ML14252A521
| ML14252A521 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/26/2014 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Klett A DORL/LPL2-2 301-415-0489 | |
| Shared Package | |
| ML14202A521 | List:
|
| References | |
| 2.206, L-2014-237, LTR-14-1402-1 | |
| Download: ML14252A521 (29) | |
Text
Attachment to July 18th, 2014 10 C.F.R. 2.206 Enforcement Petition Florida Power & Light Company Turkey Point Nuclear Plant Attachment - Seven Letter from the Florida Power & Light Co. to the NRC dated July 26th, 2014 -
Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit (28-pages).
10 CFR 50.90 L-2014-237 July 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating License Nos. DPR-31 and DPR-41
Subject:
Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit
References:
- 1. Florida Power & Light Company Letter L-2014-216, "License Amendment Request No.
231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit," July 10, 2014.
- 2. Florida Power & Light Company Letter L-2014-226, "License Amendment Request No.
231, Application to Revise Ultimate Heat Sink Temperature Limit - Request for Emergency Approval," July 17, 2014.
- 3. Florida Power & Light Company Letter L-2014-235, "License Amendment Request No.
231, Application to Revise Ultimate Heat Sink Temperature Limit - Supplement 1, and Response to Request for Additional Information" July 22, 2014.
- 4. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393)," July 21, 2014 (BOP).
- 5. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393)," July 25, 2014 (BOP 5.1 and 6, SCVB 3).
In Reference 1, Florida Power & Light Company (FPL) requested an amendment to the Technical Specifications (TS) for the Turkey Point Nuclear Plant (Turkey Point), Units 3 and 4.
The proposed amendment would revise the ultimate heat sink (UHS) water temperature limit from 100F to 104'F. In Reference 2, FPL requested the U.S. Nuclear Regulatory Commission (NRC) to review and approve the application on an emergency basis.
FPL supplemented the Reference I application and provided responses to a related request for additional information (RAI) in Reference 3.
Florida Power & Light Cempany 9760 SW 344"t St., Florida City, FL 33035
Florida Power & Light Company L-2014-237 License Amendment Request No. 231 Response to Request for Additional Information Page 2 of 2 The enclosures to this letter provide the FPL response to Balance of Plant RAIs 1, 2, 3, 4 and 6 (Enclosure 1) contained in References 4 and 5, and Containment and Ventilation Branch RAI-3 (Enclosure 2) contained in Reference 5.
The additional information provided in the enclosure to this letter does not impact the no significant hazards determination and environmental considerations previously provided in Reference 1.
There are no new commitments made in this submission.
If you have any questions or require additional information, please contact Mr. Robert Tomonto at 305-246-7327.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: July 26, 2014.
Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant Enclosures 1) Response to Balance of Plant RAIs 1, 2, 3, 4 and 6
- 2) Response to Containment and Ventilation Branch RAI-3 cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 1 of 24 Response to Request for Additional Information (RAI)
Balance of Plant RAIs 1, 2, 3, 4 and 6 Turkey Point Units 3 and 4 License Amendment Request No. 231 Application to Revise Ultimate Heat Sink Temperature Limit
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 2 of 24
Background
By letter dated July 10, 2014, as supplemented by letters dated July 17, July 22, and July 24, 2014, Florida Power & Light Company (FPL) submitted a license amendment request for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to the Turkey Point Technical Specifications (TSs), Section 3/4.7.4, Ultimate Heat Sink."
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided and determined that it needs additional information to complete the review. The NRC staff's request for additional information (RAI) is contained in References 1 and 2. The FPL response to Balance of Plant (BOP) RAIs 1, 2, 3, 4 and 6 follows. The FPL response to BOP RAI-5 and 5.1 will be provided by separate correspondence.
BOP RAI-1 The licensee stated that the Turkey Point HX3/HX4 computer program determines CCW heat exchanger gain to the ICW system is equal to the heat lost from the CCW system and is also equal performance based on the conservation of energy equations for heat transfer between the ICW and CCW systems, and the performance equation for the heat exchanger. The heat to the heat transferred within the heat exchanger as described by the total surface area, the heat exchanger heat transfer coefficient, and the logarithmic mean temperature difference, LMTD.
The licensee further stated that in order to develop the HX3/HX4 computer program, a design basis case needs to be established. The program requires four inputs to define a design basis case: (1) CCW inlet temperature, (2) CCW outlet temperature, (3) ICW flow rate, and (4) heat load. The design basis case is determined by first finding the most limiting safety analysis case.
Once the most limiting case is found, several iterations are performed on calculating the TR and maximum allowable temperatures. The design basis cases embedded in the program and verification cases are created to verify the CCW heat exchangers, at a minimum, remove the necessary heat for the corresponding safety and cool down scenarios at a given UHS temperature.
A.
What is the peak required heat removal rate for the CCW heat exchangers from all accident analyses? Explain the peak heat removal rate in terms the removal rate per CCW heat exchanger and in terms of combined heat removal rate for the two CCW HX required per TS 3/4.7.2 Limiting Condition for Operation (LCO).
Response
The peak required heat removal rate for the CCW heat exchangers (HX) is 124.4 MBTU/hr. TS 3/4.7.2 requires at least two CCW HX in service, equating to 62.2 MBTU/hr for each heat exchanger as described in UFSAR Table 9.3-1. This scenario corresponds to the post-accident LOCA response yielding the maximum CCW supply temperature.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 3 of 24 B.
Does the HX3/HX4 program determine tube resistance (TR) for each CCW HX, or does it determine a combined TR for the two CCW HX in service? Do the Turkey Point TR limits shown in Figure 3.5-1 of your submittal represent the TR per CCW HX or a combined effective TR for the two CCW HX in service? Explain this response in terms of inputs to the HX3/HX4 program (i.e., is Turkey Point inputting ICW flow and CCW flow to each CCW heat exchanger, or are the inputs for total flow?).
Response
The HX3/iHX4 program determines TR for each individual CCW HX based on individual flow and temperature measurements for each HX. The TR limits shown in Figure 3.5-1 represent the output of the HX3/HX4 program. Compliance with TS SR 4.7.2.a verifies at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that two combined HX exceed the administrative limit shown in Figure 3.5-1.
