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| {{#Wiki_filter:February 6, 2006EA-05-195 Florida Power and Light CompanyATTN:Mr. J. A. Stall, Senior Vice PresidentNuclear and Chief Nuclear Officer P. O. Box 14000 Juno Beach, FL 33408-0420SUBJECT:EXERCISE OF ENFORCEMENT DISCRETION - TURKEY POINT NUCLEARPLANT (NRC Inspection Report Nos. 05000250,251/2005013) | | {{#Wiki_filter:ary 6, 2006 |
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| | ==SUBJECT:== |
| | EXERCISE OF ENFORCEMENT DISCRETION - TURKEY POINT NUCLEAR PLANT (NRC Inspection Report Nos. 05000250,251/2005013) |
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| ==Dear Mr. Stall:== | | ==Dear Mr. Stall:== |
| The purpose of this letter is to provide you with the results of our review of findings involvingcertain fire response procedures at the Turkey Point Nuclear Plant that would not be effective in ensuring a safe shutdown of Units 3 and 4 should a severe fire develop in certain fire zones. | | The purpose of this letter is to provide you with the results of our review of findings involving certain fire response procedures at the Turkey Point Nuclear Plant that would not be effective in ensuring a safe shutdown of Units 3 and 4 should a severe fire develop in certain fire zones. |
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| | This issue was discussed at a regulatory conference held in the NRCs Region II Office on November 16, 2005. |
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| | To summarize our review of this matter, the NRC has concluded that the significance of the findings was very low for Unit 3 and low to moderate for Unit 4. In addition, the NRC has concluded that the exercise of enforcement discretion is appropriate for these findings in accordance with the NRC Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). The NRC will also refrain from including the findings in the Agency Action Matrix in accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program. The bases for our conclusions regarding the significance of the findings is described below and in Enclosure 1. |
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| | As background, NRC Inspection Report No. 05000250,251/2005010, was issued on October 7, 2005, and it documented a finding (one apparent violation of 10 CFR Part 50, Appendix R) based on the NRCs review of three separate unresolved items (URIs 05000250,251/2004007-001, -006, and -007). The collective significance of the finding was assessed under the significance determination process as a preliminary greater than Green issue (i.e., an issue of at least low to moderate safety significance which may require additional NRC inspection). The cover letter to NRC Inspection Report No. 05000250,251/2005010 informed Florida Power and Light Company (FPL) of the NRCs preliminary conclusion, provided FPL an opportunity to request a regulatory conference on this matter, and forwarded the details of the NRCs preliminary estimate of the change in core damage frequency (CDF) for the finding. |
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| | On November 15, 2005, FPL submitted a letter to the NRC documenting its intent to adopt the risk-informed, performance-based fire protection program under 10 CFR 50.48(c), which includes approaches in National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating |
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| | Florida Power and Light Company 2 Plants, 2001 Edition. In accordance with the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), FPL requested enforcement discretion for existing identified noncompliances, noncompliances identified during its NFPA 805 transition process, and the noncompliance that was the subject of the November 16, 2005, regulatory conference. |
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| This issue was discussed at a regulatory conference held in the NRC's Region II Office onNovember 16, 2005.To summarize our review of this matter, the NRC has concluded that the significance of thefindings was very low for Unit 3 and low to moderate for Unit 4. In addition, the NRC hasconcluded that the exercise of enforcement discretion is appropriate for these findings inaccordance with the NRC Interim Enforcement Policy Regarding Enforcement Discretion forCertain Fire Protection Issues (10 CFR 50.48). The NRC will also refrain from including the findings in the Agency Action Matrix in accordance with NRC Inspection Manual Chapter 0305,Operating Reactor Assessment Program. The bases for our conclusions regarding the significance of the findings is described below and in Enclosure 1.As background, NRC Inspection Report No. 05000250,251/2005010, was issued onOctober 7, 2005, and it documented a finding (one apparent violation of 10 CFR Part 50,Appendix R) based on the NRC's review of three separate unresolved items(URIs 05000250,251/2004007-001, -006, and -007). The collective significance of the finding was assessed under the significance determination process as a preliminary "greater than Green" issue (i.e., an issue of at least low to moderate safety significance which may require additional NRC inspection). The cover letter to NRC Inspection ReportNo. 05000250,251/2005010 informed Florida Power and Light Company (FPL) of the NRC'spreliminary conclusion, provided FPL an opportunity to request a regulatory conference on this matter, and forwarded the details of the NRC's preliminary estimate of the change in coredamage frequency (CDF) for the finding.On November 15, 2005, FPL submitted a letter to the NRC documenting its intent to adopt therisk-informed, performance-based fire protection program under 10 CFR 50.48(c), which includes approaches in National Fire Protection Association (NFPA) Standard 805,
| | At FPLs request, an open regulatory conference was conducted on November 16, 2005, to discuss FPLs position on this issue. The enclosures to this letter include the list of attendees at the regulatory conference and material presented by FPL and NRC. |
| "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Florida Power and Light Company2Plants," 2001 Edition. In accordance with the NRC's Interim Enforcement Policy RegardingEnforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), FPL requested enforcement discretion for existing identified noncompliances, noncompliances identified during its NFPA 805 transition process, and the noncompliance that was the subject of the November 16, 2005, regulatory conference.At FPL's request, an open regulatory conference was conducted on November 16, 2005, todiscuss FPL's position on this issue. The enclosures to this letter include the list of attendees at the regulatory conference and material presented by FPL and NRC.During the conference, FPL presented the results of its estimate of the increase in CDFincluding influential assumptions and risk analysis methodology. FPL's presentation addressed the three aspects of the finding separately (i.e., URI 05000250,251/2004007-001, -006, and-007), and provided the following conclusions on the matter. In summary, FPL agreed with the NRC's view that URI 05000250,251/2004007-001 was a violation of 10 CFR Part 50,Appendix R, but concluded that the significance of this issue was very low. FPL disagreed with that portion of the finding consisting of URIs 05000250,251/2004007-006 and -007, concludingthat procedural requirements were acceptable, a performance deficiency did not exist, and thusthis finding did not represent a violation. Furthermore, FPL concluded that the significance ofURIs 05000250,251/2004007-006 and -007, even if considered to be a finding, was very low.
