Text

Response to NRC Request for Additional Information Regarding the Responses to GL 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
	ML090920410
Person / Time
Site:	Turkey Point
Issue date:	03/19/2009
From:	Jefferson W; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-04-002, L-2009-063, TAC MC4725
	Download: ML090920410 (71)
	v • d • e

FPL MAR 1:9 2009 L-2009-063 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Florida Power & Light Company Turkey Point Unit 3 Docket No. 50-250

Subject:

Response to NRC Request for Additional Information Regarding the Responses to GL 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors,"

TAC NO. MC 4725

References:

(1) Letter from B. L. Mozafari (U. S. Nuclear Regulatory Commission) to J. A.

Stall (FPL), "Turkey Point Nuclear Plant, Unit 3 - Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Sump Recirculation During Design Basis Accidents at Pressurized-Water Reactors, Request for Additional Information" December 22, 2008 (TAC NO. MC4725)

(2) Letter L-2008-033 from William Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris, Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated February 28, 2008 (ML080710429)

(3) Letter L-2008-138 from William Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated June 30, 2008 (ML081960386)

(4) Generic Letter 2004-02, "Potential Impact 'of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004 This submittal provides the Florida Power and Light Company (FPL) responses to the U. S. Nuclear Regulatory Commission (NRC) request for additional information (Reference 1) regarding our Supplemental Information provided previously (References 2 and 3) on the subject of the NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors" (Reference 4).

an FPL Group company

Turkey Point Unit 3, Docket No. 50-250 L-2009-063, Page 2 of 3 provides the Turkey Point Nuclear Plant, Unit 3 responses to the request for additional information. The supplemental information previously provided, in References 2 and 3, continues to apply. This information is being provided in accordance with 10 CFR 50.54(f).

As part of this response, there was one commitment made, as follows:

1. FPL will analyze a sodium tetraborate sample to ensure its suitability and will periodically re-sample. FPL will proceduralize this requirement.

Letter'L-2008-226 from William Jefferson, Jr. (FPL) to U.S. Nuclear Regulatory Commission "Request for Extension of Completion Date of the Turkey Point Unit 3 Generic Letter 2004-02 Actions," dated October 31, 2008 provided a target completion date for a milestone to evaluate that Turkey Point Unit 4 testing, bounds the Unit 3 strainer system. This evaluation will be complete on or before May 31, 2009.

Please contact Mr. Robert Tomonto at (305) 246-7327, if you have any questions regarding this response.

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

Executed on March __, 2009.

Sincerely yours, William Jfei'son, JK Site Vice President Turkey Point Nuclear Plant

Attachment:

(1)

Turkey Point Unit 3, Docket No. 50-250 L-2009-063, Page 3 of 3 cc: NRC Regional Administrator, Region I1 USNRC Project Manager, Turkey Point Nuclear Plant Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 1 of 68

.Attachmerit-1 Responses to NRC's Request for Additional Information on FPL's Turkey Point Nuclear Plant Unit 3 (PTN3)

GL 204-02-Supplementat-Responses-dated--February 28, 2008 and June 30, 2008 Introduction Overview of Turkey Point Unit 3 Conservatisms:

In FPL's Turkey Point Unit 3 Supplemental response of June 30, 2008, FPL summarized some of the actions and analyses that provided conservatism and margin to Turkey Point Unit 3 compliance with GL 2004-02. These included:

The new sump strainer system installed in Turkey Point Unit 3 in the fall of 2007 is a General Electric design with a surface area of approximately 5,500 ft2 with 3/32-inch perforations to retain debris. The new strainers replaced the previous sump screens which had a combined total surface area of approximately 63ft_2 with a.4-inch screen mesh.

Debris head loss testing was performed for a variety of surface areas. Although testing demonstrated that acceptable debris head losses could be obtained for 3,256 ft2 , FPL installed approximately 5,500 ft 2 for additional margin.

0 A uniform factor of 1.1 has been applied to the Zone of Influence (ZOI) radius to ensure the calculation was conservative.

0 100% of the Calcium Silicate.(cal-sil).generated.is.assumed..to.transport to the strainers.

100% of unqualified coatings, regardless of types and location inside containment, were assumed to fail as particulates and transport to the screen. EPRI and industry testing indicates some unqualified coatings do not fail and some coatings fail as chips and may not transport to the sump.

0 The near-field effect was not credited in the debris head loss testing. The steps taken to minimize near-field effects in the tests included placing the flow return near the bottom of the test tank to helpsuspend debris; and usingrmotor driven agitators to ensure that debris remained suspended. This maximizes the amount of debris on the screen and will provide very conservative results.

0 The design basis strainer flow rates are 2,697 gpm for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and then 3,750 gpm at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ... 3,750 gpm, .which represents the maximum flow, was utilized from initiation in the debris head loss testing.

The following response to NRC's Requests for Additional Information (RAI's) provides another opportunity to discuss in more detaiil; TUrkey PoinitlJnit"3 analyses and conservatisms. This should facilitate NRC's review and conclusion that Turkey Point Unit 3 design and analyses are conservative, and demonstrate that there is sufficient ECCS NPSH margin available as required by GL 2004-02.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 2 of 68 RESPONSE TO NRC RAIs Contained in NRC's December 22, 2008 Letter.

RAI-1: Please provide clarification of whether the containment spray system (CSS) is required to operate in recirculation mode for a secondary system high energy line break (HELB). If the CSS is required to operate in recirculation mode following a secondary system HELB, please describe your evaluation of this event including the performance of the new sump strainer.

RAI-1 RESPONSE: As asked by NRC in an earlier RAI 34, February 8, 2006 [B.T. Moroney, NRC Project Manager Plant Licensing Branch 11-2, to J. A. Stall, FPL "Turkey Point, Units 3 and 4, Request for Additional Information RE: Response to Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design-Basis Accidents at Pressurized-Water Reactors" (TAC NOS. MC4725 and MC4726)", Dated February 8, 2006],

and answered in the Turkey Point Unit 3 June 30, 2008 supplemental response to GL 2004-02, , page 7 of 89 [L-2008-138, W. Jefferson Jr., FPL, to U.S. NRC, "Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors", Dated June 30, 2008], the ECCS, which includes the containment spray system, is not required to operate in the recirculation mode following a secondary system high energy line break.

RAI-2: Please provide your evaluation that establishes that breaks at or near the reactor nozzle will not result in a more limiting debris generation condition than the breaks presented in the supplemental response. Please describe the insulating material(s) for the reactor vessel.

RAI-2 RESPONSE: Turkey Point Unit 3 determined break locations in accordance with Section 3.3.4 of NEI 04-07 and Regulatory Guide 1.82. The analyzed locations were:

" Breaks in the reactor coolant system (e.g., hot leg, crossover leg, cold leg, pressurizer surge line), main steam, and main feedwater lines with the largest amount of potential debris within the postulated ZOI

Large breaks with two or more different types of debris, including the breaks with the most variety of debris, within the expected ZOI

Breaks in areas with the most direct path to the sump

Medium and large breaks with the largest potential particulate debris to insulation ratio by weight, and

Breaks that generate an amount of fibrous debris that, after its transport to the sump screen, could form a uniform thin bed that could subsequently filter sufficient particulate debris to create a relatively high head loss referred to as the 'thin-bed effect.' The minimum thickness of fibrous debris needed to form a thin bed has typically been estimated at 1/8 inch thick based on the nominal insulation density.

All RCS piping and attached energized piping was evaluated.

From these break location considerations, the limiting break that resulted in the bounding debris generation was S1. The drawing below depicts the S1 break and the associated shadowed area.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 3 of 68

. Te. ,a - "

Figure 2-1 S1 Break and Shadowed Area As provided in the Turkey Point Unit 3/4 UFSAR, the reactor vessel insulation is of the reflective type, supported from the nozzles and consisting of inner and outer sheets of stainless steel spaced 3 inches apart. The Reactor Vessel Head Permanent insulation (i.e., within the IHA -

Integrated Head Assembly) for Unit 3 & 4 consists of self supporting panels, constructed of reflective metallic insulation (RMI), that are attached to one another with stainless steel buckles.

RAI-3: Please provide information that illustrates how the debris that would be generated from a pressurizer surge line break was considered in the break selection process, or verify that the only target material for a surge line break is reflective metal insulation (RMI).

RAI-3 RESPONSE: As summarized in the Turkey Point Unit 3, June 30, 2008, submittal [L-2008-138, W. Jefferson Jr., FPL, to U.S. NRC, "Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors", Dated June 30, 2008]:

1. Four sections of the pressurizer surge line containing Cal-Sil and one section containing Nukon were replaced with RMI,

2. Cal-Sil insulation and jacketing on the pressurizer relief tank was removed and replaced with a post-LOCA qualified coating, and

3. The reactor coolant pump insulation was replaced with RMI.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 4 of 68 Given these modifications and the fact that the reactor coolant loop piping is RMI, a postulated pressurizer surge line break would primarily target RMI insulation systems.

Turkey Point Unit 3 followed the deterministic approach; the surge line break was not a selected limiting break.

Break locations were determined in accordance with Section 3.3.4 of NEI 04-07 and Regulatory Guide 1.82. For Turkey Point Unit 3 the analyzed locations were:

Breaks in the reactor coolant system (e.g., hot leg, crossover leg, cold leg, pressurizer surge line), main steam, and main feedwater lines with the largest amount of potential.

debris within the postulated ZOI

Large breaks with two or more different types of debris, including the breaks with the most variety of debris, within the expected ZOI

" Breaks in areas with the most direct path to the sump

Medium and large breaks with the largest potential particulate debris to insulation ratio by weight, and

Breaks that generate an amount of fibrous debris that, after its transport to the sump screen, could form a uniform thin bed that could subsequently filter sufficient particulate debris to create a relatively high head loss referred to as the 'thin-bed effect.' The minimum thickness of fibrous debris needed to form a thin bed has typically been estimated at 1/8 inch thick based on the nominal insulation density.

All RCS piping and attached energized piping is evaluated.

From these break location considerations, the limiting break that resulted in the bounding debris generation was S1. Figure 2-1 on the previous page depicts the S1 break and the associated shadowed area.

RAI4: Please provide information that justifies ignoring the potential fibrous debris generation from break locations not considered in the break selection process. It is possible that fibrous debris outside of the currently selected break zone of influence (ZOls), when combined with relatively small amount of Cal-Sil (calcium silicate) debris, could result in a more limiting debris load on the strainer. It is a staff position that a fiber bed much less than 1/8 inch in thickness, when combined with microporous or particulate insulation debris, could result in significant head losses (see Enclosure 1 of ADAMS Accession No. ML080230112)

RAI-4 RESPONSE: The Turkey Point Unit 3 break selection process followed industry and NRC agreed deterministic processes for maximizing in-containment post break releases of fibrous insulation, Cal-Sil, and other potential debris. This process was used for decision making regarding i) the removal of insulation fiber, Cal-Sil, etc., that could be a target of pipe breaks inside the secondary shield wall and ii) to size the strainers for Turkey Point Unit 3. The deterministic process for Turkey Point Unit 3 maximizes fiber, debris, etc., and, coupled with chemical effects, represents the worst case that can challenge the new sump strainers when recirculation is required. No further information can be provided since the deterministic break selection process was followed on Turkey Point Unit 3.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 5 of 68 Turkey Point Unit 3 strainer testing and plant modification of insulation systems inside the secondary shield wall break locations was conducted in accordance with the current established processes. As provided in the June 30, 2008, submittal, based on the deterministic break selection process, and changes to insulation systems, Turkey Point Unit 3 is a very low fiber plant. As an example, Table 3.b-1 in Attachment 1 to the Turkey Point Unit 3, June 30, 2008, supplemental submittal, shows that there is no fiber impacted by the S1, S2, S3, and S5 breaks, other than latent fiber. Following the Turkey Point Unit 3 changes to the insulation systems inside the secondary shield wall, there is very little fiber remaining. The only fiber insulation systems inside the secondary shield wall are on 3", 4", and 6" piping at the top of the pressurizer. The Pressurizer is located on the level above the reactor coolant piping and is enclosed by a concrete vault. Below the Pressurizer vault is a steel skirt that effectively precludes any significant LOCA energy from entering the vault or from any potential debris exiting the vault. Further, because the elevation of the top of the pressurizer is high above reactor coolant system piping, selected breaks do not target this material, hence it would not be expected to impact sump screens. A summary of the remaining fiber at the top of the pressurizer includes:

Table 4-1 Top of Pressurizer Piping that Contains Nukon Insulation - Only Fiber Insulation Remaining Inside the Secondary Shield Wall Length and Volume of Length and Volume of Length and Volume of Nukon on 3" Piping Nukon on 4" Piping Nukon on 6" Piping 11.6 ft 2.8 ft4 45.9 ft 13.0 ft3 5.1 ft 3.2ft Hence, the only fiber that is expected at the sump screens for Turkey Point Unit 3 is from latent sources. As provided in the June 30, 2008 submittal, this results in a latent fiber source of approximately 15% of 77.2 pounds. Note that the 15% is conservative since there is minimal fiber insulation in containment to start with. Using 2.4 pounds per cubic foot results in approximately 4.8 cubic feet of fiber. If it is assumed that all of this source goes to the screens and spreads equally, this results in a 0.0104 inch thickness. It is FPL's engineering judgment that a bed thickness this thin, even when "combined with microporous or particulate insulation debris" would not result in higher head loses than those observed in the Turkey Point Unit 3 test programs.

RAI-5: Please provide the materials and construction of the jacketing systems for the insulation within the ZOls for the selected breaks. Please provide the type of debris expected to be generated if the jacketing systems are damaged. Please provide information that justifies that the jacketing material itself will not contribute to strainer head loss, or that head loss effects of the jacketing material have been appropriately considered.

RAI-5 RESPONSE: The jacketing system for the piping insulation within the ZOls for the selected break is metal fastened by rivets. The walkdown performed to quantify the insulation did not specify whether the jacketing was stainless steel or aluminum. Based on a walkdown on Unit 4, which is comparable to Unit 3, both stainless steel and aluminum jacketing systems for insulation are used in containment. If insulation is replaced, stainless steel jacketing meeting ASTM A-1 77 type 301, 302, or 304, 0.020" to 0.024" thick, is used.

All Cal-Sil and Nukon insulation is jacketed. The zone of influence for the jacketing is assumed

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 6 of 68 to be the zone of influence for the underlying insulation. The debris generated is, therefore, the underlying insulation in the zone of influence. The only Nukon in the zone of influence was removed. The only insulation under the jacketing within the ZOIs is, therefore, Cal-Sil or Microtherm, which is installed on the bottom head of the steam generators. The quantity for Microtherm is relatively small, 2.28 ft3 .

The velocities required to lift materials over a curb (lift velocity) are provided in NUREG/CR-6808. The lift velocities over a 2" curb are 0.3 ft/sec for aluminum RMI and 0.84 ft/sec for stainless steel RMI. The velocity under the strainer is approximately 0.1 ft/sec, and the velocity entering the strainer disks is approximately 0.02 ft/sec. These velocities are well below the velocity required to lift RMI above a 2-inch curb, and the bottom of the disks are approximately 5 inches above the floor. The aluminum and stainless steel jacketing are heavier gauge than the RMII approximately 20 mils versus 2.4 mils. Therefore, the jacketing will not transport.

RAI-6: The debris characteristics discussion in the supplemental response dated June 30, 2008, did not provide a debris size distribution for Cal-Sil and Microtherm debris, as was requested in the NRC's Revised Content Guide. Provide the assumed debris size distribution and characteristic size for Cal-Sil and Microtherm debris generated during a loss-of-coolant accident (LOCA) so that the staff can verify the prototypicality of the debris used for head loss testing. Also, specifically identify the quantity of individual fines assumed to be generated for each of these types of debris for comparison to the debris used for head loss testing. Provide a technical basis for any assumptions made that are not consistent with approved guidance in the Nuclear Regulatory Commission (NRC) staff's approved safety evaluation (SE) on NEI [Nuclear Energy Institute] 04-07.

RAI-6 RESPONSE: As stated in our supplemental response and discussed in the staff's SE of NEI 04-07, the categories in any size distribution are related to the transport model. For the purposes of determining the strainer debris load and head loss at Turkey Point Unit 3, a single integrated transport model was not used. Instead, each debris type was addressed separately.

These debris specific transport analyses did not use the size distribution as part of the input.

Therefore, detailed size distributions were not required or developed for the determination of the strainer debris load or head loss. That is, all of the maximum Cal-Sil and Microtherm insulation generated were assumed to transport.

The size distribution of generated debris is a function of the insulating material and whether it lies within the ZOI. The table below provides a summary of the assumed debris type and size.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 7 of 68 Table 6-1 Debris Size Distribution - Inside Debris Source Material (Type) the ZOI Small Fines Large Pieces CalSil Insulation (Particulates) 100% --

Microtherm 100%

Size Distribution of Debris from Inside the ZOI The strainer vendor test specification required the test vendor to purchase Thermo 12 CalSil insulation from Industrial Insulation Group (11G) to be used during the head loss testing. A density of 14.5 Ib/ ft3 is used for CalSil, based on NEI 04-07.