Basis:
The TR for each of the CCW HX is calculated individually. The surveillance parameters are obtained for each CCW HX (3 per Unit). The TR limit in figure 3.5-1 of the submittal represents the TR per CCW HX. The purpose of figure 3.5-1 was to illustrate how the HX3/HX4 program functions.
The HX3/HX4 computer program utilizes physical input parameters and field measurements from surveillance test, organizes the subroutines, handles the inputs/outputs, and performs the calculation. The first step to use HX3/HX4 program is the selection of the specific unit (Unit 3 or Unit 4) being tested. To assess the individual CCW HX performance, the current surveillance parameters are entered into the program. The HX3/HX4 program equates the heat gain by the ICW system, the heat loss from CCW and then determines the overall heat transfer coefficient,
'U', based on the surveillance heat transfer rate and logarithmic mean temperature difference.
The HX3/HX4 program determines the TR based on the surveillance overall heat transfer coefficient 'U', first principle equations and appropriate film coefficients. Thus the TR calculated by the HX3/HX4 program accounts for why the overall heat transfer coefficient 'U',
determined by the surveillance data does not match the theoretical 'U' from first principles.
This TR is used to determine the maximum allowable ICW temperature that will maintain CCW supply and return temperatures at or below the temperature limits of the design case. The maximum allowable ICW temperature is compared to the current ICW supply temperature to determine whether CCW HX cleaning is necessary. The maximum allowable inlet ICW temperature is based on the design basis case thermal hydraulic conditions and current heat exchanger thermal performance.
The five "known" parameters are the four temperatures (inlet and outlet on both sides of the HX) and the ICW mass flow rate through the tubes (recorded as a volumetric flow rate). The number of plugged tubes is also input and it affects the flow velocity through the tubes and the overall available heat transfer area. In the process of calculating TR, HX3/HX4 is required to
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Enclosure I Page 4 of 24 calculate parameters such as LMTD, CCW flow, heat load and film coefficients. Some of this data is displayed for information purposes in the HX3/HX4 output. This process is illustrated in Figure 1.
Operator Entered Surveillance Data TICE in Tlcw &.
ICW Flow Rate
- of plugged tubes jHX3IHX4 Rev. 2 STube resistance co mputed Design Case Tc =
TCCW Or Heat Load ICW flow HK Configuration Maximum allowable ICW temperature (HX3/HX4 Rev.
2 output)
Figure 1: HX3/HX4 Rev. 2 Program Flow Diagram ICW System:
The ICW system (tube side) is equipped with flow instrumentation downstream of each of the CCW HX. The ICW flow instrumentation will provide a precise tube side (ICW) flow for calculating the HX performance.
CCW System:
The CCW system (shell side) is not equipped with individual flow instrumentation per each CCW HX. The flow instrumentation is located at the discharge header of the CCW HX. As described above, the five "known" parameters are the four temperatures (inlet and outlet on both sides of the HX) and the ICW mass flow rate through the tubes (recorded as a volumetric flow rate). They are surveillance data inputs for the CCW HX fouling evaluation. Therefore, using the ICW flow instrumentation is a conservative approach used in the computer program.
C.
Is the HX3/HX4 Program Line as shown in Figure 3.5-1 of the submittal determined by the peak required heat removal rate provided in RAI-1.A above?
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 5 of 24
Response
Yes. As stated in FPL Letter L-2010-113 dated October 21, 2010, Attachment 4, Table 2.5.4.3-3, analysis performed as part of Extended Power Uprate (EPU) employed two different computer models to analyze CCW heat removal capability and determine the limiting CCW temperatures. The first methodology was a GOTHIC model of the containment response, which included a simplified CCW model. The second was a thermal-hydraulic model using AFT Fathom to further refine the CCW system temperature response. Both methodologies analyzed various post-accident scenarios, including the scenario discussed in RAI-1.A above. The HX3/HX4 design program line was based on the peak required heat removal rate in RAI-L.A from the thermal-hydraulic model because that scenario resulted in the least margin for most temperatures when utilizing HX3/HX4.
Basis:
During the development of the HX3/HX4 program, numerous safety analyses contain CCW and ICW system heat removal requirements. Each case is defined by numerous parameters such as peak heat load, CCW supply temperatures, CCW return temperatures, CCW flow rate and ICW flow rate. A case with restrictive temperature or flow requirements may require a lower TR than the highest peak removal case. The line shown in Figure 3.5-1 is validated by verifying each safety analysis case is bounded by every allowed TR / intake temperature combination.
The case with the peak required heat removal rate is the EPU LOCA Maximum CCW Supply Temperature case from the thermal hydraulic analysis. This case has a heat removal requirement of approximately 62.2 MBTU/hr. For conservatism, an additional margin of 2.6 MBTU/hr was added to this scenario to create the HX3/HX4 design case. This case defines the TR versus ICW temperature line shown in Table 3.5-1. A non-conservative design input was recently identified that the incorrect ICW flow as used in this case (8,325 gpm per heat exchanger). The ICW flow used in the GOTHIC analysis was 9% lower at 7,600 gpm.
Subsequent calculation revisions demonstrated the existing Figure 3.5-1 HX3/HX4 Program Line remained bounding of all scenarios. The heat loads and margins are detailed below. The increase in ICW temperature did result in an increase in maximum CCW supply temperatures.
This had an impact on piping input margins as discussed in BOP RAI-4.C.
Analyses then determined what the GOTHIC and thermal-hydraulic models would have calculated for heat removal and CCW temperatures if the scenarios had been performed at various points along the HX3/HX4 program line. The GOTHIC and thermal-hydraulic models were not re-performed. Instead, the relevant results of each scenario (heat removal, CCW temperatures, ICW temperatures, etc.) were used to recalculate the overall heat transfer coefficient 'U' by replacing the TR assumed in the scenario with the TR along the HX3/HX4 program line for a given temperature. A new overall heat transfer rate was calculated using the HX3/HX4 adjusted 'U', the CCW return temperature from the safety analysis scenario and the
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 6 of 24 ICW supply temperature of interest. This method was repeated for the scenarios of both the GOTHIC and thermal-hydraulic models.