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| At the conference, the NRC requested that FPL provide additional information to support its riskanalysis. This information was subsequently submitted by letter dated November 23, 2005.
| | During the conference, FPL presented the results of its estimate of the increase in CDF including influential assumptions and risk analysis methodology. FPLs presentation addressed the three aspects of the finding separately (i.e., URI 05000250,251/2004007-001, -006, and-007), and provided the following conclusions on the matter. In summary, FPL agreed with the NRCs view that URI 05000250,251/2004007-001 was a violation of 10 CFR Part 50, Appendix R, but concluded that the significance of this issue was very low. FPL disagreed with that portion of the finding consisting of URIs 05000250,251/2004007-006 and -007, concluding that procedural requirements were acceptable, a performance deficiency did not exist, and thus this finding did not represent a violation. Furthermore, FPL concluded that the significance of URIs 05000250,251/2004007-006 and -007, even if considered to be a finding, was very low. |
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| FPL's presentation and subsequent correspondence provided 15 inputs on the safety significance of the finding. The following three of the inputs were incorporated into the NRC'sfinal significance determination: (1) reducing the main control room fire ignition frequency, (2) modifying the time at which the operating charging pump would be stopped during a main control room fire, and (3) reducing the time that reactor coolant pump (RCP) leakage could have created conditions for a small break loss of coolant accident (LOCA). A detailed discussion of the NRC's basis for acceptance or rejection of all inputs is provided inEnclosure 1.After considering the information developed during the inspection, the information presented atthe conference, and the supplemental information provided by FPL after the conference, theNRC has concluded that the final inspection findings are appropriately characterized as verylow for Unit 3 and low to moderate for Unit 4.
| | At the conference, the NRC requested that FPL provide additional information to support its risk analysis. This information was subsequently submitted by letter dated November 23, 2005. |
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| The NRC also concluded that a violation of 10 CFR 50.48(b)(1) and 10 CFR Part 50,Appendix R, Sections III.G.2 and III.G.3, occurred. In particular, Appendix R, Section III.G.2states, in part, that where cables or equipment (including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground) of redundant trains of systems necessary to achieve and maintain hot shutdownconditions are located within the same fire area outside of primary containment, one of three means of ensuring that one of the redundant trains is free of fire damage shall be provided. | | FPLs presentation and subsequent correspondence provided 15 inputs on the safety significance of the finding. The following three of the inputs were incorporated into the NRCs final significance determination: (1) reducing the main control room fire ignition frequency, (2) modifying the time at which the operating charging pump would be stopped during a main control room fire, and (3) reducing the time that reactor coolant pump (RCP) leakage could have created conditions for a small break loss of coolant accident (LOCA). A detailed discussion of the NRCs basis for acceptance or rejection of all inputs is provided in Enclosure 1. |
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| Section III.G.3 states that alternative shutdown capability should be provided where theprotection of systems (whose function is required for hot shutdown) does not satisfy therequirements of Section III.G.2.
| | After considering the information developed during the inspection, the information presented at the conference, and the supplemental information provided by FPL after the conference, the NRC has concluded that the final inspection findings are appropriately characterized as very low for Unit 3 and low to moderate for Unit 4. |
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| Florida Power and Light Company3In this case, the following three instances were identified where FPL failed to satisfy the aboveAppendix R requirements: (1) FPL failed to protect control circuits and cables that could cause maloperation of motor-operated valve (MOV) MOV-4-626, "RCP Thermal Barrier Component Cooling Water System Return Isolation Valve," in fire zone (FZ) 67. This condition existed since at least September 9, 2003, when it was first identified by FPL. (2) FPL failed to protectcontrol circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves MOV-3-716B and MOV-3-626 in FZ 63 and MOV-4-716Bvalve in FZ 67. This condition existed since at least February 9, 2001, when the applicable procedure page was last revised FPL. (3) FPL failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooli ng system valvesin FZ 106 and did not meet the alternative shutdown capability requirements. Specifically,under certain scenarios, FPL's procedure may not have mitigated a spurious closure of valves MOV-3-716A and MOV-4-716A in a timely manner, possibly resulting in an RCP seal LOCA and pressurizer level dropping below the indicating range. This condition existed since at least April 24, 2002, when the applicable procedure pages were last revised.The NRC also reviewed FPL's request that the violation be considered for enforcementdiscretion. On June 16, 2004, the NRC published a final rule revising its regulations in10 CFR 50.48, which governs fire protection at operating nuclear power plants. This revision became effective on July 16, 2004, and it added a new paragraph (c) to 10 CFR 50.48 that allows reactor licensees to voluntary comply with the risk-informed, performance-based fire protection approaches in NFPA 805 (with limited exceptions stated in the rule language) as an alternative to complying with 10 CFR 50.48(b) or the requirements in their fire protection license conditions. As part of the transition to 10 CFR 50.48(c), licensees will establish the fundamentalfire protection program identified in NFPA 805 and will perform a plant-wide assessment toidentify fire areas and fire hazards and to evaluate compliance with their existing fire protection licensing basis. This fire protection assessment is beyond the normal licensee review of their fire protection program. With regard to applicable noncompliances, licensees are required to adopt compensatory measures until compliance is either restored to 10 CFR 50.48(b) or achieved per 10 CFR 50.48(c).In order to provide incentives for licensees initiating efforts to identify and correct subtleviolations that are not likely to be identified by routine efforts, the NRC issued EnforcementPolicy Statement revisions on June 16, 2004, and January 14, 2005, allowing enforcementdiscretion for certain fire protection noncompliances identified as part of the transition to 10 CFR 50.48(c) as well as existing identified compliances which could reasonably be corrected under 10 CFR 50.48(c). This interim enforcement discretion policy is consistent with the long-standing policy included in Section VII.B.3, "Violations Involving Old Design Issues," of the Enforcement Policy, which addresses discretion when licensee undertake a comprehensive review and assessment. This exercise of discretion provides appropriate incentives for licensees to initiate efforts to identify and correct subtle violations that are not likely to be identified by routine efforts. As such, the NRC Interim Enforcement Policy RegardingEnforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) provides enforcement discretion for licensees who wish to take advantage of the new rule to resolve existing noncompliances (i.e., implement corrective actions until the licensee has transitioned to 10 CFR 50.48(c)) provided that certain criteria are met.In this case, the NRC concluded that (1) the noncompliance