L-2013-319, Florida Power & Light Companys Turkey Point Units 3 and 4, Response to NRC Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns
| ML13338A581 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/22/2013 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2013-319 | |
| Download: ML13338A581 (7) | |
Text
November 22, 2013 0
U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Florida Power & Light Company's Turkey Point Units 3 and 4, Response to NRC Request for Additional Information Associated With Near-Term Task Force Recommendation 2.3, Seismic Walkdowns
References:
- 1. NRC Letter, Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns, dated November 1, 2013. Agencywide Documents and Access Management System (ADAMS) Accession No. ML13304B418.
- 2. 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. ADAMS Accession No. ML12053A340.
- 3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-416), "Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Seismic" dated November 27, 2012. ADAMS Accession No. ML12349A162.
- 4. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2013-198), "Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Turkey Point Seismic Walkdown Report Update, dated July 13, 2013.
ADAMS Accession No. ML13213A195.
- 5. NRC Letter to Nuclear Energy Institute, "Endorsement of Electric Power Research Institute (EPRI) Draft Report 1025286, 'Seismic Walkdown Guidance'," dated May 31, 2012.
ADAMS Accession No. ML12145A529.
- 6. EPRI Report 1025286, Seismic Walkdown Guidance for Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic, dated June 2012. ADAMS Accession No. ML12188A031.
Florida Power & Linht Company 9760 S.W. 344Ttreet FHomesead, FL 33035
Turkey Point Units 3 and 4 L-2013-319 Docket Nos. 50-250 and 50-251 Page 2 of 2 On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) Staff issued a letter requesting additional information per Title 10 of the Code of Federal Regulations, Section 50.54(f) (hereafter called the 50.54(f) letter) (Reference 2). The 50.54(f) letter requested that licensees conduct seismic hazard walkdowns to verify the plant configuration with the current licensing basis. 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 the assessment to be completed. In Enclosure 1, to Reference 1, the Staff identifies the request for additional information. In Reference 1, the Staff requests that licensees submit additional information within 30 days from November 1, 2013.
The Turkey Point seismic walkdown reports were submitted to the NRC for review (References 3 and 4). Seismic walkdowns at Turkey Point were conducted using the Staff endorsed guidance (Reference 5), and EPRI Report 1025286, "Seismic Walkdown Guidance" (Reference 6).
The enclosure to this letter provides the response to the NRC Request for Additional Information (RAI) from Enclosure 1 of Reference 1.
This letter contains no new regulatory commitments.
Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Turkey Point Licensing Manager, at (305) 246-7327.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on November -,ZZ, 2013 Sincerely, Michael Kiley Site Vice President Turkey Point Nuclear Plant Enclosure cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant
L-2013-319 Enclosure Florida Power & Light Company's Turkey Point Units 3 and 4 Response to NRC Request for Additional Information (RAI)
Associated With Near-Term Task Force Recommendation 2.3, Seismic Walkdowns Page 1 of 5
L-2013-319 Enclosure NRC RAI No. 1:
Conduct of the walkdowns, determination of potentially adverse seismic conditions (PASCs)O, dispositionin2 of issues, and reporting Therefore, in order to clarify the process that was followed, provide a description of the overall process used by the licensee (and its contractors) to evaluate observations identified in the field by the SWEs. The process should include how a field observation was determined to be a PASC or not and how the bases for determinations were recorded. Once a determination was made that an observation was a PASC, describe the process for creating a condition report (or other tracking mechanism), performing the LBE (or other determination method), and the resultant action, such as entering it into the CAP, or documenting the result and basis.
Also, in order to confirm that the reported information supports concluding that the plant meets the CLB, please follow one of the following three acceptable alternatives:
(a) Provide a supplement to the table or text from the original walkdown report, if needed, to include similar conditions as the above examples and situations and for conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination. The supplement should include a short description of each condition, how it was dispositioned and the basis for the disposition, as follows: 1) for each condition that was entered into the CAP, provide the CAP reference number, initiation date, and (if known) the planned completion date, or 2) for all other conditions, provide the result of the licensing basis evaluation (or other determination method), the basis for the result, and how (or where) the result was captured in the plant's documentation or existing plant process.
(b) Following the plant's standard procedures, confirm that a new CAP entry has been made to verify if appropriate actions were taken when reporting and dispositioning identified PASCs (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination). The eventual CAP closeout, including the process followed and actions taken, should be in sufficient detail to enable NRC resident inspectors to follow up.
(c) If no new conditions are identified for addition to the supplement or the CAP entry mentioned above is deemed not necessary, provide a statement of confirmation that all potentially seismic adverse conditions (including conditions for which a calculation, analysis (if more than a simple analysis), or evaluation was used for a determination) identified during the walkdowns and walk-bys were addressed and included in the report to the NRC.
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L-2013-319 Enclosure FPL Response to RAI No. 1:
For Turkey Point Units 3 and 4 seismic walkdowns, if an observation could not be resolved with a simplistic engineering evaluation based on the Seismic Walkdown Engineer's EPRI guidance training, or on an existing drawing, or on a calculation that provided the basis for a satisfactory determination, the observation was designated as unknown (i.e., "U" ) or as No (i.e., "N" ). The items identified by a "U" or "N" were conservatively considered as potentially adverse seismic conditions (PASCs) by the seismic walkdown engineers (SWEs) and entered as such in the applicable checklist. If the walkdown checklist produced a "U" or "N" answer, the related observation was considered a PASC and the basis for the answer was recorded on the checklist.
