L-2010-131, Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196

Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196

ML101760019
Person / Time
Site:	Turkey Point
Issue date:	06/23/2010
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2010-131, TAC ME1624, TAC ME1625
Download: ML101760019 (76)

Text

JUN2 3 20of91 FPL. L-2010-131 POWERING TODAY. 10 CFR 50.90 EMPOWERING TOMORROW.

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 (TAC NOS. ME1624 and ME1625)

References:

(1) W. Jefferson (FPL) to U.S. Nuclear Regulatory Commission (L-2009-133),

"License Amendment Request 196: Alternative Source Term and Conforming Amendment," Accession No. ML092050277, June 25, 2009.

(2) J. Paige (NRC) to M. Nazar, "Turkey Point Units 3 and 4 - Request for Additional Information Regarding Request to Adopt Alternate Source Term (TAC Nos.

ME1624 and ME1625)," Accession No. ML100700446, March 24, 2010 (3) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-065), "Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 (TAC Nos. ME 1624 and ME1625)," Accession No. ML101090027, April 14, 2010.

(4) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-083),

"Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST),"

Accession No. ML101450028, May 21, 2010 (5) Email from J. Paige (NRC) to S. Franzone (FPL), Follow-up Requests for Additional Information Re: Turkey Point, Unit 3 and 4 AST LAR, Accession No. ML101480750, May 28, 2010.

By letter L-2009-133 dated June 25, 2009 [Reference 1], Florida Power and Light (FPL) requested to amend Facility Operating Licenses DPR-31 and DPR-41 and revise the Turkey Point Units 3 and 4 Technical Specifications (TS). The proposed amendments revise the TS to adopt the alternative source term (AST) as allowed in 10 CFR 50.67.

Additional information was requested by the NRC staff by letter dated March 24, 2010

[Reference 2]. FPL provided its initial RAI response on April 14, 2010 [Reference 3]

and followed it with a supplemental response on May 21, 2010 [Reference 4]. On May 28, 2010, FPL received an email from the NRC containing six additional RAIs related to the quality of the meteorological data [Reference 5]. During a public meeting at NRC headquarters in Rockville, MD on June 7, 2010, the NRC noted that an AST proposed change to TS 3/4.7.5 Surveillance Requirement (SR) 4.7.5.c.2a regarding the control room filter test acceptance criteria might conflict with Regulatory Guide (RG) 1.52 an FPL Group company k

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Page 2 of 2 recommendations. The attachment to this letter provides the FPL response to both the six RAIs and this question from the NRC staff.

In accordance with 10 CFR 50.91 (b)(1), a copy of this letter is being forwarded to the State Designee of Florida.

This submittal does not alter the significant hazards consideration or the environmental assessment previously submitted by FPL letter L-2009-133 [Reference 1].

This letter contains no new commitments and no revisions to existing commitments.

Should you have any questions regarding this submittal, please contact Mr. Robert J.

Tomonto, Licensing Manager, at (305) 246-7327.

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

Executed on June 2., 2010.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant Attachment cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Resident Inspector, Turkey Point Nuclear Plant Mr. W. A. Passetti, Florida Department of Health

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment License Amendment Request 196 Page 1 of 74 Response to 5/28/2010 RAIs on AST LAR Attachment Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 2 of 74 Response to 5/28/2010 RAIs for AST LAR Response to Request for Additional Information The following information is provided by Florida Power & Light (FPL) in response to the Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI). This information was requested to support License Amendment Request (LAR) 196, "Alternative Source Term (AST) and Conforming Amendment," submitted by FPL letter L-2009-133 on June 25, 2009 [Reference 1].

On March 24, 2010, FPL received a letter from the NRC Project Manager (PM) containing twenty RAIs from the Accident Dose Branch and the Containment and Ventilation Branch on AST LAR 196 [Reference 2]. On April 14, 2010, FPL provided its response [Reference 3] to these RAIs.

On April 27, 2010, a telephone conference call was held between FPL, NRC PM, and several NRC technical reviewers to discuss the response. Several issues developed during the call related to the quality of the meteorological data and resulted in six follow-up questions from the NRC Accident Dose Branch regarding the quality of the meteorological data supporting the AST LAR.

On May 12, 2010 another telephone conference call was held between FPL, NRC PM, and NRC technical reviewers to discuss the follow-up questions on the quality of the meteorological data for years 2003-2007. On May 21, 2010, FPL provided supplemental response addressing proposed changes to TS Table 4.4-4 on RCS Specific Activity and TS 3/4.7.5 on Control Room Emergency Ventilation System (CREVS) [Reference 4].

On May 28, 2010, FPL received an email from the NRC PM containing these six RAIs on the quality of the meteorological data supporting the AST LAR [Reference 5]. On June 7, 2010, a public meeting was held at the NRC headquarters in Rockville, MD in which issues regarding the quality of the meteorological data and the proposed CREVS TS change were discussed. In that meeting, the NRC noted that LAR 196 had proposed a change to TS 3/4.7.5 Surveillance Requirement (SR) 4.7.5.c.2 to reduce the methyl iodide penetration criteria from 2.5% to 1.25%

in order to increase the credited efficiency of the control room filter from 95% to 97.5% for elemental iodines and organic iodides. The NRC further noted that the proposed TS change was outside the recommended limits for filter efficiencies specified in Regulatory Guide (RG) 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered Safety Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants [Reference 6]. Accordingly, FPL is retracting this proposed SR change.

On June 11, 2010, FPL transmitted revised meteorological data sets for years 2005-2009 in support of AST LAR 196 [Reference 7].

As the time interval of the meteorological data set supporting AST LAR 196 has been changed, FPL's response to the six RAIs is provided here for years 2005-2009 only.

1. Pleaseprovide a detailed description of the technical review of the 2003 through 2007 hourly meteorologicaldata. What was the process and what specific criteria were used to determine the validity of the data? At what time intervals and at what levels of expertise were each review performed?

Review of the meteorological data for 2003 through 2007 used in support of the original LAR 196 submittal identified several instances where the data quality was less than what was expected. As stated in FPL's April 14, 2010 RAI response, the original AST submittal provided five years of meteorological data for which the most recent five year period had

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 3 of 74 Response to 5/28/2010 RAls for AST LAR been chosen to be most representative of current conditions. Since the original submittal, the 2008 and 2009 data sets have become available and have been determined to be of higher quality than the earlier 2003 and 2004 data sets. Accordingly, FPL has revised its selection of the five year period for supporting meteorological data from 2003-2007 to 2005-2009.

The revised hourly meteorological data for 2005-2009 was transmitted to the NRC by letter on June 11, 2010 after completing independent quality reviews of the data to assure that it provided a technically accurate representation of the meteorological conditions at the site.

The plant utilizes two towers to monitor meteorological conditions. The Land Utilization (LU) 10 meter meteorological (MET) tower is located just south of the plant and collects 10 meter data including temperature, wind speed, wind direction, and sigma theta values. This data is used primarily to supply plant meteorological conditions to support Emergency Plan requirements. The South Dade (SD) 60 meter MET tower is located some 5.5 miles south-southwest of the plant and collects similar data at both 10 meter and 60 meter elevations.

The data for the two elevations allows for characterization of both lower and upper meteorological conditions and for calculation of vertical temperature differences that provide the preferred means for determining atmospheric stability classes since they are effective indicators of worst-case stability conditions. This information is used primarily in the plant's radiological dose consequence analyses.

The designated site meteorological services contractor, Meteorological Solutions, Inc. (MSI),

reviews raw meteorological data that is forwarded periodically from the LU department. The hourly meteorological data then undergoes a series of programmatic quality data checks that flag invalid field contents, e.g., missing or out of range values, anomalous trends including persistent values or repeated sequences, and incomplete field strings. Based on diagnostic results, MSI's experience, and with the knowledge of LU management, MSI may make selected substitutions of good data for invalid or missing data in order to increase the data recovery rates to levels recommended by RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants. Such substitutions have included using LU 10 meter MET tower data for corresponding SD 10 meter MET tower data or using one SD channel of temperature data for another, i.e., cross-channel substitutions (B for A, A for B) at the same elevation, or using either LU or SD 10 meter wind direction data for SD 60 meter wind direction. The results are then formatted into listings that form the basis for the monthly, quarterly, and annual site meteorological reports.

Conversion of the hourly meteorological data for 2005-2009 supplied by the site into ARCON96 hourly card image input or into PAVAN card image input involved a quality comparison of the raw meteorological data and MSI processed meteorological reports. The comparison conducted by Numerical Application, Inc. (NAI) identified situations where invalid data might need to be replaced by "missing" or flagged as invalid (fields of nines per RIS 2006-04). Where such situations occurred, specifically for such items as zero wind speed that might be a valid calm wind speed, or might be an indication of invalid or missing reading, the reading was flagged for tracking purposes. Spot checking of the data was also carried out by plotting extracted information to identify anomalies, field validation via Excel spreadsheets, conditional highlighting of potential issues in spreadsheets. Differences, substitutions, or any anomalies were flagged in this manner such that either data resolution or

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 4 of 74 Response to 5/28/2010 RAIs for AST LAR elimination from the final reformatted data files could be accomplished. The MSI provided comparative data and justification for certain substitutions, e.g., using LU or SD 10 meter wind direction for invalid SD 60 meter wind direction, or using LU 10 meter wind directions and/or wind speeds for South Dade MET tower 10 meter wind directions and wind speeds.

These data substitutions and their proposed justifications were evaluated for validity.

Applicable guidance was taken from the NRC Regulatory Issues Summary RIS-2006-004 on ensuring the quality of meteorological data files used for accident dose assessment. Its guidance included assuring invalid data was indicated by fields of nines, e.g., 9999, and wind directions were indicated in the range from 1' to 3600. RIS recommendations on wind speed bins for the determination of Joint Frequency Distributions (JFD's) were also followed.

In the initial AST submittal, the JFD distributions based on the reported stability class were used as PAVAN input for calculation of the offsite (EAB and LPZ) X/Q values. The stability class is a derived value based on vertical temperature differences (60 meter minus 10 meter) as specified in RG 1.23. The stability class was previously calculated based on these substituted data sets using either the vertical temperature difference (AT) from a single channel (A 60-A 10 or B60-B 10) or from a combination (A 60 -B10 or B60 -Al 0) of two channels.

Channel A was nominally the "preferred" channel to retrieve stability class inputs. For the newly generated data sets, NAI independently calculated hourly stability class values, based on a consistent paired channel (A-A or B-B) process, to assure that no cross-channel biases could be introduced. Also, NAI decided to preferentially choose Channel A at all times, unless Channel A was bad. When Channel A was bad (either 10 meter or 60 meter instrument, or both), Channel B was used if both 10 and 60 meter Channel B readings were valid. If neither channel is available on a consistent channel basis, 9999 was used to indicate bad or missing stability data.

NAI used applicable regulatory guidance such as NUREG-0917 on screening meteorological data for anomalies and potentially problematic persistent patterns and the METDQA module to screen the hourly meteorological data for such items as:

1. Inconsistency between expected stability class and time of day (day or night)

2. Inconsistency between wind speeds and expected stability classes for those speeds

3. Inconsistent delta-T comparison to auto-convective lapse rate

4. Inconsistent stability classes detected during periods of precipitation

5. Large changes in stability class from one hourly period to the next

6. Persistence of wind direction, wind speed or stability class for longer than 8 or 12 consecutive hours (changed by NAI to screen for periods greater than 24 hrs)

7. Out of range wind speeds, or those that are identical between upper and lower sensors

8. Reports maximums, minimums, and other statistics for selected parameters NAI implemented this module from the ORNL RSICC code distribution center and added functionality which allowed the module to process information from the MSI processed files, formatted monthly reported met data, and pre-formatted ARCON96 data file formats.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 5 of 74 Response to 5/28/2010 RAls for AST LAR The process described above including selected substitutions identified in RAI #3 below has resulted in data recovery rates in excess of the 90% criterion specified in RG 1.23 except for the first six months of 2005 when the SD 60 meter Channel A Temperature values were flagged as invalid resulting in a yearly recovery rate of only 46.6%. However, the recovery rate for the SD 60 meter Channel A Temperature is 86.72% when averaged over the five year period 2005-2009. See Table 1-1 below for a summary of yearly recovery rates for measured key meteorological parameters.