was not associated with a findingthat the reactor oversight process significance determination process would evaluate as Red, or Florida Power and Light Company4it would not be categorized at Severity Level I; (2) FPL submitted a letter of intent beforeDecember 31, 2005, stating its intent to transition to 10 CFR 50.48(c), which includes approaches in NFPA 805; and (3) the licensee entered the noncompliance into its corrective action program and implemented appropriate compensatory measures (including an operabilityevaluation to demonstrate that safety will be maintained during operation and shutdown). Regarding compensatory measures, FPL incorporated acceptable manual operator actions into applicable procedures to address the finding at the time of the original inspection. Based on the above, in accordance with the NRC's Interim Enforcement Policy Regarding EnforcementDiscretion for Certain Fire Protection Issues (10 CFR 50.48), and in consultation with the Director, Office of Enforcement; I have been authorized to exercise enforcement discretion such that the above violation will not be cited. In addition, based on the above correctiveactions and in accordance with NRC Inspection Manual Chapter 0305, Operating ReactorAssessment Program, the NRC will also refrain from including the finding in the Agency ActionMatrix. You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRC's"Rules of Practice," a copy of this letter, its enclosures, and your response (should you choose to provide one) will be made available electronically for public inspection in the NRC PublicDocument Room or from the NRC's document system (ADAMS) which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, anyresponse should not include any personal privacy, proprietary, classified, or safeguards information so that it can be made available to the Public without redaction. Should you have any questions regarding this letter, please contact Mr. D. Charles Payne,Chief, Engineering Branch 2, Division of Reactor Safety, at (404)562-4669. | | The NRC also concluded that a violation of 10 CFR 50.48(b)(1) and 10 CFR Part 50, Appendix R, Sections III.G.2 and III.G.3, occurred. In particular, Appendix R, Section III.G.2 states, in part, that where cables or equipment (including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground) of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of three means of ensuring that one of the redundant trains is free of fire damage shall be provided. |
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| | Section III.G.3 states that alternative shutdown capability should be provided where the protection of systems (whose function is required for hot shutdown) does not satisfy the requirements of Section III.G.2. |
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| | Florida Power and Light Company 3 In this case, the following three instances were identified where FPL failed to satisfy the above Appendix R requirements: (1) FPL failed to protect control circuits and cables that could cause maloperation of motor-operated valve (MOV) MOV-4-626, RCP Thermal Barrier Component Cooling Water System Return Isolation Valve, in fire zone (FZ) 67. This condition existed since at least September 9, 2003, when it was first identified by FPL. (2) FPL failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves MOV-3-716B and MOV-3-626 in FZ 63 and MOV-4-716B valve in FZ 67. This condition existed since at least February 9, 2001, when the applicable procedure page was last revised FPL. (3) FPL failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves in FZ 106 and did not meet the alternative shutdown capability requirements. Specifically, under certain scenarios, FPLs procedure may not have mitigated a spurious closure of valves MOV-3-716A and MOV-4-716A in a timely manner, possibly resulting in an RCP seal LOCA and pressurizer level dropping below the indicating range. This condition existed since at least April 24, 2002, when the applicable procedure pages were last revised. |
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| | The NRC also reviewed FPLs request that the violation be considered for enforcement discretion. On June 16, 2004, the NRC published a final rule revising its regulations in 10 CFR 50.48, which governs fire protection at operating nuclear power plants. This revision became effective on July 16, 2004, and it added a new paragraph (c) to 10 CFR 50.48 that allows reactor licensees to voluntary comply with the risk-informed, performance-based fire protection approaches in NFPA 805 (with limited exceptions stated in the rule language) as an alternative to complying with 10 CFR 50.48(b) or the requirements in their fire protection license conditions. As part of the transition to 10 CFR 50.48(c), licensees will establish the fundamental fire protection program identified in NFPA 805 and will perform a plant-wide assessment to identify fire areas and fire hazards and to evaluate compliance with their existing fire protection licensing basis. This fire protection assessment is beyond the normal licensee review of their fire protection program. With regard to applicable noncompliances, licensees are required to adopt compensatory measures until compliance is either restored to 10 CFR 50.48(b) or achieved per 10 CFR 50.48(c). |
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| | In order to provide incentives for licensees initiating efforts to identify and correct subtle violations that are not likely to be identified by routine efforts, the NRC issued Enforcement Policy Statement revisions on June 16, 2004, and January 14, 2005, allowing enforcement discretion for certain fire protection noncompliances identified as part of the transition to 10 CFR 50.48(c) as well as existing identified compliances which could reasonably be corrected under 10 CFR 50.48(c). This interim enforcement discretion policy is consistent with the long-standing policy included in Section VII.B.3, Violations Involving Old Design Issues, of the Enforcement Policy, which addresses discretion when licensee undertake a comprehensive review and assessment. This exercise of discretion provides appropriate incentives for licensees to initiate efforts to identify and correct subtle violations that are not likely to be identified by routine efforts. As such, the NRC Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) provides enforcement discretion for licensees who wish to take advantage of the new rule to resolve existing noncompliances (i.e., implement corrective actions until the licensee has transitioned to 10 CFR 50.48(c)) provided that certain criteria are met. |
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| | In this case, the NRC concluded that (1) the noncompliance was not associated with a finding that the reactor oversight process significance determination process would evaluate as Red, or |
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| | Florida Power and Light Company 4 it would not be categorized at Severity Level I; (2) FPL submitted a letter of intent before December 31, 2005, stating its intent to transition to 10 CFR 50.48(c), which includes approaches in NFPA 805; and (3) the licensee entered the noncompliance into its corrective action program and implemented appropriate compensatory measures (including an operability evaluation to demonstrate that safety will be maintained during operation and shutdown). |
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| | Regarding compensatory measures, FPL incorporated acceptable manual operator actions into applicable procedures to address the finding at the time of the original inspection. Based on the above, in accordance with the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), and in consultation with the Director, Office of Enforcement; I have been authorized to exercise enforcement discretion such that the above violation will not be cited. In addition, based on the above corrective actions and in accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, the NRC will also refrain from including the finding in the Agency Action Matrix. |