Table 1 compares the heat removal in the safety analyses to the heat removal if the analysis had been performed at 104'F and the corresponding TR as determined by the HX3/HX4 program line. Tables 2 and 3 compare the CCW system supply temperature in the safety analyses to the corresponding temperature as determined by the HX3/HX4 adjusted conditions for Units 3 and 4, respectively. Tables 1, 2 and 3 demonstrate that use of HX3/HX4 at 104'F will ensure that post-accident heat removal capability and CCW supply temperature are maintained.
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Page 7 of 24 Table 1: Unit 3 and 4 Heat Load Comparison Unit 3 Unit 4 CCW HX CCW HX Case Safety Analysis Capability at Safety Analysis Capability at Heat Load ICW Inlet Heat Load ICW Inlet (BTU/hr)
Temp of 1040F (BTU/hr)
Temp of 1040F (BTU/hr)
(BTU/hr)
Max CCW Supply Temp. (LOCA) 62,166,960 66,589,026 62,166,960 66,612,969 Max RHR Outlet Temp. (LOCA) 55,997,280 59,436,085 55,997,280 59,456,644 Max ECC Outlet Temp. (LOCA) 56,795,400 60,402,257 56,795,400 60,423,362 Max ICW Outlet Temp. (LOCA) 41,352,840 45,414,374 41,352,840 45,429,180 Max CCW Return 1 Temp. (LOCA) 59,461,560 62,867,601 59,461,560 62,886,219 Max CCW Return 2 Temp. (LOCA) 55,185,480 58,047,392 55,185,480 58,062,894 Max ECC Outlet Temp. (MSLB) 53,494,920 56,858,573 53,494,920 56,878,873 Max CCW Supply Temp. (LOCA) 62,148,649 64,309,048 62,412,648 64,645,911 Max RHR Outlet Temp. (LOCA) 56,135,893 57,661,376 56,384,681 57,959,058 Max ECC Outlet Temp. (LOCA) 58,481,021 60,241,675 58,740,769 60,549,447 Max CCW Return I Temp. (LOCA) 59,497,942 61,324,599 59,763,600 61,640,364 Max CCW Return 2 Temp. (LOCA) 55,257,362 56,629,335 55,497,938 56,909,752 Max ECC Outlet Temp. (MSLB) 58,890,476 60,735,072 59,136,244 61,029,039
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Page 8 of 24 Table 2: Unit 3 Temperature Comparison CCW Temperatures Gothic HX3/HX4 Rev. 2:
Safety Analysis Til 1040F Case TO2 (OF)
TO, (OF)
TO2 (°F)
TO, (OF)
Max CCW Supply Temp. (LOCA) 158.6 174.6 157.54 174.6 Max RHR Outlet Temp. (LOCA) 152.4 169.5 151.40 169.5 Max ECC Outlet Temp. (LOCA) 153.3 169.9 152.27 169.9 Max ICW Outlet Temp. (LOCA) 145.1 157.1 143.89 157.1 tMax CCW Return Temp. 1 152.1 184.3 150.45 184.3 (LOCA)
MaxCCW Return Temp.2 146.5 185.4 145.30 185.4 Max ECC Outlet Temp. (MSLB) 149.1 164.7 148.13 164.7 CCW Tern eratures Thermal-Hydraulic HX3/HX4 Rev. 2:
Safety Analysis Ti I = 1040F Case To2 (OF)
To, (OF)
T.2 (OF)
To, (°F)
Max CCW Supply Temp. (LOCA) 153.030 168.95 152.55 168.95 Max RHR Outlet Temp. (LOCA) 147.147 164.27 146.77 164.270 Max ECC Outlet Temp. (LOCA) 149.297 166.404 148.87 166.404 Max CCW Return Temp. 1 149.479 168.879 148.99 168.879 (LOCA)
Max CCW Return Temp. 2 144.697 166.882 144.28 166.882 (LOCA)
Max ECC Outlet Temp. (MSLB) 148.160 165.4 147.71 165.400,
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Page 9 of 24 Table 3: Unit 4 Temperature Comparison CCW Temperatures Gothic HX3/HX4 Rev. 2:
Safety Analysis Til = 104'F Case To,. (°F)
To1 (OF)
TO2 (°F)
T., (OF)
Max CCW Supply Temp. (LOCA) 158.6 174.6 157.53 174.6 Max RHR Outlet Temp. (LOCA) 152.4 169.5 151.39 169.5 Max ECC Outlet Temp. (LOCA) 153.3 169.9 152.27 169.9 Max ICW Outlet Temp. (LOCA) 145.1 157.1 143.88 157.1 Max CCW Return Temp. 1 152.1 184.3 150.44 184.3 (LOCA)
Max CCW Return Temp. 2 146.5 185.4 145.29 185.4 (LOCA)
Max ECC Outlet Temp. (MSLB) 149.1 164.7 148.12 164.7 CCW Temperatures Thermal-Hydraulic HX3/HX4 Rev. 2:
Safety Analysis Ti 1 1040F Case TO2 (°F)
To, (OF)
TO2 (OF)
Tol (OF)
Max CCW Supply Temp. (LOCA) 152.760 168.75 152.27 168.75 Max RHR Outlet Temp. (LOCA) 147.380 164.58 146.99 164.580 Max ECC Outlet Temp. (LOCA) 149.540 166.72 149.10 166.720 Max CCW Return Temp. 1 149.730 169.22 149.23 169.220 (LOCA)
I Max CCW Return Temp. 2 144.930 167.21 144.50 167.210 (LOCA)
Max ECC Outlet Temp. (MSLB) 148.390 165.7 147.92 165.700 D.
What is the tolerance, accuracy, or margin-of-error for the TR calculated by Turkey Point's HX3/HX4 program?
Response
No specific tolerance or uncertainty has been determined for the TR calculated by the HX3/HX4 program. Instead, uncertainty of the HX3/HX4 output is applied to the TS SR 4.7.2.a comparison of actual versus maximum allowable canal temperature by use of the administrative limit. Presently, the administrative limit is 3YF less than the HX3/HX4 program line as supported by sensitivity studies of the output of the HX3/HX4 program.