Table 1-1 Turkey Point - Met Data Recovery Percentages - After MSI and NAI Screenin!

After Substitution of 2005,2007 & 2009 10M Wind Direction into 60M Wind Directions Year Hours Stability 10M WS 60M WS 10M Dir 60M Dir 10MAT 10MBT wI AT 60M B T 2005 8760 94.79% 99.79% 90.89% 99.09% 99.79% 94.53% 96.64% 94.77%

2006 8760 99.75% 100.00% 100.00% 100.00% 100.00% 98.54% 95.70% 98.39% 95.53%

2007 8760 99.76% 99.84% 94.24% 97.24% 97.24% 91.54% 99.77% 91.52% 99.75%

2008 8784 99.75% 99.80% 100.00% 100.00% 100.00% 98.82% 99.00% 98.75% 98.96%

2009 8760 99.97% 100.00% 100.00% 100.00% 100.00% 98.32% 99.98% 98.30% 99.95%

All 43824 98.80% 99.89% 97.03% 99.27% 99.41% 96.35% 98.22% 97.79%

2. Were sigma theta wind measurements used to determine the atmosphericstability category for any of the data used in the ARCON96 or PA VAN computer assessments?

No sigma theta wind measurements were used to determine the atmospheric stability category for any of the data used in the ARCON96 or PAVAN computer assessments for 2005-2009.

3. Page 12 of the enclosure to the April 14, 2010 response states that in some cases, substitutions were made when there was a considerableamount of invaliddatafrom the primary measurement trains. Were substitutions madefor infrequent random occurrences of afew hours duration? Does the discussion at the top ofpage 13 summarize all of the substitutions? Were the temperature difference data in the computer inputfiles for 2003, the second half of 2004, the second half of 2005, the last three quartersof 2006, and 2007, other thanAugust through October, inclusive, essentially all measured only on the primary tower?

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 6 of 74 Response to 5/28/2010 RAIs for AST LAR NAI reviewed each of the MSI implemented substitutions in 2005-2009 for accurate data transfer from the source files as well as for justifications for making the substitutions. The following general decision-making guidelines were applied to these substitutions.

• Use Channel A AT unless only Channel B AT is available.

The MSI supplied data frequently switched between Channel A and B use for determining stability class. The NAI QA data consistently used Channel A 10 meter and 60 meter temperature measurements, when they were available. If either or both Channel A temperature readings were missing, only then was Channel B used (if, of course, the values were present and valid). The NAI QA data does not contain any mixed Channel A and B based stability class results.

" Invalid data marked with Fields of Nines Consistent with the guidance in RIS 2006-04, invalid data was be marked with appropriate 9999 filled fields. Blank, "MISG," "N/A," and "-" fields were replaced, as well as values that were out of range (negative values, for instance).

" Treatment of Zero or Very Low Wind Speeds Although MSI generally assigned missing or invalid tags to zero or very low wind speeds; such readings in the raw data files were examined for the possibility that such readings were legitimate "calm" conditions, and not an indication of stuck or malfunctioning wind speed instrumentation. Each occurrence was therefore identified and dispositioned.

" Resolution of Persistence Reporting from METDQA Program Module The METDQA program module identified potentially problematic persistence of wind direction, speed, or stability class. Any cases identified by METD QA lasting longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were examined to determine if the persistence represents actual met data/site conditions, or potentially results from stuck or malfunctioning instrumentation.

" Resolution of "Stability Class Jumps" Identified by METDQA Program module.

The METDQA program module also identified potentially problematic jumps of 2 or more stability classes in consecutive hourly readings. Any cases identified by METDQA were examined to determine if the stability class jump represented actual met data/site conditions, or potentially resulted from invalid readings or other instrumentation problems.

" Visual Examination of Plotted Met Data for Anomalous Trends The Excel spreadsheets which capture and process the meteorological data were used to plot selected data fields, and the plots were examined for potential impact of retaining or rejecting the responsible met data readings. This process was subjective but could identify trends that strictly digital screening might miss.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 7 of 74 Response to 5/28/2010 RAIs for AST LAR See the attached Data Substitution Summary that provides a detailed accounting of all data substitutions applied to the Turkey Point SD MET Tower "Raw" data that were generated by either MSI or NAT.

4. Regulatory Guide 1.23, "MeteorologicalMonitoringProgramsfor Nuclear PowerPlants,"

states that vertical temperaturedifference accuracyshould be within +/-0.1 'C (+0.18 'F).

Were each pair of temperaturesensors used to make measurements of temperature difference as a function of height calibratedjointly as a pair? This would includepairing of one temperaturesensor with another temperaturesensor of anotherpair, if one sensor of a set pairwas unavailable.

The meteorological temperature instrumentation is calibrated and replaced on a six month interval using approved plant procedures. The temperature instrumentation (2 @10m and 2

@ 60m) is calibrated in a series of sequential and overlapping tests. The temperature elements (thermistors) are initially verified for range and accuracy with an acceptance criterion of +/-0.90 F in a Measurement & Test Equipment (M&TE) dry well calibrator. The temperature elements are then installed in the tower and the ambient temperature loop instrumentation, from the tower to a CR1000 data logger, is procedurally verified to be within +/-0.90 F of the M&TE readings using a handheld digital M&TE thermometer. The in-situ data taken (5 data points) is averaged and compared to the averaged M&TE readings.

Another verification of the ambient and differential temperature data is performed utilizing an electronic check between the data logger, the plant ERDADS computer, and the control room recorder. A final loop integrity check is performed and documented.

A review of the as-found/as-left meteorological ambient temperature loop data taken for 2005-2009 was performed (see Tables 4-1 & 4-2 below). The temperature data for June 2005 was not retrievable. The as-found data for December 2005 and June 2009 for the 10m temperatures were determined to be slightly low and out of the 0.9 'F tolerance. The remaining as-found and all of the as-left data for this period were within +/-0.9'F.

The differential temperature data is digitally calculated by comparison of the ambient temperatures within the data logger at the meteorological tower. The data is calculated from paired temperature elements (60m-Om), A-A and B-B, and digitally transmitted to the ERDADS computer. A review of the differential temperature data was performed using the as-found/as-left data from the ambient temperature calibrations and calculating the respective temperature differentials (see Tables/Figures below). For December 2005, the differential temperature readings were uncharacteristically high due to the out-of-tolerance ambient temperature as-found data for that calibration date. It was noted that approximately 50% of the as-found/as-left data fell within the +/-0.1 8'F criteria specified in Regulatory Guide (RG) 1.23, Rev 1, Meteorological Monitoring Programs for Nuclear Power Plants [Reference 12]

while approximately 90% of the data fell within +/-0.540 F.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 8 of 74 Response to 5/28/2010 RAIs for AST LAR Table 4-1 Comparison of As-Found Differential Temperatures Between A and B Temperature Probes As Found (Averages)

Normalized Normalized Normalized Normalized Temp A @ Temp B @ Temp A @ Temp B @ Normalized Normalized 60m 60m lom lom ATemp A ATemp B M&TE Temp Temp A- Temp Temp B - M&TE Temp Temp A - Temp Temp B- A60m - B60m -

Date 60m 60A M&TE 60B M&TE lOm 10A M&TE 10B M&TE AlOm B110m Dec-05 77.02 76.79 -0.23 76.75 -0.27 79.52 78.33 -1.19 78.45 -1.07 0.96 0.8 Jun-06 80.04 80.06 0.02 80 -0.04 85.74 85.72 -0.02 85.57 -0.17 0.04 0.13 Dec-06 76.12 76.73 0.61 75.57 -0.55 77.22 77.53 0.31 76.76 -0.46 0.3 -0.09 Jun-07 85.3 84.98 -0.32 85.15 -0.15 88.39 88.22 -0.17 88.23 -0.16 -0.15 0.01 Dec-07 66.96 67.27 0.31 67.42 0.46 76.26 76.5 0.24 76.65 0.39 0.07 0.07 Jun-08 83.04 83.33 0.29 83.23 0.19 85.3 85.55 0.25 85.9 0.6 0.04 -0.41 Dec-08 62.02 61.92 -0.1 61.83 -0.19 64.58 64.24 -0.34 64.07 -0.51 0.24 0.32 Jun-09 81.2 80.58 -0.62 80.82 -0.38 80.78 79.84 -0.94 80.26 -0.52 0.32 0.14 Dec-09 79.82 79.58 -0.24 79.64 -0.18 80.12 79.27 -0.85 79.54 -0.58 0.61 0.4 Figure 4-1 Normalized Differential Temperatures - As Found

• ATemp A a ATemp B 1.2 1

0.8 0.6 4 i 0.4 tI 0.2 0

-0.2

-0.4

-0.6

-0.8 Dec-05 Jun-06 Dec-06 Jun-07 Dec-07 Jun-08 Dec-08 Jun-09 Dec-09

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 9 of 74 Response to 5/28/2010 RAIs for AST LAR Table 4-2 Comparison of As-Left Differential Temperatures Between A and B T emperature Probes As Left (Averages)

Normalized Normalized Normalized Normalized Temp A @ Temp B @ Temp A @ Temp B @ Normalized Normalized 60m 60m lom lom ATemp A ATemp B M&TE Temp Temp A - Temp Temp B - M&TE Temp Temp A- Temp Temp B- A60m - B60m -

Date 60m 60A M&TE 60B M&TE lom 10A M&TE 10B M&TE AlOm B1 Om Dec-05 78.02 77.85 -0.17 77.94 -0.08 80.38 80.53 0.15 80.68 0.3 -0.32 -0.38 Jun-06 82.42 81.98 -0.44 82.09 -0.33 84.32 84.06 -0.26 83.93 -0.39 -0.18 0.06 Dec-06 77.34 76.84 -0.5 77.06 -0.28 77.04 76.3 -0.74 76.22 -0.82 0.24 0.54 Jun-07 86.31 86.22 -0.09 86.26 -0.05 87.69 87.46 -0.23 87.77 0.08 0.14 -0.13 Dec-07 69.12 69.08 -0.04 69.49 0.37 75.02 75.72 0.7 75.56 0.54 -0.74 -0.17 Jun-08 83.17 83.35 0.18 83.11 -0.06 84.51 84.61 0.1 84.57 0.06 0.08 -0.12 Dec-08 63.64 63.67 0.03 63.48 -0.16 63.5 63.38 -0.12 63.18 -0.32 0.15 0.16 Jun-09 82.4 81.52 -0.88 81.7 -0.7 81.82 81.5 -0.32 81.4 -0.42 -0.56 -0.28 Dec-09 79.64 79.08 -0.56 78.97 -0.67 81.3 81.03 -0.27 81.14 -0.16 -0.29 -0.51 Figure 4-2 Normalized Differential Temperatures - As Left

• ATemp A m ATemp B]

1.2 1

0.8 0.6 U 0.4 9i 0.2

• U 0

U U

-0.2 *

-0.4 U

-0.6

-0.8 De .c-05 Jun-06 Dec-06 Jun-07 Dec-07 Jun-08 Dec-08 Jun-09 Dec-09

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 10 of 74 Response to 5/28/2010 RAIs for AST LAR Table 4-3 As-Found to As-Left Normalized Differential Temperatures for A Temperature Probes with Mean Values AL AF Atemp Atemp Mean 12/10/04 to 6/28/05 0.28 NA

• 6/28/ 05 to 12/9/05 NA 0.96

• 12/9/05 to 6/9/06 -0.32 0.04 -0.140 6/9/06 to 12/13/06 -0.18 0.30 0.060 12/13/06 to 7/13/07 0.24 -0.15 0.045 7/13/07 to 12/5/07 0.14 0.07 0.105 12/5/07 to 6/18/08 -0.74 0.04 -0.350 6/18/08 to 12/2/08 0.08 0.24 0.160 12/2/08 to 6/23/09 0.15 0.32 0.235 6/23/09 to 12/9/09 -0.56 0.61 0.025 12/9/09 to 6/10 -0.29 TBD _____

• • ATempA Mean is0.0175 Figure 4-3 AF to AL Delta Temp A-A 0.80 0.60 0.40 0.20 0.00 I -0.20

-0.40

-0.60

-0.80

-1.00

/ 'I, 5/ C/ / / / /' V10,

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 11 of 74 Response to 5/28/2010 RAIs for AST LAR Table 4-4 As-Found to As-Left Normalized Differential Temperatures for B Temperature Probes with Mean Values ATempB (uF)

AL AF Mean Atemp Atemp 12/10/04 to 6/28/05 0.77 NA 6/28/ 05 to 12/9/05 NA 0.80 **

12/9/05 to 6/9/06 -0.38 0.13 -0.125 619106 to 12/13/06 0.06 -0.09 -0.015 12/13/06 to 7/13/07 0.54 0.01 0.275 7/13/07 to 12/5/07 -0.13 0.07 -0.030 12/5/07 to 6/18/08 -0.17 -0.41 -0.290 6/18/08 to 12/2/08 -0.12 0.32 0.100 12/2/08 to 6/23/09 0.16 0.14 0.150 6/23/09 to 12/9/09 -0.28 0.40 0.060 12/9/09 to 6/10 -0.51 TBD

• • ATempB Mean is 0.015625 Figure 4-4 AF to AL Delta Temp B-B 1.20 1.00 0.80 i 0.60 0.40 0.20 I) 0.00

-0.20

-0.40

-0.60

-0.80

-1.00 -I.