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| | You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRC's |
| | "Rules of Practice," a copy of this letter, its enclosures, and your response (should you choose to provide one) will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS) which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, any response should not include any personal privacy, proprietary, classified, or safeguards information so that it can be made available to the Public without redaction. |
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| | Should you have any questions regarding this letter, please contact Mr. D. Charles Payne, Chief, Engineering Branch 2, Division of Reactor Safety, at (404)562-4669. |
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| Sincerely, | | Sincerely, |
| /RA/ BY LOREN PLISCO ACTING FOR | | /RA/ BY LOREN PLISCO ACTING FOR/ |
| /William D. Travers Regional AdministratorDocket Nos. 50-250, 50-251License Nos. DPR-31, DPR-41
| | William D. Travers Regional Administrator Docket Nos. 50-250, 50-251 License Nos. DPR-31, DPR-41 |
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| ===Enclosures:=== | | ===Enclosures:=== |
| 1. NRC Evaluation of Licensee's Risk Significance Inputs 2. List of Attendees 3. Material Presented by Licensee 4. Material Presented by NRC Florida Power and Light Company5 | | 1. NRC Evaluation of Licensees Risk Significance Inputs 2. List of Attendees 3. Material Presented by Licensee 4. Material Presented by NRC |
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| | Florida Power and Light Company 5 |
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| | REGION II OFFICE, ATLANTA, GA. |
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| | I. OPENING REMARKS, INTRODUCTIONS AND MEETING INTENT Mr. H. Christensen, Deputy Director, Division of Reactor Safety (DRS) |
| | II. NRC REGULATORY CONFERENCE POLICY Mr. C. Payne, Chief, Engineering Branch 2, DRS III. STATEMENT OF THE ISSUE WITH RISK PERSPECTIVES Mr. C. Payne, Chief, Engineering Branch 2, DRS IV. SUMMARY OF APPARENT VIOLATIONS Mr. C. Payne, Chief, Engineering Branch 2, DRS V. LICENSEE RISK PERSPECTIVE PRESENTATION VI. LICENSEE RESPONSE TO APPARENT VIOLATIONS VII. BREAK / NRC CAUCUS Mr. H. Christensen, Deputy Director, Division of Reactor Safety (DRS) |
| | VIII. CLOSING REMARKS Mr. H. Christensen, Deputy Director, Division of Reactor Safety (DRS) |
| | Enclosure 4 |
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| | Material Presented by NRC -2-Draft Apparent Violation 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R, Section III.G. Section III.G.2 states, in part, that where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of three means of ensuring that one of the redundant trains is free of fire damage shall be provided. Section III.G.3 states that alternative shutdown capability should be provided where the protection of systems whose function is required for hot shutdown, does not satisfy the requirements of III.G.2. Section III.L of Appendix R provides requirements to be met by alternative shutdown methods. Section III.L.2.b states, in part, that The reactor coolant makeup function shall be capable of maintaining the reactor coolant level...within the level indication in the pressurizer in PWRs. |
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| REGION II OFFICE, ATLANTA, GA.I.OPENING REMARKS, INTRODUCTIONS AND MEETING INTENTMr. H. Christensen, Deputy Director, Division of Reactor
| | Contrary to the above, on February 13, 2004, the inspectors identified three examples where 10 CFR 50, Appendix R requirements were not met: |
| | a. The licensee failed to protect control circuits and cables that could cause maloperation of MOV-4-626, RCP Thermal Barrier Component Cooling Water System Return Isolation Valve in FZ 67. This condition existed since at least September 9, 2003, when it was first identified by the licensee. |
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| Safety (DRS)II.NRC REGULATORY CONFERENCE POLICYMr. C. Payne, Chief, Engineering Branch 2, DRSIII.STATEMENT OF THE ISSUE WITH RISK PERSPECTIVESMr. C. Payne, Chief, Engineering Branch 2, DRSIV.SUMMARY OF APPARENT VIOLATIONSMr. C. Payne, Chief, Engineering Branch 2, DRSV.LICENSEE RISK PERSPECTIVE PRESENTATIONVI.LICENSEE RESPONSE TO APPARENT VIOLATIONS VII.BREAK / NRC CAUCUSMr. H. Christensen, Deputy Director, Division of Reactor
| | b. The licensee failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves MOV-3-716B and MOV-3-626 in FZ 63; and MOV-4-716B valve in FZ 67. This condition has existed since at least February 9, 2001, when the applicable procedure page was last revised. |
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| Safety (DRS)VIII.CLOSING REMARKSMr. H. Christensen, Deputy Director, Division of Reactor
| | c. The licensee failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves in FZ 106; and did not meet the alternative shutdown capability requirements. Specifically, the licensees procedure may not mitigate a spurious closure of valves MOV-3-716A and MOV-4-716A in a timely manner, possibly resulting in an RCP seal LOCA, and pressurizer level dropping below the indicating range. This condition has existed since at least April 24, 2002, when the applicable procedure pages were last revised. |
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| Safety (DRS)Enclosure 4 Material Presented by NRC-2--2-Draft Apparent Violation10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants licensed tooperate prior to January 1, 1979, must satisfy the applicable requirements ofAppendix R, Section III.G. Section III.G.2 states, in part, that where cables orequipment, including associated non-safety circuits that could prevent operationor cause maloperation due to hot shorts, open circuits, or shorts to ground, ofredundant trains of systems necessary to achieve and maintain hot shutdownconditions are located within the same fire area outside of primary containment,one of three means of ensuring that one of the redundant trains is free of firedamage shall be provided. Section III.G.3 states that alternative shutdown capability should be provided where the protection of systems whose function isrequired for hot shutdown, does not satisfy the requirements of III.G.2. SectionIII.L of Appendix R provides requirements to be met by alternative shutdownmethods. Section III.L.2.b states, in part, that "The reactor coolant makeupfunction shall be capable of maintaining the reactor coolant level...within the levelindication in the pressurizer in PWRs." Contrary to the above, on February 13, 2004, the inspectors identified threeexamples where 10 CFR 50, Appendix R requirements were not met:a.The licensee failed to protect control circuits and cables that could causemaloperation of MOV-4-626, "RCP Thermal Barrier Component CoolingWater System Return Isolation Valve" in FZ 67. This condition existedsince at least September 9, 2003, when it was first identified by thelicensee. b.The licensee failed to protect control circuits and cables that could causemaloperation of necessary RCP thermal barrier component coolingsystem valves MOV-3-716B and MOV-3-626 in FZ 63; and MOV-4-716Bvalve in FZ 67. This condition has existed since at least February 9,2001, when the applicable procedure page was last revised. c.The licensee failed to protect control circuits and cables that could causemaloperation of necessary RCP thermal barrier component coolingsystem valves in FZ 106; and did not meet the alternative shutdown capability requirements. Specifically, the licensee's procedure may notmitigate a spurious closure of valves MOV-3-716A and MOV-4-716A in atimely manner, possibly resulting in an RCP seal LOCA, and pressurizerlevel dropping below the indicating range. This condition has existedsince at least April 24, 2002, when the applicable procedure pages werelast revised.Note: The apparent violation discussed at this Regulatory Conference is subjectto further review and subject to change prior to any resulting enforcement action.