It also required purchase of microtherm insulation, to be used during the head loss testing. A density of 12 Ib/ft3 is used for microtherm, based on NEI 04-07.

The Turkey Point Unit 3 maximum microtherm insulation generated is very small and on the order of 2.3 cu ft. Cal-Sil maximum insulation generated is 56.18 cu. ft. 100% of this material was scaled by area and used for testing.

Thermo 12 Gold calcium silicate made by Industrial Insulation Group and supplied by Insulation Materials Corporation was used. The calcium silicate was mechanically pulverized and sifted through a 0.1" by 0.1" screen, following procedures based on NEDO-32686-A, October 1998.

The material was visually inspected.

Microtherm purchased from Microtherm, Inc. was used in these tests. The insulation was mechanically broken up into a powder and sifted through an approximately 0.1" x 0.1" screen following procedures based on NEDO-32686-A, October 1998. The material was visually inspected.

The fiber and particulate debris was pre-soaked in water and pre-mixed (wet slurry) before it was added to the mixing pool. This debris was added to the tank uniformly over the top surface of the water.

References to Small fines and Large pieces correspond to those categories as listed in Table 3-3 of the NRC NEI 04-07 Safety Evaluation.

As can be seen from the tables, 100% of calcium silicate and microtherm is analyzed and tested as small fines by the procedures described since all debris generated is assumed to transport.

Therefore, the technical basis for debris characteristics assumptions are consistent with approved guidance in the NRC staffs approved safety evaluation on NEI 04-07.

RAI-7: On page 37, the June 30, 2008, supplemental response indicates that debris size distributions were assumed for Nukon and RMI in the downstream effects evaluations. Provide

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 8 of 68 these assumed debris size distributions. Specifically, for each type of debris, provide the percentage of debris assumed in each debris size category, and the characteristic size for each debris type, and provide a technical basis for these values.

RAI-7 RESPONSE: A calculation was performed to determine the debris concentration and depletion coefficients of particulates and fibrous material that could be ingested into the Emergency Core Cooling System (ECCS) and Containment Spray System (CSS). The debris concentration and depletion values serve as inputs to the component wear evaluations downstream of the strainers. This calculation was used to support the work related to the GSI-191 Downstream Effects for FPL at the Turkey Point Unit 3.

This calculation utilized the following debris breakdown:

Table 7-1 Debris Size (Fines, Small, Large and Intact) and Erosion Rate Debris Debris Debris Type Breakdown Size % Breakdown % Erosion Rate %

Nukon Fines 8% N/A Nukon Small 25% 10%

Nukon Large 32% 10%

Nukon Intact 35% 0%

Transco/Mirror RMI Fines* 75% N/A Transco/Mirror RMI Intact (Large) 25% 0%

For RMI, fines are pieces smaller than 4" squares, consisting of small fines X" and less and small pieces greater than 1/4" and smaller than 4" squares. Intact pieces are pieces 4" and larger. The calculation further broke down the quantities of fines to determine the quantity that was small enough to pass the strainers holes.

Fibrous Insulation Debris Size Categorization (Prior to Erosion)

The size of fibrous debris (Nukon) was divided into four categories based on transport properties so that the transport of each type could be analyzed independently. The four categories presented in NEI 04-07, Appendix VI, Table VI-1 are shown in the following table:

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 9 of 68 Table 7-2 Fibrous Debris Sizes Size Description Airborne Behavior Waterborne Behavior Readily moves with Individual fibers airflows and slow to Easily remains suspended Fines or small groups settle out of air, even in water - even relatively of fibers after completion of quiescent water blowdown Readily moves with Readily sinks in along and transports hot water the Pieces of debris depressurization air floor when flow velocities Small Piece that easily pass flows and tends to and pool turbulence are Pieces through gratings settle out when sufficientubject to lowsufficient.

airfows Subject to subsequent erosion.

swith Readily sinks in hot water, Pieces of debris Transportsi and can transport along the Large that do not easily depressurization floor when flow velocities Pieces pass flows but generally is and pool turbulence are through gratings flows bu grallygs sufficient. Subject to stopped by gratings subsequent erosion.

Readily sinks in hot water, Transports with and can transport along the dynamic floor when flow velocities Damaged but depressurization and pool turbulence are Intact relatively intact flows but is stopped sufficient. Still encased in pillows by gratings; may its cover, thereby not attached to remainpiping iscvr hrb o subject to subsequent erosion.

The 8.22 cu. ft. of Nukon previously generated in calculations has now been removed from containment. However, for downstream effects analysis, Nukon and Latent Fiber were retained for conservatism in the analysis.

The quantity of fines that will transport and pass through the screens is based on Alion Test Report ALION-REP-FPL-4196-03. This report states that small and large Nukon fiberglass insulation in the small and large categories has a 10% erosion rate over the mission time and intact fibrous debris is not subject to erosion. Thus, the quantity of fiber from Table 7-1 that will reach the screens as fines is 8%, plus 10% of the 25%, and 10% of the 32%, of the total quantity generated. All of the latent fiber was considered to be fines that will reach the screen.

No credit was taken for fiber debris suspended in inactive pools. In the absence of strainer bypass fractions, all fiber fines are conservatively assumed to initially bypass the strainers.

RMI Insulation Debris Size Categorization Reflective Mirror Insulation (RMI) thickness typically ranges between 2 to 2.4 mils (mil =

1/1 0 0 0 th inch). This calculation conservatively assumed a maximum of 2.4 mils thickness for all RMI.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 10 of 68 The debris size distribution for RMI debris endorsed by the NRC SER for NEI 04-07 is broken into only two categories, small fines and large pieces. The NEI 04-07 proposed distribution for RMI debris is 75% small fines and 25% large pieces. Table 3-3 of the SER for NEI 04-07 confirms this distribution.

Based on a review of the guidance documents, it is possible to further refine the debris size distribution of RMI as 5% small fines (1/4-inch squares or smaller), 70% small pieces (larger than

%-inch squares but smaller than 4-inch squares) and 25% large pieces (4-inch squares and larger)

To be conservative it was assumed that anything smaller than 1.1 times the screen size will pass through the screen. The quantity of RMI that would penetrate the screens was then calculated and then used in subsequent downstream effects analysis.

RAI-8: Given that at Turkey Point Unit 3 there appears to be no margin between the walkdown latent debris value and the input value to the transport/head loss analysis, describe the statistical methodology used to compute the sample mass used in the estimates of total latent debris mass. Provide the accuracy of the individual sample mass measurements and the influence of the uncertainty in the samples on the total calculated mass of latent debris. In responding to this question, please state any assumptions made or conservatisms taken during the analysis.

RAI-8 RESPONSE:

Statistical methodoloqy The calculation of latent debris derived a conservative estimate of the total mass of latent debris that could be generated inside the Turkey Point Unit 3 containment based on the postulated events set forth in GSI-191. The derivation is based on the observation and measurement of dust and lint inside the containment. A containment walkdown was performed to collect latent debris samples from the plant surfaces listed in Table 8.1 below. As stated within Section 3.5.2.2 of the NRC Safety Evaluation Report for NEI 04-07, "Pressurized Water Reactor Sump Performance Evaluation Methodology", Volume 2, Revision 0, December 6, 2004, a minimum of three (3) samples of each surface type is required. However, to conservatively increase statistical sampling accuracy and to provide redundancy for discrepant samples, a minimum of four (4) samples were collected from each surface type. Note, that five (5) samples were collected from horizontal concrete surfaces (floors) and horizontal cable trays.

A total of fifty (50) samples were collected.

Table 8.1 Plant surface Types Horizontal concrete surfaces (floors)

Vertical concrete surfaces (walls)

Grated surfaces at support beams Containment liner (vertical)

Cable trays (vertical)

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 11 of 68 Cable trays (horizontal)

Horizontal equipment surfaces (heat exchangers, air coolers, etc.)

Vertical equipment surfaces (steam generators, air coolers, pressurizer, etc.)

Horizontal HVAC duct surfaces Vertical HVAC duct surfaces Horizontal piping surfaces Vertical piping surfaces (pipes running vertically)

In probability and statistics, the t-distribution or Student's t-distribution is a probability distribution function used for conservatively estimating the mean of a normally distributed population when the sample size is by necessity small compared to the population size. The t-distribution methodology successfully solves the mathematical problems associated with inference based on small samples where the calculated mean (Xm) and calculated standard deviation (s) may by chance deviate from the actual mean and actual standard deviation (i.e.,

what you would measure if you had many more data items - a larger number of samples). As a result, the t-distribution statistical approach is best suited for conservative derivation of the amount of latent debris that has accumulated in the containment.

An upper tailed t-distribution value of 1.638 for a 90% confidence level was selected and used for statistical evaluation of each containment surface type containing four (4) samples. An upper tailed t-distribution value of 1.533 for a 90% confidence level was selected and used for statistical evaluation of each containment surface type containing five (5) samples. Selection of the 90% confidence level upper tailed t-distribution values cited above is technically robust and appropriate for this application based on the walkdown team's inspection and observation that each containment surface type appeared to have a normal distribution of dirt and lint.

Additionally, each sample location was randomly selected by the inspection team.

The debris sample data was analyzed to estimate the total latent debris mass. The samples were grouped by surface type (i.e., vertical equipment, horizontal cable tray, etc.). These represent random samples (n) of the total population of areas. The sample mean (Xm) and the sample standard deviation (s) were determined for the debris mass found per unit area.

Xm Yxi / n s2 [ 1 / (n-1) * [ " xi2 - ( xi) 2 /n]

Where: Xm is the mean for a group of samples (gm/ft 2) xi is the individual mass per area (gm/ft )

n is the number of samples in the group s is the sample standard deviation Assuming the latent debris (dust and lint) is normally distributed as indicated by observation, and the number of samples is small relative to the total population, an upper limit on the mean debris loading (uu1 ) is determined from the t-distribution. Use of the 90% confidence level means there is a 90% probability that the actual meaný latent debris loading (u) is less than or equal to uUu*

1/2 -1/2 xm- tul

s * (n) (u(xm+tul *s*(n)

Uu1 ZXrm + t., * [ s * (n)-'/ 2 ]

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 12 of 68 Where: t, 1 is the upper-tailed t-distribution value at 90% confidence for sample size n uu, is the upper limit on the mean debris loading at 90% confidence (gm/ft2)

To estimate the total debris mass for a surface type, uu, is multiplied by the total area for that surface type. The total latent debris mass is then the sum of the derived values for each surface type.

Sample Mass Measurement Accuracy The walkdown plan specified that a scale with an accuracy of at least 0.1 grams was to be used to measure the mass of each latent debris sample. The actual scale accuracy was determined to be 0.0003 grams.

Influence of the Uncertainty in the Samples Masslin cloths were used to obtain the latent debris samples. Plastic bags were used to store the Masslin cloths with each latent debris sample. Prior to the walkdown, the mass of each plastic bag with the Masslin cloth inside was measured. Following the walkdown, the mass of each sample (plastic bag with Masslin cloth and latent debris) was measured utilizing the same scale that was used for the pre-walkdown measurements. Each latent debris sample mass was obtained by taking the difference between the post-walkdown and pre-walkdown sample masses.

The uncertainty associated with the difference of two values is equal to the sum of the uncertainty associated with each value. The minimum latent debris sample mass was 0.12 grams. Based on a scale accuracy of 0.0003 grams, the maximum data uncertainty is estimated to be 0.5%. The average data uncertainty is estimated to be 0.1%.

RAI-9: Please provide a more detailed discussion of the technical basis for the total area of tapes, stickers, etc. beyond just the values used in the calculation of strainer sacrificial area, including any assumptions that would reduce the quantity of material transported to the sump screen.

RAI-9 RESPONSE: A containment walkdown was performed to identify and measure plant labels, stickers, tape, tags, and other debris in accordance with the guidelines in the walkdown plan. Equipment tags located in containment will become debris, unless they are located outside the Zone of Influence (ZOI) of the postulated pipe break and are qualified for the post LOCA environment. Therefore, post LOCA qualified equipment tags located outside the ZOI (attached by wire, threaded fastener, rivets or qualified tie wraps) are not counted as debris.

Accessible containment areas were examined during the walkdown. Stickers, labels and other debris were quantified, measured and recorded on the Foreign Material Record Sheets. All miscellaneous or non-recurring items were captured individually. Several types of labels and stickers were found consistently on certain plant structures and equipment throughout containment and were measured. The total number of light bulbs in containment lighting was established by drawings, specifications or equipment lists as applicable.

It was observed that many items, such as junction boxes, conduits, and cable trays were

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 13 of 68 marked with paint rather than a label or sticker and therefore will not create any foreign debris.

Other items such as post LOCA qualified conduit labels (metal tags attached by metal wire or qualified tie-wraps) will not become debris following a GSI-191 pipe break unless they are located in the ZOI. The specific items that could potentially become foreign debris are discussed below.

Light Bulbs Lighting is located throughout containment and consists of a light bulb and a metal fixture that is a half-sphere opening toward the floor. The light bulbs are standard size and were modeled as a 3" diameter x 5" high cylinder. The metal fixtures will not be affected by containment spray or elevated containment pressure and will not become transportable debris due to a pipe break.

Light bulbs can potentially break and become debris during post LOCA conditions due to the increased pressure inside containment. The total number of light bulbs and fixtures was determined from lighting drawings. The drawings indicate a maximum of one hundred forty five (145) light bulbs in containment. In addition, floodlights are located inside containment at Elevation 58'-0" and have a flat glass surface. This surface was modeled as an 8" diameter circle. There is a maximum of twenty nine (29) floodlights inside containment. Note that only a couple of containment lighting fixtures had the protective glass covering surrounding the light bulb installed. Therefore, it was conservatively assumed that all light bulbs will become debris during LOCA conditions.

Adhesive Adhesive residue was found at numerous locations throughout the plant. Based on walkdown observations and discussion with plant personnel, a significant number of various signs have been removed inside containment with adhesive residue remaining behind in many areas. The adhesive is usually very thin and 1/32" was used as the adhesive thickness to determine the total volume of adhesive. Note that adhesive was counted, measured and recorded in different locations in all containment elevations. It was conservatively assumed that all adhesive will become debris during LOCA conditions.

Equipment Tags Equipment inside Turkey Point Unit 3 containment is labeled with a 4" x 2.25" hard plastic tag.

The tags are attached to equipment by metal wire or blue tie wraps. Equipment tags attached by metal wire will not become debris outside the ZOI. In addition, the blue tie wraps in Turkey Point Unit 3 containment are qualified for post-LOCA conditions. Therefore, equipment tags attached by blue tie-wraps also will not become debris outside the ZOI. Equipment tags that are within the ZOI will become debris during a LOCA. As a result, equipment tags were counted in the ZOI of one loop (Loop C) and in the affected portions of the adjacent loop (Loop B) to determine the total number of equipment tags that would become debris during a LOCA.

A total of approximately forty (40) tags were counted in each area. For conservatism, fifty (50) equipment tags was used as the total number of tags that will become debris inside the ZOI during a LOCA.

Conduit Tape Green conduit tape is applied to electrical conduits throughout containment. The tape is 1"

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 14 of 68 wide and wraps around the circumference of the conduit. A 2" diameter conduit was assumed for calculating the area of the tape. The tape is applied arbitrarily and is found on only a fraction of the conduits. The application frequency of the tape was difficult to determine; therefore, the total amount of conduit tape in containment was conservatively estimated based on a sampling performed on one elevation. Two separate one-eighth (1/8) sections of the 30'-

6" containment elevation were inspected by walkdown and the total amount of tape was counted.

There were approximately 15 to 20 pieces of tape in each 1/8 containment elevation section that was inspected. Therefore, twenty (20) pieces of tape per section was assumed for containment elevations 14'-0" and 30'-0" and 10 pieces of tape was assumed for each 1/8 containment section at elevation 58'-0" which yields 160 pieces of conduit tape for each of the two lower containment elevations and 80 pieces of tape for elevation 58'-0". This conservative estimate yields a total of 400 pieces of tape in the containment. This assumption is reasonable and conservative because there is much less conduit installed at the 58'-0" elevation. In addition, much of the conduit is 1" diameter, and therefore, would yield a smaller amount of tape than the 2" conduit diameter used to calculate a total tape area. It is assumed that all conduit tape will become debris during LOCA conditions.

Miscellaneous Various miscellaneous items that will become debris during a postulated LOCA were identified throughout containment. These items were individually counted and measured during the walkdown and were entered into the foreign debris surface area determination. This debris category includes items such as blue and red tape, duct tape, and various plastic labels and tags. that are not attached with approved tie wraps or steel wire.

Results Based on the walkdown results, containment foreign material debris totals were tabulated.

These materials are assumed to become available for transport to the containment sump during a postulated LOCA. A 10% margin was added to the label, sticker, tape, placards, and other miscellaneous debris total to account for areas of containment that were inaccessible during the walkdown due to high dose rate or ongoing work activities.

No assumptions were made that would reduce the quantity of material transported to the sump screen.