E.
Are the CCW and ICW flow rates used as input to the HX3/HX4 program measured values in the field, or are they calculated values from flow analysis? In either case, what
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 10 of 24 is the tolerance, accuracy, or margin-of-error for the CCW and ICW flow rates that are used?
Response
As stated in response to RAI-1B ICW flow rate is a field-measured value obtained during the surveillance test and CCW flow rate is a value calculated by HX3/HX4 program. ICW flow rate measurement uncertainty is + 1.37 % full scale (15,000 GPM).
F.
For the TR limits shown in Figure 3.5-1, define how many CCW and ICW pumps are running.
Response
As described in BOP RAI-1.C, the HX3/HX4 Rev 2 program line illustrated in Figure 3.5-1 is based on the EPU LOCA Maximum CCW Supply Temperature scenario plus additional margin. This scenario is the safety related scenario with the highest peak heat load. In this scenario two ICW pumps and one CCW pump are operating.
The TR limits shown in Figure 3.5-1 dictate the maximum ICW temperature for a given tube resistance as determined by surveillance. These limits are applicable for any ICW and CCW pump combination during any credible scenario. These limits are validated by verifying each CCW safety analysis case is bounded by every allowed tube resistance / intake temperature combination.
A non-conservative design input was recently identified that the incorrect ICW flow as used in this case (8,325 gpm per HX associated with two ICW pumps operating). The ICW flow used in the GOTHIC analysis was 9% lower at 7,600 gpm (associated with one ICW pump operating). Subsequent calculation revisions demonstrated the existing Figure 3.5-1 HX3/HX4 Program Line remained bounding of all scenarios. The heat loads and margins are detailed in BOP RAI 1.C.
G.
What has been the typical TR immediately after putting a clean CCW heat exchanger in service during this current season for which the licensee is requesting an emergency TS change?
Response
The TR for each HX after cleaning varies between HX based on several factors including the number of tube plugged, the effectiveness of the cleaning, and the impacted unit. Surveillance tests performed on Unit 3 during the months of June and July 2014 have yielded an effective TR
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 11 of 24 immediately after cleaning for the two best HX of 0.002160 hr-fti-°F/BTU. In the same period of time for Unit 4, average TR immediately after cleaning has been 0.001936 hr-ft2-°F/BTU.
For comparison, typical post-EPU results immediately after cleaning through 2013 yield an average TR of 0.001777 hr-ft2i-F/BTU on Unit 3 and 0.001612 hr-ft2-°F/BTU on Unit 4.
H.
Is the HX3/HX4 program a safety-related program, and does it meet the quality assurance requirements of Title 10 of the Code of Federal Regulations, Part 50, Appendix B?
Response
Yes. Nextera Energy fleet procedure IM-AA-101, Software Quality Assurance Program, paragraph 4.0 (and 7.1.3) commits to the following Regulatory Requirements:
A Quality Assurance Topical Report (QATR) commitment for computer software applications is used in applications affecting safety to be compliant with the requirements of NQA-1-1994, Supplement I1 S-2 and Subpart 2.7. For software classified as SQA Level A, the use of "shall" in the statement identifies a requirement to be fulfilled. For all other classification levels, refer to the SRS, SDD, SVVP detail checklists for minimum requirements commensurate with a graded SQA approach.
Paragraph 5.3.1 of IM-AA-101 indicates Level "A" software is defined as Safety Related:
"Software products classified as Level A have a direct effect on the ability of a Safety-Related System, Structure or Component (SSC) to perform its intended function..." Paragraph 5.7.1 of procedure IM-AA-101 indicates that "A site Master Software Index (MSI) shall be maintained to record and control software products that are approved for production use...." The HX3/HX4 software in question is entered in the Nextera/FPL Turkey Point Master Software Index as Level A (for Safety-Related use).
I.
Describe the current Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment," program for the CCW heat exchangers. Explain how the licensee will continue to meet the acceptance criteria or performance monitoring criteria of the program for the increase in UHS to 104'F.
Response
GL 89-13 Test Program:
The only safety-related heat exchangers cooled by service water (ICW) are the Component Cooling Water (CCW) heat exchangers. There are three 50 percent CCW heat exchangers in each Unit. Two heat exchangers are required to be operational with the third being an installed
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 12 of 24 spare. The CCW Heat Exchangers are routinely performance tested at a minimum frequency of once per month, in accordance with Technical Specification 4.7.2. More frequent testing is performed when necessary to ensure that the required heat exchanger performance is met at times when elevated ICW cooling water temperatures occur. Currently, test frequency is once per week due to summer ICW cooling water temperatures.
The performance test results are used to establish the heat transfer capability of each heat exchanger, and the associated fouling condition. A calculation is then performed to determine the maximum allowable ICW temperature at which the heat exchanger could perform the design basis heat transfer function. Historical data shows that the maximum allowable ICW temperature is in the range of 108'F to 112'F, immediately after cleaning, depending on cleaning effectiveness. Since the heat exchangers operate in parallel, in pairs, the maximum allowable ICW temperature for each pair is then calculated, and the calculated maximum temperatures are entered in a chart used for monitoring. The chart projects reduction in maximum temperatures, based on historical observed fouling rates. The most fouled pair of heat exchangers at any given time establishes the upper limit on acceptable ICW operating temperature. This upper limit is further reduced by three degrees F to account for performance test uncertainty. Currently, performance testing is conducted at a weekly frequency (or less),
due to fouling conditions and fouling rates. An example of the performance monitoring chart is shown below.
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Page 13 of 24 UNIT 3 ICW TEMPERATURE (LIMITS) VS DATE I TIME 120.00 110.00 I-XzLU.
Co LA.
0z Coj w
100.00 90.00 80.00 70.00 60.00 DATE / TIME The CCW Heat Exchanger Performance Monitoring Procedure satisfies TS 4.7.2.a requirements by verifying that two CCW Heat Exchangers and one CCW pump are capable of removing the design basis heat load. Plant operators measure the ICW supply temperature to the CCW heat exchangers every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, enter the measured temperature on the chart, and validate that the ICW temperature is less than the upper limit established by testing. When ICW temperature approaches the limit, the most fouled heat exchanger is removed from service and cleaned.