10

I, / / / 'to", / I/ /

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 12 of 74 Response to 5/28/2010 RAIs for AST LAR As shown in Tables/Figures 4-1 and 4-2 above, meteorological tower ambient temperature instrument accuracies are generally within the +0.9°F of M&TE as specified in RG 1.23.

However, the instrument accuracies for the vertical temperature differences are often outside of the +/-0. 1 8'F specified in RG 1.23. The vertical AT measurement is important as it is the preferred method for determining the Pasquill stability classes at nuclear power plants for licensing purposes because it is an effective indicator for the worst-case stability conditions.

The stability class is an indication of atmospheric stability or the amount of turbulent mixing in the atmosphere and its effect on effluent dispersion.

As shown above, the as-found and as-left temperature readings for both channels at both elevations are "normalized" against their corresponding M&TE readings (Temp - M&TE).

The vertical temperature difference (AT) for each channel is then calculated by subtracting the normalized channel temperature at 10 meters from the normalized channel temperature at 60 meters (T 60-T10 ). The resulting AT values are the as-left and as-found normalized AT values for each channel that define the instrument accuracies between the calibrations, i.e.,

beginning with the as-left values and ending with the as-found values over the six month calibration interval. During this period, the instruments will experience some drift which, for purposes of this discussion, has been assumed to be linear in its behavior. Thus, as shown in Tables/Figures 4-3 and 4-4 above, a six month representative AT value can be derived by taking the average of the beginning and end AT values for each temperature channel. When the AT is within the +/-0.18°F specified in RG 1.23, no adjustment to the meteorological data would be considered necessary. However, since the AT values have been observed to be outside of this accepted range, the averaged AT value for each channel will be applied as a bias or correction factor to the hourly meteorological data. The effects of this correction will be small shifts in the calculated stability classes for the hourly meteorological data and result in small changes to the calculated atmospheric dispersion factors (X/Qs). When the resultant biased X/Q values exceed the unbiased X/Qs, the more conservative value will be used. This technical approach will assure conservative radiological dose consequences for the analyzed design basis accidents.

5. With regardto the discussion on page 13, providefurther clarificationof the basesfor the differences in the reported hourly atmosphericstability categories when comparingthe 2005 through 2006 data provided in support of the current LAR and the data that were providedfor the Turkey Pointcombined operating license application (COLA). Why are the atmosphericstability categoriesprovided in support of the currentLAR more appropriatefor use in the currentLAR than the atmosphericstability categories in the Turkey Point COLA data base?

The quality review of the PTN meteorological data for 2005-2009 is discussed in response to RAI #1 above. As stated in the RAI #11 response on page 13 of Reference 3, meteorological data sets for years 2003-2007 that was submitted to support AST LAR 196 on July 21, 2009

[Reference 9] used the seven wind speed categories (bins) provided in the PTN quarterly meteorological reports while the meteorological data sets for 2002, 2005, and 2006 that was submitted to support the COLA on August 7, 2009 [Reference 10] used thirteen wind speed

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 13 of 74 Response to 5/28/2010 RAIs for AST LAR bins more in keeping with NRC Regulatory Issues Summary (RIS) 2006-04, "Experience with Implementation of Alternative Source Terms," recommendations [Reference 11]. As stated in the RAI #17 response on page 20 of Reference 3, FPL recognized that RIS 2006-04 recommends a larger number of wind speed categories than was used in developing the joint frequency distributions for input to PAVAN for the original AST submittal. Thus, consistent with RIS recommendations, joint frequency distributions were "rebinned" into the thirteen wind speed categories suggested in the RIS, i.e., calm, 0.5, 0.75, 1.0, 1.25, 1.5, 2.0, 3.0, 4.0, 5.0, 6.0, 8.0, and 10.0 meters/second (mps), plus one more for wind speeds > 10 mps. This is the maximum number of groups that can be accommodated by ARCON96. The revised meteorological data set for 2005-2009 submitted to support AST LAR 196 on June 11, 2010

[Reference 7] reflects this approach and yields comparable results with the COLA data.

6. NRC staff notes that there appears to be several lengthy cases when datafrom the primary measurementsystem were eitherflagged as invalid or NRCjudges that the data appearto be anomalous. What corrective actions were implemented to upgrade the meteorological measurementprogram to ensure thatproblems were promptly identified andfixed to minimize the occurrence of subsequentproblems? At what intervals were calibrations performedfor each instrument train? Were calibrationfindings used in any way to modify or determine the validity of data collectedsince the priorcalibration? Were meteorological data measurements at the Turkey Pointsite eitherpriorto 2003 or after 200 7 made primarily on the primary tower with few data substitutions,particularlywith regardto use of instrumentsjointly pairedin either TrainA or Train B of the temperaturedifference measurements?

Quality verification and correction of the meteorological data sets for 2005-2009 is discussed in FPL's attached response to RAI #1. Condition Report (CR) 2010-11408 was initiated to document a persistent history of problems with the meteorological tower temperature sensors and their adverse impact on the quality of the meteorological data. The CR also identified concerns regarding the adequacy of maintenance and oversight of the meteorological tower equipment, program, and data. CR 2010-11412 was initiated to document the need for an aggregate review of all performance issues associated with the meteorological towers. CR 2010-14752 was initiated to document that the calibration process used for the SD 60 meter meteorological tower temperature sensors does not fully meet the guidance given in RG 1.23; specifically, it does not meet the vertical differential temperature acceptance criterion of

+/-0.180 F. CR 2010-14755 was initiated to document inconsistent application of the meteorological data substitution rules that has resulted in numerous issues with the development of FPL responses to regulatory questions regarding the quality of the meteorological data. A representative list of CRs generated to document problems with the meteorological equipment since mid 2004 has been compiled and is shown below.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 14 of 74 Response to 5/28/2010 RAIs for AST LAR Meteorological Records 2004-2010 CR Number Description 2004 2004-00393 NRC Inspection revealed suspect adverse data collection 2004-02468 PM Semiannual calibrations 2004-02628 Trespassers located @ 60M Tower 2004-03157 10 m tower WS and WD failed 2004-03245 Missed PM Semiannual Calibrations 2004-03295 PM Reset Semiannual Calibrations 2004-07718 High Wind Tower Flatlined 2004-07724 10 m tower WS failed low 2004-07725 10 m tower WS failed low 2005 2005-05330 I&C to support Land U with records 2005-16903 SWD-I-103-004 affects both towers during Calibrations 2005-17023 Administrative back up files to Land U for Met Towers 2005-29519 60 meter indications failed 2005-29592 Back up battery @ 1Oim tower failed 2005-30276 60 mn tower WS, WD delta failed 2005-35063 Miscalculations for Delta Temp 2005-35163 Generator Voltage bad @ 10 met tower 2005-35509 Failed power transformer for data logger 2006 2006-00727 List of CR's to NRC found blank for Met Towers 2006-01576 Wind Sensor out high wind Land U Tower 2006-02938 New FAA requirements for 60m Tower 2006-03841 Confusion between barometric readings @ tower & control room 2006-04003 10 m tower WS sensor failed 2006-05172 10 in tower WS sensor needed calibration 2006-06800 Line power loss @ SD Tower caused erratic control room readings 2006-14643 1Oin tower transmitter card failed 2006-15553 10 in tower indication failure 2006-33298 South Dade Met Tower temperature problems continue to degrade 2006-33417 New FCC Registration requires painting & lighting

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 15 of 74 Response to 5/28/2010 RAIs for AST LAR 2007 2007-09137 10 m tower equipment accidentally de-energized 2007-20093 PM Semiannual Calibrations 2007-23783 60 m tower WD failed 2007-23920 SD Met tower wind direction not responding 2007-24125 60m tower sensors out of service 2007-30096 SD Met tower indications flatlining 2007-30404 Temp Sensor 1Om reading low 2007-32212 60 m tower Temp A low 2007-32453 10 m tower WD in alarm 2007-35025 Data availability problem on ERDADS 2007-39943 PC/M for Met Towers ERDADS 2007-41006 10 m tower wind direction failed low.

2008 2008-00002 10 m tower indication failure 2008-03350 2 error traps found during NRC RP Inspection 2008-04646 Met tower data limited 2008-04759 PM Semiannual Calibrations 2008-05678 10 m tower Temp B sensor reading low 2008-09408 RCO readings indicate met tower reading bad 2008-12527 60 m tower Sensors 2008-18778 Issue during Semiannual Calibration 2008-19437 U-3 Met Tower data indications are bad 2008-37481 Needed major revision to DCS for Met Towers 2009 2009-11083 Met tower DCS ink status offline 2009-16423 Semiannual Calibration parts issue 2009-18977 Fall protection for climbing towers 2009-34961 AC/back up unit no working @ 60 m tower 2010 2010-02138 Vegetation height @ Met towers 2010-06944 HD sensor missing @ Land U tower 2010-11408 Poor performance of temp sensors and inadequate program support 2010-11412 An aggregate review of Met Tower/ ownership 2010-14752 Calibration program for SD Met Tower doesn't fully meet RG 1.23.

2010-14755 Met data substitution rules not consistently applied

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 16 of 74 Response to 5/28/2010 RAIs for AST LAR In response to these CRs, a System Engineer has now been assigned responsibility for oversight of the meteorological equipment performance and for monitoring the output meteorological data. The meteorological tower data loggers and radio communications equipment at the site and at both the South Dade (SD) and Land Utilization (LU) towers were upgraded in May 2007 to assure compatibility with the Distributed Control System (DCS).

The installed wind direction and wind speed instrumentation for both towers are currently being refurbished or replaced. FPL acknowledges that further improvements in equipment, procedures, programs, and processes will be required to achieve performance objectives that are recommended in RG 1.23.

The Land Utilization (LU) 10 meter meteorological (MET) tower is located just south of the plant and collects 10 meter data including temperature, wind speed, wind direction, and sigma theta values. This data is used primarily to supply plant meteorological conditions to support Emergency Plan requirements. The South Dade (SD) 60 meter MET tower is located some 5.5 miles south-southwest of the plant and collects similar data at both 10 meter and 60 meter elevations. The data for the two elevations allows for characterization of both lower and upper meteorological conditions and for calculation of vertical temperature differences that provide the preferred means for determining atmospheric stability classes since they are effective indicators of worst-case stability conditions. This information is used primarily in the plant's radiological dose consequence analyses.