RAI-10: The June 30, 2008, supplemental response assumed 0% paint chip transport, but does not provide adequate basis to substantiate this assumption. Please provide the following information to justify this assumption:

RAI-10a: An explanation of how the transport calculation accounts for the washdown of paint chips into the outer annulus near the strainer. A curb lift velocity metric does not apply for paint chips that wash down from upper elevations onto or near the strainer.

RAI-10a RESPONSE: The transport analysis did not consider paint chips washing down from

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 15 of 68 upper elevations in close vicinity to the strainers such that they will collect on the strainers before settling. Rather than account for paint chips that would not transport, 100% of the debris in the form of coatings was assumed to transport to the strainers in the form of particulate. This is consistent with NEI 04-07, Volume 1, Table 3-3 and the associated discussion. It is stated that the particle sizes shown in the table are conservative with respective to head loss. This position is endorsed by the staff position in NEI 04-07, Volume 2. Also, 100% of the calculated amount of foreign debris, 93 sq. ft., was deducted from the strainer area. The foreign material includes labels, tags, glass, etc. The density of nearly all of these materials is greater than water and they would not transport. These conservative positions would offset the amount of paint chips that could potentially reach the strainers.

RAI-10b: The velocities quoted in the supplemental response for the regions beneath the strainers and between strainer disks appear to be average velocities. However, local velocities typically vary significantly from these average values and can be much higher near the suction of the ECCS piping and along flow channels in the sump pool where much of the flow from the spray or break moves toward the strainers. Please explain how local variations in the flow velocity have been accounted for.

RAI-10b RESPONSE: The 2" curb lift velocity for paint chips is 0.50 ft./sec. The velocity under the strainers is approximately 0.103 ft./sec. The strainers sit approximately 5" above the floor.

There is significant margin, approximately a factor of five, to account for flow variations.

RAI-10c: A justification that the paint chips at Turkey Point Unit 3 are physically similar to the paint chips for which the test results in NUREG/CR-6808 were derived.

RAI-10c RESPONSE: NUREG/CR-6808 investigated the transport characteristics of and provided test results for epoxy based paint chips from 1/8" square to 11/2" x 1". Turkey Point Unit 3 has epoxy and inorganic based coatings in containment. NEI 04-07, Table 3-3, shows the material densities of typical coatings. Epoxy based chips have a density of 94 lb/ft3 . Inorganic zinc based paint has a density of 457 lb/ft3 . With respect to density it is conservative to base debris transport on the lighter material. The size distribution for which the test results in NUREG/CR-6808 were derived is broad and was accepted as representative for Turkey Point.

At Turkey Point Unit 3 100% of the debris in the form of coatings was assumed to transport to the strainers in the form of particulate. This is consistent with NEI 04-07, Volume 1, Table 3-3 and the associated discussion. It is stated that the particle sizes shown in the table are conservative with respect to head loss. This position is endorsed by the staff position in NEI 04-07, Volume 2.

RAI-10d: Given the information in Table 3.e-1 in the supplemental response, the unqualified coatings debris transport fraction appears to be 1 because the quantity transported is equal to the quantity generated. In light of this information, please clarify how the conclusion that paint chips are non-transportable is applied in the transport calculation.

RAI-1 Od RESPONSE: At Turkey Point Unit 3 100% of the debris in the form of coatings was assumed to transport to the strainers in the form of particulate. This assumption is conservative relative to the amount of coatings that reach the strainer. This is consistent with NEI 04-07, Volume 1, Table 3-3 and the associated discussion. It is stated that the particle sizes shown in

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 16 of 68 the table are conservative with respective to head loss. This position is endorsed by the staff position in NEI 04-07, Volume 2. The quantity of coatings that were determined by the debris generation calculation was not reduced by any assumption for a quantity that would be in the form of paint chips.

RAI-1 1: The extrapolation of test results to different conditions is discussed in the supplemental response. The supplemental response states that the sector test head loss was scaled to the full-sized strainer system based on velocity and bed thicknesses. State all other extrapolations or scaling that was performed for the head loss evaluation (e.g., temperature and mission time).

Provide the methodology for all scaling including the inputs and assumptions used.

RAI-11 RESPONSE: A MathCAD model was used to scale module test data for plant application to the Turkey Point Unit 3 ECCS suction strainer design. This calculation determined the scaled strainer head loss.

Debris quantities and flow rates are scaled based on the ratio of test module perforated area to plant strainer perforated area. The purpose of this scaling is to ensure the test debris bed composition and perforated test velocity matches the plant conditions. The plant perforated area was reduced by 5% for conservatism, to account for any area lost during installation, and by 93 ft2 for the foreign materials.

Parametermoduie = Parameterplant x Areaperforated.module / (0.95 x Areaperforated.plant - Areascarrciai)

Parameter = Flow Rate (gpm) or Debris Quantity (mass)

Area = Surface Area (ft2) (after accounting for foreign materials)

The test data used as inputs for the scaling calculation is from the CDI module head loss testing data report for Test PTN3-M-0.01 1T-1 OOCS-PC-2.556P-C1, C2.

Table 11-1 Test Results Matrix Flow Clean Max Flow Time2 Final Final Final Final Test Rate1 Head Head Rate @ Head Flow 2 Water Loss Loss @ Max Max Loss Rate Time Temp (gpm) ("H20) (" H20) (gpm) (min) (gpm) ( H20) (mn) (oF)

PTN3-M-0.011T-loocS- 258.0 0.1 10.2 260 542 8.8 259 767 60 PC-2.556P-C2 PTN3-M-O.C11T-5OOCS- 185.5 0.0 9.6 186 1197 8.3 186 1260 59 PC-2.556P-C1 ___ _ _ _ _ _ _ ____ _ _ _ _ _ _ ____ _ _ _ ___

Note 1: Specified flow rate Note 2: Test duration was measured from data acquisition start, not from debris addition The purpose of the calculation is to determine the head loss of the Turkey Point Unit 3 ECCS strainers during a loss of coolant accident (LOCA) based on test results and applied correction factors. Test strainer head loss is scaled based on velocity, and bed thickness differences.

Debris head loss and clean strainer head loss are scaled independently.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 17 of 68 Assumptions:

1. Debris bed thickness does not exceed 1/2 of the strainer interplate distance during sector testing, so the entire perforated plate area of the plant strainer is used for velocity and bed thickness calculations.

2. Turbulent flow exists within the debris bed. This scaling methodology is applicable to turbulent bed flow only.

3. Equal flow distribution is assumed on all plant strainers.

For strainer internals, the following relationship is used:

Head Loss

Head Loss j.4 (Flow Rate pjp, 1I Flow Rate

Turbulent flow is assumed, and the test and plant disks are hydraulically similar, allowing for use of the hi = f(Q 2) relationship.

The relationship used for scaling of the debris bed loss is the following:

hil = Vx-L*_ih Ax 1_LP_2 Debris Loss Equation hi 2 Vx P2' Ax 2 ' P1 where (1) represents the plant conditions, and (2) represents the test conditions. This relationship is described by this equation and is fundamental to the sizing methodology used in the calculation.

hi is the head loss, vx is the velocity in the x direction, Ax is the debris bed thickness, p is the fluid viscosity, p is the density.

However, the test results show that the headloss plot is erratic due to borehole formation, which causes turbulent flow through the perforated plate. Since the flow is turbulent the test headloss cannot be scaled with temperature. The debris loss equation must be modified to eliminate the temperature dependent factors of viscosity and water density. In the resulting equation the test headloss is multiplied by the ratio of plant velocity to test velocity, and also multiplied by the ratio of plant debris thickness to test debris thickness, to provide a test headloss that is representative of the plant conditions Testing did not continue for the entire mission time. A termination criteria was applied after reaching the maximum head loss which was determined by monitoring the head loss trend during testing. After reaching the maximum head loss, the module tests were terminated when there was no upward trend >1% for 30 minutes (sudden increases or decreases were neglected).

The scaling calculations considered instrument inaccuracies for pressure drop, flow, measured mass of debris, and temperature. In each case the instrument inaccuracy was taken in the most conservative direction. Since viscosity was not used in the equation the instrument inaccuracy for temperature had no effect. The instrument inaccuracy for pressure drop had a significant effect on strainer head loss. Measured clean strainer head losses for scaled flows of 2697 gpm and 3750 gpm were 0" and 0.1", respectively. An instrument inaccuracy of 1" was

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 18 of 68 added to each of these. Therefore, the clean strainer head losses were almost entirely because of accounting for instrument inaccuracy.

RAI-12: Please provide the clean strainer head loss (CSHL) methodology. Include information that shows the CSHL is independent of debris build up on the strainer, or provide justification that the CSHL calculation was conservative or prototypical.

RAI-12 RESPONSE: The clean strainer head loss is composed of the sum of tested clean strainer disk loss, calculated plenum and connecting piping losses and the original calculated ECCS/CS piping losses.

Table 12-1 below shows the results of the actual disk testing performed without debris and chemical effects. Clean head loss was measured for each of the test flow rates independent of and prior to the addition of debris. The test was performed using a 15 disk strainer module with flow scaled according to the actual area of the strainer installed with conservative assumptions.

The size of the plant strainer was reduced by 93 sq.ft. to account for tags, labels, etc. that could potentially block the strainer. The size was reduced another 5% for conservatism.

The following table summarizes clean strainer test data from the test report.

Table 12-1 Flow Specified Measured Clean Final Flow Final Water Test Flow Strainer Head Loss Temperature 3750 gpm 258.0 gpm 0.1" 259 gpm 60°F 2697 gpm 185.5 gpm 0.0" 186 gpm 59 0 F Another calculation related to test scaling added instrument accuracy (1 inch) to the measured clean head loss. The values from Table 12-2, 0.090 feet for Case 2 and 0.083 feet for Case 1, include instrument accuracy and are selected for use in the clean system head loss calculation.

This potentially represents more than 1000% margin to the measured clean strainer head losses. Thus, the clean strainer disk head loss is composed almost entirely of instrument accuracy allowance.

Table 12-2 Flow Adjusted Clean Strainer Calculated Plenum and Head Loss Piping Head Loss 3750 gpm 0.090' 2.28' 2697 gpm 0.083' 1.18' The Turkey Point Unit 3 ECCS strainers are connected via a piping network that will cause a flow unbalance; i.e., strainers closest to the sump will have a greater flow rate than strainers furthest from the sump. A calculation was developed to determine the piping head loss and the flow distribution. Using a conservative approach, uniform strainer flow was assumed to determine the piping head loss values. The use of clean strainer head loss values based on uniform flow is conservative because they are higher than the non-uniform flow clean strainer head loss values.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 19 of 68 The piping head loss with a clean strainer is 2.28 feet for Case 2 and 1.18 feet for Case 1. The total clean system head loss for Case 2 is 2.370 feet and for Case 1 is 1.263 feet. It is noted that the piping head loss with clean strainers is smaller than the piping head loss with fouled strainers; this is because unbalanced flow (with the majority of flow entering the strainers nearest the sump) can be modeled with clean strainers, and that flow unbalance leads to lower piping head loss.

The flow through the strainer internals is assumed to be turbulent, due to the abrupt direction changes and abrupt expansions from the strainer discs to plenum. The clean strainer head loss is scaled using 2

Head loss clean = Head loss Test.clean X (FlowRate PlantDisk / FlowRate TestDisk)

Where:

Headloss clean = plant strainer clean head loss Headloss Test.Clean = test strainer clean head loss FlowRate PlantDisk = plant disk flow rate FlowRate TestDisk= the test flow rate Previously existing ECCS/CS piping losses are reported in a Westinghouse Pegysis calculation, for the two flow cases. The head losses were adjusted for flow rates in the NPSH analysis.

To summarize, the clean strainer head loss is conservative for the following reasons:

The clean strainer head loss includes the maximum instrument uncertainty, which accounts for nearly all of the final value.

The clean strainer head loss was added to the debris only head loss when the debris only head loss was measured from outside the strainers to the strainer plenum.

By adding the clean strainer head loss to the debris only head loss, it also became subject to the chemical bump up factor.

The use of head loss values based on uniform strainer flow is conservative because they are higher than the non-uniform flow head loss numbers.

RAI-13: It was implied that the debris was added to the sector test prior to starting the recirculation pump. Provide details on the test sequence and also provide justification that adding debris prior to starting the recirculation pump would result in prototypical or conservative head loss values during the test.

RAI-13 RESPONSE: The photograph below shows the test facility used. It will aid in understanding the RAI response. The eight motors shown in the photograph are for the agitators. Also, a schematic of the test facility is shown.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 20 of 68 Photograph of test facility I;. t~aw'~iz'z~ ~Agitator l 441 Tank Schematic of sector test facility. Agitators are shown.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 21 of 68 The test sequence was as follows:

The data acquisition system was initiated. The data acquisition system was used to record head loss, flow rate, and temperature data at approximately one sample every two seconds until test termination.

The recirculation pump was started. The flow rate was set by adjusting the flow control valve in the discharge. The flow rate was adjusted as needed throughout the test to maintain the specified flow rate.

" Clean head loss was measured for each of the test flow rates.

" The water surface was observed for vortexing or other signs of air ingestion.

The recirculation pump was shut down.

Water was removed from the tank and added to the particulate debris.

The agitators were turned on and then each debris type in slurry form was added to the tank.

When the debris was well mixed in the tank the recirculation pump flow was re-initialized. The flow re-initialization time was recorded.

Head loss and flow rate data were recorded manually at intervals of approximately five minutes.

Water temperature was recorded manually at intervals of no more than fifteen minutes.

After the recirculation pump was started, wet fiber was added to the tank based on the schedule shown in Table 13-1.

Table 13-1 Interval Time - Minutes Fiber Addition Lbs (g) 0 Pump start with particulate 1 40 0.0717 (32.55) 2 45 0.0717 (32.55) 3 50 0.0717 (32.55) 4 55 0.0717 (32.55) 5 60 0.0717 (32.55) 6 65 0.0717 (32.55) 7 70 0.0717 (32.55) 8 75 0.0717 (32.55) 9 80 0.0717 (32.55) 10 85 0.0717 (32.55) 11 90 0.0717 (32.55)

Flow was set to 258 gpm. 258 gpm is the scaled flow representing a plant flow of 3750 gpm.

The initial flow, 258 gpm, met the termination criteria as discussed in RAI 16 and the test was terminated 767 minutes from the start of the test.

" Flow was set to 185.5 gpm. 185.5 gpm is the scaled flow representing a plant flow of 2697 gpm.

The second flow, 185.5 gpm, met the termination criteria as discussed in RAI 16 and the test was terminated 1260 minutes from the start of the test.

The test results are shown in Table 13-2 below. Also, curves from the data acquisition system are shown.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 22 of 68 Table 13-2 Tact Po,,Ite IKA. afriv Flow Clean Max Flow Time2 Final Final Final Final Rate 1 @ Head Flow e2 Water Test Head Loss Head Loss @Rate Max Max Loss Rate Tim Temp (gpm) (" H20) ("H20) (gpm) (min) (gpm) ("H20) (min) (oF)

PTN3-M-0.011T-100CS- 258.0 0.1 10.2 260 542 8.8 259 767 60 PC-2.556P-C2 PTN3-M-0.OIIT-100CS- 185.5 0.0 9.6 186 1197 8.3 186 1260 59 PC-2.556P-C1 Note 1: Specified flow rate Note 2: Test duration was measured from data acquisition start, not from debris addition Note that the actual maximum head loss reading occurs prior to test termination. Figure 13-1 showing head loss versus time is presented below to make this clearer.

Figure 13-1 PTN3-M-O.011T-100CS-PC-2.556P Head Loss vs. Time 12 10-0 X* 8. Pump

.J 0

IIII 0 200 400 600 800 1000 1200 1400 Time (main)

The test results are considered conservative based on the following:

Maintaining the maximum amount of debris in suspension prior to starting the recirculation pump ensures that debris which would normally settle is still in the recirculation flow stream and is, therefore, capable of transit to the sump screens.

The test termination criterion ensured that the maximum amount of debris had the opportunity to collect on the test module and create the maximum head loss.

The value for head loss used in subsequent calculations for NPSH and flashing was based on the maximum value observed rather than the one minute average.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 23 of 68 RAI-14: Please provide documentation for the testing methodology including:

RAI-14a: debris introduction sequences (debris type and size distribution) including time between additions RAI-14a RESPONSE: Turkey Point 3 performed prototype sector testing of the GE Modular Stacked Disc Strainer at the Continuum Dynamics Inc. (CDI) test facility without chemical surrogates to develop the non-chemical debris head losses. Additionally, Alion Science and technology performed plant-specific chemical effects testing at the VUEZ test facility. Debris introduction sequences, type and size distribution including addition time are described below for both prototype and chemical effects testing.

Prototype Testing at Continuum Dynamics Inc.

Debris type Fiber Transco Thermal Wrap was used to simulate Nukon fibrous insulation and latent fiber. It was shredded by the manufacturer in accordance with procedures, and then shredded 5 more times by CDI in a leaf shredder to produce smaller shreds and more individual fibers. The material was visually inspected.

Calcium Silicate Thermo 12 Gold calcium silicate was used. The calcium silicate was mechanically pulverized and sifted through a 0.1 inch by 0.1 inch screen. The material was visually inspected.