Based on the observed fouling rate, the current frequency of cleaning for each heat exchanger is once every three weeks.
Changes to GL 89-13 Test Program:
No change to the GL 89-13 test program for the CCW heat exchangers is planned.
The proposed change to revise the UHS temperature limit in TS 3/4.7.4, Ultimate Heat Sink, from 100 degrees Fahrenheit ('F) to 104'F, would allow continued plant operation above 1 00'F ICW temperature, provided that the CCW heat exchanger performance limits were not exceeded. To ensure that these limits are not exceeded, the current program will drive the plant to perform more frequent cleaning of the heat exchangers at elevated ICW temperatures.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 14 of 24 J.
Discuss CCW HX tube plugging allowed, how the licensee controls the amount of tubes plugged, and how the licensee programmatically factors that into HX3/HX4.
Response
Component Cooling Water heat exchanger tube plugging is governed by the Intake Cooling Water System Inspection Program as described in UFSAR Chapter 16, Aging Management Programs and Time-Limiting Aging Analyses Activities. Eddy Current Testing (ECT) is performed periodically under the preventive maintenance program and the CCW Heat Exchangers Tube Integrity Inspection Program. ECT is performed on each CCW Heat Exchanger nominally every 18 months on 100% of the tubes. Frequency may be adjusted as necessary based on inspection results and industry experience. The amount of tubes that may be plugged is determined by the thermal performance surveillance test required by TS SR 4.7.2.b(2). Preemptive actions are put in place to replace CCW HX tubes prior to reaching conditions where additional tube plugging would result in unsatisfactory performance test results.
Response to question RAI-1.B above discusses how the number of plugged tubes factors into the HX3/HX4 program.
K.
Does this amendment request affect any other safety-related HX tube plugging allowances? Explain.
Response
No. The Component Cooling Water (CCW) System heat exchangers are the only Safety Related heat exchangers supplied by the UHS. The ICW system also supplies the Non Safety Related Turbine Plant Cooling Water (TPCW) heat exchangers. Other Safety Related heat exchangers, such as the RHR heat exchangers, and Safety Injection pump coolers, as well as the Spent Fuel Pit heat exchangers are cooled by CCW. The request demonstrates that the CCW cooling capacity of these other heat exchangers remains the same. The Emergency Diesel Generators (EDGs) have their own cooling system. Therefore, this request does not affect other safety related HX tube plugging allowances.
L.
Section 9.3 of the Updated Final Safety Analysis Report states, "[Tihe GOTHIC Computer Code, which was used in containment integrity analyses, was also used to conservatively calculate limiting CCW system and ICW system post-accident operating temperatures." Discuss the relationship between the calculation results of Gothic and HX3/HX4 for determining CCW HX performance and limits.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 15 of 24
Response
As stated in Section 9.3 of the UFSAR, the results of GOTHIC analysis were used in conjunction with an AFT Fathom incompressible flow network analysis to determine CCW system piping temperatures during post-accident conditions. Both the GOTHIC and AFT Fathom models were used to develop the design case, and therefore the program line of HX3/HX4, as discussed in response to BOP RAI-1.C.
BOP RAI-2 The licensee stated that in June 2014, UHS temperatures almost approached the currently analyzed maximum temperature of 100°F. Engineering and environmental analyses has determined that the cooling water heat transfer capability is diminished because of the presence of a higher-than-normal algae content. While immediate eradication of the algae is possible, there are biological impacts from a sudden algae die off and decay that must be mitigated and/or avoided. Thus, a controlled chemical treatment of the canal system over the course of several weeks is planned to gradually reduce the near-term algae content and improve heat transfer efficiency.
SR 4.7.2(b) requires CCW HX performance testing at least once per 31 days. However, as described above, cooling water heat transfer capability is diminished because of the presence of a higher-than-normal algae content. Required testing every 31 days seems insufficient with higher than normal algae content.
A.
Explain how often this SR should be performed under current algae conditions and what changes to SR 4.7.2 are needed.
Response
The current SR does not require revision because the heat transfer effects of algae are accounted for in the surveillance test. Existing requirements for SR 4.7.2.a and 4.7.2.b(2) would identify the algae effects.
Basis:
The CCW HX performance test required by SR 4.7.2 assesses the performance of the CCW HX for several key parameters.
- The test records actual flow and temperature data from the field and uses HX3/HX4 to determine the tube resistance of each heat exchanger at the time of the test.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Enclosure I Page 16 of 24
" The HX3/HX4 program determines the maximum allowable canal temperature using the current tube resistance and assuming post-accident conditions (temperature, flow rate and heat transfer).
" The test procedure compares the current maximum allowable canal temperature to the value determined during the previous test to check the rate of fouling degradation between tests. Currently, procedural acceptance criteria requires that time-based fouling does not decrease the maximum allowable canal temperature by more than 0.5°F per day.
" If fouling degradation rate acceptance criteria is not met, then the procedure ensures one of the following 1) significant margin exists to actual temperature (greater than 10 degrees) to accommodate the greater rate of fouling; 2) the test is repeated; or 3) the heat exchanger with the lowest allowable canal temperature is cleaned.
TS SR 4.7.2.a requires that at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that two CCW heat exchangers are capable of removing design basis heat loads. This SR is met by comparing the actual temperature to the maximum allowable canal temperature from the last surveillance test, as degraded per the rate discussed above and offset through the administrative limit.
During the period of elevated algae conditions, the rate of change of maximum allowable canal temperature has not exceeded procedural requirements (i.e. not greater than 0.5°F/day).
Additionally, if the rate of change were to increase greater than current procedural acceptance criteria, the existing TS SR would identify the change and initiate appropriate corrective action.
Therefore, existing TS surveillances are sufficient and no changes to SR 4.7.2 are needed.
B.
How often during this season of higher than normal algae and the time of the request for an emergency TS change has the licensee found it necessary to clean and switch CCW HXs?
