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| | number = ML14035A216 | | | number = ML14035A216 |
| | issue date = 01/30/2014 | | | issue date = 01/30/2014 |
| | title = Seabrook Station, 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 Assessments | | | title = 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 Assessments |
| | author name = Walsh K | | | author name = Walsh K |
| | author affiliation = NextEra Energy Seabrook, LLC | | | author affiliation = NextEra Energy Seabrook, LLC |
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Category:Letter
MONTHYEARML24009A1152024-01-29029 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L 2023 LLE-0043 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML24022A0652024-01-22022 January 2024 Senior Reactor and Reactor Operator Initial License Examinations L-2024-003, NextEra Energy Seabrook, LLC - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report2024-01-11011 January 2024 NextEra Energy Seabrook, LLC - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report ML23312A1822023-12-22022 December 2023 Issuance of Amendment No. 172 Revision to Cooling Tower Service Water Loop or Cell Requirements L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-180, Submittal of Changes to the Technical Specification Bases2023-12-13013 December 2023 Submittal of Changes to the Technical Specification Bases L-2023-177, Supplement to Seabrook Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-29029 November 2023 Supplement to Seabrook Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, L-2023-160, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms, Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms, Background Checks, and Security Event Notifications Final Rule ML23318A0772023-11-14014 November 2023 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000443/2024011 IR 05000443/20234032023-11-0707 November 2023 Security Baseline Inspection Report 05000443/2023403 and Independent Spent Fuel Storage Installation 07200063/2023401 IR 05000443/20230032023-11-0606 November 2023 Integrated Inspection Report 05000443/2023003 IR 05000443/20230102023-10-19019 October 2023 Triennial Fire Protection Inspection Report 05000443/2023010 ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published ML23275A0522023-10-0202 October 2023 Requalification Program Inspection IR 05000443/20234012023-09-0808 September 2023 Cybersecurity Inspection Report 05000443/2023401 (Cover Letter Only) IR 05000443/20234202023-09-0505 September 2023 Security Baseline Inspection Report 05000443/2023420 IR 05000443/20230052023-08-31031 August 2023 Updated Inspection Plan for Seabrook Station (Report 05000443/2023005) L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update IR 05000443/20233022023-08-16016 August 2023 Operator Licensing Retake Examination Report 05000443/2023302 IR 05000443/20230022023-08-0808 August 2023 Integrated Inspection Report 05000443/2023002 L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment L-2023-104, Preparation and Scheduling of Operator Licensing Examinations2023-08-0303 August 2023 Preparation and Scheduling of Operator Licensing Examinations L-2023-103, Inservice Inspection Examination Report2023-08-0303 August 2023 Inservice Inspection Examination Report ML23192A0782023-07-11011 July 2023 Operator Licensing Retake Examination Approval L-2023-087, Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452)2023-06-29029 June 2023 Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452) SBK-L-23053, Radiological Emergency Plan (Ssrep), Revision 802023-06-22022 June 2023 Radiological Emergency Plan (Ssrep), Revision 80 ML23157A0722023-06-0606 June 2023 Notification of Conduct of a Fire Protection Team Inspection L-2023-074, Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update2023-06-0202 June 2023 Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update L-2023-071, NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal2023-05-22022 May 2023 NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal IR 05000443/20233012023-05-15015 May 2023 Initial Operator Licensing Examination Report 05000443/2023301 L-2023-064, License Amendment Request 23-01, Revision 1, Update the Period of Applicability (Poa) for the Pressure-Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves2023-05-11011 May 2023 License Amendment Request 23-01, Revision 1, Update the Period of Applicability (Poa) for the Pressure-Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves IR 05000443/20230012023-05-11011 May 2023 Integrated Inspection Report 05000443/2023001 ML23129A0312023-05-0909 May 2023 Reactor Operator Retake License Examination ML23117A3652023-05-0404 May 2023 Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment Request to Remove Period of Applicability from PTL and Low Temperature Over Pressure Protection Curves SBK-L-23044, 2022 Annual Radiological Environmental Operating Report2023-04-28028 April 2023 2022 Annual Radiological Environmental Operating Report SBK-L-23031, 2022 Annual Radioactive Effluent Release Report2023-04-28028 April 2023 2022 Annual Radioactive Effluent Release Report SBK-L-23033, 2022 Annual Environmental Operating Report2023-04-11011 April 2023 2022 Annual Environmental Operating Report L-2023-053, Core Operating Limits Report for Cycle 232023-04-0505 April 2023 Core Operating Limits Report for Cycle 23 ML23088A1522023-03-29029 March 2023 Summary of Meeting Between Nrc/Region I and C-10 - Questions Regarding Seabrook 4Q2022 Inspection Report L-2023-021, Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-03-28028 March 2023 Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update L-2023-028, and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications2023-03-27027 