| | Note: The apparent violation discussed at this Regulatory Conference is subject to further review and subject to change prior to any resulting enforcement action. |
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Supplement to 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,
ML23333A0152023-11-27027 November 2023
Attachment G - Arcadis Memo Re FPL Year 4 Raasr Final (June 2, 2023, Appended to Derm letter)-1
ML23333A0102023-11-27027 November 2023
Attachment B - 11/07/2022 - Waterkeeper Scoping Comments-1
L-2023-146, 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
L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles2023-11-15015 November 2023
License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles
IR 05000250/20230032023-11-0909 November 2023
Integrated Inspection Report 05000250/2023003 and 05000251/2023003
ML23310A1342023-11-0404 November 2023
10 CFR 2.206 Petition - LTR-23-0216-1 Petition Amendment; Turkey Point Subsequent Renewal with Petitioner 11/04/2023
ML24016A2622023-10-25025 October 2023
Subsequent License Renewal Updated List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected Project
L-2023-077, License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis2023-10-11011 October 2023
License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis
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
IR 05000250/20230102023-09-29029 September 2023
Biennial Problem Identification and Resolution Inspection Report 05000250/2023010 and 05000251/2023010
ML23234A1922023-09-27027 September 2023
Issuance of Amendment Nos. 297 and 290 Regarding Conversion to Improved Standard Technical Specifications
ML23265A5492023-09-22022 September 2023
Transmittal of WCAP-18830-P/NP Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles to Support a License Amendment Request from FPL - License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis
ML23243A9522023-09-0808 September 2023
Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application
ML23243A9542023-09-0808 September 2023
Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application
ML23243A9532023-09-0808 September 2023
Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application
ML23243A9552023-09-0808 September 2023
Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application - Tribe- Section 106 Letters
ML23199A2352023-09-0505 September 2023
Letter to EPA-Turkey Point Nuclear Generating Station, Units 3 and 4 - Notice of Availability of Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal
ML23199A2482023-09-0505 September 2023
Ltr to Florida Power and Light Co - Turkey Point Nuclear Generating Units 3 and 4 - Notice of Availability of Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal
L-2023-110, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-08-25025 August 2023
Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project
IR 05000250/20230052023-08-21021 August 2023
Updated Inspection Plan for Turkey Point, Units 3 & 4 (Report 05000250/2023005 and 05000251/2023005)
L-2023-115, Inservice Inspection Program Owner'S Activity Report (OAR-1)2023-08-21021 August 2023
Inservice Inspection Program Owner'S Activity Report (OAR-1)
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 05000250/20230022023-08-14014 August 2023
Integrated Inspection Report 05000250/2023002 and 05000251/2023002
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
ML23242A0922023-08-0606 August 2023
Request for Withholding Information from Public Disclosure for Turkey Point Nuclear Generating Unit Nos. 3 and 4
ML23201A0872023-08-0303 August 2023
Audit Plan in Support of Review of License Amendment
ML23198A2702023-08-0303 August 2023
Issuance of the Site-Specific Environmental Impact Statement Scoping Process Summary Report Associated with the Turkey Point Nuclear Generating Unit Numbers 3 and 4, Subsequent License Renewal Application, Environmental Report Supplement 2
L-2023-094, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-07-27027 July 2023
Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project
ML23178A1872023-07-25025 July 2023
Review of the Spring 2022 Steam Generator Tube Inspections During Refueling Outage No. 33
ML23188A1242023-07-20020 July 2023
Acknowledgment of Temporary Suspension Request for License Request for License Amendment Request Reactor Protection System, Engineered Safety Features System, and Nuclear Instrumentation System
ML23200A0672023-07-18018 July 2023
Tp 2023 RQ Inspection Notification Letter
ML23173A0812023-07-17017 July 2023
Supplement to Regulatory Audit Plan in Support of Review of License Amendment Request Supporting Digital Instrumentation & Control Modernization Project (EPID L-2022-LLA-0105) - Non-Proprietary
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)
2024-02-05
[Table view]
Category:Meeting Agenda
MONTHYEARPMNS20230969, Public Meeting to Receive Comments on the Draft Site-Specific Turkey Point Environmental Impact Statement2023-09-0707 September 2023
Public Meeting to Receive Comments on the Draft Site-Specific Turkey Point Environmental Impact Statement
PMNS20230973, Public Meeting to Receive Comments on the Draft Site-Specific Turkey Point Environmental Impact Statement2023-09-0707 September 2023
Public Meeting to Receive Comments on the Draft Site-Specific Turkey Point Environmental Impact Statement
PMNS20230932, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-08-14014 August 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230879, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-08-0101 August 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230809, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-07-11011 July 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230775, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-06-30030 June 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230732, Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request for Transition to a 24-month Fuel Cycle for Turkey Point Generating Unit Nos. 3 and 42023-06-26026 June 2023
Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request for Transition to a 24-month Fuel Cycle for Turkey Point Generating Unit Nos. 3 and 4
PMNS20230718, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-06-12012 June 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230673, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-05-26026 May 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230599, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-05-15015 May 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230594, Annual Assessment Meeting2023-05-0404 May 2023
Annual Assessment Meeting
PMNS20230447, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-04-20020 April 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230449, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-04-18018 April 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230409, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-04-11011 April 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230253, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-04-0707 April 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230278, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-04-0303 April 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230308, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-03-27027 March 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230226, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-03-0707 March 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230223, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-03-0606 March 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230192, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-03-0101 March 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230168, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-02-22022 February 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230134, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-02-22022 February 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230159, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-02-15015 February 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230049, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 42023-01-27027 January 2023