Response
Turkey Point normally cleaned one CCW heat exchanger per unit bi-weekly prior to the recent elevated algae conditions during summer months. In conjunction with higher canal water temperature and the lower heat transfer rate, heat exchanger cleanings have increased to one per unit weekly.
C.
Explain how the licensee will account for the diminished heat transfer capability caused by the higher-than-normal algae concentration during the controlled chemical treatment that will last for several weeks.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 17 of 24
Response
The impact of the algae in the CCW heat exchangers is factored in the TR from the CCW heat exchanger performance test.
Basis:
As discussed in response to RAI-1.B, HX3/HX4 attributes all discrepancies between heat transfer coefficient 'U' determine from the surveillance test and the theoretical 'U' based on film coefficients and first principles to the tube resistance TR. As such, effects of the current algae condition are accounted for by HX3/HX4 as increased TR. This is highlighted in the response to RAI-l.G which shows a significant difference between the normal post-EPU TR of a recently cleaned HX and the current seasonal TR of a recently cleaned HX.
D.
Provide a discussion related to any possible negative effects on the plant's safety-related component, structures, and or systems caused by the higher-than-normal algae content.
Response
The cooling canal system supplies water to the Safety Related Intake Cooling Water (ICW)
System and in doing so contacts the inside of the ICW system, and the Safety Related intake and discharge structures. It does not supply other Safety-Related Systems, Structures or Components. The other Safety Related Systems, Structures or Components requiring cooling, such as the Emergency Diesel Generators, have cooling systems independent of the Cooling Canal Water containing the algae. The algae, as well as the activities performed to kill the algae, may have the effect of creating a slime coating on external structures, which is only an appearance concern. Internal to the ICW system, the algae is addressed under the CCW heat exchanger cleanliness and cleaning program. The majority of the piping in the ICW system is cement lined where the algae would not be a concern. Small bore piping in the ICW system is stainless steel, which the algae is not expected to negatively affect. The ICW basket strainers, which are monitored for D/P, may experience a slight increase in the frequency of backwashing required. Instrumentation such as flow elements, PIs, DPIs, etc. are normally connected to the process pipe with 3/8" stainless steel tubing. A minimal amount of silt increase in the sensing lines would be expected as the algae dies. The existing PM program performs periodic cleaning of critical sensing lines due to the seawater process fluid and these are not expected to be negatively affected. The preliminary report on the algae supporting the chemical treatment of the canals notes algae blooms detected in the canals as far back as 2004. The report indicates that the algae may also produce an environment conducive to creating Microbiological Induced Corrosion (MIC). This is countered by the concrete lining of ICW piping and that for the system where the algae is in contact with component steel. MIC on structural portions of the intake and discharge structures would be included in general corrosion and detected by normal
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 18 of 24 system monitoring per the Systems and Structures Monitoring Program described in UFSAR Chapter 16.
BOP RAI-3 The licensee stated that a technical evaluation of the component cooling water system was also performed to determine if emergency containment cooling (ECC) system and containment spray (CS) system performance would be affected by the proposed change in UHS temperature. It was determined that adequate margin (emphasis added) exists in the CCW system such that post-accident CCW system supply and return temperatures would remain as currently analyzed in the containment integrity analyses. This ensures that the peak containment pressure is not altered by the proposed TS change. The technical evaluation confirmed that adequate CCW design margin (emphasis added) would remain under the proposed operating conditions to allow a reasonable degree of equipment degradation to occur while demonstrating that the affected safety-related components on the accident unit could continuously perform their design function as currently analyzed.
A.
Describe the post-accident CCW supply and return temperature profiles as determined in Turkey Point's current Maximum Hypothetical Accident (MHA; loss-of-coolant accident (LOCA) and main steam line break (MSLB)) analysis when the UHS (ICW) is at 100 'F and in the MHA for the UHS (ICW) at 104 'F. Identify all differences between the two analyses including changes or additions in design inputs, assumptions, methodology, and conclusions.
Response
The response to this question is provided in the response to SCVB RAI-1.B contained in FPL letter L-2014-236 dated July 24, 2014.
B.
Provide additional discussion related to the "adequate margin exists" terminology throughout the amendment request (for example, but not limited too), as it applies to pump net positive suction head). Please provide numerical values and specifically address those statements (for example, "the existing margin was 'x' and the new margin is now 'y' ").
Response
The request discusses margin in multiple locations when addressing various parameters that are evaluated at the elevated canal conditions. Each parameter is discussed below.
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Enclosure I Page 19 of 24 Heat removal and CCW temperature The response to BOP-1.C contains the specific margins for the analysis of HX3/HX4 compared to the GOTHIC and Fathom models of the CCW System.
Pump Net Positive Suction Head (NPSH)
CCW System:
The limiting Component Cooling Water pump NPSH conditions are evaluated in UFSAR Section 9.3 and corresponds to post-accident conditions when maximum CCW return temperature is 182.5°F. As discussed in response to RAI BOP-1.C above, the analysis in support of this request does not increase post-accident CCW temperatures. Therefore, there is no change to CCW pump NPSH.
ICW System The impact of the increased ICW inlet temperature was evaluated for the ICW pumps regarding available Net Positive Suction Head (NPSHa) and flow. The limiting condition of ICW Pump NPSHa is a Loss of Offsite Power (LOOP), with a single failure of an Emergency Diesel Generator and the remaining EDG operating at a maximum overfrequency condition. The change in the NPSHa from 100°F to 104'F under these conditions is approximately -0.5% and is considered negligible. The ICW pump manufacturer has concurred with the assessment that the effect of increased temperature for the limiting NPSH scenario is acceptable.
Additionally, sensitivity runs for both Units have also shown that increasing the ICW inlet temperature working fluid from 100°F to 104'F for accident cases and LOOP scenarios produces results that have less than a 0.01% decrease in pump outputs. The tables below show the results of the sensitivity runs for both Units.