Calibration and replacement of the temperature sensors for both meteorological towers is performed every six months. See response to RAI #4 above for a detailed discussion of the calibration process, its findings and use in the determination of the validity of the data collected. See the attached response to RAI #3 for discussion of data substitutions.

TS 3/4.7.5.4.c On June 7, 2010, a public meeting was held at the NRC headquarters in Rockville, MD in which issues regarding the quality of the meteorological data and the proposed CREVS TS change were discussed. In that meeting, the NRC noted that LAR 196 had proposed a change to TS 3/4.7.5 Surveillance Requirement (SR) 4.7.5.c.2 to reduce the methyl iodide penetration criteria from 2.5% to 1.25% in order to increase the credited efficiency of the control room filter from 95% to 97.5% for elemental iodines and organic iodides. The NRC further noted that the proposed TS change was outside the recommended limits for filter efficiencies specified in Regulatory Guide (RG) 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered Safety Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants [Reference 6]. FPL has reviewed the RG 1.52 recommended acceptance criterion for methyl iodide penetration for activated carbon filters with 2 inches total bed depths and the maximum assigned credit for activated carbon (filter) decontamination efficiencies. As PTN's control room charcoal beds are 2 inches in depth, FPL has concluded that the proposed decrease in the penetration criteria and associated increase in filter efficiency for elemental iodine and organic iodide removal is not supported by the RG.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 17 of 74 Response to 5/28/2010 RAIs for AST LAR Accordingly, FPL is retracting the SR 4.7.5.c.2 change proposed on June 25, 2009 in the AST LAR 196 [Reference 1]. The affected pages of the TS (page 3/4 7-17) and TS Bases (page 100) were later modified with the proposed CREVS TS submittal [Reference 4] on May 21, 2010.

The attached TS and TS Bases pages thus reflect the later changes without the changes to the methyl iodide penetration criteria.

To partially offset this effective decrease in the control room filter efficiencies for elemental iodines and organic iodides from 97.5% to 95% in the dose calculations, FPL will be increasing the credited control room filter efficiency for particulate from 97.5% to 99%. In addition, FPL will be reducing the amount of unfiltered air inleakage to the Control Room from 115 scfm to 100 scfm in order to preclude any encroachment on the AST LAR 196 indicated margin to the regulatory dose limits.

References

1. W. Jefferson (FPL) to U.S. Nuclear Regulatory Commission (L-2009-133), "License Amendment Request 196: Alternative Source Term and Conforming Amendment," Accession No. ML092050277, June 25, 2009.

2. J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - Request for Additional Information Regarding Request to Adopt the Alternate Source Term (TAC Nos. ME 1624 and ME1625)," Accession No. ML100700446, March 24, 2010

3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-065), "Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 (TAC Nos. ME1624 and ME1625)," Accession No. ML101090027, April 14, 2010

4. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-083), "Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI)

Regarding Alternative Source Term (AST)," Accession No. ML101450028, May 21, 2010

5. Email from J. Paige (NRC) to S. Franzone (FPL), Follow-up Requests for Additional Information Re: Turkey Point, Unit 3 and 4 AST LAR, Accession No. ML101480750, May 28, 2010

6. Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants, Rev 3, June 2001

7. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-121), "Revised Meteorological Data for 2005-2009 Supporting Alternative Source Term and Conforming License Amendment Request 196," June 11, 2010

8. Regulatory Guide 1.23, Rev 1, Meteorological Monitoring Programs for Nuclear Power Plants, March 2007

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 18 of 74 Response to 5/28/2010 RAIs for AST LAR

9. W. Jefferson (FPL) to U.S. Nuclear Regulatory Commission (L-2009-163), "Transmittal of Meteorological Data CD Supporting Alternative Source Term and Conforming License Amendment Request 196 - Supplemental Information," Accession No. ML100680718, July 21, 2009.

10. M. Gettler (FPL) to U.S. Nuclear Regulatory Commission (L-2009-146), "Supplemental Meteorological Data in Support of Application for Combined License," Accession No. ML092250585, August 7, 2009

11. NRC Regulatory Issues Summary 2006-04, "Experience with Implementation of Alternative Source Terms," March 7, 2006

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 19 of 74 Response to 5/28/2010 RAIs for AST LAR SURVEILLANCE REQUIREMENTS (Continuefdl

1) Verifying that the air cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of greater than or equal to 99% DOP and halogenated hydrocarbon removal at a system flow rate of 1000 cfm +/-10%.

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, and analyzed per ASTM D3803 - 1989 AT 301C and I 95% relative humidity, meets the methyl iodide penetration criteria of less than 2.5% or I the charcoal be replaced with charcoal that meets or exceeds the stated performance I requirement, and

3) Verifying by a visual inspection the absence of foreign materials and gasket deterioration.

d. At least once per 12 months byverifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 1000 cfm +/-10%;

e. At least once per 18 months by verifying that on a Containment Phase "A" Isolation test signal the system automatically switches into the recirculation mode of operation.

f. Perform system flow balancing within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following CREVS component maintenance affecting system performance, e.g., filter replacement, fan or damper adjustment.

TURKEY POINT - UNITS 3 & 4 3/4 7-17 AMENDMENT NOS. 205 AND 199

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 20 of 74 Response to 5/28/2010 RAIs for AST LAR Procedure No.: Procedtue

Title:

Page:

100 Approval Date:

0-ADM-536 Technical Specification Bases Control Program 1/19/10 ATTACHMENT 1 (Page 89 of 112)

TECHNICAL SPECIFICATION BASES 3/4.7.5 (Cont'd)

.... tclPa- Em......

=airo

r. Til**Jat xciSat m -, udufrd t b..... OPERJ)L t

?............

.. O17

.... 1-.. .. . .. . .... -11 . ... t '.I:fj ' ' f pa-agsanoeU ohara It Ldd st i-ltariTit and wiJne eout L,.e1Ltpag** y dteto a

.ILk1s~eLJt cndr iytio I winch cidd.

the st ai.ed4 fail.o opra-o einpoelr -pest pro ea fitrsh.ave ( ex..en iroathanling unitno d atad or d h asocre anb thoa rvenrnueat contfun a rfll andn5)tAons. tidudampnraeario paaadioperThingztests throvid itarane supply th .af air ato ipmntewhinof A NSf N-m1 (iOa!97 ha3f t rasurane s

oxtfilh t- Ths a s noto teiorted below ietrn spe fication talues detho Dab0-19f 8thi C ac1rdaf c r G41rgwith ettie 9 hatest aomito (30dC h antd95

&OCiAo A;nly snris .it Add/Isert7 1nnext pas SyAtem componernts air not subjetcte toatrapid i suatn having etmes of many years, even under continuous ~flow

• elaffvehumidity) area asi specfied ~ heGnf"er.Tae conditions. ~Visual ~inspetiont ~ andt~10teAoperating tests Msthear by provide ai'surancd maprov ide hof system oeacsta reliability ut and emtdrng will ensurd early the'detectioi of conditions test for each which could.

test parameFterTh cause the inpifil oid on operate system spcfidmehl enqito improperly.

vauei" IUe filterstepcrformasad

,msd supfosu tests prove ed in that te filters have been properly installed, that.no deterioration or damage has occured, and that all components and subsystems operate properly. The in-situ tests are performed in accordance with the methodology and intent of ANSI N510 (1975) and-provide assurance that filteri performance has not deteriorated below returned specification values due to aging, conta~minlationl, or other effdcts. Charcoal samples are- tested using AST.M D3803-1989 in-acco .rdance with Generic Letter 99-02. The test conditio'ns (30'C and .95%

relative humidity) are as specified: nthe in Generic etter. 'Table- ofr the ASTM standard

'provi ,des the' 'tolerances' that must be .met duIring the test for each test parame'ter. TheI specified methyl iodide penetration value is brased on the, assumptions used in the LOCA Analysis.

'3/4.7.6 Snubbers.

Allesnubbers arentrequired OPERABngtLE th ensure thatdthe structural integrity of the Reactor Coolant Systeni add all Other safety-related systems is. niaintained during add following a seismic or other event intitiating dyrinamic loads.

The visual. inspection frequency is based upon maintaining- a. constant level of snubber protection to each safety-related system during an earthquake or severe transient.

Therefore,. the required inspection interval varies inversely with the observed snubber failures and is determined by the number of inoperable snubbers, found during a inspectio~n. finsp~ections performed befo~re.that. intier al has elapsed may be used as a new reference point to determnine the' next.inspec~tion. However, 'the results of such early inspections perfdrmed befobre the original requireId time-.interval has elapsed (nominal, time less 25%). mayý not be used to lengthien the required inspection interval, Any inspection whose results require a. shorter inspection interval will override the previous schedule.

• • Insert 1 is associated with proposed CREVS TS change submitted on May 21, 2010 [L-2010-083]

Accession No. ML101450028 and is not provide here.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 21 of 74 Response to 5/28/2010 RAIs for AST LAR Data Substitution Summary NAI reviewed the Turkey Point and MSI supplied data files for 2005-2009 meteorological data.

A number of issues were identified; some were one time only events, and some were recurring events that needed to be resolved as a group. The following listing provides the items that required resolution:

One Time Items

1) June 24, 2009 (JD 175): The 09:00 WD1O value of"20" appeared to be an invalid, stuck reading, but this value was transferred to the MSI file.

NAI recommended that this value be replaced by 9999 or with valid Land Use tower data. - Accepted by FPL.

2) 2007, Julian Dates 1-85: Resolve why TAlO and TB1O were set identically equal to each other in Raw data file.

Substitution was identified by MSI in other documentation (RAI Response to NRC).

Review by NAI documented in table below.

Recurring Items

1) Use of B-Channel delta-T for stability class: In a large number of cases in all years, the stability class reported in the ASCII, text formatted NRC daily and monthly reports appear to have been calculated using B-channel delta-T's instead of A-Channel delta-T's, when both channels appear to be valid. In some cases, the ASCII, text formatted NRC daily and monthly reports appear to have incorrect, zero values, which don't match the MSI file.

NAI recommends that stability classes be recalculated from delta-T values, using a documented and consistent set of rules governing:

a. Use B-Channel only if A-Channel delta-T is missing or clearly questionable.

b. Don't mix IOM A and 60M B channels, or vice-versa, unless clear evidence of suitability of valid substitution has been provided and reviewed. Fill stability with 9999 if a valid pair (A-channel or B-channel) is not available. -

Accepted by FPL.

2) Treatment of zero value wind speeds: In a number of cases, MSI replaced zero value wind speeds with 9999 (invalid or missing flag) and substituted 360 degrees for direction, instead of allowing the zero wind speed and direction to be detected as "calms" for downstream processing in X/Q computer codes.

NAI recommended that zero wind speed values be reported as zeros, and not replaced by 9999 flags, unless other reasons confirm instrument failures

a. examine prior and subsequent speeds for speed trends.

b. consider persistence, other conditions (60M winds, stability, precipitation)

c. log, for documentation purposes, instances of "failed instrument" determinations. - Accepted by FPL.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 22 of 74 Response to 5/28/2010 RAIs for AST LAR

3) Resolution of persistence reports from METDQA: This NAI version of the NRC developed program reports persistence of wind directions and stability classes for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (NAI version - the NRC version used 8 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).

NAI recommended that each instance should be examined to determine if stuck sensors, or faulty stability class determinations have lead to this flag. The "Action" column of the tabular reports that follow can capture these determinations. - Accepted by FPL.

4) Resolution of "stability class jumps" identified by METDQA:

NAI recommended that a simple review of other conditions around the time of the identified jump should be documented in the Action column of the following tabular reports. - Accepted by FPL. Suggestions from Shaw meteorologist regarding contributing factors was noted for use in these determinations.

5) Met Data Plot Review: Plots have been constructed for various Met Data parameters. If anomalous trends or step changes are identified, they should be reviewed for impact on final data files used for determination of X/Q's.