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and 4
PMNS20230080, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-01-26026 January 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230060, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-01-18018 January 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20230003, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2023-01-0505 January 2023
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20221243, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Planned Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 32022-12-0202 December 2022
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss the Planned Digital Instrumentation and Controls License Amendment Request for Turkey Point Nuclear Generating, Unit Nos. 3 and
PMNS20221177, Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request for Transition to a 24-month Fuel Cycle Turkey Point Generating Unit Nos. 3 and 42022-11-22022 November 2022
Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request for Transition to a 24-month Fuel Cycle Turkey Point Generating Unit Nos. 3 and 4
PMNS20221132, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2022-10-31031 October 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20221080, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2022-10-17017 October 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20221057, Meeting Between the U.S. Nuclear Regulatory Commission and Florida Power & Light Company to Discuss Review of Digital Instrumentation and Controls License Amendment Requests for Turkey Point Nuclear Generating, Units 3 and 42022-10-11011 October 2022
Meeting Between the U.S. Nuclear Regulatory Commission and Florida Power & Light Company to Discuss Review of Digital Instrumentation and Controls License Amendment Requests for Turkey Point Nuclear Generating, Units 3 and 4
PMNS20220997, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests2022-10-0303 October 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications License Amendment Requests
PMNS20220876, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss Review of Defense-in-Depth and Diversity (D3) Evaluation for Turkey Point Nuclear Generating, Units 3 and 4 (Turkey Point)2022-09-22022 September 2022
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss Review of Defense-in-Depth and Diversity (D3) Evaluation for Turkey Point Nuclear Generating, Units 3 and 4 (Turkey Point)
PMNS20220998, Notice of Meeting with Florida Power and Light Company (FPL) Regarding Turkey Point Setpoint Methodologies as It Relates to the Improved Technical Specification (ITS) Conversion License Amendment Request2022-09-22022 September 2022
Notice of Meeting with Florida Power and Light Company (FPL) Regarding Turkey Point Setpoint Methodologies as It Relates to the Improved Technical Specification (ITS) Conversion License Amendment Request
PMNS20220935, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications (ITS) License Amendment Requests2022-09-0909 September 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications (ITS) License Amendment Requests
PMNS20220930, Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss Acceptance Review of the Turkey Point Digital Instrumentation and Controls License Amendment Request2022-09-0808 September 2022
Meeting Between the U.S. Nuclear Regulatory Commission (NRC) and Florida Power & Light Company (FPL) to Discuss Acceptance Review of the Turkey Point Digital Instrumentation and Controls License Amendment Request
ML22227A1302022-08-17017 August 2022
License Amendment Request Reactor Trip Breaker Completion Time Extension - Public Meeting August 17, 2022 (EPID L-2022-LRM-0061) (Slides)
PMNS20220832, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications (ITS) License Amendment Requests2022-08-16016 August 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Units 3 and 4 Improved Technical Specifications (ITS) License Amendment Requests
PMNS20220799, Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request to Extend the Completion Time for an Inoperable Reactor Trip Breaker for the Turkey Point Generating, Unit Nos. 3 and2022-08-16016 August 2022
Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request to Extend the Completion Time for an Inoperable Reactor Trip Breaker for the Turkey Point Generating, Unit Nos. 3 and 4
PMNS20220748, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Requests2022-08-0303 August 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the St. Lucie Plant, Units 1 and 2 and Turkey Point Nuclear Generating, Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Requests
PMNS20220701, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request2022-07-14014 July 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request
PMNS20220683, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request2022-06-28028 June 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request
ML22172A2172022-06-22022 June 2022
LAR: Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project (Non-Proprietary)
PMNS20220609, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request2022-06-14014 June 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request
PMNS20220582, Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request to Replace Reactor Coolant Pump Seals for the Turkey Point Generating Unit Nos. 3 and 42022-06-10010 June 2022
Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request to Replace Reactor Coolant Pump Seals for the Turkey Point Generating Unit Nos. 3 and 4
PMNS20220592, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request2022-06-0606 June 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request
ML22144A3902022-05-24024 May 2022
RCP Seal Solutions - May 24 2022 Slide Material (Public)
PMNS20220454, Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request2022-05-17017 May 2022
Meeting with NextEra Energy/Florida Power & Light Company to Discuss the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Improved Technical Specifications (ITS) License Amendment Request
PMNS20220478, Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request to Replace Reactor Coolant Pump Seals for the Turkey Point Generating Unit Nos. 3 and 42022-05-11011 May 2022
Pre-submittal Meeting with NextEra Energy/Florida Power & Light Company to Discuss a Planned License Amendment Request to Replace Reactor Coolant Pump Seals for the Turkey Point Generating Unit Nos. 3 and 4
2023-09-07
[Table view] |
Text
ary 6, 2006
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION - TURKEY POINT NUCLEAR PLANT (NRC Inspection Report Nos. 05000250,251/2005013)
Dear Mr. Stall:
The purpose of this letter is to provide you with the results of our review of findings involving certain fire response procedures at the Turkey Point Nuclear Plant that would not be effective in ensuring a safe shutdown of Units 3 and 4 should a severe fire develop in certain fire zones.