Results from Sensitivity Run Cases 11 100 16,062 15,424 0
6,601 6,178 7,046 6,050 5,308 33.8 11 104 16,062 15,423 0
6,601 6,178 7,046 6,050 5,308 33.61 A%/o 0.000
-0.006 0.000 0.000 0.000 0.000 0.000
-0.562 20 100 0
20,711 0
4,543 4,271 5,122 3,431 3,343 36.72 20 104 0
20,711 0
4,543 4,271 5,122 3,431 3,343 36.53 A% 1 0.000 0.000 0.000 0.000 0.000 0.000
-0.517 Note: All flows in GPM
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Page 20 of 24 1 j 1100 16,073 16,004 0
6,281 6,039 6,244 6,385 6,932 33.63 1 lj 104 16,072 16,003 0
6,280 6,039 6,243 6,385 6,931 33.44 A
-0.006
-0.006
-0.016 0.000
-0.016 0.000
-0.014
-0.565 15j 100 0
0 20867 4,104 3,916 4,070 4,451 4,325 36.55 15j 104 0
0 20866 4,104 3,916 4,070 4,451 4,325 36.35 A%
-0.005 0.000 0.000 0.000 0.000 0.000
-0.547 Note: All flows in GPM This minor change in pump output negligible. Therefore, the ICW pumps are considered acceptable with 104'F inlet process fluid temperature.
BOP RAI-4 The licensee stated that the proposed TS change increases the maximum allowable (measured)
ICW system supply temperature from 1 00°F to 104'F. This change does not alter any assumptions on which the plant safety analysis is based. The affected components were originally designed with margin that allows for cooling water temperatures greater than the plant design basis of 1 00'F, although no credit had previously been taken for this margin. A review of ICW system components between the ICW pumps and the CCW and turbine plant cooling water (TPCW) HXs was performed for the increased UHS analytical temperature of 104'F. The specified design temperature for many of the components is 1000F, which corresponds to the current UHS TS temperature limit. However, a review of information specific to the affected components indicates that all ICW components between the pump and the heat exchangers are rated for service temperatures well in excess of 1 00'F. A review of ICW pump materials indicates that the projected 4'F increase in process fluid would have an insignificant effect on the materials in contact with the fluid, including thermal expansion and material temperature service rating.
A.
Provide additional discussion related to the specified design temperature of the ICW system. Specifically, provide a discussion that includes that an increased temperature review was performed on associated pumps seals, piping supports, spring cans, and pipe snubbers.
Response
The ICW pumps are not equipped with mechanical seals. A bushing and packing material provide the seal for the pumps. Braided carbon packing with a maximum rated temperature of 600'F is used on all of the ICW pumps and is not challenged by the increased UHS temperature.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 21 of 24 The limiting component is the packing box bearing which is rated for 140'F. However, an administrative limit of 11 5°F is maintained for the packing gland temperature.
The temperatures that the piping from each of the ICW pumps to the inlet and discharge of the CCW Heat Exchanges (HXs) are detailed in Calculation PTN-BFJM-96-004. Based on the calculation, the temperatures on the inlet and discharge of the shell side of the CCW HXs which service the CCW system remain unchanged. Temperatures on the inlet and discharge of the CCW tubes rise from 100°F and I 16°F to 104'F and 122.2°F respectively from that assessed as the operating conditions as part of the 2012 Extended Power Uprate (EPU). Accordingly, since there are no changes to the CCW piping from the CCW HXs, only the ICW piping and associated supports will be evaluated herein.
An analysis of the effects of EPU on the operating and design temperatures, pressures and flow rates of piping in the ICW system was performed under Calculation PTN-3SHC-09-7016. As stated in the calculation, numerical thermal pipe stress calculations were not performed based on low operating temperatures experienced. The calculation also made reference to the 1995 Uprate Evaluation which had similar conclusions.
In the 1995 uprate campaign, there were numerous calculations and evaluations used to determine the impact of the increased temperatures on various pipe support components as well as nozzle loads which have been summarized under PTN Calculation 05006-NP-005. In that calculation, the maximum temperature evaluated on the discharge of the CCW Heat Exchangers was 125°F. Therefore, the proposed temperature increase under PTN-BFJM-96-004 remains bounded by the analysis performed in support of the 1995 Uprate.
Given that there is no change to the maximum temperature evaluated, it is concluded that a thermal analysis not required. Therefore, the subject piping system including its various piping supports remain adequate with respect to the thermal effects of the temperature increase. It is noted that there are no spring cans or snubbers on the sections of piping that pass from the ICW pumps to the inlet of the CCW HXs and from the CCW discharge to the discharge canal.
B.
Provide additional justification relating to an increase in UHS/ICW temperature to non-safety-related components and systems that could lead to a reactor trip or cause flooding from components that are cooled by UHS/ICW.
Response
Review of the Turbine Plant Cooling Water (TPCW) heat exchangers (ref. Dwg 5610-M-146),
indicates that the design temperature for materials is 150F. Operating procedures 3/4-NOP-008 provide guidance for adjusting TPCW flows and if necessary, reducing reactive power and Generator load if the TPCW header temperatures remain above 103'F to protect the Generator from thermal transients and minimize TPCW related alarms, while balancing the need to
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 22 of 24 minimize Generator H2 leakage. TPCW header temperature alarms at 11 0°F. However, this condition would not directly or indirectly result in a reactor trip or cause flooding from the TPCW heat exchangers.
The effect on canal temperature for the condenser is a decrease in vacuum (increase in absolute pressure) based on the ability of the circulating water (CW) to remove heat. This is affected by the CW temperature and the efficiency of the condenser. Unit 4 data was used to calculate the Condenser Cleanliness Factor (CPF) and to predict a Condenser Pressure for a CW inlet temperature of 104'F. Since Unit 3 condenser bundles were recently cleaned the Unit 4 calculated CPF and the Unit 4 expected Condenser Pressure with a CW water inlet temperature of 1040F will bound Unit 3. Based on actual plant data the resulting cleanliness factor was calculated to be 56.48%. The expected Condenser Pressure at a CW temperature of 104'F and a CPF of 56.48% was calculated to be 5.856 in-HgA or 24.114 in-Hg Vacuum (all other factors remaining stable). The condenser vacuum of 24.114 in-Hg Vacuum exceeds an alarm setpoint but is not at the trip setpoint (22 in-Hg Vacuum at 100% power). Procedures 3/4-NOP-010 provide guidance for plant operation in regard to condenser vacuum.