Silicon Carbide Black Silicon Carbide was used to represent epoxy phenolic qualified and non-qualified coatings and latent particulate debris. ElectroCarb black silicon carbide size 800 was used in the tests. The particles had an average diameter of approximately 10 microns as measured by the manufacturer using a Helios particle size analyzer. The material was visually inspected.

Inorgqanic Zinc (IOZ)

Carboline Zinc filler was used to simulate the qualified IOZ coatings. The material was visually inspected.

Microtherm Microtherm was used in these tests. The insulation was mechanically broken up into a powder and sifted through an approximately 0.1 inch x 0.1 inch screen. The material was visually inspected.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 24 of 68 Debris Introduction The debris was mixed into a slurry prior to its introduction into the test tank / pool. The particulate slurry was added to the tank/pool and thoroughly mixed to minimize settling and maintain a uniform distribution of particles. After mixing the particulate the test was initiated by starting the pumps.

After starting the pumps with all the particulate debris in the tank, fibrous insulation was introduced into the tank/pool. The fiber was added to the tank/pool in a manner to simulate the initial concentration of fiber in the plant pool at the start of recirculation. The fiber was introduced into the test over a period of time, which corresponds to the time required for the plant fiber concentration to decrease by approximately 80% based on an assumed exponential function.

The fiber was divided into equal amounts and added to the test. The amount of fiber introduced into the test tank at each interval was approximately equal to the concentration of fiber in the plant at the start of recirculation. The time and the interval are provided in Table 14.a-1 below.

Table 14.a-1 Latent Fiber Debris Addition Schedule Time Interval Time Interval (m) (min)(min) 0 6 65 1 40 7 70 2 45 8 75 3 50 9 80 4 55 10 85 5 60 11 90 Chemical Effects Testing at Vuez Debris Type The containment materials included in the test are divided into the three categories that correspond exactly to where the materials will lie within the test tank: submerged, un-submerged, and on the sump screen. Each category is scaled according to either the pool volume ratio or the screen area ratio of the plant versus the test apparatus based on the transport characteristics or location of the debris within the containment. Table 14.a-2 provides the materials types and quantities included in the test.

The debris bed composition and thickness selected for the VUEZ chemical effects testing is based on the range of plant specific debris loads and size characteristics determined in the plant-specific debris generation, transport, head loss analysis and prototype testing. Based on the results of the plant specific debris generation and transport analysis, the expected characteristics on the sump screen contain all 3 sizes of fibrous debris: fines, small pieces (< 6 inch on a side), and large pieces (> 6 inch on a side). While prototype testing uses a debris mixture that includes both fines and small pieces, the VUEZ size distribution selected is

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 25 of 68 primarily represented by Class numbers (No.) 1 through 5 in Table 3-2 and Figure 3-3 of NUREG/CR-6808. This ensures that the characteristic size of debris is small compared to the characteristic size of the VUEZ screen.

Table 3-2 Size Classification Scheme for Fibrous DebrisZ No. Description 1 Very small pieces of fiberglass material; "microscopic fines that appear to be cylinders of&varng LID.

2 Single, flexible strands of fiberglass; essentially acts as a suspending strand.

3 Multiple attached or interwoven strands that exhibit considerable flexibility and that, because of random orientations induced by turbulent drag, can extibit low settling velocities.

4 - - Fiber clusters that have more rigidity than Class 3 debris and that react to drag forces as a semi-rigid body.

S Clumps of fibrous debris that have been noted to sink when saturated with water. Generated by different menods by various researchers but easily created by manual shredding of fiber matting-6 Larger clumps of fibers lying between Classes 5 and 7.

7 ,-- Fragments of fiber that retain some aspects of the original rectangular construction of the fiber matting. Typically precut pieces of a large blanket to simulate moderate-size segments of original blanket.

Figure 3-3. Fiberglass Insulation Debris of Two Example Size Classes Figure 14.a-1

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 26 of 68 The particulate surrogates were procured with an average size distribution near 10 micron.

Table 14.a-2 Testing Material Quantities 1.1 Aluminum (1) 0.251 ft' 233.4 cm' 1.2 Zinc In Galvanized Plate 9.234 ft2 8578.3 cm' 1.3 Concrete (1) 0.051 ft2 47.0 cm2 0.001 ft 2 0.6 cm 2 1.4 Carbon Steel 1.5 NUKON (1). 0.001 lbs 0.25 gm 1.6 Microtherm (1) 0.001 Ibs 0.2 gm S, " r',,*',*,i * ,;, a Thtoj.S~~~

s,__,*___

~~ ___,

3.103 ft2 2883.17 cm2 11.1 Aluminum (1) 11.2 Zinc in Galvanized Plate 4.337 f 4065.90 cm 11.3 Concrete (1) 0.034 ft2 31.32 cm2 11.4 Carbon Steel 0.006 5.4 cm

~~V . lD~bisoni Sree - -ip~-

111.1 NUKON 0.0002 lbs 0.09 gm 111.2 Cal-Sil 0.0138 lbs 6.27 gm 111.3 Silica Sand (Dirt/Dust Surrogate) 0.0011 lbs 0.49 gm 111.4 MicroTherm 0.0006 lbs 0.26 gm III. 5 Silicon Carbide 0.0333 lbs 15.12 gm Boric Acid (H3 B10 3) 793.05 gm ()P NaTB (Na 2B4O 7 1 0H2 0) 153.16 gm (2,3)

(1) Table 14a-3 shows the material loading that preserves the plant release rates. Use material loadings from Table 14a-3. Table 14a-3 combines the submerged and unsubmerged aluminum and submerged and un-submerged concrete.

(2) NaTB was added at a rate of 3.65 gm per hour starting at hour 9 and continued until the loop pH reached 7.2. (other alternative is to inject 19g every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ).

(3) If less than 100% purity the weight of the material was adjusted The batch quantities listed below represent the amount of each material to add/remove at each of the prescribed times. The positive values denote material addition while the negative numbers denote material removal.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 27 of 68 Table 14.a-3 Material Loading Scheme Loading Time Alum. Microtherm Concrete Condition Sub. (cm2) (gm) (cm 2)

Batch A 0 Hrs 4,300 0.2 106 Batch B 9 Hrs -346 Batch C 17.8 Hrs -837 -28 Final Scaled -- 3,116.6 0.2 78 Quantity RAI-14b: Description of test facility RAI-14b RESPONSE: Turkey Point 3 performed prototype sector testing of the GE Modular Stacked Disc Strainer at the Continuum Dynamics Inc. (CDI) test facility without chemical surrogates to develop the non-chemical debris head losses. Additionally, Alion Science and Technology performed plant-specific chemical effects testing at the VUEZ test facility. The test facilities for both prototype and chemical effects testing are described below.

Prototype Testing at Continuum Dynamics Inc.

Testing was performed using a module test article with 16 strainer disks which models 15 sectors (pairs of disks) that simulates a full size strainer module. The debris load and flow rate are scaled proportionally to plant accident conditions. The module end disks differ from the plant strainer disks in that the disk sides facing the pool (exterior face) are fabricated from 1/8 inch stainless steel sheet metal. The disk sides facing the gap (interior face) are covered with stainless steel perforated plate with 3/32 inch holes and include a wire cloth overlay. The internal frame work is 1/2 inch thick, which allows the internal flow rate to remain prototypic.

The spacing between the wire cloth surfaces on module test disk sets is nominally 1.3 inches.

The module test article provides approximately 352.3 ft2 of perforated plate area.

The test module disks were aligned vertically as the plant strainer disks and one end was discharged into the vertical plenum which provides a reservoir for the test tank suction line. A photograph of the sector test module is shown in Figure 14.b-1. The module was placed into a rectangular tank, approximately 10 ft long by 6 ft wide by 4 ft deep (approximately 1,800 gallon capacity).

The test article assembly was located near the center of the test tank. The test article was placed such that the bottom of the test article was approximately 4.2 inches above a platform on the bottom of the tank. Figure 14.b-2 is a simplified plan of the test arrangement. Figure 14.b-3 shows an overall view of the test arrangement.

A Godwin Dri-prime CD100M diesel pump drew liquid from the plenum of the test article through a Krohne magnetic flow meter. Flow was regulated by adjusting a flow control valve or by varying engine rpm. The flow return was located behind the plenum near the bottom of the test tank to help suspend debris. The flow return was a four inch diameter pipe ending approximately 2 inches above the tank bottom. Eight motor driven agitators were used to

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 28 of 68 maintain the debris in suspension and to minimize settling. Two submersible pumps withdrew water from the tank and passed it through copper coils in agitated ice baths and returned the cooled water to the tank to maintain the specified temperature. The submersible pumps and return flow were located at the short tank wall near the end of the strainer disks. The cooling flow was not started until many turnover times after all the fiber was added. A differential pressure transmitter measured the suction pressure in the test article plenum relative to the tank water height.

Figure 14.b-1

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 29 of 68 Return Test Header Tank Agitator Plenum Test PIIIII Article Platform Foot 7FT Figure 14.b-2 Figure 14.b-3

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 30 of 68 Chemical Effects Testing at Vuez The experimental facility consists of six identical, parallel, mutually independent, circulating loops (Figure 14.b-4).

Vuez Test Facility (row of six loops)

Figure 14.b-4 Figure 14.b-5 below shows the design of each of the loops.

Figure 14.b-5. Design of the loops /Main parts

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 31 of 68 Essential components of the experimental facility are:

Load bearing structure (a frame for mounting of 6 circulating loops, i.e. 6 leaching tanks, 6 pumps, piping and measuring sensors);

6 leaching tanks with a volume of 59 liters each provided with necessary openings for measuring sensors, coolant inlet and outlet, sampling, etc; 6 horizontal filter boxes with sieve 6 pumps EM 4PP/PVDF with a flow-rate of 0 to 2 m 3/h, Hmax = 5 m; An intake line made of stainless steel with a diameter of 20 mm; A delivery line - PVC hose with a diameter of 20 mm provided with stainless steel fittings; A control valve in the delivery line of each loop; A sampling valve in the delivery line of each loop; and A mobile desk for a microscope assembly.

Power supply as well as the measurement, control and data acquisition Leaching tank with a filter box Basic dimensions and parameters of the leaching tank are as follows:

External dimensions 444 x 304 x 566 mm Internal dimensions 440 x 300 x 562 mm Maximum working volume 59 liters Volume of the heating part of the tank: 13.2 liters Both the leaching tank and the filter box were made of stainless steel. In the upper part of the leaching tank, a handling opening was provided with dimensions 190 x 300 mm. The cap of the opening was plexi-glass with a thickness of 8 mm. Between the cap and the opening frame is a Silicone seal.

The leaching tank is provided with a double bottom. The lower, heating volume is filled with water heated by a heating coil. The working volume of the leaching tank is heated by heat transfer through the upper bottom separating the working volume from the heating volume containing the heating fluid. The working volume is provided with openings for connection of intake and delivery lines, and openings for thermometers and instrument pipes leading to differential pressure sensors. All 6 leaching tanks were located on a shared frame. They are mutually insulated to prevent the interference of thermal effects. The insulated surfaces are covered with zinc-coated sheet.

Circulation system Circulation of the working fluid in each loop is ensured by a pump, type CASTER EM4PP/PVDF, provided with a magnetic clutch.

The nominal parameters of the pump are:

Flow-rate 2 m 3/h (33 liter/min)

Delivery head 5 m The intake line from the filter box to the pump consists of stainless steel tubes DN 20.

The flow-rate in the system is controlled manually by throttling. The throttling valve is installed in the delivery line of the system. Using a T-piece, the delivery line is provided with a branch

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 32 of 68 containing a sampling valve to enable sampling of the working fluid.

The working fluid circulation system is identical in all 6 loops.

Instrumentation and control system The following parameters are measured:

Instantaneous flow-rate of the working fluid in the intake line upstream of the pump; Working fluid temperature; Heating fluid temperature (water in the volume between the double bottoms);

Head loss on the filter bed (doubled measurement for each loop);

(Visually) level height of the working fluid above the bottom, and; pH of the working fluid (laboratory instrument).

RAI-14c: General procedure for conducting the tests RAI-14c RESPONSE: The procedures that were followed during the 1) Prototype testing Program at the Continuum Dynamics Inc. (CDI) test facility and 2) Chemical Effects Testing Program at VUEZ are summarized below.

1) Prototype Sector Testing at CDI Debris Preparation Debris types were identified along with the mass that was to be used. Debris was prepared by breaking the material into the desired size distribution as necessary. The latent fiber size distribution was checked visually against a reference photograph. All debris was weighed dry and added to the test tank wet.

Test Conditions The test article and setup were verified in accordance with procedures and documented. The dimension for the disk set thickness (outer perforated plate surface to outer perforated plate surface), the disk pitch, distance between wire mesh on adjacent disks, perforation size, perforation spacing, wire cloth wire diameter and the wire cloth opening on the test article were measured and recorded. A proper seal between the test article and the plenum was insured.

The tank was filled to 3.0 inches +1 inch/-0 inch with water. The test setup was checked for leaks. The instrument lines for the differential pressure transducers were bled and the DP cell was checked against the water height to verify correct operation. The specified water temperature for the test was 65 OF +0 *F/-10 IF. The water level and temperature were measured prior to the start of the test.

Test Initiation The data acquisition system was initiated. Head loss, flow rate, and temperature data were collected electronically at approximately 1 sample every 2 seconds until the test was terminated. The pump was started. The flow rate was set by adjusting the flow control valve in the discharge line. The flow rate was adjusted as needed throughout the test to maintain the specified flow rate. Clean head loss was measured for each of the test flow rates. The water

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 33 of 68 surface was observed for vortexing or other signs of air ingestion. Vortex formation/air ingestion or lack thereof was recorded. The pump was shut down.

Debris Addition Water was removed from the tank and added to the particulate debris (calcium silicate, IOZ, silicon carbide, and Microtherm) to form slurries. The agitators were turned on and then each particulate debris type in slurry form was added to the tank. When the particulate debris was well mixed in the tank the pump flow was re-initialized. The flow re-initialization time was recorded. Head loss and flow rate data were recorded manually at intervals of approximately 5 minutes. Water temperature was recorded manually at intervals of no more than 15 minutes.

After the pumps were started with all of the particulate debris in the tank, wet fiber was added to the tank based on the schedule provided in the latent fiber debris addition schedule provided in the response to RAI 14a.

Test Termination After all the debris was added the initial test flow rate was maintained until termination criterion was achieved. The termination criterion could not be applied until one hour after the final fiber addition. After the termination criterion was met the subsequent flow rate was set. The first (largest) flow rate data was referred to as C2 the second (lower) flow rate data was referred to as C1. The water surface was periodically observed for vortexing or other signs of air ingestion.

Vortex formation/air ingestion or lack thereof was recorded. The subsequent flow rate was maintained until the termination criterion was again reached. After the final flow rate had reached a termination point the agitators were stopped and then the data acquisition system and pump were stopped to minimize disturbance to the debris bed, and a backup copy of the data file was made.

Test Termination Criteria Each test could be completed by meeting a stabilization (steady state) criterion of less than or equal to a 1% increase in head loss over a 30 minute period. If the head loss was varying up and down, then an average head loss was to be used to determine the termination criterion.

Sudden increases or decreases of head loss were to be ignored in determining termination. If the head loss exceeded the maximum allowable head loss required by the instrumentation specifications prior to reaching stabilization, the flow rate was to be reduced until the termination criteria could be achieved.

Post Test After being slowly drained, the tank was examined for residual debris. The test article assembly was examined and disassembled. The debris loading surfaces were inspected for the presence or absence of boreholes or other surface anomalies. The number, size and density of any such anomalies were recorded. Findings were documented and photographed. The test article and test facility were cleaned after the disassembly and examination process were completed. After testing was completed the instruments used in the tests were checked. The magnetic flow meter was checked against another calibrated flow meter with similar accuracy. The DP cell was checked against a column of water. Balances were checked with a weight from another calibrated balance with similar accuracy. Tapes and calipers were checked against another

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 34 of 68 calibrated tape measure or caliper with similar accuracy. The thermocouple was checked against another calibrated thermocouple with equivalent accuracy.

2) Chemical Effects Testing at Vuez Chemical effects testing at VUEZ were performed in accordance with the following test procedures.

Materials/Coupons Preparation The types and quantity of material and coupons are provided in the response to RAI 14.a.

These values were conservatively rounded up. The test coupons were marked to provide positive identification for the testing and project files. The marking, initial weight and initial surface area were recorded. Marking was done using marking iron or other dependable means.

Pre- Test Activities The test was performed with non chemical water (demineralized or reverse osmosis water) at temperature. The pre-test was conducted by adding both fiber and particulate debris at the same time. The pre-test was run for at least 5 pool turnovers and until such time as the water was essentially clear and measurable differential pressure was achieved.

The acceptance criteria was dP< 5kPa.