March 2023 and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications ML23073A1562023-03-23023 March 2023 Relief Request 4RA-22-01, Relief from the Requirements of the ASME Code L-2023-012, License Amendment Request 23-01, Remove Period of Applicability (Poa) from Pressure Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves2023-03-15015 March 2023 License Amendment Request 23-01, Remove Period of Applicability (Poa) from Pressure Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves L-2023-025, Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-12023-03-15015 March 2023 Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-1 L-2023-029, and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)2023-03-10010 March 2023 and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3) L-2023-023, Revised Steam Generator Tube Inspection Report2023-03-0303 March 2023 Revised Steam Generator Tube Inspection Report ML23020A1002023-03-0303 March 2023 OEDO-22-00419 - 2.206 Petition for Seabrook Station Structure Concrete Concerns (EPID L-2022-CRS-0000)- Closure Letter 2024-01-29
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NEXTera ENERGA7Y1 January 30, 2014 10 CFR 50.54(f)SBK-L-14016 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Seabrook Station 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 Assessments
References:
- (1) NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident; dated March 12, 2012.(Accession No. ML12073A348)
(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," dated May 31, 2012. (Accession No. ML12144A142)
(3) NextEra Energy Letter, SBK-L-12243, Response to NRC 10 CFR 5054(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3. Flooding, dated November 27, 2012.(4) NRC Letter, Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns; dated December 23, 2013. (Accession No.ML13325A891)
On March 12, 2012, the NRC staff issued Reference 1 requesting information pursuant to Title 10 of the Code of Federal Regulations
§50.54(f).
Enclosure 4 of that letter contains specific requested information associated with Near-Term Task Force Recommendation 2.3 for Flooding.Per Reference 2, the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012.NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874
'U.S. Nuclear Regulatory Commission SBK-L-14016/Page 2 By Reference 3, NextEra Energy Seabrook, LLC (NextEra) 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 with each applicable flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. The results of this effort were to be maintained on site for future NRC audits.Following 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 4 the NRC staff has issued a request for addition information (RAI).The RAI questions and the NextEra responses are provided below.RAI Number 1: Confirmation that the process for evaluating APM was reviewed Response:
NextEra has completed a review of the process used at Seabrook Station to evaluate APMs.RAI Number 2: Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI.Response:
The original walkdown effort at Seabrook Station followed the guidance provided in NEI 12-07, including a definition for a small margin. Additional actions have been taken to make the process consistent with the information provided in this RAI.RAI Number 3. If changes are necessary, a general description of any process changes to establish this consistency.
Response:
As stated above, the original walkdown effort followed the guidance provided in NEI 12-07, including a definition for a small margin. However, a specific APM had not been assigned to the seals associated with flood protection features.
These items have now been addressed in accordance with the guidance provided in this RAI and entered into the NextEra corrective action process, 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 or Approach 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 example 2 in Section 3.13 ofNEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was
- U.S. Nuclear Regulatory Commission SBK-L-14016/Page 3 small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater 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 as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as aflooding seal, it was only necessary to determine that the seal configuration 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".As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns 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 this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform 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 not petformed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action (s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the RAI response." Report the APM as "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 for seals and below grade walls/floors.
As part of the actions taken to address this RAI, the seals and below grade walls/floors have been assigned an APM value of "undetermined" and have been entered into the CAP process through Action Request 1934467 for further evaluation of their available physical margin. Implementation of interim actions will be pursued, if necessary.
This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.
U.S. Nuclear Regulatory Commission SBK-L-14016/Page 4 Should you have any questions regarding this submittal, please contact Mr. Michael Ossing, Licensing Manager at 603-773-7512.
I declare under penalty of perjury that the foregoing is true and correct.Executed on January _ 2014.Sincerely, Kevin Walsh Site Vice President NextEra Energy Seabrook, LLC cc: NRC Region I Administrator J. G. Lamb, NRC Project Manager NRC Senior Resident Inspector