A sensitivity case was run to determine a CPF value that would cause the Condenser Pressure to increase to its trip set point if the intake canal temperature reaches 104'F while at 100% power).
It was determined that the Condenser would have to be operating with a CPF of 37% with the existing condenser operating configuration in order to reach the turbine trip set point of 22 in-HG Vacuum.
Precipitation of suspended solids from ICW water in BOP SSCs is proportional to a number of variables associated with the canal water, including temperature. Precipitation of solids from ICW water is proportional to the water temperature and during an increase in ICW temperature from 100'F to 1040F, the precipition rate would be expected to remain proportional.
BOP RAI-5 The response to BOP RAI-5 will be provided in separate correspondence.
BOP RAI-6 What is the maximum allowed cooling water temperature (in this case, component cooling water for Turkey Point) supplied to the residual heat removal, safety injection, containment spray, and chemical volume control systems' pumps and motors (if applicable) for continuous/accident operation? This information should come from vendor-supplied documentation.
Florida Power & Light Company L-2014-237 Response to BOP Request for Additional Information Page 23 of 24
Response
Except for short surveillance and maintenance runs, the Residual Heat Removal (RHR) pumps, Containment Spray (CS) pumps and the Safety Injection Pumps are not normally in continuous operation during plant operation at full power. One of the 3 charging pumps is normally in service for inventory/pressure control during plant operation at full power. The charging pumps are not credited for accident conditions.
The Chemical Volume Control System (CVCS) pumps have hydraulic coupling oil coolers that are cooled by CCW. The maximum heat load of one hydraulic coupler occurs when the CVCS pump is operating at the minimum speed (i.e. 80% slip = 307,945 Btu/hr per vendor information). All three CVCS pumps (for each unit) are supplied by a common CCW header to and from the coolers. Per 3/4-OP-047, CCW flow for all three pumps, although only one is normally running, is procedurally controlled at 150-165 gpm. Maximum oil temperature allowed per vendor information is 2200F. Recent operator rounds indicate that both Unit 3 and 4 hydraulic coupling oil temperatures are below 125 0F. Therefore there is sufficient margin in the CCW cooling of the Charging Pump hydraulic coupling oil.
The RHR pump motors are not cooled by Component Cooling Water (CCW). The RHR Pump mechanical seals are cooled by CCW through mechanical seal coolers with process fluid on the tube side and CCW water on the shell side. Per Drawing 5610-M-450-96, Sheet 1, CCW is to be available at 145°F initially, decreasing to 1250F in 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
The CS Pump mechanical seal is cooled by CCW through a mechanical seal cooler. The maximum operating temperature for the Containment Spray Pump mechanical seal is 205'F.
Per the vendor data sheets for the mechanical seals on the Unit 4 CS pumps, 3 gpm of flow at 150OF is needed for the CS pump seal coolers. Though the Unit 3 mechanical seals are of a different design, the heat load for the CCW system is relatively small, approximately 150,000 BTU/hr (Unit 4 seals are approximately 50,000 BTU/hr). The CCW flow to the CS pumps is procedurally controlled at 12 gpm to 17.5 gpm for Unit 3 and 12 gpm to 16 gpm for Unit 4.
The HHSI pumps use CCW for cooling the bearing lubricating oil housing and mechanical seals. CCW circulates through the HHSI pump mechanical seal and the (thrust) bearing Lube oil coolers continuously during normal and accident conditions. The pump vendor (Flowserve) used a CCW temperature of 165°F to evaluate the seal and the lube oil cooling capability.
Flowserve concluded that the maximum seal chamber and bearing oil housing temperature could reach as high as 193.7 'F and 215 'F, respectively. There is no adverse impact on the HHSI mechanical seals. However, the bearing oil was replaced by a high temperature synthetic oil as a part of EPU changes, and the minimum CCW flow rate to each pump was raised from 5.8 GPM to 7.0 GPM.
Florida Power & Light Company Response to BOP Request for Additional Information L-2014-237 Page 24 of 24 References
- 1. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393)," July 21, 2014 (BOP).
- 2. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), " Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393)," July 25, 2014 (BOP 5.1 and 6, SCVB 3).
Florida Power & Light Company L-2014-237 Response to SCVB Request for Additional Information Page 1 of 2 Response to Request for Additional Information (RAI)
Containment and Ventilation Branch RAI-3 Turkey Point Units 3 and 4 License Amendment Request No. 231 Application to Revise Ultimate Heat Sink Temperature Limit
Florida Power & Light Company L-2014-237 Response to SCVB Request for Additional Information Page 2 of 2
Background
By letter dated July 10, 2014, as supplemented by letters dated July 17, July 22, and July 24, 2014, Florida Power & Light Company (FPL) submitted a license amendment request for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to the Turkey Point Technical Specifications (TSs), Section 3/4.7.4, Ultimate Heat Sink."
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided and determined that it needs additional information to complete the review. The NRC staff s request for additional information (RAI) is contained in Reference 1. The FPL response to Containment and Ventilation Branch (SCVB) RAI-3 follows.
SCVB RAI-3 Please confirm whether the licensee has received information from Westinghouse in 2014 regarding errors in mass and energy release calculations that may be applicable to Turkey Point.
If Turkey Point has received this information, please describe any impact that it may have on the responses to the SCVB RAIs provided in the licensee's letter dated July 24, 2014 (L-2014-236).
FPL Response FPL has received information from Westinghouse regarding errors in the LOCA mass and energy release calculations that is applicable to the Turkey Point units. Turkey Point specific sensitivity calculations performed by Westinghouse demonstrated that the impact on Turkey Point analyses is not significant and well within the impact presented in NSAL-14-2. This conclusion equally applies to the responses provided to the SCVB RAIs in FPL letter L-2014-236 dated July 24, 2014.
Reference
- 1. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393)," July 25, 2014 (BOP 5.1 and 6, SCVB 3).