Once a determination was made that an observation was a PASC, it was entered into the Corrective Action Program (CAP) for appropriate evaluation and resolution. All PASCs have been entered in the CAP, with the exception of six items from Reference 3. Three of these six items were identified in Table 5-2 for Unit 3, and the other three were identified in Table 5-2 for Unit 4. All six items involved equipment anchors where not all anchors were visible due to physical obstructions. These six items were designated in the checklists as "U". Upon further consideration, based on-a simplistic evaluation, the SWEs determined, and documented, in Reference 3, pages 29 and 30 for Unit 3, and pages 27 and 28 for Unit 4, that these items were found acceptable. As such, these six items were not entered in the CAP.
As stated above, issues that could not be resolved with simplistic engineering evaluations from walkdowns were considered as PASCs and were entered into the CAP program. The CAP process performed an initial operability determination, and then as part of the engineering resolution to the CAP item, the licensing basis evaluation was performed and documented within the condition report/action request (AR), if warranted. This followed the standard CAP process which also includes any additional actions, such as document updates to reflect field conditions, or repairs, in the respective AR.
There were no observations that were dispositioned by other means. Therefore, no supplement to the text or tables of the original walkdown reports is needed. As such, per acceptable approach in RAI I (c) above, FPL confirms herein that:
All potentially adverse seismic conditions, (including conditions for which a calculation, analysis, or evaluation was used for a determination), identified during the Turkey Point Units 3 and 4 seismic walkdowns and walk-bys were addressed and included in the reports to the NRC (References 3 and 4, Table 5-2 and Table 5-3).
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L-2013-319 Enclosure NRC RAI No. 2:
Conduct of the Peer Review Process As a result of the walkdown report reviews, the staff noted that some descriptions of the peer reviewers and the peer review process that was followed were varied and, in some cases, unclear.
In some cases, the staff could not confirm details of the process, such as if the entire process was reviewed by the peer review team, who were the peer reviewers, what was the role of each peer reviewer, and how the reviews affected the work, if at all, described in the walkdown guidance.
Therefore, in order to clarify the peer review process that was actually used, please confirm whether the following information on the peer review process was provided in the original submittal, and if not, provide the following.
(a) Confirmation that the activities described in the walkdown guidance on page 6-1 were assessed as part of the peer review process.
(b) A complete summary of the peer review process and activities. Details should include confirmation that any individual involved in performing any given walkdown activity was not a peer reviewer for that same activity. If there were cases in which peer reviewers reviewed their own work, please justify how this is in accordance with the objectives of the peer review efforts.
Also, if there are differences from the original submittal, please provide a description of the above information. If there are differences in the review areas or the manner in which the peer reviews were conducted, describe the actual process that was used.
The peer review process assessed all of the activities described on page 6-1 of the guidance document. FPL previously provided the names of each peer reviewer, which peer review task they performed and their role for each task described in EPRI guidance page 6-1.
The information can be found in the following report sections:
- Report 12Q4117-RPT-001 Rev. 1, Unit 3 FPL report (initial submittal), Appendix F, Section 3 through 6 (Reference 3 Enclosure)
Report 12Q4117-RPT-002 Rev. 1 Unit 4 FPL report (initial submittal), Appendix F, Section 3 through 6 (Reference 3 Enclosure)
Report 12Q4117-RPT-001 Rev. 2, Unit 3 FPL report (supplemental submittal), Appendix F, Section 3 through 6 (Reference 4 Enclosure)
Report 12Q4117-RPT-002 Rev. 2 Unit 4 FPL report (supplemental submittal), Appendix F, Section 3 through 6 (Reference 4 Enclosure)
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L-2013-319 Enclosure Based on the above report sections, FPL has followed the EPRI guidance for performing peer reviews with regards to qualifications, task performed and roles.
The following Turkey Point initial and supplemental reports provide the names of the peer reviewers and a list of the activities each reviewer performed:
- Report 12Q4117-RPT-001 Rev. i, Unit 3 FPL report (initial submittal), Appendix F, Section 3 (Reference 3 Enclosure)
- Report 12Q4117-RPT-002 Rev. 1 Unit 4 FPL report (initial submittal), Appendix F, Section 3 (Reference 3 Enclosure)
- Report 12Q4117-RPT-001 Rev. 2, Unit 3 FPL report (supplemental submittal), Appendix F, Section 3 (Reference 4 Enclosure)
" Report 12Q4117-RPT-002 Rev. 2 Unit 4 FPL report (supplemental submittal), Appendix F, Section 3 (Reference 4 Enclosure)
In References 3 and 4, Appendix F, Section 3.2, Peer Review Process, Subsection Seismic Walkdown (initial), it is noted that A. Restrepo also performed duties associated with performing the Individual Plant Examination for External Events (IPEEE) review to ensure previous enhancements were maintained. His role was to identify if the walkdowns produced any deficiencies in enhancements that were implemented for equipment identified in the Turkey Point IPEEE response. This did not conflict with his role as the lead peer reviewer for the initial seismic walkdown activities.
Based on the above report sections, it is concluded that FPL has followed the EPRI guidance for performing the peer reviews with regards to qualifications, roles, responsibilities and activities.
None of the peer reviewers reviewed their own activities.
Section 3.2 of the supplemental reports for Turkey Point Units 3 and 4 (Reference 4) identifies A. Restrepo as the lead peer reviewer. This section was not updated correctly to reflect that George Tullidge was the lead peer reviewer for all the supplemental walkdowns activities. All other tables and sections in Appendix F of Reference 4 accurately reflect the correct roles for both of these individuals. There are no other differences in the submittals (References 3 and 4) with regards to the above information or peer review process.
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