Tank Fill Each Loop was filled with the appropriate quantity (59 liters) of demineralized water in accordance with the applicable procedure. The data acquisition system was turned on. The pumps were started with the throttle valve 100% open. After 15 minutes of operation, an initial water chemistry sample (sample No. 0) was taken and the pH measured and recorded Tank Heat- Up The proper fluid quantity was introduced, then the pumps were started with the throttle valve 100% open. The heater elements were then activated and the temperature was allowed to increase to the required initial loop temperature of 190 0 F. Once the desired initial temperature was obtained the test chamber was operated for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to ensure that steady state conditions have been achieved. The temperature steady state is defined as a stable temperature that does not vary by more than +/-2°C (3.6°F) in a 30 minute time frame.

Adiust Flow Once temperature steady state was achieved, the flow rate was adjusted to the specified flow rate specified for each test case (See response to RAI 14e).

Add Debris to Create Debris Bed A portion of the hot fluid from the tank being loaded was removed and placed into a container.

Then the scaled quantity of debris reaching the strainer was introduced into the container with

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 35 of 68 the hot fluid. The debris in the container was thoroughly mixed for at least 5 minutes. The debris slurry was then introduced to the test apparatus screen such that all the debris could distribute across the screen while avoiding bypass from the screen area, and the screen assembly covered. The differential pressure was allowed to reach steady state with the initial debris bed.

Stabilization of debris bed Following the creation of the debris bed, stabilization of debris bed was obtained by circulation of the solution during at least 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Boric acid addition Boric acid as specified in the response to RAI 14b (793.05 gm) was introduced to achieve the dissolved boron quantities. The loop was operated for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to ensure thorough mixing using a mechanical device. A pH measurement was then taken. The pH during this phase was approximately five (5).

Add Submerged Debris Following the boric acid addition and mixing, the material in the baskets and the metal coupons were placed in each loop. For each loop, baskets were prepared in accordance with the following table and also installed. The batch quantities listed represent the amount of each material to add/remove at each of the prescribed times. The positive numbers denote material addition while the negative numbers denote material removal.

Table 14.c-1 Loading Alum. Microtherm Concrete Condition Time Sub. (cm 2) (gm) (cm 2)

Batch A 0 Hrs 4,300 0.2 106 Batch B 9 Hrs -346 Batch C 17.8 Hrs -837 -28 Final Scaled 3,116.6 0.2 78 Quantity _3,116. 0.2_ 78 The metal coupons and material were added in such a manner that no stagnant pockets were formed. The materials exposed to spray were also placed in the respective tanks for the duration of the testing.

Test Start Time Definition The test start time (t=0) was defined as the time at which the fluid was conditioned and the test materials had been introduced. The pH conditioning to achieve a pH in the expected range was verified through a pH measuring procedure.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 36 of 68 Removal of Baskets Coupons and baskets containing debris were removed from the loops in different steps.

Remaining Acids and Buffer Addition The buffer dissolution started at t=9 hours. The quantity of buffer provided targets for the following pH values.

Table 14.c-2 Time-Hours Sump pH 0 5 9 5 50 7.2 720 7.2 NaTB was added at rate of 3.65 g per hour starting at hour 9 and continued until the loop pH reached 7.2.

Sampling Fluid sampling and monitoring of the liquid level due to the sample removal were performed as described below.

Individual samples were stabilized by adding a 10% HNO3 solution to samples with a pH lower than 2.

Samples were analyzed in four batches. At the beginning of each new batch (samples 1, 11, 21 and 31) double volume samples were taken (i.e. 100 ml instead 50 ml). A 50 ml sample was skipped in each batch. This was needed to allow time to set up the Atomic Emission Spectroscopy (AES)-Inductively Coupled Plasma (ICP) analyses.

Sample No.1 (1000 ml) was taken after the termination of buffer addition.

Periodically makeup water was added to the tank to replace sample volumes that were removed from the tank.

Table 14.c-3 2 00-03:00 0/03:00 50 Ogm jg6; 3 00-06:00 0/03:00 50 22 13-00:00 2/00:00 50 4 00-09:00 0/03:00 50 23 14-00:00 1/00:00 50 5 00-12:00 0/03:00 50 24 15-00:00 1/00:00 50 6 00-18:00 0/06:00 50 25 16-00:00 1/00:00 50 7 01-00:00 0/06:00 50 26 17-00:00 1/00:00 50 8 01-06:00 0/06:00 50 27 18-00:00 1/00:00 50 9 01-12:00 0/06:00 50 28 19-00:00 1/00:00 50

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 37 of 68 10 02-00:00 0/12:00 50 29 20-00:00 1/00:00 50 M Fý , OQ/-0 30 21-00:00 1/00:00 50 12 03-12:00 1/00:00 50 V3'1 V __ --

13 04-00:00 0/12:00 50 32 24-00:00 2/00:00 50 14 04-12:00 0/12:00 50 33 25-00:00 1/00:00 50 15 05-00:00 0/12:00 50 34 26-00:00 1/00:00 50 16 06-00:00 1/00:00 50 35 27-00:00 1/00:00 50 17 07-00:00 1/00:00 50 36 28-00:00 1/00:00 50 18 08-00:00 1/00:00 50 37 29-00:00 1/00:00 50 19 09-00:00 1/00:00 50 38 30-00:00 1/00:00 50 PH measurement By procedure, pH was measured at the test temperature. Measurements were recorded at the test temperature (in-situ) at least 2 times per day. Additionally, the pH was measured every hour for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . PH measurements were also taken after the addition of any makeup water to the loops. Moreover, pH measurements were performed after cooling the sample fluid to 250C.

Evaporation Compensation and Pool Level Control Evaporated losses were compensated by the addition of demineralized water. Water level was recorded daily and maintained such that submerged materials were completely submerged at all times.

Flow rate adiustment The flow rate was adjusted to maintain the given flow rate in each test. Flow adjustments were made when the measured flow rate was 15% lower or higher than the target flow rate (0.15 L/min. for a target of 1.00 L/min). All flow adjustments were recorded in the test logs.

Analyses of Fluid Samples Fluid samples were analyzed for various elements (Al, K, Mg, Ca, Cu, Fe, Ni, Na, Si, Zn), using AES ICP spectroscopy. Chloride (CI) analysis was done by a wet chemistry method. All analyses were done in accordance with the applicable procedures.

Test Termination The maximum duration of any test was limited to 30 days from time zero plus additional time added for any temperature correction.

Examination of Test Samples The test coupons were weighed and photographed before and after the testing. Prior to weighing, the coupons were dried in an oven to remove moisture.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 38 of 68 Materials Submerged in Test Apparatus Examination The material samples (non debris bed) were weighed and photographed before and after the testing. Prior to weighing, the material samples were dried to remove moisture. The samples were declared as "dry" when a loss of weight less than 5% over a 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months drying period was measured.

Debris Bed Sample Examination The debris bed was portioned to retain a wet sample and dry sample after the testing. Prior to portioning, the debris bed in its wet form was photographed and inspected for amorphous materials and a general condition assessment was recorded. The dry sample portion was dried to remove moisture. The debris bed was declared as "dry" when a loss of weight less than 5%

over a 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months drying period was measured. The wet portion of the debris bed sample was secured in an air-tight and watertight container in the wet condition for future examination. The records were retained and attached to the test report and the debris bed was maintained for future examination (Scanning Electron Microscopy/Energy Disperse Spectrometer (SEM/ EDS) analyses).

RAI-14d: Debris introduction zones RAI-14d RESPONSE:

Prototype Testing at Continuum Dynamics Inc. (CDI)

The prototype test was a loop test with the test article located in a test tank rather than at the end of a long flume, see Figure 14.d-1 below. The test tank was well mixed using six (6) mechanical agitators during debris addition and during head loss testing. The debris was introduced onto the top surface of the water around the perimeter of the test article. Note that the tank walls were not far from the strainer so the debris was added near the strainer and did not settle outside the strainer because of the agitation.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 39 of 68 Figure 14.d-1 Chemical Effects Testinq at Vuez The test was conducted in a vessel with representative structural materials, insulation and debris samples included in the simulated containment environment. Prior to the initiation of the test, a screen was loaded with scaled quantities of the plant specific debris mixture within the test tank.

RAI-14e: Fibrous size distribution and comparison to transport evaluation predictions showing that non-prototypical fiber sizes were not added to the test.

RAI-14e RESPONSE:

Prototype Testing at Continuum Dynamics Inc.

The amount of fibrous debris generated for transport was originally calculated to be 8.2 ft 3.

However, the insulation on reactor coolant pumps and pressurizer surge line was replaced with RMI to eliminate the fibrous debris. Thus the amount of fiber generated for transport is now zero (Table 14.e-1). The only fiber considered for testing was that attributed to a conservative estimate of latent fiber, approximately 15% of total latent debris, a relatively small amount.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 40 of 68 Table 14.e-1 Generated Debris Debris Type Quantity Plant Material I Test Material Generated 0.0 ft 3 Fibrous Debris Nukon

______________________ I Transco Fiberglass Insulation_______________

Transco Fiberglass Latent Fiber Insulato Insulation 11.58 lb The procedure used to process shredded fibrous insulation (Transco Thermal Wrap was used to simulate latent fiber debris) is as follows. The fiber shreds received from the manufacturer were reduced in size by shredding the fiber material 5 more times to produce smaller shreds and more individual fibers. Samples of the shredded fibers were then suspended in a container with water over a Y2" X Y2" grid. The size of the shreds was compared to fiber shreds from reference photographs (for example, Figure 14.e-1) to ensure the desired fiber size was obtained. If the fiber was too coarse, then the fiber was re-shredded.

A single integrated transport model was not used for the purposes of determining the strainer debris load and head loss for Turkey Point Unit 3. Instead, each debris type was addressed separately. Therefore, detailed size distributions were not required or developed for the determination of the strainer debris load or head loss. A comparison between the fiber size distribution and the debris transport model is not applicable. 100% of the latent fiber was conservatively assumed to transport to the strainer disks.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 41 of 68 Figure 14.e-1 Fiber Shred Size Measurement

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 42 of 68 Chemical Effects Testing at Vuez The fiber load consisted of latent fiber (NUKON) with the characteristics shown in Table 14.f-2.

As discussed in the prototype testing above, comparison to the debris transport model is not applicable because the debris specific transport analyses did not assume the size distribution for the input.

Table 14.e-2 Fibrous Debris Density Size Distribution Nukon 2.4 lb/ft 7.0 microns (fiber diameter)

RAI-14f: Particulate debris size distributions RAI-14f RESPONSE:

Prototype Testinq at Continuum Dynamics Inc.

The particulate debris size or size distributions used for the prototype sector testing are provided in Table 14.f-1 below.

Table 14.f-1 Particulate Debris Characteristics Particulates Micro Silicon Latent therm Carbide Particulate Average Sifted on Sifted on Approx.

Size 0.1" by 0.1" 0.1" by 0.1" 10-microns 10-micron 10-microns Distrib. Screen Screen diameter Chemical Effects Testing at Vuez Sump screen particulate debris materials represented in the test were: Cal-Sil, qualified and unqualified coatings, surrogates and dirt/dust surrogate. Silicon Carbide surrogate material was used for unqualified and qualified coatings. Dirt Mix and Iron Oxide surrogates were substituted for dirt/dust debris. The Iron Oxide surrogate consisted of a mixture of two Iron Oxide sources (Specification #2008 and Specification #9101-C). Debris size distribution or average particle size used in the test is provided in Table 14.f-2.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 43 of 68 Table 14.f-2 Particulates Size Distribution Size Distribution per NEI 04-07 Cal Sil 5 micron - Mean 2 - 100 micron -Range

< 75 microns - Fine-37.04%

> 75 microns - Medium-0.56%

< 500 microns - Medium-20.80%

>500 microns - Medium-12.60%

< 2000 microns - Medium-0.95%

>2000 microns -Coarse-28.05%

Black Iron Oxide (FE 30 4) Particle size= 1 - 5 microns (Specification #2008)

Black Iron Oxide Grade Average Particle size = 25 microns (Specification #9101 -C)

> 19 microns 3% maximum Silicon Carbide 8.3 - 10.3 microns 50% minimum

> 3 microns 94% minimum RAI-14q: Amounts of each debris type added to each test RAI-14q RESPONSE:

Prototype Testing at Continuum Dynamics Inc.

The amount of debris added was the same for each test. The amount of fiber and particulates added is provided in Tables 14.g-1 and 14.g-2.

Table 14.g-1 Fiber (Ib)

Nom Bed Nukon Latent Fiber Test Label Thickes Thickness Fiber Scaled 0.011 0.0 0.79 Debris Loads

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 44 of 68 Chemical Effects Testinq at Vuez The amounts of debris added during the chemical effects tests performed at VUEZ are provided in Table 14.g-3 below.

Table 14.g-3 1.1 Aluminum (1) 0.251 ft' 233.4 cmr 1.2 Zinc In Galvanized Plate 9.234 f 8578.3 cm2 1.3 Concrete (1) 0.051 F 47.0 cm2 0.001 ft2 0.6 cm 2 1.4 Carbon Steel 1.5 NUKON (1) 0.001 lbs 0.25 gm 1.6 Microtherm1) 0.001 lbs 0.2 gm 3.103 f 2883.17 cm 2 I1.1 Aluminum (1) 4.337 F 4065.90 cm2 11.2 Zinc in Galvanized Plate 0.034 ft2 31.32 cm2 11.3 Concrete (1)

II4 Carbon Steel 0 _006 _ 5.4 _ft2 cm2 111.1 NUKON 0.0002 lbs 0.09 gm 111.2 Cal-Sil 0.0138 lbs 6.27 gm 111.3 Silica Sand (Dirt/Dust Surrogate) 0.0011 lbs 0.49 gm 111.4 MicroTherm 0.0006 lbs 0.26 gm III. 5 Silicon Carbide 0.0333 Ibs 15.12 gm

...... l'd"ii! ,n"i_ _ __,_ _ _**_ _ _ _

Boric Acid (H3 B0 3 ) 793.05 gm (3)

NaTB (Na 2B4O7 10H 2 0) 153.16 gm (2,3)

RAI-14h: Test strainer area for each test RAI-14h RESPONSE:

Prototype Testing at Continuum Dynamics Inc.

The module test article provided approximately 352.3 ft2 of perforated plate area.

Chemical Effects Testina at Vuez The test screen area is 0.0897 ft2 . The screen consists of perforated holes 3/32 inch in diameter with 0.156 inch staggered spacing between holes with a specific sieve on its upper part.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 45 of 68 RAI-14i: Test flow rates RAI-14i RESPONSE:

Prototype Sector Testingi at CDI Two tests cases were performed using the same debris load and different test flow rates. The flow rates correspond to different flow alignments (See response to RAI-20). The test was started with the Case 2 flow rate. After the test reached the termination criteria, the test flow rate was reduced to the Case 1 flow rate and continued until reaching the termination criteria.

The flow rates were scaled to the module test article perforated area. The calculated flow rates were increased by 1% to account for instrument uncertainty. The test flow rates are provided in Table 14.i-1.

Table 14.i-1 Test Flow Rates Module Flow Module Flow plus 1%

(gpm) (gpm)

Case 1 (Cl) 183.7 185.5 Case 2 (C2) 255.4 258.0 Chemical Effects Testing at Vuez Designing a test flow rate for the test apparatus was aimed at matching the test screen approach velocity with that of the sump strainers in containment. This value is based on ECCS flow rates and sump screen area and then scaled such that the test apparatus approach velocity would yield the same approach velocity within the test facility limitations. However, the test approach velocity could not be matched to the sump strainer velocity because of the test loop limitation of 1 L/min (to avoid stagnant flow regions within the loop). As a result, the test approach velocity exceeded the approach velocity for the sump strainers in containment.

However, since flow resistance is proportional to the square of the velocity, actual head loss for the test case was greater than in-plant loss. The purpose of this test was to establish the change in resistance (head loss) due to chemical effects. Therefore, the noted deviation in screen approach velocity did not impact the validity of the test results.

The test flow velocity was 0.0066 ft/sec and the flow rate was 0.264gpm.

RAI-140: Description of debris introduction (including debris mixes and concentrations) showing that agglomeration did not occur RAI-140 RESPONSE:

Prototype Sector Testing at CDI Debris type and introduction are discussed in the response to RAI 14a. The test procedures for debris loading and debris addition (introduction) are described in the response to RAI 14c.

As described in the response to RAI 14a, the fiber was added to the tank/pool in a manner to

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 46 of 68 simulate the initial concentration of fiber in the plant pool at the start of recirculation. The fiber was introduced into the test over a period of time, which corresponds to the time required for the plant fiber concentration to decrease by approximately 80% based on an assumed exponential function. The fiber was divided into equal amounts and added to the test. The amount of fiber introduced into the test tank at each interval was approximately equal to the concentration of fiber in the plant at the start of recirculation.

Six mechanical agitators were used during debris addition and during the head loss tests to ensure that the debris was well mixed, and maintained in suspension so that settling of debris was minimized.

Chemical Effects Testing at Vuez Chemical effects testing at VUEZ was designed to replicate the potential corrosive interactions of the spray and pool fluid chemistry with those materials and debris sources in containment and resident in the sump screen. These potential interactions may cause additional precipitates and/or impacts on debris head loss over the 30-day mission time. To provide a representative test, certain scaled parameters were selected to ensure that the reactions took place in the correct quantity and environment and that the resultant debris head losses satisfactorily reflected any chemical effects.