NAI recommended that supplied plots (or others, as requested or as needed) be reviewed and determinations of impact (or lack thereof) be listed in the Action column of the following tabular reports. - Accepted by FPL.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 23 of 74 Response to 5/28/2010 RAIs for AST LAR 2005 - MSI/TP Identified Substitutions/Flaged Entries in Yellow Hi2hlight Julian Time Parameter Reason Action NAI Review Date 2005 All Stability Consistency Use of B channel delta-T only when Channel A is missing or invalid.

If both channels are invalid, then set stability to missing.

1-180 TA60 Bad Sensor TB60 was substituted for TA60 from Jan. 1 until time of temperature sensor change out.

NAI reviewed 2005 data plotted from MSI QA File spreadsheets as well as raw data files.

+ 4 Data was reviewed, and normal variations of wind direction were occurring during this time, and METD_QA Identified: WIND wind speeds were very 3 1600 WDIR: HEIGHT= 60.0M Unknown consistent, but slightly variable.

FROM SECTOR ENE FOR PREVIOUS 31 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND 14 200 WDIR: HEIGHT= 10.OM Unknown wind speeds were very FROM SECTOR SE FOR consistent, but slightly variable. PREVIOUS 24 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METDQA Identified: WIND 14 300 WDIR: HEIGHT= 60.0M Unknown wind speeds were very FROM SECTOR SE FOR consistent, but slightly variable. PREVIOUS 25 HOUR PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 24 of 74 Response to 5/28/20 10 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 15 1100-1600 Stability Unknown

-Monthly Additional instances of this reports show Stability Class =5, while NAI calculates Stability Class 1. Reports show screening issue will not be Delta-t to be zero, while MSIQA Fiesas,33F/0 listed, but will be resolved in a similar manner.

The lapse rate is the rate of cooling of ascending air. The dry air adiabatic lapse rate is -

1°C/100M, while the saturated air lapse rate is only about 0.55"C/100M since condensation will begin to occur, which reduced the METDQA Identified: LAPSE amount of temperature change. RATE An autoconvective lapse rate is 1100 -3.6 defined to be more than 1200 -3.6 15 1100-1400 Autoconvective Lapse Rate Unknown 3.4°C1100M, which represents a 1300 -3.8 condition where the cooling rate 1400 -3.9 is such that the density of air EXCEEDS increases with elevation. Such a AUTOCONVECTIVE LAPSE condition usually only occurs at RATE OF -3.4"C/100M low levels, over surfaces which are easily and intensely heated.

See Julian Date 15. METD_QA Identified: LAPSE RATE 0900 -39 16 0900-1000 Autoconvective Lapse Rate Unknown 1000 -4.2 EXCEEDS SATURATED AIR AUTOCONVECTIVE LAPSE I RATE OF -3.4°C/100M

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 25 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005

• METDQA IDENTIFIED:

STABILITY CLASS JUMPED 2100 Stability Unknown FROM E TO AOVER ONE 16 HOUR PERIOD

• METD_QA IDENTIFIED:

STABILITY CLASS JUMPED 21 0800 St yUnknown FROM E TO A OVER ONE 0Stability HOUR PERIOD

• METDQA IDENTIFIED:

STABILITY CLASS JUMPED 27 0900 SUnknown FROM F TO BOVERONE 7Stability HOUR PERIOD

• l METDOQA IDENTIFIED:

STABILITY CLASS JUMPED 60 0800 Stabily Unknown FROM E TO A OVER ONE Sality HOUR PERIOD See Julian date 15. METDQA Identified: LAPSE RATE 1000 -3.7 63 1000-1200 Autoconvective Lapse Rate Unknown 1100 -4.1 1200 -3.7 EXCEEDS SATURATED AIR AUTOCONVECTIVE LAPSE RATE OF -3.4°C/100M METDQA IDENTIFIED:

STABILITY CLASS JUMPED FROM G TO BOVERONE 65 0800 1 Stability Unknown

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 26 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 See Julian date 15.

S METDQA Identified: LAPSE RATE Autoconvective Lapse Rate Unknown 2100 -3.7 68 2100-2200 EXCEEDS SATURATED AIR AUTOCONVECTIVE LAPSE oRATE OF -3.4"C/100M See Julian date 15. METDQA Identified: LAPSE RATE 0200 -3.8 0400 -4.1 Unknown 0500 -4.0 69 0200-0600 Autoconvective Lapse Rate 0600 -3.8 EXCEEDS SATURATED AIR AUTOCONVECTIVE LAPSE RATE OF -3.4"(/1100M METD_QA IDENTIFIED:

STABILITY CLASS JUMPED 73 09iUnknown FROM E TO A OVER ONE 7309 Stabilty UkwHOUR PERIOD

• METD_QA IDENTIFIED:

STABILITY CLASS JUMPED 74 09iUnknown FROM E TO A OVER ONE Stability 0 HOUR PERIOD

• METDQA IDENTIFIED:

STABILITY CLASS JUMPED FROM E TO A OVER ONE 0800 Stability Unknown HOM ERIOD 88 HOUR PERIOD

• I METDQA IDENTIFIED:

STABILITY CLASS JUMPED 0800 Stability Unknown FROM F TO BOVERONE 89 HOUR PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 27 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 98 0800 MSI-provided graphs indicate To Wind Missing or invalid 60m 60m wind direction corresponds To Wind Direction, 60m data reasonably well with 1Om wind 129 1200 direction.

mMETDQA IDENTIFIED:

STABILITY CLASS JUMPED i1 0800 S yUnknown FROM F TO AOVERONE 0Stability HOUR PERIOD m METD QA IDENTIFIED:

STABILITY CLASS JUMPED 113 0800 St y Unknown FROM F TO BOVERONE tability HOUR PERIOD mMETD_QA IDENTIFIED:

STABILITY CLASS JUMPED 122 0800 Stability Unknown FROM E TO A OVER ONE HOUR PERIOD mMETDQA IDENTIFIED:

STABILITY CLASS JUMPED 123 0800 Stability Unknown FROM E TO A OVER ONE HOUR PERIOD METDQA IDENTIFIED:

STABILITY CLASS JUMPED 125 0800 Stability Unknown FROM A TO EOVERONE HOUR PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 28 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Tim Date 2005 See Julian date 15.

METDQA Identified: LAPSE RATE 0600 -4.4 0700 -5.4 0800 -6.9 143 0600-1000 1 Autoconvective Lapse Rate Unknown 0900 -6.4 1000 -3.6 EXCEEDS SATURATED AIR AUTOCONVECTIVE LAPSE RATE OF -3.4°C/100M METD_QA IDENTIFIED:

0800:STABILITY CLASS JUMPED FROM A TO E OVER ONE HOUR PERIOD 0900:STABILITY CLASS 151 0800-0900 Stability Unknown JUMPED FROM E TO A OVER ONE HOUR PERIOD METD_QA IDENTIFIED:

0700:STABILITY CLASS JUMPED FROM E TO A OVER ONE HOUR PERIOD 1300:STABILITY CLASS 168 0700-1300 Stability Unknown JUMPED FROM A TO E OVER ONE HOUR PERIOD METDQA IDENTIFIED:

STABILITY CLASS JUMPED FROM A TO E OVER ONE 170 1300 1 Stability Unknown HOUR PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 29 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND 200 0 WDIR: HEIGHT= 10G0M Unknown wind speeds were very FROM SECTOR E FOR consistent, but slightly variable. PREVIOUS 28 HOUR PERIOD 218 1700 MSI-provided graphs indicate To To Wind Direction, 60m Missing or invalid 60m 60m wind direction corresponds 224 1700 data reasonably well with 10m wind 22 1direction.

Data was reviewed, and normal variations of wind speed were occurring during this time, and wind speeds were elevated at METDQA Identified: WIND both the 1GM and 60M sensors. SPEED OF 25.1M/SEC Data was reviewed, and normal variations of wind speed were occurring during this time, and wind speeds were elevated at METDQA Identified: WIND both the 1OM and 60M sensors. SPEED OF 26.4M/SEC Data was reviewed, and normal variations of wind speed were METDQA Identified: WIND occurring during this time, and SPEED OF 27.GM/SEC 238 200 WSPD: HEIGHT= 60GOM Unknown wind speeds were elevated at both the 10M and 60M sensors.

Data was reviewed, and normal variations of temperatures were METD_QA Identified:

occurring during this time on STABILITY CLASS E LASTED 264 0900 Stability Unknown both A and B channels. FOR PREVIOUS 39 HOUR

-PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 30 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 Data was reviewed, and normal variations of wind speed were occurring during this time, and wind speeds were elevated at METD_QA Identified: WIND both the 1OM and 60M sensors. SPEED OF 25.6MISEC Data was reviewed, and normal variations of wind speed were occurring during this time, and wind speeds were elevated at METDQA Identified: WIND both the 1OM and 60M sensors. SPEED OF 30.0M/SEC Data was reviewed, and normal variations of wind speed were occurring during this time, and wind speeds were elevated at METDQA Identified: WIND both the 1OM and 60M sensors. SPEED OF 25.1M/SEC Data was reviewed, and normal variations of wind speed were occurring during this time, and 297 600 WSPD: HEIGHT= l.OM Unknown wind speeds were elevated at METDOQA Identified: WIND both the 1OM and 60M sensors. SPEED OF 28.9M/SEC Data was reviewed, and normal variations of wind speed were occurring during this time, and 297 700 WSPD: HEIGHT= lOOM Unknown wind speeds were elevated at METDQA Identified: WIND both the 1OM and 60M sensors. SPEED OF 28.7M/SEC

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 31 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND 304 800 WDIR: HEIGHT= 60.0M Unknown wind speeds were very FROM SECTOR NE FOR consistent, but slightly variable. PREVIOUS 44 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND 308 1400 WDIR: HEIGHT= 10.OM Unknown wind speeds were very FROM SECTOR NE FOR consistent, but slightly variable. PREVIOUS 29 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METDQA Identified: WIND 308 1400 WDIR: HEIGHT= 60.OM Unknown wind speeds were very FROM-SECTOR NE FOR consistent, but slightly variable. PREVIOUS 29 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND 336 200 WDIR: HEIGHT= 60.OM Unknown wind speeds were very FROM SECTOR NNW FOR consistent, but slightly variable. PREVIOUS 27 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND 336 400 WDIR: HEIGHT= 10.OM Unknown wind speeds were very FROM SECTOR NNW FOR consistent, but slightly variable. PREVIOUS 29 HOUR PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 32 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 343-344 2000-0200 MSI substituted 9999's (indicating bad reading or failed 344 1900 sensor) for 0.0 "raw data" wind speed.

344 2200 345 1900  ?NAI cannot confirm that this "bad data" flag application is 346 0300-0500, appropriate. Wind speeds of 1900 WSPD: HEIGHT= 10.0 M Choice of treatment of 0.0 wind speed 0.0mph are valid readings for value calms, and would be counted 349 1900-2000, 3for input to ARCON96, 2300 343-346 Likely Calm, not with other JFD data. along missing 350 0400 349-352 Likely Calm, not missing 351 2200-2300 352 0300,2000, 2200 Data was reviewed, and normal variations of wind direction were occurring during this time, and METD QA Identified: WIND wind speeds were very FROM-SECTOR NNW FOR 356 0 WDIR: HEIGHT= l.OM Unknown consistent, but slightly variable. PREVIOUS 32 HOUR PERIOD Data was reviewed, and normal variations of wind direction were occurring during this time, and METDQA identified: WIND 356 1000 WDIR: HEIGHT= 60.OM Unknown wind speeds were very FROM SECTOR NNW FOR consistent, but slightly variable. PREVIOUS 37 HOUR PERIOD METDQA IDENTIFIED:

STABILITY CLASS JUMPED FROM E TO AOVERONE 356 0900 Stability Unknown HOUR PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 33 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2005 MSI substituted 9999's (indicating bad reading or failed 357 1sensor) for 0.0 "raw data" wind speed.

357-358 2200-0000 3-358 0200-000, NAI cannot confirm that this 358 0200-0500, "bad data" flag application is 0700-0800 appropriate. Wind speeds of Choice of treatment of 0.0 valid readings for 0.0mph are would 358-359 1800-0600 WSPD: HEIGHT= 10.0 M wind speed value calms, and be counted for input to ARCON96, along 361-362 1700-0300, 357-359 Likely Calm, not with other JFD data.