This issue was discussed at a regulatory conference held in the NRCs Region II Office on November 16, 2005.
To summarize our review of this matter, the NRC has concluded that the significance of the findings was very low for Unit 3 and low to moderate for Unit 4. In addition, the NRC has concluded that the exercise of enforcement discretion is appropriate for these findings in accordance with the NRC Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). The NRC will also refrain from including the findings in the Agency Action Matrix in accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program. The bases for our conclusions regarding the significance of the findings is described below and in Enclosure 1.
As background, NRC Inspection Report No. 05000250,251/2005010, was issued on October 7, 2005, and it documented a finding (one apparent violation of 10 CFR Part 50, Appendix R) based on the NRCs review of three separate unresolved items (URIs 05000250,251/2004007-001, -006, and -007). The collective significance of the finding was assessed under the significance determination process as a preliminary greater than Green issue (i.e., an issue of at least low to moderate safety significance which may require additional NRC inspection). The cover letter to NRC Inspection Report No. 05000250,251/2005010 informed Florida Power and Light Company (FPL) of the NRCs preliminary conclusion, provided FPL an opportunity to request a regulatory conference on this matter, and forwarded the details of the NRCs preliminary estimate of the change in core damage frequency (CDF) for the finding.
On November 15, 2005, FPL submitted a letter to the NRC documenting its intent to adopt the risk-informed, performance-based fire protection program under 10 CFR 50.48(c), which includes approaches in National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating
Florida Power and Light Company 2 Plants, 2001 Edition. In accordance with the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), FPL requested enforcement discretion for existing identified noncompliances, noncompliances identified during its NFPA 805 transition process, and the noncompliance that was the subject of the November 16, 2005, regulatory conference.
At FPLs request, an open regulatory conference was conducted on November 16, 2005, to discuss FPLs position on this issue. The enclosures to this letter include the list of attendees at the regulatory conference and material presented by FPL and NRC.
During the conference, FPL presented the results of its estimate of the increase in CDF including influential assumptions and risk analysis methodology. FPLs presentation addressed the three aspects of the finding separately (i.e., URI 05000250,251/2004007-001, -006, and-007), and provided the following conclusions on the matter. In summary, FPL agreed with the NRCs view that URI 05000250,251/2004007-001 was a violation of 10 CFR Part 50, Appendix R, but concluded that the significance of this issue was very low. FPL disagreed with that portion of the finding consisting of URIs 05000250,251/2004007-006 and -007, concluding that procedural requirements were acceptable, a performance deficiency did not exist, and thus this finding did not represent a violation. Furthermore, FPL concluded that the significance of URIs 05000250,251/2004007-006 and -007, even if considered to be a finding, was very low.
At the conference, the NRC requested that FPL provide additional information to support its risk analysis. This information was subsequently submitted by letter dated November 23, 2005.
FPLs presentation and subsequent correspondence provided 15 inputs on the safety significance of the finding. The following three of the inputs were incorporated into the NRCs final significance determination: (1) reducing the main control room fire ignition frequency, (2) modifying the time at which the operating charging pump would be stopped during a main control room fire, and (3) reducing the time that reactor coolant pump (RCP) leakage could have created conditions for a small break loss of coolant accident (LOCA). A detailed discussion of the NRCs basis for acceptance or rejection of all inputs is provided in Enclosure 1.
After considering the information developed during the inspection, the information presented at the conference, and the supplemental information provided by FPL after the conference, the NRC has concluded that the final inspection findings are appropriately characterized as very low for Unit 3 and low to moderate for Unit 4.
The NRC also concluded that a violation of 10 CFR 50.48(b)(1) and 10 CFR Part 50, Appendix R, Sections III.G.2 and III.G.3, occurred. In particular, Appendix R,Section III.G.2 states, in part, that where cables or equipment (including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground) of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of three means of ensuring that one of the redundant trains is free of fire damage shall be provided.
Section III.G.3 states that alternative shutdown capability should be provided where the protection of systems (whose function is required for hot shutdown) does not satisfy the requirements of Section III.G.2.
Florida Power and Light Company 3 In this case, the following three instances were identified where FPL failed to satisfy the above Appendix R requirements: (1) FPL failed to protect control circuits and cables that could cause maloperation of motor-operated valve (MOV) MOV-4-626, RCP Thermal Barrier Component Cooling Water System Return Isolation Valve, in fire zone (FZ) 67. This condition existed since at least September 9, 2003, when it was first identified by FPL. (2) FPL failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves MOV-3-716B and MOV-3-626 in FZ 63 and MOV-4-716B valve in FZ 67. This condition existed since at least February 9, 2001, when the applicable procedure page was last revised FPL. (3) FPL failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves in FZ 106 and did not meet the alternative shutdown capability requirements. Specifically, under certain scenarios, FPLs procedure may not have mitigated a spurious closure of valves MOV-3-716A and MOV-4-716A in a timely manner, possibly resulting in an RCP seal LOCA and pressurizer level dropping below the indicating range. This condition existed since at least April 24, 2002, when the applicable procedure pages were last revised.
The NRC also reviewed FPLs request that the violation be considered for enforcement discretion. On June 16, 2004, the NRC published a final rule revising its regulations in 10 CFR 50.48, which governs fire protection at operating nuclear power plants. This revision became effective on July 16, 2004, and it added a new paragraph (c) to 10 CFR 50.48 that allows reactor licensees to voluntary comply with the risk-informed, performance-based fire protection approaches in NFPA 805 (with limited exceptions stated in the rule language) as an alternative to complying with 10 CFR 50.48(b) or the requirements in their fire protection license conditions. As part of the transition to 10 CFR 50.48(c), licensees will establish the fundamental fire protection program identified in NFPA 805 and will perform a plant-wide assessment to identify fire areas and fire hazards and to evaluate compliance with their existing fire protection licensing basis. This fire protection assessment is beyond the normal licensee review of their fire protection program. With regard to applicable noncompliances, licensees are required to adopt compensatory measures until compliance is either restored to 10 CFR 50.48(b) or achieved per 10 CFR 50.48(c).