Chemical loads that are present in the containment pool were replicated for testing by using the same concentration (ppm by weight value) in. testing as is present in containment. The fluid temperature and pH that would be present in the containment pool were also approximated during testing.

Debris type and size distribution are discussed in the response to RAI 14a. Debris addition (introduction) is discussed in the response to RAI 14c.

The fiber and particulate mixture was thoroughly mixed in a beaker containing the test solution.

The mixture was slowly added through a funnel to ensure an even distribution across the test screen area while the pump was circulating. The bed was constructed to be uniform (minimal clumps, unevenness, etc.).

The VUEZ testing was similar to the prototype testing in that all the debris was accumulated on the screen. The bed was similar in that debris was homogeneously mixed into the tank and surface dependent upon localized flow velocities. The VUEZ debris bed was homogeneously mixed and manually formed to be as uniform as possible to represent the overall debris bed on the sector. The circulation of fluid was essential to the development of a homogeneous chemical solution by which corrosion and subsequent precipitation would occur.

RAI-15: Provide documentation of the amount of debris that settled in the agitated and nonagitated areas of the test tank. The supplemental response stated that debris was maintained in suspension using stirring. No information was provided to show that the stirring did not drive nonprototypical debris onto the bed nor prevent debris from collecting naturally on the strainer. Please provide information that verifies that the stirring did not result in nonprototypical bed formation.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 47 of 68 RAI-15 RESPONSE: The test module consisted of 16 strainer disks to simulate 15 disks. The outer sides of the two outer disks were covered with stainless steel plate. The agitators were located on either side of the test module. The turbulence created by the agitators was generated outside the stainless steel plate. The following picture is from the test report.

Photograph of Test Facility The particulate debris was added to the sector test prior to starting the recirculation pump. The particulate debris was mixed with water removed from the tank to form slurries. The test tank was equipped with eight mixing agitators. The agitators were equipped with propellers to force water vertically downward and flush debris off the bottom of the test tank. The agitators flushed debris into suspension and not on to or off of the strainer disks. These agitators were turned on and then each particulate debris type in slurry form was added to the tank. When the particulate debris was well mixed in the tank the recirculation pump was started. Wet fiber was added to the tank in eleven increments over a 90 minute period.

The debris used for testing consisted of particulate and fiber. The assumption was made that the maximum amount of debris in solution would produce the maximum and, therefore, the most conservative head loss across the strainer. The area of the test that was not subject to agitation was under the test module. Debris settled under the test module that was as thick as 2-1/2". It sloped to zero thickness at the edge of the test module. The debris consisted almost entirely of particulate. In the area of the tank not under the test module there was a thin film of debris. This was the result of debris in suspension that settled out uniformly in the agitated area.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 48 of 68 The test was run for over eleven hours to determine maximum head loss at 3750 gpm and for over eight hours more for the head loss at 2697 gpm. The debris bed formed had considerable time to settle and compact.

Based on the uniformity of the debris on the disks, the test resulted in a compact, conservative, and prototypical debris bed. The post test photographs below show one of the disks and the resulting debris coverage. The photographs are typical of each of the test disks. They show no evidence of debris being washed away from the screen by the agitation. The potential for washing away debris from the screens was discussed with the test engineer at the testing facility. He witnessed the test for Turkey Point 3 and numerous tests and has never seen evidence of debris being washed from the screens by the agitators.

.... i., * . i *I*

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 49 of 68 Post Test Photoaraphs of TvDical Test Disk

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 50 of 68 RAI-16: Please provide the test termination criteria and sufficient data to show that the tests were run in accordance with that criteria.

RAI-16 RESPONSE: Head loss testing was done in two phases. The first phase was to determine head loss based only on the debris without chemical effects. The second phase was to determine head loss including chemical effects.

For head loss based only on the debris, the test termination criteria were as follows:

The head loss was determined based on flow rates of 2697 gpm and 3750 gpm. Each test could be considered completed by meeting a criterion of less than or equal to 1% increase in the one minute average head loss over a 30 minute period. This termination criterion Could not be applied until at least one hour after the final fiber addition. A table showing the test results is shown below. Test flow rates of 185.5 gpm and 258 gpm were scaled values based on 2697 gpm and 3750 gpm, respectively. Also, a graph of head loss versus time is shown.

For the flow rate scaled for 3750 gpm, the graph shows that the maximum value for head loss shown in the table occurs at 542 minutes. This value is not exceeded for the next 30 minutes and all values beyond 572 minutes did not exceed this maximum value. Therefore, this test termination criterion was met for the debris only head loss test.

For the flow rate scaled for 2697 gpm, the graph shows that the maximum value for head loss shown in the table occurs at 1197 minutes. This value is not exceeded for the next 30 minutes and until test termination. Therefore, this test termination criterion was met for the debris only head loss test.

Table 16-1 Test Results Matrix Flow Clean Max Flow Time2 Final Final Final Final Rate 1 Head Head Rate @ Head Flow 2 Water Test Loss Loss @ Max Max Loss Rate Time Temp (gpm) ("H20) ("H20) (gpm) (min) (gpm) (" H20) (mn) (oF)

PTN3-M-0.O11T-100CS- 258.0 0.1 10.2 260 542 8.8 259 767 60 PC-2.556P-C2 PTN3-M-2.511T-1000S- 185.5 0.0 9.6 186 1197 8.3 186 1260 59 PC-2.556P-C1___ ______ ___ ___ ______

Note 1: Specified flow rate Note 2: Test duration was measured from data acquisition start, not from debris addition Note that the actual maximum head loss reading occurs prior to test termination. Figure 16-1 showing head loss versus time is presented below to make this clear.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 51 of 68 Figure 16-1 PTN3-M-0.011T-100CS-PC-2.556P Head Loss vs. Time 12 10-o- 8 _ _ _

0

-J CD Cl 0 200 400 600 800 1000 1200 1400 Time m in)

Fiber addition was completed 90 minutes after the pump was restarted, or 169 minutes after test commencement. The application for termination criterion was commenced 542 minutes after test commencement or 373 minutes after final fiber addition. Therefore, this test criterion was met.

Test termination for the testing done for chemical effects is not applicable. The testing done to determine chemical effects was performed over the entire 30 day mission time. The purpose of the test was to determine a chemical bump up factor to be applied to the debris only test results. The chemical bump up factor so determined is multiplied by the debris head loss without chemical effects. The test report found that the chemical bump up factor had an initial early rise during approximately the first 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months of the test. The chemical bump up factor showed a gradual increase to 3.75 during the remaining 30 days. The testing was terminated after 30 days because that encompasses the required mission time of the ECCS. A value of 3.75, the maximum chemical bump up factor determined during the 30 days of testing, was used in subsequent calculations for NPSH and flashing.

RAI-17: Provide information that shows that flashing will not occur within the strainer. The flashing evaluation did not provide the margin to flashing through the strainer. The supplemental response stated that a small amount of containment air pressure was credited, but the amount of overpressure credited was not provided, nor was the available margin to flashing. The total head loss including chemical effects was not provided. Submergence was stated to be less than 1 foot. Include the inputs and assumptions used to make this determination. Provide the margin to flashing at the limiting point during recirculation.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 52 of 68 RAI-17 RESPONSE: Inputs and Assumptions to Determine Submerqence:

Table 17-1 shows the minimum water level required and the conservatively calculated debris bed loss for the two different flow rates.

Table 17-1 Large Break LOCA, Post LOCA 300 F SumpStrainer Disc Debris Bed Loss, ft Flows, Submergence LB/SB Top Elev gpm 0.6/7.2 Ft/in Case 1 17.35 16.75 3.634 2697 Case 2 17.35 16.75 3.829 3750 Small Break0 LOCA, 170 F

Submergence 0.28/3.36 Ft/in Case 1 17.03 16.75 3.634 2697 Case 2 17.03 16.75 3.829. 3750 Table 17-2 below shows the pressure available to preclude the water from flashing because of the pressure drop across the screen face. The column titled Over Pressure is the partial air pressure converted to feet of water plus the pressure of the sump water above the highest point of the screen minus the pressure drop across the screen. This value is the margin to flashing.

The column "HL screen ft. of water" shows the head loss across the screen, which includes chemical effects.

Table 17-2 Over Prer Temp Pair Pvap Viscosity Density HLscreen Wtrheight Conversion Pressure ft. of. ft. of lbfsec/ft2 Ib./cu.ft. ft. of wter OF psia psia water psi/ft. wtr water water 65 9.65641 0.3057 2.21 E-05 62.34 3.829 0.28 0.432903 18.75719 70 9.748376 0.3632 2.05E-05 62.31 3.829 0.28 0.432674 18.98155 80 9.932308 0.5073 1.80E-05 62.22 .3.829 0.28 0.432083 19.43802 90 10.11624 0.6988 1.60E-05 62.12 3.829 0.28 0.431361 19.9029 100 10.30017 0.9503 1.42E-05 62.00 3.829 0.28 0.430528 20.37552 110 10.4841 1.2763 1.28E-05 61.68 3.829 0.28 0.429597 20.85549 120 10.66803 1.6945 1.17E-05 61.71 3.829 0.28 0.428564 21.34352 125 10.76 1.9444 1.12E-05 61.63 3.829 0.28 0.427997 21.59135 130 10.85197 2.225 1.07E-05 61.55 3.829 0.28 0.427431 21.83984 140 11.0359 2.892 9.81E-06 61.38 3.829 0.28 0.424917 22.42291 150 11.21983 3.277 9.05E-06 61.19 3.829 0.28 0.424917 22.85578 160 11.40376 4.745 8.38E-06 60.99 3.829 0.28 0.423569 23.374 170 11.58769 5.996 7.80E-06 60.79 3.829 0.28 0.422132 23.9014 170 11.58769 5.996 7.80E-06 60.79 3.829 0.28 0.422132 23.9014 180 11.77162 7.515 7.26E-06 60.57 3.829 0.28 0.420618 24.43749 190 11.95556 9.343 6.84E-06 60.34 3.829 0.28 0.419049 24.98124 200 12.13949 11.529 6.37E-06 60.11 3.829 0.28 0.41741 25.5339 210 12.32342 14.125 6.12E-06 59.86 3.829 0.28 0.415708 26.09539

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 53 of 68 220 12.50735 17.188 5.86E-06 59.61 3.829 0.28 0.413979 26.66351 230 12.69128 20.78 5.61E-06 58.80 3.829 0.28 0.412132 27.24522 240 12.87521 24.97 5.36E-06 59.08 3.829 0.28 0.410285 27.83217 250 13.05915 29.82 5.11E-06 58.80 3.829 0.28 0.408326 28.43312 260 13.24308 35.42 4.85E-06 58.52 3.829 0.28 0.406368 29.03987 270 13.42701 41.85 4.60E-06 58.22 3.829 0.28 0.404309 29.66077 280 13.61094 49.18 4.35E-06 57.92 3.829 0.28 0.40225 30.28802 290 13.79487 57.53 4.09E-06 57.62 3.829 0.28 0.400108 30.9289 300 13.9788 66.98 3.84E-06 57.31 3.829 0.28 0.397965 31.57669 Assumptions Applicable to Turkey Point Unit 3 and Unit 4 1 It is assumed that the water in the sump is at saturation. This is a conservative assumption. The temperatures of the water in the containment sump are consistently lower than the temperature of the containment atmosphere. The pressure of the containment atmosphere is created by the steam produced during the LOCA and the partial pressure of air in containment. The temperature of the water in the containment sump is produced by the hot water created by the LOCA and the water from the RWST pumped into containment during the injection phase. The water from the RWST is at a much lower temperature than the water created by the LOCA. Therefore, it is conservative to assume that the water in the sump and the steam in the containment atmosphere are at saturation.

2 Further evidence that this assumption is conservative is in an evaluation written for Turkey Point. This evaluation was written for Turkey Point Unit 3, but the basis for the evaluation is from UFSAR Figures 3.5.3-32, 3.5.3-33, and 3.5.3-34, which are applicable to both units. This evaluation concluded that there is 476 inches of water pressure available from containment atmospheric pressure to preclude flashing. 476 inches of water is equivalent to 39.67 ft. of water. Although these curves are for minimum safeguards (and therefore would not represent the minimum containment pressure for a LBLOCA), they do illustrate that significant margins exist. For a small break LOCA, significantly less debris would be generated and the screen head loss would be reduced significantly.

3 Heating of the air in containment behaves as an ideal gas.

4 Post LOCA containment atmosphere water vapor and air are at approximately the same temperature.

5 Containment atmospheric pressure at plant elevation is 14.7 psia.

6 Relative humidity in containment is conservatively considered to be 100%.

7 Post LOCA containment pool temperature is conservatively assumed to be equal to containment atmosphere temperature.

8 The partial pressure of air in containment at the beginning of the postulated LOCA can be credited for the purposes of evaluating head loss margin to flashing at the ECCS/CS sump screen debris bed.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 54 of 68 9 Debris bed head loss values for the large break LOCA are compared to the submergence for small break LOCA even though debris generated and transported for the SBLOCA is significantly less.

Turkey Point Unit 3 Assumptions:

1 Strainer screen head loss cannot be scaled for temperature due to the assumed turbulent nature of flow through the ECCS/CS suction strainer debris bed as a result of the boreholes formed in the debris buildup.

As shown in the table above, the partial pressure of air in containment was credited to prevent flashing. The partial pressure of air was determined using the most conservative assumptions.

In accordance with the Technical Specifications the minimum containment pressure relative to atmosphere at which the plant may be operated is -2 psig. It is conservative to assume that vapor pressure is at a maximum. In accordance with the Technical Specifications the maximum containment temperature at which the plant may be operated is 125 0 F. The vapor pressure at this temperature is 1.94 psia. The initial containment pressure was thus determined, 14.7 psia -

2 psi -1.94 psi = 10.76 psia. The partial pressure of air was then adjusted according to temperature over the entire range from 650 to 3000.

RAI-18: The supplemental response stated that the vortexing evaluation was conducted with submergence levels less than those expected during recirculation. However, the flow rate assumed for the vortexing evaluation was not provided. Strainer modules hydraulically closer to the pump suctions would have higher flow rates early in debris bed formation. The supplemental response did not provide the actual flow rates through the modules under clean conditions nor state whether some modules could experience higher flow rates than others.

Provide the maximum flow through the vortex limiting strainer module in the array under clean conditions. Verify that the flow rates used for the vortexing evaluation and strainer testing bound the actual flow rates expected.

RAI-18 RESPONSE: The table below shows the results of the actual testing performed without chemical effects. The table is repeated directly from the test report with some editorial changes for clarification.

The column "Specified Test Flow" was based on scaling calculations. The column for final flow shows that the actual flow measured is very near the calculated flow. The scaling calculation for a flow rate of 3750 gpm determined the following:

Velocity Test = Flow Rate Test / Area Test

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 55 of 68 Velocity Test = .001628 ft/s Velocity Plant = Flow Rate Plant / Area Plant Adjusted Velocity Plant = .001615 ft/s The scaling calculation determined flows based on balanced flow through all of the strainers and did not account for higher flow through the downstream strainers. The observations made during the test with respect to vortexing only confirm that vortexing will not occur at design velocities assuming balanced flow.

The vortexing calculation was based on the following formula:

Fr x [pL/(pL-pg)] 0 5/0.2(hb/Dh)2.5 < 1

Where, Fr Froude Number 3 pL = water density, Ibm/ft3 pg = air density, Ibm/ft hb = water depth above hole/break/strainer, ft Dh = hydraulic diameter, ft Fr = U/(g x Dh)°5

Where, U = velocity of flow into the top gaps of the strainer, ft/s g = gravitational constant, ft/s2 Dh = hydraulic diameter of the top gaps of the strainer, ft For conservatism the approach velocity was increased by a factor of 2 to adjust the flow rate for the head loss due to the 10 module train and was increased by an additional factor of 3 to simulate the increased flow rate near the suction end of the strainer. The result was 0.222, which is less than 1.

The maximum flow through the vortex limiting strainer module in the array under clean conditions was not determined. However, by assuming a 6 fold flow increase, there is significant conservatism in the calculation for vortexing.

The calculation for head loss through the piping, elbows, bellows, and plenums determines the head losses through the individual components in the strainer system. This allows head losses between different components in the strainer system to be determined.

The degree of imbalance is limited and flow to one strainer that is six times the balanced flow cannot occur. Using the relationship that head loss is proportional to the flow squared and the measured clean head loss through the strainer module of 0.1" at design flow, increasing the flow six times will create a pressure drop of 3.6" through the strainer module. At 3750 gpm of RHR flow the head loss from the most downstream module, nearest to the pump suction, to the most upstream module is 2.8". This head loss is based on balanced flow, and would be less than 2.8" with imbalanced flow. Since 2.8" is the maximum head loss across the most downstream module with clean strainers, a flow rate of six times the balanced flow cannot

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 56 of 68 occur. Therefore, the vortex calculation bounds the maximum flow that could go through the most downstream strainer module.