2100 missing 361-362 Likely Calm, not 364 0400,0700 missing 364-365 1900-0700 364 Likely Calm, not missing 365-365 Likely Calm, not missing NAI review of this plot, plus the plot on next page (60M - 1OM Alpha vs. Bravo Delta Temperature) indicates that the trend in IOM A-B delta-T is likely due to drift inthe Bravo NAI Identified: See channel (see yellow/Alpha line accompanying plot that shows in second plot - no trend; while significant trend in 1pOM Temp 2Q05-2Q05 1OM Temperature -A-B Delta-T Unknown pink/Bravo corcin line gets a step tedo Q05, A-B Delta-T. This trend may "correction"at end of 2Q2005), affect choice of A or B channel so the NAI implementation o for determining Stability.

Delta-T based stability calculations will eliminate any problems the drifting B channel might have introduced.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 34 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2005 Alpha minus Bravo dT (OF) @ 60 Meters and Alpha minus Bravo dT (OF) @ 10 Meters 2.0 1.9 I1.8 1.7 1.6 1.5 1.4 1.3 1.2 1.1 1.0 T T .0.9 0.8 0.7 0.6 0.5 0.4 0.3 0.2 0.1 0.0

-0.1

-0.2

-0.3

-0.4

-0.5

-0.6

-0.7

-0.8

-0.9 A-1.0

-1.1

-1.2

-1.3

-1.4

-1.5

-1.6

-1.7

-1.8

-1.9

-2.0 1/1/2005 0:00 2/20/2005 0:00 4/11/2005 0:00 5/31/2005 0:00 7/20/2005 0:00 9/8/2005 0:00 10/28/2005 0:00 12/17/2005 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 35 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Alpha Turkey Point "MSI QA File" - 2005 60M Minus IOM -p and Bravo delta Temperature (°F) --- Bravo with Rain at center Zero Line ------ Rain event S 6.000 5.000 4.000 3.000 2.000 1.000 0.000

-1.000

-2.000 1 ll i, . 1 . ..I.

.. .. .. . .. I , '1.-3 .00 0 1/1/2005 0:00 2/20/2005 0:00 4/11/2005 0:00 5/31/2005 0:00 7/20/2005 0:00 9/8/2005 0:00 10/28/2005 0:00 12/17/2005 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 36 of 74 Response to 5/28/2010 RAIs for AST LAR 2006 - MSI/TP Identified Substitutions/Flaimed Entries in Yellow HiMRhliht Julian Time Parameter Reason Action NAI Review Date 2006 All Stability Brevity Use of B channel delta-T only where Channel A is 9999 1 Various WSPD: HEIGHT= 10.0 M Choice of treatment of 0.0 2 wind speed value.

3 4 Raw data files appear to 7 report 0.5 (starting speed 13 of instrument) when wind 15 speed is below 0.5 mph. NAI cannot confirm that this 16 uu I -V%^ "bad data" flag application is 24 missing appropriate. Wind speeds of 007 Likely Calm, not 0.0mph are valid readings for missing calms, and would be counted 013 Likely Calm, not for input to ARCON96, along missing with other JFD data.

015 Likely Calm, not missing 016 Likely Calm, not missing 024 Likely Calm, not missina 7 1000 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly. _l I 16 1000 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM G TO C OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

48 1000 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation

_______________________increases markedly. _____________________________

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 37 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 62 1000 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

63 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

65 0900 Stability Unknown METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

66 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

69 1800 WDIR: HEIGHT= 10.OM Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR SE FOR occurring during this time, and PREVIOUS 39 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR SE 1800 WDIR: HEIGHT= 60.OM FOR PREVIOUS 28 HOUR

-PERIOD 74 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM G TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

77 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO AOVERONE transition from positive to negative. Solar radiation increases markedly.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 38 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 78 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

91 200 WDIR: HEIGHT= 10.0M Unknown Data was reviewed, and normal METD_QA IDENTIFIED: WIND variations of wind direction were FROM SECTOR E FOR occurring during this time, and PREVIOUS 32 HOUR PERIOD wind speeds were very consistent, but slightly variable.

92 0800 Stability Unknown METD _QA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO B OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

93 0800 Stability Unknown METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM G TO C OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

94 0800 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO B OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

95 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 39 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 95 0100-2400 TA10, DTA Unknown TB1O substituted, DTA recalculated.

jr = j~~Alsomiigad channels to get valid delta-T's should be avoided unless absolutely necessary.

99 0800 Stability Unknown 1 METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO B OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

100 1300 Stability Unknown M METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM A TO E OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

Rainfall followed in next hour.

108 0900 Stability Unknown M METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO B OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

108-109 TA10, DTA Unknown TB10 substituted, DTA recalculated.

Also, mixing A and B channels to get valid delta-Ts should be avoided unless

______________ _ ___ _absolutely necessary.

109 09001 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO AOVERONE Un~l ID OlD~tr-On transition from positive to negative. Solar radiation increases markedlv.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 40 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 110 0800 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

112 1200 WDIR: HEIGHT= 10.0M Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR SE FOR occurring during this time, and PREVIOUS 25 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR SE 1200 WDIR: HEIGHT= 60.OM FOR PREVIOUS 25 HOUR

-PERIOD 115 0800 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

See 2005 Julian date 15.

METDQA Identified: LAPSE RATE 1117 1200-1300 Autoconvective Lapse Rate Unknown 0900 -4.1 1000 -4.1 EXCEEDS AUTOCONVECTIVE LAPSE RATE OF -3.4"C/100M 124 0800 Stability Unknown MMETDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

126 0800 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to negative. Solar radiation increases markedly.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 41 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 140 0700 Stability Unknown METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM F TO B OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

136-137 TA1 0, DTA Unknown TB1 0 substituted, DTA recalculated.

IAlso, mixing A and B channels to get valid delta-Ts should be avoided unless absolutely necessary.

149 0700 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

150 0700 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly..

151 0700 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

235 1500 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Immediately following a FROM A TO E OVER ONE rain event. Wind speeds HOUR PERIOD and directions changed markedly.

244 1300 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM A TO E OVER ONE transition from positive to HOUR PERIOD negative. Wind speeds and directions change markedly. I

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 42 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 277 400 WDIR: HEIGHT= 10.0M Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 27 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR ENE 400 WDIR: HEIGHT= 60.OM FOR PREVIOUS 27 HOUR PERIOD 296 0800 Stability Unknown M METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to HOUR PERIOD negative. Solar radiation increases markedly.

308 1800 WDIR: HEIGHT= 10.OM Unknown Data was reviewed, and normal METD_QA IDENTIFIED: WIND variations of wind direction were FROM SECTOR NE FOR occurring during this time, and PREVIOUS 32 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR NE 1800 WDIR: HEIGHT= 60.OM FOR PREVIOUS 32 HOUR PERIOD 309 600 Stability Unknown "Normal" variations in data METDQA IDENTIFIED:

readings do not indicate any STABILITY CLASS D LASTED instrument problems. FOR PREVIOUS 28 HOUR PERIOD 310 1700 WDIR: HEIGHT= 10.0M Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 42 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR ENE 900 WDIR: HEIGHT= 60.OM FOR PREVIOUS 34 HOUR

-PERIOD

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 43 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2006 344 2200 WDIR: HEIGHT= 60.0M Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 25 HOUR PERIOD wind speeds were very consistent, but slightly variable.

346 2100 WDIR: HEIGHT= 10.CM Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 46 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR ENE 2000 WDIR: HEIGHT= 60.0M FOR PREVIOUS 42 HOUR

-PERIOD 364 100 WDIR: HEIGHT= 60.CM Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 37 HOUR PERIOD wind speeds were very consistent, but slightly variable.

Q3-2006 A-B Delta-T @ 60M & 10M Unknown NAI review of this plot indicates NAI Comment: Review plot that the trend in 1OM A-B delta- below for clear trend in A-B tracks a similar trend in 60M A- delta-T during the third quarter.

B delta T, so any impact will be offset. This is confirmed by review of the plot on next page (60M - 1OM Alpha vs. Bravo Delta Temperature) which shows no bias or trend in TA60M-1 OM or TB60M-TB1 OM.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 44 of 74 Resoonse to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2006 Alpha minus Bravo dT (°F) @ 60 Meters and Alpha minus Bravo dT (*F) @ 10 Meters 2.0 1.9 1.8 1.7 1.6 1.5 1.4 1.3 1.2 1.1 1.0 0.9 0.8 0.7 0.6 0.5 0.4 0.3 0.2 0.1 0.0

-0.1

-0.2

-0.3

-0.4

-0.5

-0.6

-0.7

-0.8

-0.9

-1.0 It44

.2 1.3 1.4

.5

.6 1.7 1/ 0 0 1.8 1.9

?.0 112/2006 0:00 2/21/2006 0:00 4/12/2006 0:00 6/11/2006 0:00 7/21/2006 0:00 9/9/2006 0:00 10/29/2006 0:00 12/18/2006 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 45 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2006 60M Minus IOM and Bravo delta Temperature (OF) S with Rain at r-enter Zero Line 6.000 5.000 4.000 3.000 2.000 1.000 0.000

-1.000

-2.000 I I  !"-3.000 1/2/2006 0:00 2/21/2006 0:00 4/12/2006 0:00 6/1/2006 0:00 7/21/2006 0:00 9/9/2006 0:00 10/29/2006 0:00 12/18/2006 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 46 of 74 Response to 5/28/2010 RAIs for AST LAR 2007- Substitutions Made by MSI/TP in Yellow Hiahliaht Julian Time Parameter Reason Action NAI Review Date 2007 All Stability Consistency Use of B channel delta-T only when Channel A is missing or invalid.

If both channels are invalid, then set stability to missing.

1-31 1900-0800 31-59 2000-0800 60-90 2000-0700 91-120 2000-0400 121-152 2100-0400 153-181 2100-0400 Solar Radiation >zero at night Set to zero 182-212 2100-0400 213-243 2000-0400 244-273 2000-0500 274-304 2000-0700 305-334 1900-0700 335-365 1900-0700 Various Various Sigma Theta LWS<3.5 mph Set to missing 37 0000 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS D LASTED "Normal" variations in data FOR PREVIOUS 40 HOUR readings do not indicate PERIOD any instrument problems 44 1300 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from near zero to HOUR PERIOD very negative. Solar radiation increases markedly.

53 0900 Stability Unknown METDQA IDENTIFIED:

STABILITY CLASS JUMPED Both channels of delta-T FROM E TO A OVER ONE transition from positive to negative. Solar radiation increases markedly.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 47 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 81 400 WDIR: HEIGHT= 10.01M Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 37 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR ENE 400 WDIR: HEIGHT= 60.OM FOR PREVIOUS 37 HOUR

_PERIOD 86 1900 WDIR: HEIGHT= 10.01M Unknown Data was reviewed, and normal METDQA IDENTIFIED: WIND variations of wind direction were FROM SECTOR ENE FOR occurring during this time, and PREVIOUS 50 HOUR PERIOD wind speeds were very consistent, but slightly variable. WIND FROM SECTOR ENE 1900 WDIR: HEIGHT= 60.OM FOR PREVIOUS 50 HOUR

_PERIOD 100 2400 UWS,UWD,LWD, Sigma Theta Essentially Constant Set to Missing " o'that the identified values are essentially constant (bad or stuck sensor reading) and that the substitution for 9999 (missing has been made.

101-109 100-2400 UWS,UWD,LWD, Sigma Theta Essentially Constant Set to Missing I that the identified values are essentially constant (bad or stuck sensor reading) and that the substitution for 9999 (missing has been made.

110 100-1100 UWS,UWD,LWD, Sigma Theta Essentially Constant Set to Missing M that the identified values are essentially constant (bad or stuck sensor reading) and that the substitution for 9999 (missing has been made.