In order to provide incentives for licensees initiating efforts to identify and correct subtle violations that are not likely to be identified by routine efforts, the NRC issued Enforcement Policy Statement revisions on June 16, 2004, and January 14, 2005, allowing enforcement discretion for certain fire protection noncompliances identified as part of the transition to 10 CFR 50.48(c) as well as existing identified compliances which could reasonably be corrected under 10 CFR 50.48(c). This interim enforcement discretion policy is consistent with the long-standing policy included in Section VII.B.3, Violations Involving Old Design Issues, of the Enforcement Policy, which addresses discretion when licensee undertake a comprehensive review and assessment. This exercise of discretion provides appropriate incentives for licensees to initiate efforts to identify and correct subtle violations that are not likely to be identified by routine efforts. As such, the NRC Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) provides enforcement discretion for licensees who wish to take advantage of the new rule to resolve existing noncompliances (i.e., implement corrective actions until the licensee has transitioned to 10 CFR 50.48(c)) provided that certain criteria are met.
In this case, the NRC concluded that (1) the noncompliance was not associated with a finding that the reactor oversight process significance determination process would evaluate as Red, or
Florida Power and Light Company 4 it would not be categorized at Severity Level I; (2) FPL submitted a letter of intent before December 31, 2005, stating its intent to transition to 10 CFR 50.48(c), which includes approaches in NFPA 805; and (3) the licensee entered the noncompliance into its corrective action program and implemented appropriate compensatory measures (including an operability evaluation to demonstrate that safety will be maintained during operation and shutdown).
Regarding compensatory measures, FPL incorporated acceptable manual operator actions into applicable procedures to address the finding at the time of the original inspection. Based on the above, in accordance with the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), and in consultation with the Director, Office of Enforcement; I have been authorized to exercise enforcement discretion such that the above violation will not be cited. In addition, based on the above corrective actions and in accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, the NRC will also refrain from including the finding in the Agency Action Matrix.
You are not required to respond to this letter. In accordance with 10 CFR 2.390 of the NRC's
"Rules of Practice," a copy of this letter, its enclosures, and your response (should you choose to provide one) will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS) which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, any response should not include any personal privacy, proprietary, classified, or safeguards information so that it can be made available to the Public without redaction.
Should you have any questions regarding this letter, please contact Mr. D. Charles Payne, Chief, Engineering Branch 2, Division of Reactor Safety, at (404)562-4669.
Sincerely,
/RA/ BY LOREN PLISCO ACTING FOR/
William D. Travers Regional Administrator Docket Nos. 50-250, 50-251 License Nos. DPR-31, DPR-41
Enclosures:
1. NRC Evaluation of Licensees Risk Significance Inputs 2. List of Attendees 3. Material Presented by Licensee 4. Material Presented by NRC
Florida Power and Light Company 5
REGION II OFFICE, ATLANTA, GA.
I. OPENING REMARKS, INTRODUCTIONS AND MEETING INTENT Mr. H. Christensen, Deputy Director, Division of Reactor Safety (DRS)
II. NRC REGULATORY CONFERENCE POLICY Mr. C. Payne, Chief, Engineering Branch 2, DRS III. STATEMENT OF THE ISSUE WITH RISK PERSPECTIVES Mr. C. Payne, Chief, Engineering Branch 2, DRS IV. SUMMARY OF APPARENT VIOLATIONS Mr. C. Payne, Chief, Engineering Branch 2, DRS V. LICENSEE RISK PERSPECTIVE PRESENTATION VI. LICENSEE RESPONSE TO APPARENT VIOLATIONS VII. BREAK / NRC CAUCUS Mr. H. Christensen, Deputy Director, Division of Reactor Safety (DRS)
VIII. CLOSING REMARKS Mr. H. Christensen, Deputy Director, Division of Reactor Safety (DRS)
Enclosure 4
Material Presented by NRC -2-Draft Apparent Violation 10 CFR 50.48 (b)(1) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R,Section III.G.Section III.G.2 states, in part, that where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of three means of ensuring that one of the redundant trains is free of fire damage shall be provided.Section III.G.3 states that alternative shutdown capability should be provided where the protection of systems whose function is required for hot shutdown, does not satisfy the requirements of III.G.2.Section III.L of Appendix R provides requirements to be met by alternative shutdown methods.Section III.L.2.b states, in part, that The reactor coolant makeup function shall be capable of maintaining the reactor coolant level...within the level indication in the pressurizer in PWRs.
Contrary to the above, on February 13, 2004, the inspectors identified three examples where 10 CFR 50, Appendix R requirements were not met:
a. The licensee failed to protect control circuits and cables that could cause maloperation of MOV-4-626, RCP Thermal Barrier Component Cooling Water System Return Isolation Valve in FZ 67. This condition existed since at least September 9, 2003, when it was first identified by the licensee.
b. The licensee failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves MOV-3-716B and MOV-3-626 in FZ 63; and MOV-4-716B valve in FZ 67. This condition has existed since at least February 9, 2001, when the applicable procedure page was last revised.
c. The licensee failed to protect control circuits and cables that could cause maloperation of necessary RCP thermal barrier component cooling system valves in FZ 106; and did not meet the alternative shutdown capability requirements. Specifically, the licensees procedure may not mitigate a spurious closure of valves MOV-3-716A and MOV-4-716A in a timely manner, possibly resulting in an RCP seal LOCA, and pressurizer level dropping below the indicating range. This condition has existed since at least April 24, 2002, when the applicable procedure pages were last revised.
Note: The apparent violation discussed at this Regulatory Conference is subject to further review and subject to change prior to any resulting enforcement action.