RAI-19: Provide final integrated chemical effects head loss values and updated head loss, vortexing and flashing evaluation based on these values.

RAI-19 RESPONSE: The integrated chemical effects head loss values were calculated as follows:

The table below shows the results of the actual testing performed without chemical effects. The table below is repeated directly from the test report with some editorial changes for clarification.

Table 19-1 Measured Measured Specified Maue MasrdFinal Water Flow Test Flow Clean Strainer Maximum Final Flow Temperature Test Flow_ -Head Loss Head Loss Temperature 3750 gpm 258.0 gpm 0.1" 10.2" 259 gpm 60°F 2697 gpm1 185.5 gpm 0.0" 9.6" 186 gpm 59°F Table 19-2 repeats the measured clean strainer head loss and shows the head losses after adjustments for actual test flow versus calculated test flow, actual tested debris bed thickness versus calculated debris thickness, and inaccuracies of the test instruments. The -table is a combination of information from the calculation for total head loss. The adjusted total head loss does not include chemical effects.

Table 19-2 Measured Adjusted Strainer Adjusted Clean Calculated Flow Maximum Screen Total Head Strainer Head Plenum and Head Loss Loss Loss Piping Head Loss 3750 gpm 10.2" 12.254"/1.021' .090' 2.28' 2697 gpm 9.6" 11.624"/0.969' .083' 1.18' To account for chemical effects a chemical bump up factor (CBU) was determined by separate testing. The testing performed was an 30 day integrated chemical effects test. The value of CBU so determined is 3.75. Therefore, the adjusted strainer screen total head loss with chemical effects is 1.021 x 3.75 = 3.829 ft.

The adjusted strainer screen total head loss was increased to 12.254" from the 10.2" measured by adding the instrument inaccuracy of 1" and multiplying by the ratio of actual test flow divided by calculated test flow and actual tested debris bed thickness divided by the calculated debris thickness. The adjusted clean strainer head loss was then added to the result.

3.829 ft. of head loss across the strainer screen was used in the evaluation for flashing. The response in RAI 17 shows this value in the table, which is taken directly from the flashing evaluation.

The head loss across the strainer screen at 2697 gpm was determined in the same manner as it was at 3750 gpm.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 57 of 68 Head loss across the strainer screen was not used in the vortexing calculation. The vortexing calculation was based on the following formula:

Fr x [pl/(pL-pg)] 0-5/0.2(hb/Dh)2.5 < 1

Where, Fr = Froude Number 3 pL = water density, Ibm/ft3 pg air density, Ibm/ft hb = water depth above hole/break/strainer, ft Dh = hydraulic diameter, ft 05 Fr= U/(g x Dh) ,

Where, U = velocity of flow into the toý gaps of the strainer, ft/s g = gravitational constant, ft/s Dh = hydraulic diameter of the top gaps of the strainer, ft For conservatism the approach velocity was increased by a factor of 2 to adjust the flow rate for the head loss due to the 10 module train and was increased by an additional factor of 3 to simulate the increased flow rate near the suction end of the strainer. The result was 0.222, which is less than 1.

RAI-20: Provide the assumptions and methods used to evaluate the maximum recirculation sump flow rates. Please discuss the basis for specifying a change in sump flow from 2697 gpm to 3750 gpm at the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months point in the event, as well as the pump operating configurations, assumptions, and methodology to calculate the flows for both cases.

RAI-20 RESPONSE: The flow rates are dependent upon the flow alignments. The allowable flow alignments are dependent upon containment pressure and temperature. The applicable emergency operating procedure (EOP) states that containment spray is required when containment pressure is greater than 14 psig or containment temperature is greater than 122 0 F.

When containment spray is required in the recirculation mode one RHR pump must take suction from the containment sump and discharge to one HHSI pump and one containment spray pump. The limiting NPSH case for the RHR pumps during the short term circulation alignments was determined to be the High-Head/Cold-Leg recirculation with containment spray alignment. The calculated flow rate for this configuration is 2697 gpm. The flow in piggyback operation is higher to the cold legs than to the hot legs.

The Turkey Point design basis considers Net Positive Suction Head (NPSH) identified for post-accident Post -LOCA recirculation of ECCS System operation as follows:

Case 1 - NPSH evaluation for short term recirculation alignment with one residual heat removal (RHR) pump taking suction from the recirculation sumps (time < 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months )

Case 2 - NPSH evaluation for long term recirculation alignment with one RHR pump taking

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 58 of 68 suction from the recirculation sumps (time > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months )

Case 1 - During the initial recovery stage, the operation of the ECCS is procedurally restricted to one RHR pump taking suction from the containment sump. This is the period of time after switchover to recirculation has occurred but before 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months have elapsed following LOCA.

The RHR pump discharges and delivers flow to one High Head Safety Injection (HHSI) pump and one Containment Spray (CS) pump. In this alignment the RHR discharge is isolated from the RCS cold legs thereby reducing overall flow below the maximum of Case 2. The sump fluid is at elevated saturation conditions. The containment pressure is conservatively assumed to be at the same temperature and saturation pressure as the sump fluid. The fluid in the sump is assumed to be at 300 OF Table 20-1 Pump Pump Flow Rate NPSHr Sump Temp (FO)

(gpm)

RHR 1 @ 2697 10 300 sat The 2697 gpm flow rate is based on a Westinghouse Pegysis code flow analyses of the RHR, HHSI, and CS pumps operating with RHR taking suction from the sump with RHR delivering to HHSI and CS in the 'piggyback' alignment. This flow is lower than the maximum flow case because RHR flow to the RCS cold legs is isolated.

Case 2 - For the time period after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the ECCS is procedurally aligned to allow recirculation from one (1) RHR pump taking suction from the containment sump. The RHR pump discharges and delivers flow to the RCS. The sump fluid is assumed to be at 170 OF.

Values for the specific case are displayed below:

Table 20-2 Pump Pump Flow Rate Pump p NPSHr Sump Temp (OF)

(gpm)

RHR 1 @ 3570 14 300 sat The revised Case 2 design condition is based on the maximum flow rate from a single RHR pump. Flow from more than one RHR pump is not permitted during the recirculation mode.

The higher RHR flow is due to RHR delivery directly to the RCS. The maximum flow rate allowed by the system configuration and procedures is 3,750 gpm as limited by valve HCV 758. The maximum flow rate occurs in alignments that do not utilize containment spray. This is a conservative assumption since the flow rate of each RHR pump is limited to this maximum by valve HCV-3-758 (RHR heat exchanger outlet common header discharge valve).

The use of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as the time period to differentiate the flow rates is based on a previous procedural requirement to only use one RHR pump in the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months post LOCA. The use of one RHR pump was to prevent flashing when the sump temperature was greater than or equal to 212 0 F. The use of two RHR pumps was allowed after 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . After the installation of the containment sumps the EOP's were changed to allow the use of only one RHR pump for the entire time of the accident. It was determined during the design of the containment sump strainers that the number of strainers required to allow the flow rate for two RHR pumps was excessive. However, the specification for the strainers still used the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period to

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 59 of 68 differentiate flows. Testing for the containment strainers was based on a temperature range from 65 0 F to 300°F and a maximum temperature of 170°F 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the accident.

Therefore, the strainers had to meet the specified pressure drops with a flow of 3750 gpm at temperatures from 65 0 F to 170°F and a flow of 2697 gpm at temperatures from 170°F to 300 0 F.

The maximum flow of 3750 gpm actually cannot occur until containment spray is secured.

RAI-21: Provide the method used for estimation of the head losses in the suction lines.

RAI-21 RESPONSE: To calculate the head losses in the clean piping, plenums, elbows, and bellows the following assumptions were made.

1 Flow is steady state.

2 Water is clean.

3 Flow rate is proportional to the perforated surface area. A single style plate was used in the design of the strainer modules. Therefore, flow rate is also proportional to the number of disks.

4 Elevation head is ignored.

5 Pipes fit perfectly together and have no additional resistance at connections.

The following references were used.

1 Flow of Fluids through Valves, Fittings, and Pipes. Crane Technical Paper 410 2 Fluid Power Design Handbook by Yeaple. 3rd Edition 1996 3 Hydraulic Analysis of Boiling Water Reactors, NEDM-20363-13-01 August 2006 by D. C.

Rennels 4 Handbook of Hydraulic Resistance, 3rd edition by Idelchik The absolute roughness of commercial steel used was 0.00015 ft. The resulting friction used was 0.015.

The head loss was determined for both the north and south sumps. The maximum head loss to the north sump is bounding and is the head loss stated in the hydraulic report and used in subsequent calculations. The hydraulic report calculates the head loss through the strainers to where the piping penetrates the containment floor.

Pressure drop for the suction line from where it penetrates the containment floor to the RHR pump suction was based on the existing calculations for NPSH which was developed using the hydraulic modeling program PEGISYS. To determine the pressure drops from the existing calculation for different flows, the relationship that pressure drop is proportional to the velocity squared was used.

RAI-22: The licensee states that the net positive suction head required (NPSHr) for the pumps were based on pump test curves. While use of NPSHr data provided by the manufacturer may be acceptable, it is not clear whether the equivalent of the Regulatory Guide 1.82, Revision 3, 3% criterion was used. Please provide the basis for the NPSHr values for the ECCS and CSS pumps.

TurkeyPoint Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 60 of 68 RAI-22 RESPONSE: The curve for NPSHr supplied by Ingersoll Rand for the RHR pumps is based on 3% pump head loss degradation. The RHR pumps provide the suction to the HHSI and containment spray pumps during recirculation. The NPSHr for the HHSI pump at runout is 30 ft. The NPSHr for the containment spray pump at runout is 35 ft. The RHR pump head at runout is 165 ft., which is well in excess of the NPSHr for these pumps. The suction pressure supplied to the HHSI and containment spray pumps during recirculation is sufficient to account for a 3% pump head loss degradation for the NPSH required for these pumps.

RAI-23: The supplemental response does not discuss the distinction between cold-leg and hot-leg recirculation scenarios, in which the pump lineups and, therefore, the flow rates may be different. If plant procedures address both scenarios, NPSH results for both scenarios should be presented, or a basis should be provided establishing that one or the other scenario is limiting.

RAI-23 RESPONSE: The limiting NPSH case for the RHR pumps during the short term recirculation alignments was determined to be the High-Head/Cold-Leg recirculation with containment spray alignment. This is the lower of the two design flows at which NPSH is calculated. The lower flow occurs at temperatures from 170°F to 300 0 F. The calculation methodology assumes a containment pressure equal to the greater of minimum containment partial air pressure at the start of the accident or a pressure equal to the saturation pressure at the containment sump temperature. At the higher design flow of 3750 gpm the sump temperature is 170°F and lower. At these temperatures the partial pressure of air in containment is above the saturation pressure of the sump and adds margin to the NPSH.

Because of this conservative methodology the lower margin for NPSH occurs at the lower of the two design flows. The alignment for the lower flow is one RHR pump discharging to one HHSI pump and one containment spray pump in piggyback operation. The calculation of record for this configuration determines the flow rate is 2697 gpm. This calculation shows that the flow in piggyback operation is higher to the cold legs than to the hot legs.

3750 gpm is the maximum flow rate that can occur in any of the recirculation scenarios. All recirculation flow goes through one of the RHR pumps. Only one RHR pump may be used during the entire period of the postulated accident. The flow rate of each RHR pump is limited to this maximum by valve HCV-3-758. Refer to RAI 20 for when this maximum flow rate is applicable.

Therefore, by establishing the minimum NPSH margins for flows of 2697 gpm and 3750 gpm all potential operating configurations in the recirculation mode are bounded. The minimum NPSH margin at a flow of 2697 gpm is 3.1 ft. and occurs at a temperature of 196.7°F and above. The minimum NPSH margin at a flow of 3750 gpm is 3.8 ft. and occurs at a temperature of 170'F.

RAI-24: Please provide technical justification in support of the assumption of "no blockage of the refueling pool canal drains." Please identify the type, physical characteristics (size, shape, etc.) an amount of debris which may be blown into the refueling cavity during a LOCA. If it is determined that drainage from the water held up in the cavity could be blocked, please specify the volume of water held up in the cavity and state the effect on minimum containment sump pool level.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 61 of 68 RAI-24 RESPONSE: FPL has performed containment design reviews and walkdowns to assess flow chokepoints and flow paths from potential high energy break locations to the containment sump suction strainers including upwards from inside the biological shield wall through the floor at elevation 58' and into the Refueling cavity and outside the biological shield wall. This review concluded that the refueling canal drains could become chokepoints with the perforated drain covers installed. The review recommended removing the drain covers during operation. This action was taken. It is FPL's judgment that this action is sufficient to preclude blockage of the refueling canal drains. Additionally, in the event of a LOCA, the limiting breaks are within the secondary biological shield wall around the RCS loop level. The location of the limiting breaks in relation to the refuel pool canal drains presents a torturous pathway from the loops up through the 58 foot level floor. This is due to the large solid floor area above the secondary shield wall and the grating above the area outside the shield wall at elevation 58', relatively small compartment areas covered with grating, and tight clearances around stairs, curbs and penetrations. It is FPL's judgment that navigation of this pathway by sufficient debris to block the refuel pool canal drains is not credible. A further impediment to debris blocking the refuel pool canal drains is a curb surrounding the refueling pool. The refueling pool is surrounded almost completely by a 4" high curb. The curb is either a 4" x 4" concrete curb or an 8" wide stainless steel curb depending on the location around the refueling canal. The only location where no curb exists is on the east side for a length of 2' - 6".

While there is no exact way to quantify the type, size and shape, if you assume that significant debris is able to make its way vertically over 40 feet against the forces of gravity through the aforementioned tortuous path, the following design features preclude total blockage of both drain paths:

Any debris that lands on the 58' elevation and not directly in the refueling canal must be washed over a 4" high curb to fall into the refueling canal with the exception of a 2' - 6" opening in the curb on the east end.

Drains are redundant.

Drains are separated 6'- 6".

Drain diameters are large so that larger debris of conforming size would be required to simultaneously block and perfectly seal both drains without pass through for significant water holdup.

The drain covers are removed during normal operation to allow smaller debris to pass through the drain.

The refueling cavity is large with a lot of area for debris to 'hide out'.

Therefore, the fuel transfer canal drains do not create a chokepoint at Turkey Point Unit 3.

RAI-25: Your June 30, 2008, response to GL 2004-02 states that the final sump fluid pH is achieved by manual addition of sodium tetraborate (STB) following a LOCA rather than by dissolution of STB already stored in the lowest elevation of the reactor building. Please provide the procedure for addition of sodium tetraborate following a LOCA. Where is the sodium

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 62 of 68 tetraborate stored during normal plant operation? How is the sodium tetraborate transported to the containment building and how is it physically added to the sump?

RAI-25 RESPONSE: Post Loss of Coolant Accident (LOCA) sump recirculation water is buffered with sodium tetraborate decahydrate manually from outside the containment. Sodium tetraborate decahydrate, which is stored in the Central Receiving Warehouse, is moved to the boric acid batching tank area in the auxiliary building, which is outside of containment.

The post accident chemical injection process is entered from either the "Loss of Reactor or Secondary Coolant" procedure for very small breaks where more than 155,000 gallons remains in the refueling water storage tank (RWST), or from the "Transfer to Cold Leg Recirculation" procedure for a break size where less than 155,000 gallons remains in the RWST. Both procedures contain the same system alignments and processes for mixing and transferring the buffer solution from the boric acid batching tank to the charging portion of the chemical and volume control system.

Water from the primary water system is used to fill the boric acid batching tank to a level specified by procedure. Sodium tetraborate decahydrate is manually added to the tank and mixed until dissolved. One of three boric acid transfer pumps is selected and valves are manipulated to transfer the buffer solution directly to the suction of one of three charging pumps. This injection alignment to the reactor coolant system continues until the boric acid storage tank contents are injected into the RCS. The buffered water spills out of the break and mixes with containment sump water inside of containment. The first batch of buffer solution is injected into the reactor coolant system within eight hours following a LOCA. As required, Nuclear Chemistry draws a sample of recirculation flow from the residual heat removal system and determines sump pH in the hot lab. This process of batching, buffer injection, and pH determination is repeated until the containment sump pH is greater than 7.2.

RAI-26: What surveillance requirements are in place to ensure that the required quantity of sodium tetraborate is available to provide adequate sump buffering?

RAI-26 RESPONSE: Turkey Point Nuclear Plant procedure "Schedule for Plant Checks and Surveillances" requires quarterly verification to: "Ensure that 66 drums of Borax (Sodium Tetraborate Decahydrate) are available in the Central Receiving Warehouse."

RAI-27: What surveillance requirements are in place to ensure that the sodium tetraborate's chemical and physical properties are maintained in a manner that allows for timely addition, dissolution, and adequate pH control? Are chemical tests performed periodically to ensure the buffer capacity of the stored sodium tetraborate? Are physical tests performed to ensure that densification of the sodium tetraborate has not occurred over time? If the sodium tetraborate is exposed to humid conditions in the storage facility the pellets/granules may solidify which would impede both dissolution and addition to the sump. How is this potential phenomena addressed at Turkey Point?