121 1100-1700 All Winds System Change Out Set to Missing has no information about the availability of this data, bul All Temperatures 124 1100-1700 All Winds System Change Out Set to Missing All Temperatures

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 48 of 74 Response to 5/28/2010 RAls for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 126 2100-2400 UWD Essentially Constant Set equal to 1Gm WD data that the raw data shows UWD to be essentially constant, and the 999 field was inserted into the QA file.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Om wind direction, the 999 field was replaced with 1Om wind direction data.

127-181 100-2400 UWD Essentially Constant Set equal to 1Gm WD data that the raw data shows UWD to be essentially constant, and the 999 field was inserted into the QA file.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Gm wind direction, the 999 field was replaced with 1Gm wind direction data.

182 1400 Stability Unknown METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Over one-half inch rainfall FROM A TO E OVER ONE this hour. HOUR PERIOD 182-193 100-2400 UWD Essentially Constant Set equal to 1Gm WD data that the raw data shows UWD to be essentially constant, and the 999 field was inserted into the QA file.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Gm wind direction, the 999 field was replaced with 1Gm wind direction data.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 49 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 194 100-1100 UWD Essentially Constant that the raw data shows UWD to be essentially 1000 TB60 & dT-B Delta-T>1.8°F constant, and the 999 field was inserted into the QA file.

1100 TA60 & dT-A Delta-T>1.8 0 F UWD set equal to 1 Om WD Based on MSI-provided graphs 1400 All Temperatures Delta-T>1.8°F data. that indicate 60m wind direction corresponds reasonably well Temperatures and differential with 1Om wind direction, the 999 temperatures set to Missing field was replaced with 1Om wind direction data.

217 0600 UWS, UWD UWS=0.5 Set to zero NAI cannot confirm this substitution. The raw data

-shows upper wind speed as 0.24 mph, and upper wind direction = 187.10. The MSI substitution of zero was over-ridden and became 9999 (invalid or missing with a 360*

-direction).

218 1600-2400 UWD &UWS; LWD UWD & UWS =0; LWD UWS set to missing; 1OM WS thatthe raw data constant WD and Sigma Theta from Land shows UWD, UWS = 0, and Use IOM tower substituted for LWD to be essentially constant 1OM data. UWD set equal to after 0700 on JD 219, and that LWD. the 999 field was inserted into the QA file for these entries.

IM Fr MLU OM WS, WD &sigma theta into MSI OA file.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 10m wind direction, the 999 field was replaced with 10m wind direction data.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 50 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 219-228 100-2400 UWD & UWS; LWD Essentially Constant UWS set to missing; 1OM WS that the raw data WD and Sigma Theta from Land shows UWD, UWS = 0, and Use 1OM tower substituted for LWD to be essentially constant, 1OM data. UWD set equal to and that the 999 field was LWD. inserted into the QA file for these entries.

fW1O MWS, WD &sigma theta into MSI QA file.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Om wind direction, the 999 field was replaced with 1Om wind direction data.

229 100-1400 UWD & UWS; LWD Essentially Constant UWS set to missing; 1OM WS that the raw data WD and Sigma Theta from Land shows UWD, UWS = 0, and Use 1OM tower substituted for LWD to be essentially constant 1OM data. UWD set equal to until about 1400, and that the LWD. 999 field was inserted into the QA file for these entries.

lU 0 0M WS, WD &sigma theta into MSI QA file.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 10m wind direction, the 999 field was replaced with 1Om wind direction data.

233 1600 WDIR: HEIGHT= 60.OM Unknown Data was reviewed, and normal METD_QA IDENTIFIED: WIND variations of wind direction were FROM SECTOR E FOR occurring during this time, and PREVIOUS 45 HOUR PERIOD wind speeds were very consistent, but slightly variable.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 51 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 245 1500 Stability Unknown METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Over one-half inch rainfall FROM B TO F OVER ONE fell in previous hour. HOUR PERIOD 247 1400 Stability Unknown METD_QA IDENTIFIED:

STABILITY CLASS JUMPED Over one-quarter inch FROM A TO E OVER ONE rainfall fell in previous HOUR PERIOD hour, trace this hour.

267 1200-2400 UWD, LWD Essentially Constant 1OM WS WD and Sigma Theta that the raw data from Land Use 1GM tower shows UWD to be essentially substituted for 10m data. UWD constant, and that alternative set equal to LWD. values were from LU 1GM WS, WD & sigma theta into MSI QA file.

1200-2400 TA10 Essentially Constant Set to Missing Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Gm wind direction, the 999 field was replaced with 1Gm wind direction data.

NAI confirms accurate substitution of 1Gm WD data into 60m WD based on MSI-provided graphs that indicate 60m WD corresponds reasonably well with 1Gm WD.

(3o40degrees, when TB10 was reading near 80 degrees) and MSI QA file values set to missing.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 52 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 268-273 100-2400 UWD, LWD Essentially Constant 10M WS WD and Sigma Theta that the raw data from Land Use 1GM tower shows UWD to be essentially substituted. UWD set equal to constant, and that alternative LWD. values were" from LU 1OM WS, WD &sigma theta into MSI QA file.

TA10 Essentially Constant Set to Missing Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Gm wind direction, the 999 field was replaced with 1Gm wind direction data.

n (3to 40ýdegree~s when TB1G was reading near 80 degrees) and MSI QA file values set to missing.

283 0200 Stability Unknown "Normal" variations in data METDQA IDENTIFIED:

readings do not indicate any STABILITY CLASS D LASTED instrument problems. FOR PREVIOUS 34 HOUR

___________ I ____________ +/- _____________________________ .3

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 53 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 274-296 100-2400 UWD, LWD Essentially Constant 1OM WS WD and Sigma Theta that the raw data from Land Use 1OM tower shows UWD to be essentially substituted. UWD set equal to constant, and that alternative LWD. values were i from LU 1OM WS, WD &sigma theta into MSI QA file.

TA1 0 Obviously erroneous Set to Missing Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 10m wind direction, the 999 field was replaced with 1Om wind direction data.

ý (30 to40 degrees, when TB10 was reading near 80 degrees) and MSI QA file values set to missing.

297 100-1300 UWD, LWD Essentially Constant 1OM WS WD and Sigma Theta that the raw data from Land Use 1OM tower shows UWD to be essentially substituted. UWD set equal to constant, and that alternative LWD. values wer from LU 1 OM WS, WD & sigma theta into MSI QA file.

100-1500 TAI0 Obviously erroneous Set to Missing Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Im wind direction, the 999 field was replaced with 1 Om wind direction data.

M010(30ý40degrees, when TB1 0 was reading near 80 degrees) and MSI QA file values set to missing.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 54 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2007 297 1400-1500 TA10, TB10 Obviously erroneous Set to Missing 306 1900 Stability Unknown -a METDQA IDENTIFIED:

STABILITY CLASS D LASTED "Normal" variations in data FOR PREVIOUS 40 HOUR readings do not indicate any instrument problems

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 55 of 74 Response to 5/28/2010 RAIs for AST LAR

-a-60M Wind Speed mph Turkey Point "MSI QA File" - 2007 Wind Speeds mph 1OM Wind Speed mph 30.00 25.00 20.00 15.00 10.00 5.00 p 3 30-Oct 19-Dec 0.00 2-Jun 22-Jul 10-Sep 3-Jan 3-Jan 22-Feb 22-Feb 13-Apr 13-Apr 2-Jun 22-Jul 1O-Sep 30-Oct 19-Dec

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 56 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2007 Alpha minus Bravo dT (OF) @ 60 Meters and Alpha minus Bravo dT (OF) @ 10 Meters 4- -_ 2.0 1.9 ZioT is-ideal 1.8 1.7 1.6 1.5 1.4

--1.3 1.2 1.1

___ 1.0 0.9 0.8

-0.7 0.6 0.5 0.4 0.3 0.2 0.1 0.0

-0.1

-0.2

-0.3

-0.4

-0.5

-0.6

-0.7

-0.8

-0.9

-1.0

-1.1

-1.2

-1.3

-1.4

-1.5

-1.6

-1.7

-1.8

-1.9

-2.0 1/3/2007 0:00 2/2212007 0:00 4/13/2007 0:00 6/2/2007 0:00 7/22/2007 0:00 9/10/2007 0:00 10/30/2007 0:00 12/19/2007 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 57 of 74 Response to 5/28/2010 RAIs for AST LAR Wind Speeds 2005 80 70 40a00*  ;-- MIJOM 30 20 10 Wind directions 2005 400 350 300 -3 4 250200 200~ j~ I~71-I,,W 200' *s:i t 4 U 100o 50 1 190 379 568 757 946 1135 1324 1513 1702 1891 2080 2269 2458 2647 2836 3025 3214 3403 3592 3781 3970 4159 4348 4537 4726 4915 5104 52935482 5671 5860 6049 6238 6427 6616 6805 6994 7183 7372 7561 7750 7939 8128 8317 8506 8695 1OM WS/60M WS 10WD/60M WD Correl 0.854146 Correl 0.823948 Slope 1.034228 Slope 0.804531 Intercept 4.082811 Intercept 26.27945 10M WS/LU WS 1OWD/LUWD Correl 0.865296 Correl 0.692074 Slope 0.874367 Slope 0.712917 Intercept -0.02998 Intercept 52.9332

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 58 of 74 Response to 5/28/2010 RAIs for AST LAR Wind Speeds 2006 40 30 2  ::60M0 S LUW'S 20 -

10 VWnd directions 2006 400 300 7 250 r-6 M S 200 -A 150 I 50 10M WS/60M WS 10WD/60M WD Correl 0.850453 Correl 0.769478 Slope 1.085187 Slope 0.732094 Intercept 3.558924 Intercept 33.56544 10M WS/LU WS 1OWD/LUWD Correl 0.777552 Correl 0.663662 Slope 0.714162 Slope - 0.697111 Intercept 1.571708 Intercept 55.01789

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 59 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Wind Speeds 2007 35 30 20 ~-60MMA

-10MM

'J 10 LU A~s 10 ft11 0

1 189 377 565 753 941 1129 1317 1505 1693 1891 2069 2251 2445 26W3 2921 2099 3191 23953873 V161 2949 4121 4325 4912 461 409 169 9692 0-1640 oz. U 0 121, 11-9 1091 0606 0212 0661 0669 VWnd directions 2007 400 350 .. Am 300 250

-1 r M0 200 -VIinE...

15o151A 10 . ..

50 1 190 419 566lt191 94t U 112912241912 11291UN zuo6022692*962 I56120462V9U14 06022994101 2910l. 410 6911

-26 -161.

.1.62--66-6-11 -06U- -. .. " . . .... .... 112 1661 112- --992 ... 1.. 0......

