWEEN ST. LUCIE AND SONGS 13. SACE is wrong when it implies that the situation leading to the shutdown of SONGS Units 2 and 3 is similar to events at St. Lucie Unit 2.

SACE Motion at 2; Gundersen Decl. at ¶ 36.

14. Tube-to-tube wear in the in

-plane direction caused the SONGS tube leak that culminated in that plant's shutdown. In contrast, after three full cycles of operation 6 St. Lucie Unit 2 has not experienced tube

-to-tube wear, and there is no reason to believe that such wear will occur at St. Lucie Unit 2.

15. The type of tube-to-tube wear that o c curred at SONGS had never been seen before in a commercial nuclear power plant. In contrast, the t ube-to-AVB wear exper i-enced at St. Lucie Unit 2 is well-known and understood in the nuclear industry. As a result, FPL was able to rely on well-developed industry standards that have been proven successful over many, many years of cumulative industry experience to a d-dress tube

-to-AVB wear and to ensure safe operation of St. Lucie Unit 2.

16. T he cause of the tube leak that occurred at SONGS is not a concern at St. Lucie Unit 2 , in large part because of various design differences between the steam gene r-ators at those plants, which were designed and built by different vendors. Exhibit A to this Declaration provides a detailed list of those differences.

Due to these diffe r-ences, the St. Lucie Unit 2 steam generators have not experienced, and are not e x-pected to experience, the high steam velocit y and void fraction (steam to water r a-tio) conditions that led to the in-plane "fluid elastic" vibration of steam generator tubes at SONGS.

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

Executed in Accord with 10 C.F.R. § 2.304(d)

Rudy Gil Title: Corporate Programs Engineering Manager Address: 700 Universe Blvd, Juno Beach, FL 33408 Phone: 561-694-3370 E-mail: rudy.gil@fpl.com

7 Exhibit A The differences between the St. Lucie Unit 2 and SONGS steam generators include:

1. The steam generators are designed and built by different vendors;

2. The retainer bar feature that resulted in tube wear for the SONGS steam generators is not included in the St. Lucie Unit 2 design;

3. The AVB system s are different (number of sets and arrangement), which leads to diffe r-ent flow pattern s; 4. Maximum void fraction in the SONGS steam generators is higher than that of St. Lucie Unit 2; 5. Based on nominal plant power output, it can be concluded that the mean kinetic energy at the U-bend outlet for St. Lucie Unit 2 is significantly less than at SONGS, even after i m-plementation of the power uprate;

6. The St. Lucie Unit 2 tube lane width is minimized, which positively impacts the by-pass flow , which can exist in this particular area without tubes

7. The St Lucie Unit 2 tube lane area of each Tube Support Plate presents not only rectang u-lar shape holes but also drilled holes that can favor the mixing between fluid in the tube lane and fluid in the tube bundle

8. Considering items 3, 4, and 5 above, the SONGS flow pattern departs from the classical flow pattern expected in the U

-bend of an AREVA steam generator.