RAI-27 RESPONSE: As discussed in the response to RAI-25, the emergency operating procedures call for the addition of the first batch of buffer within eight hours. This period of time is sufficient to prepare for and stage the sodium tetraborate decahydrate near the boric acid

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 63 of 68 batching tank room in preparation for the first round of batching. The boric acid batching tank has an electric mixer which is sufficient to insure dissolution of the chemical into solution. In the event the in-place mixer is out of service, the emergency operating procedures direct the technical support center staff to set up a nitrogen bottle and sparging rod at the tank to facilitate mixing. Sodium tetraborate decahydrate is accepted by the NRC as a suitable chemical for pH control of post-LOCA sump water. Calculations for post-LOCA sump pH control with this buffer are in-place, and the emergency operating procedures for mixing and injecting the buffer solution comply with requirements. Per procedure, the pH is checked by Nuclear Chemistry and when sump pH gets to 7.2 further addition of buffer is not required.

As discussed in RAI-26, the storage and availability of the material is covered under a procedure that assures the availability on demand of sufficient quantity of the material.

However, sodium tetraborate decahydrate is not included in other plant chemical specification or verification procedures.

FPL conducted a visual inspection to ensure that the material was still granular in nature during preparation of this response. FPL will analyze a sample to ensure its suitability and will periodically re-sample. FPL will proceduralize this requirement.

RAI-28: Because addition of the sodium tetraborate is performed manually (as opposed to a passive system in the containment) the amount of time required to add the required amount to buffer to the sump pool may be longer. Provide the amount of time needed to manually add the required amount of sodium tetraborate. Has the dose for the personnel performing the manual addition process been estimated? Does the time dependant sump pH profile used to determine material dissolution (e.g. aluminum, calcium, silica) consider the time required to manually add the sodium tetraborate?

RAI-28 RESPONSE: As noted in the response to RAI-25, emergency operating procedures require the addition of sodium tetraborate decahydrate to begin within eight hours following a loss of coolant accident (LOCA). Calculations for the addition of the buffer, via emergency operating procedures, result in a sump pH starting at 4.95 and increasing to a pH of 7.2 within approximately 39 hours4.513889e-4 days 0.0108 hours 6.448413e-5 weeks 1.48395e-5 months from the start of buffer addition. This is based on a one hour batch and addition cycle time by operations. Hence, the post-LOCA sump pH profile for Turkey Point Unit 3 is from 4.95 to 7.2 over a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period.

RAI-25 requests information regarding post-LOCA operator actions inside or near containment related to the mixing and addition of buffer solution. As discussed in RAI-25, the mixing and transfer of buffer solution to the containment sump is conducted in the auxiliary building which is outside of containment and away from the direct shine source term in containment. Following the accident at Three Mile Island, a dose and shielding review was conducted for Turkey Point Units 3 and 4 in accordance with the recommendations and limits established by NUREG-0578 regarding TMI-2 short term lessons learned. These criteria endorsed 10 CFR 50, Appendix A, GDC-1 9 limits of 5 Rem for these types of post-LOCA operator actions and were also adopted by NUREG-0737 regarding TMI action plan requirements. The dose and shielding review included the boric acid batching room and resulted in recommendations for physical changes and additional analysis to meet these dose criteria. Subsequent NRC inspections and the issuance of the Safety Evaluation Report concluded that plant changes and analysis were in compliance with the criteria of GDC-19 for plant personnel radiation exposures.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 64 of 68 This sump pH timing profile, discussed earlier, was used as: i) input to the Turkey Point Unit 3 calculations using the LOCA Deposition Model (LOCADM) developed by the Westinghouse Owners Group, ii) as input to post-LOCA chemical analysis conducted by Alion Science and Technology, and iii) in testing at the VUEZ facility.

RAI-29: The June 30, 2008, GL 2004-02 response states that buffer addition occurs until a pH of 7.2 is achieved. How is the sump fluid pH monitored following a LOCA to ensure that an adequate quantity of sodium tetraborate has been added to achieve a pH of no lower than 7.2?

RAI-29 RESPONSE: As discussed earlier in the response to RAI-25, emergency procedures require post-LOCA buffer addition to begin within eight hours, and continue until Nuclear Chemistry determines, via residual heat removal system sampling, that sump recirculation flow pH is determined to be greater than 7.2.

RAI-30: Please describe how the possible contact of Containment Spray water with the aluminum ladders stored above the LOCA flood level at the 58' - 0" Elevation has been considered with respect to chemical effects, i.e. will not adversely impact the sump strainers with respect to chemical effects.

RAI-30 RESPONSE: Alion Science and Technology performed plant-specific chemical effects testing for Turkey Point Unit 3, and a summary of the results are presented in the June 30, 2008 supplemental response in Topic 3.o.

The aluminum surface area in containment is summarized in Table 3.o.1, wherein the total aluminum surface area in containment is stated as 51,740 ft 2, of which 7.5 % is submerged and 92.5% is not submerged. The total square footage of the aluminum ladders surface area was conservatively calculated to be 100 ft2 . This represents 0.21 % of the un-submerged aluminum surface area in the calculations. FPL has reviewed the calculations and the conservative assumptions made regarding the percentage of submerged and un-submerged aluminum and finds that the methods and subsequent testing sufficiently bound potential chemical effects of the additional 100 ft2 of aluminum associated with these ladders.

RAI 31: Page 29 of the June 30, 2008 supplemental response states that the replacement strainer design does not have trash racks. The supplemental response also states that the original sump design did not include trash racks. However, the staff noted that existing TS 4.5.2.e.3 refers to trash racks being present. Are there plans to revise TS 4.5.2.e.3 to remove the reference to a trash rack being present to be consistent with the current design of the Turkey Point Unit 3 sump?

RAI-31 RESPONSE: The existing Unit 3 Technical Specification (TS) Surveillance Requirement 4.5.2.e.3 reads as follows:

"[Each ECCS component and flow path shall be demonstrated OPERABLE: ... At least once per 18 months by:] A visual inspection of the containment sump and verifying that the suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or abnormal corrosion."

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 65 of 68 The Surveillance Requirement specifically refers to "sump components" and parenthetically refers to trash racks, screens, etc. as examples of sump components.

During FPL's preparation, review, and verification of the Generic Letter 2004-02 Supplemental Responses for Turkey Point Unit 3, this TS Surveillance Requirement and the corresponding Bases were reviewed to determine whether any changes were required or warranted. The FPL review determined that: 1) no change was required to the Surveillance Requirement, which requires the sump components to be inspected to show no evidence of structural distress or abnormal corrosion, and 2) the parenthetical phrase "(trash racks, screens, etc.)" was intended to represent examples of "sump components" to be inspected. FPL also determined that a formal License Amendment Request was not required, but an explanation should be provided in the Bases to clarify this issue.

Therefore, in order to clarify the scope and intent of the Surveillance Requirement, the applicable TS Bases were modified to read as follows:

"Technical Specifications Surveillance Requirement 4.5.2.e.3 requires that each ECCS component and flow path be demonstrated OPERABLE every 18 months by visual inspection which verifies that the sump components (trash racks, screens, etc.) show no evidence of structural distress or abnormal corrosion. The strainer modules are rigid enough to provide both functions as trash racks and screens without losing their structural integrity and particle efficiency. Therefore, the strainer modules are functionally equivalent to trash racks and screens.

Accordingly, the categorical description, sump components, is broad enough to require inspection of the strainer modules."

The revised Bases thus make it clear that the Turkey Point Unit 3 design does not include trash racks or screens.

Based on the above discussion, FPL does not plan to revise TS Surveillance Requirement 4.5.2.e.3.

RAI-32: Page 26 of the June 30, 2008 supplemental response indicates that the replacement ECCS strainer design is a common, non-independent strainer assembly shared by both trains.

The response indicates that this design is not a departure from the current licensing basis because the original ECCS sump intake design included a permanent cross-connection between trains that was located outside of containment. Please provide the following additional information concerning the original ECCS sump intake design:

RAI-32a: Please provide a piping system diagram that includes the cross-connection line between the ECCS sump suction lines.

RAI-32a RESPONSE: A portion of the requested Turkey Point Unit 3 drawing, 5613-M-3050 Sheet 1, is provided below in Figure 32.a-1 for the Residual Heat Removal System (RHR). The cross-tie valves 3-752A and 3-752B are shown as locked open, hence the current alignment and licensing basis is for a common suction cross-tie in this part of the system.

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 66 of 68 RAI-32b: Please state whether the original ECCS sump suction lines were normally isolated, independent lines during sump recirculation mode that could be cross-connected by operator action, or whether the cross-connect was normally open in recirculation mode.

RAI-32b RESPONSE: The 1964 Turkey Point Unit 3 & 4 Preliminary Safety Analysis Report (PSAR) Revision 0, Chapter 6, Figure 6-1, "Safety Injection System" shows in the Unit 3 Figure that these same RHR System cross-tie valves are in the locked-open position per the original design. Also, PSAR Supplement 2 gives a response to the AEC (NRC) on Question 9.2, wherein a Figure 9.2-1, "Safety Injection and Spray System," shows the same cross-tie valves in the locked open position. This confirms that the original ECCS sump suction lines to the RHR pumps were configured in a cross-tied arrangement with the cross-tie valves in the locked-open position for the recirculation mode.

RAI-32c: Please identify the type of valves installed on the cross-connect line (if any), and whether remote or manual operation would be necessary to operate the valves.

RAI-32c RESPONSE: The subject cross-tie valves discussed above are manually operated, locked-open gate valves provided with reach rods in the event that remote manual operation is desired.

RAI-32d: If the cross-connection line was a normally isolated line during recirculation, then this would indicate that the original ECCS sump screens were independent screens that could be shared if desired during an event, which is a different configuration than the current replacement strainer design that does not have independence. Please justify any change to the plant licensing basis that is necessary if the independence of the original sump screens was reduced.

RAI-32d RESPONSE: See above responses. The Turkey Point plant licensing basis is maintained with the new sump screen design since the original ECCS sump suction lines to the RHR pumps were configured in a cross-tied arrangement with the cross-tie valves in the locked-open position.

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Turkey Point Unit 3, Docket No. 50-251 Attachment 1, L-2009-063 Page 68 of 68 RAI-33: The NRC staff considers in-vessel downstream effects to not be fully addressed at Turkey Point Unit 3 as well as at other pressurized-water reactors. Turkey Point Unit 3's supplemental response refers to draft WCAP-16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous, and Chemical Debris in the Recirculating Fluid." The NRC staff has not issued a final SE for WCAP-16793-NP. The licensee may demonstrate that in-vessel downstream effects issues are resolved for Turkey Point Unit 3 by showing that the licensee's plant conditions are bounded by the final WCAP-16793-NP and the corresponding final NRC staff SE, and by addressing the conditions and limitations in the final SE. The licensee may alternatively resolve this item by demonstrating, without reference to WCAP-16793 or the staff SE, that in-vessel downstream effects have been addressed at Turkey Point Unit 3. In any event, the licensee should report how it has addressed the in-vessel downstream effects issue within 90 days of issuance of the final NRC staff SE on WCAP-16793. The NRC staff is developing a Regulatory Issue Summary to inform the industry of the staffs expectations and plans regarding resolution of this remaining aspect of Generic Safety Issue-191.

RAI-33 RESPONSE: FPL was at the recent joint NEI/NRC meeting on January 14 and 15, 2009 regarding issues related to the final resolution of Generic Issue 2004-02. This RAI and presentations by the NRC are understood and actions will be taken by FPL to meet the requested NRC schedule. FPL is confident that it will be able to demonstrate that Turkey Point Unit 3 in-vessel downstream effects will be bounded by the final version of WCAP-16793-NP.

Also, at this time, FPL believes that Turkey Point Unit 3 will be in compliance with the NRC's safety evaluation of the final WCAP-16793-NP.

In FPL's June 30, 2008 supplemental response on Generic Letter 2004-02, the response to Topic 3.n stated that Turkey Point Unit 4 was bounded by the generic results for in-vessel fuel effects related to fiber and debris bypass contained in WCAP-16793-NP, Rev.0. As further noted in the response to Topic 3.n, Turkey Point Unit 3 performed a unit specific analysis for chemical plate out on the fuel that yielded satisfactory results for fuel temperatures of only 366 OF. In the June 30, 2008 supplemental response, Attachment 2, Enclosure 2, FPL also provided Turkey Point Unit 3 responses to NRC staff's Limits and Conditions related to the staff's initial review of WCAP 16793-NP.

FPL believes that sufficient evaluation has been conducted for Turkey Point Unit 3 to demonstrate acceptable in-vessel conditions. However, at the recent joint NEI/NRC meeting on January 14 and 15, 2009, NRC requested industry assurance that plants will submit a final in-vessel evaluation within 90 days after NRC issues a safety evaluation (SE) on the final version of WCAP-16793-NP. FPL will evaluate the NRC SE at the time of issuance to determine if there are additional impacts that require new or different methods for evaluating this issue. FPL fully intends to meet NRC's schedule request.

Text

FPL MAR 1:9 2009 L-2009-063 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Florida Power & Light Company Turkey Point Unit 3 Docket No. 50-250

Subject:

Response to NRC Request for Additional Information Regarding the Responses to GL 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors,"

TAC NO. MC 4725

References:

(1) Letter from B. L. Mozafari (U. S. Nuclear Regulatory Commission) to J. A.

Stall (FPL), "Turkey Point Nuclear Plant, Unit 3 - Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Sump Recirculation During Design Basis Accidents at Pressurized-Water Reactors, Request for Additional Information" December 22, 2008 (TAC NO. MC4725)

(2) Letter L-2008-033 from William Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris, Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated February 28, 2008 (ML080710429)

(3) Letter L-2008-138 from William Jefferson, Jr., (FPL) to U. S. Nuclear Regulatory Commission "Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated June 30, 2008 (ML081960386)

(4) Generic Letter 2004-02, "Potential Impact 'of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004 This submittal provides the Florida Power and Light Company (FPL) responses to the U. S. Nuclear Regulatory Commission (NRC) request for additional information (Reference 1) regarding our Supplemental Information provided previously (References 2 and 3) on the subject of the NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors" (Reference 4).

an FPL Group company

Turkey Point Unit 3, Docket No. 50-250 L-2009-063, Page 2 of 3 provides the Turkey Point Nuclear Plant, Unit 3 responses to the request for additional information. The supplemental information previously provided, in References 2 and 3, continues to apply. This information is being provided in accordance with 10 CFR 50.54(f).

As part of this response, there was one commitment made, as follows:

1. FPL will analyze a sodium tetraborate sample to ensure its suitability and will periodically re-sample. FPL will proceduralize this requirement.

Letter'L-2008-226 from William Jefferson, Jr. (FPL) to U.S. Nuclear Regulatory Commission "Request for Extension of Completion Date of the Turkey Point Unit 3 Generic Letter 2004-02 Actions," dated October 31, 2008 provided a target completion date for a milestone to evaluate that Turkey Point Unit 4 testing, bounds the Unit 3 strainer system. This evaluation will be complete on or before May 31, 2009.

Please contact Mr. Robert Tomonto at (305) 246-7327, if you have any questions regarding this response.

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

Executed on March __, 2009.

Sincerely yours, William Jfei'son, JK Site Vice President Turkey Point Nuclear Plant

Attachment:

(1)

Turkey Point Unit 3, Docket No. 50-250 L-2009-063, Page 3 of 3 cc: NRC Regional Administrator, Region I1 USNRC Project Manager, Turkey Point Nuclear Plant Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant

Turkey Point Unit 3, Docket No. 50-250 Attachment 1, L-2009-063 Page 1 of 68

.Attachmerit-1 Responses to NRC's Request for Additional Information on FPL's Turkey Point Nuclear Plant Unit 3 (PTN3)

GL 204-02-Supplementat-Responses-dated--February 28, 2008 and June 30, 2008 Introduction Overview of Turkey Point Unit 3 Conservatisms:

In FPL's Turkey Point Unit 3 Supplemental response of June 30, 2008, FPL summarized some of the actions and analyses that provided conservatism and margin to Turkey Point Unit 3 compliance with GL 2004-02. These included:

The new sump strainer system installed in Turkey Point Unit 3 in the fall of 2007 is a General Electric design with a surface area of approximately 5,500 ft2 with 3/32-inch perforations to retain debris. The new strainers replaced the previous sump screens which had a combined total surface area of approximately 63ft_2 with a.4-inch screen mesh.

Debris head loss testing was performed for a variety of surface areas. Although testing demonstrated that acceptable debris head losses could be obtained for 3,256 ft2 , FPL installed approximately 5,500 ft 2 for additional margin.

0 A uniform factor of 1.1 has been applied to the Zone of Influence (ZOI) radius to ensure the calculation was conservative.

0 100% of the Calcium Silicate.(cal-sil).generated.is.assumed..to.transport to the strainers.

100% of unqualified coatings, regardless of types and location inside containment, were assumed to fail as particulates and transport to the screen. EPRI and industry testing indicates some unqualified coatings do not fail and some coatings fail as chips and may not transport to the sump.