10M WS/60M WS 10WD/60M WD Correl 0.904966 Correl 0.760873 Slope 1.158538 Slope 0.718593 Intercept 2.637326 Intercept 30.13175 10M WS/LU WS 10WD/LUWD Correl 0.858052 Correl 0.690195 Slope 0.822128 Slope 0.729199 Intercept 0.432733 Intercept 1 48.8508

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 60 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Wind Speeds 2008 40 35 30 25

-60MAG 20 LU M 15 10 5

0 Wnd directions 2008 400 300 1~ 4 A 250J.

)0 ISO41 U S 10 1 191 381 571 751 951 1141 1331 1521 1711 1901 2091 2251 2471 2561 2551 3541 3231 3421 3611 3501 3991 4191 43(1 4561 4(51 4941 513153215511515155910591 52(15451 5551 5941 /9.1 7ZZ1 1411 15-17V75 75510171 520- 05-1 0141 10M WS/60M WS 10WD/60M WD Correl 0.905236 Correl 0.763324 Slope 1.130455 Slope 0.71852 Intercept 2.946583 Intercept 32.36286 1GM WS/LU WS 1OWD/LUWD Correl 0.878725 Correl 0.543727 Slope 0.855341 Slope 0.5281 62 Intercept 0.445252 1 Intercept 65.68353

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 61 of 74 Response to 5/28/20 10 RAIs for AST LAR 2008 2008 - No Substitutions Made by MSI/TP Julian Time Parameter Reason Action NAI Review Date 2008 2 1800 UWD Unknown METDQA program Identified:

UWD: WIND FROM SECTOR "Normal" variations in data NNW FOR PREVIOUS 24 readings do not indicate HOUR PERIOD 2200 LWD any instrument problems LWD: WIND FROM SECTOR NNW FOR PREVIOUS 29 HOUR PERIOD 8 1100 UWD Unknown METDQA program Identified:

UWD: WIND FROM SECTOR "Normal" variations in data E FOR PREVIOUS 35 HOUR readings do not indicate PERIOD 1100 LWD any instrument problems LWD: WIND FROM SECTOR E FOR PREVIOUS 28 HOUR PERIOD 135 1200 UWD Unknown METDQA program Identified:

WIND FROM SECTOR ENE "Normal" variations in data FOR PREVIOUS 24 HOUR readings do not indicate PERIOD any instrument problems 145 1400 Stability Unknown METDQA program Identified:

STABILITY CLASS JUMPED "Normal" variations in data FROM A TO E OVER ONE readings do not indicate HOUR PERIOD any instrument problems 233 1600 UWD Unknown METDQA program Identified:

UWD: WIND FROM SECTOR "Normal" variations in data SW FOR PREVIOUS 24 HOUR readings do not indicate PERIOD LWD any instrument problems LWD: WIND FROM SECTOR SW FOR PREVIOUS 24 HOUR PERIOD 253 1100 Stability Unknown METD._QA program Identified:

STABILITY CLASS D LASTED "Normal" variations in data FOR PREVIOUS 44 HOUR readings do not indicate PERIOD any instrument problems I

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 62 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2008 255 0500 Stability Unknown METDQA program Identified:

STABILITY CLASS D LASTED "Normal" variations in data FOR PREVIOUS 30 HOUR readings do not indicate PERIOD any instrument problems 272 1000 Stability Unknown METDQA program Identified:

STABILITY CLASS E LASTED "Normal" variations in data FOR PREVIOUS 35 HOUR readings do not indicate PERIOD any instrument problems 288 1600 UWD Unknown METDQA program Identified:

WIND FROM SECTOR ENE "Normal" variations in data FOR PREVIOUS 25 HOUR readings do not indicate PERIOD any instrument problems 291 0700 UWD Unknown METD_QA program Identified:

UWD: WIND FROM SECTOR "Normal" variations in data ENE FOR PREVIOUS 24 readings do not indicate HOUR PERIOD LWD any instrument problems LWD: WIND FROM SECTOR ENE FOR PREVIOUS 24 HOUR PERIOD 360 0200 UWD Unknown METD_QA program Identified:

UWD: WIND FROM SECTOR "Normal" variations in data E FOR PREVIOUS 30 HOUR readings do not indicate PERIOD 0500 LWD any instrument problems LWD: WIND FROM SECTOR E FOR PREVIOUS 24 HOUR PERIOD 361 2300 UWD Unknown M METD_QA program Identified:

WIND FROM SECTOR E FOR "Normal" variations in data PREVIOUS 24 HOUR PERIOD readings do not indicate any instrument problems I

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 63 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2008 10 and 60 Meter Wind (From) Direction 360 North 315 NW 270 West 225 SW gniith 180 0I 135 SE 90 East 45 NE 0 North 1/112008 0:00 2/20/2008 0:00 4/10/2008 0:00 5/30/2008 0:00 7/19/2008 0:00 9/7/2008 0:00 10/27/2008 0:00 12/16/2008 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 64 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2008 u 60M Wind Speed mph Wind Speeds mph S:1OM Wind Speed mph 30.00 25.00 20.00 15.00 10.00 5.00 0.00 1-Jan 20-Feb 10-Apr 30-May 19-Jul 7-Sep 27-Oct 16-Dec

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 65 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2008 60M Minus 10M and Bravo delta Temperature (*F) S 6.000 5.000 4.000 3.000 2.000 1.000 0.000

-1.000

,t-2.000 II - - - I I I I -3.000 1/1/2008 0:00 2/20/2008 0:00 4/10/2008 0:00 5/30/2008 0:00 7/19/2008 0:00 9/7/2008 0:00 10/27/2008 0:00 12/16/2008 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 66 of 74 Response to 5/28/2010 RAIs for AST LAR 2009 - MSI/TP Identified Substitutions/Flaimed Entries in Yellow Highlight Julian Time Parameter Reason Action NAI Review Date 2009 9 0900 Stability Unknown METD-_QA program Identified:

STABILITY CLASS JUMPED "Normal" variations in data FROM F TO B OVER ONE readings do not indicate HOUR PERIOD any instrument problems 25 1000 Stability Unknown METDQA program Identified:

STABILITY CLASS JUMPED "Normal" variations in data FROM F TO B OVER ONE readings do not indicate HOUR PERIOD any instrument problems 27 2300 WD10 Unknown METDQA program identified:

WIND FROM SECTOR E FOR "Normal" variations in data PREVIOUS 28 HOUR PERIOD readings do not indicate any instrument problems 57 0600 W60 Unknown METDQA program identified:

WIND FROM SECTOR ENE "Normal" variations in data FOR PREVIOUS 25 HOUR readings do not indicate PERIOD any instrument problems 58 0300 WI0 Unknown METD_QA program identified:

WIND FROM SECTOR ENE "Normal" variations in data FOR PREVIOUS 31 HOUR readings do not indicate PERIOD any instrument problems 59 0100 W60 Unknown METDQA program identified:

WIND FROM SECTOR E FOR "Normal" variations in data PREVIOUS 24 HOUR PERIOD readings do not indicate any instrument problems 84 0900 W60 Unknown METD_QA program identified:

WIND FROM SECTOR E FOR "Normal" variations in data PREVIOUS 25 HOUR PERIOD readings do not indicate any instrument problems

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 67 of 74 Response to 5/28/2010 RAIs for AST LAR Julian T Time Parameter Reason Action NAI Review Date 2009 1 1 1 E! I 111 800-2400 WD10, SigmalO Essentially constant 1OM tower WD and sigma theta Sigma Theta 10 not checked.

substituted for 10M data from 60M tower. "RAW Data" file Wdv_1 OM contains essentially constant values, which is consistent with a stuck instrument reading.

NAI concurs that the primary tower data is bad.

See Chart below for graphical depiction of the "MSI QA" data file. The blue data points clustered around the May 7, 2009 X-axis label are the substituted Land Use tower data points. They show an abrupt change from a daily swing from off ocean to off land to a Irecdominanu

!ILe nt 4 + +

111 800-2400 WD60 Essentially constant Set equal to 1OM WD data NAI verified WD60 abrupt change from 275 degrees to 25 degrees, where the reading stuck.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Om wind direction, the 60m data was replaced with 1Im wind direction data.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 68 of 74 Restonse to 5/28/2010 RAls for AST LAR Julian Time Parameter Reason Action NAI Review Date 2009 I.. .- ~-.--

i_______

NAI Identified: The plots of 60M 139-14U A-Ol & rB-O I minus 1 M delta T for A and B channels shows an offset/shift around May 18/May 20. A-channel temperature sensor was out of service for a couple of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> periods on these days, and when returned to service, both A and B channel delta-Ts seemed to be offset from prior trends. See Plot below.

112-174 100-2400 WD1G, SigmalO Essentially constant 1GM tower WD and sigma theta Sigma Theta 10 not checked.

substituted for 1GM data from 60M tower. "RAW Data" file Wdv_1GM contains essentially constant values, which is consistent wi-1~ + +

112-174 100-2400 WD60 Essentially constant Set equal to 1GM WD NAI verified WD60 continues to be about 25 degrees, where the reading stuck.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 1Gm wind direction, the 60m data was replaced with 10m wind direction data.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 69 of 74 Resnonse to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2009 151 1500 Stability Unknown METDQA program Identified:

STABILITY CLASS JUMPED "Normal" variations in data FROM A TO E OVER ONE readings do not indicate HOUR PERIOD any instrument problems 175 100-1100 WD1 0, Sigmal 0 Essentially constant 1OM tower WD and sigma theta Sigma Theta 10 not checked.

substituted for 1OM data from 60M tower. "RAW Data" file Wdvl1OM

- contains essentially constant values, which is consistent with a stuck instrument reading. For almost all of this range of data, NAI substituted 0900 WD10 NAI concurs that the primary value of 237 degrees from LU tower data is bad.

1OM data to over-write the invalid "20" value in the South Dade tower data.

175 100-1100 WD60 Essentially constant Set equal to 1 OM WD NAI verified WD60 continues to be about 25 degrees, where the reading stuck.

Based on MSI-provided graphs that indicate 60m wind direction corresponds reasonably well with 10m wind direction, the 60M data was replaced with 1Om wind direction data.

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 70 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2009 201 1300 Stability Unknown METDQA program Identified:

STABILITY CLASS JUMPED "Normal" variations in data FROM A TO E OVER ONE readings do not indicate HOUR PERIOD any instrument problems 245 0800 Stability Unknown METDQA program Identified:

STABILITY CLASS JUMPED "Normal" variations in data FROM F TO B OVER ONE readings do not indicate HOUR PERIOD any instrument problems 310 2000 W10 Unknown METDQA program identified:

WIND FROM SECTOR NE "Normal" variations in data FOR PREVIOUS 34 HOUR readings do not indicate PERIOD any instrument problems 310 2000 W60 Unknown METD_QA program identified:

WIND FROM SECTOR NE "Normal" variations in data FOR PREVIOUS 34 HOUR readings do not indicate PERIOD any instrument problems 312 0900 W10 Unknown METDQA program identified:

WIND FROM SECTOR ENE "Normal" variations in data FOR PREVIOUS 37 HOUR readings do not indicate PERIOD any instrument problems 312 0900 W60 Unknown METDQA program identified:

WIND FROM SECTOR ENE "Normal" variations in data FOR PREVIOUS 37 HOUR readings do not indicate PERIOD any instrument problems 344 0700 W60 Unknown METDQA program identified:

WIND FROM SECTOR S FOR "Normal" variations in data PREVIOUS 28 HOUR PERIOD readings do not indicate any instrument problems 353 0800 Stability Unknown METD_QA program identified:

STABILITY CLASS E LASTED "Normal" variations in data FOR PREVIOUS 40 HOUR readings do not indicate PERIOD any instrument problems

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment I License Amendment Request 196 Page 71 of 74 Response to 5/28/2010 RAIs for AST LAR Julian Time Parameter Reason Action NAI Review Date 2009 355 1000 WD60 Unknown I QA program identified:

METD WIND FROM SECTOR N FOR "Normal" variations in data PREVIOUS 28 HOUR PERIOD readings do not indicate any instrument problems

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 72 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2009 10 and 60 Meter Wind (From) Direction 360 North 315 NW 270 West 225 SW South '

180 135 SE 90 East 45 NE 0 North 3/18/2009 0:00 5/7/2009 0:00 6/26/2009 0:00 8/15/2009 0:00 10/4/2009 0:00 11/23/2009 0:00

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 73 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2009 --- 60M Wind Speed mph Wind Speeds mph 1OM Wind Speed mph 30.00 25.00 20.00 15.00 10.00 5.00 6-u -u 4-e 4-c 3-o 3-e 2-a 0.00 3-Dec 2-Jan 6-Jul 5-Aug 4-Sep 4-Oct 3-Nov

Turkey Point Units 3 and 4 L-2010-131 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request 196 Page 74 of 74 Response to 5/28/2010 RAIs for AST LAR Turkey Point "MSI QA File" - 2009 Alpha 6OM Minus 10 M delta Temperature (*F) and Bravo Channels ----- Bravo with Rain events Rain (inches) at center Zero Line 6.000 5.000 4.000 3.000 2.000 1.000 0.000

-1.000

-2.000 1-3.000 4/17/2009 0:00 5/7/2009 0:00 5/27/2009 0:00 6/16/2009 0:00 7/6/2009 0:00 7/26/2009 0:00