L-2023-069, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project
| ML23151A607 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/31/2023 |
| From: | Strand D Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23151A606 | List: |
| References | |
| L-2023-069 | |
| Download: ML23151A607 (1) | |
Text
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 May 31, 2023 L-2023-069 10 CFR 50.90 Framatome Inc. Proprietary (Not proprietary when separated from Enclosure 1)
RE:
Turkey Point Nuclear Generating Station, Units 3 and 4 Docket Nos. 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 Response to Requests for Additional Information Regarding License Amendment Request No.
276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project
References:
- 1.
License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, August 26, 2022 (ADAMS Accession No. ML22243A161)
- 2. NRC electronic memorandum, May 5, 2023, Turkey Point Nuclear Generating Unit Nos. 3 and 4 -
Request for Additional Information - RCP LAR (L-2022-LLA-0128) (ADAMS Accession No. ML23129A832)
In Reference 1 Florida Power & Light Company (FPL) submitted license amendment request 276 for Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point). The proposed license amendment is requested in accordance with the Turkey Point Units 3 and 4 Subsequent Renewed Facility Operating Licenses (SRFOL) Paragraph 3.D, Fire Protection, for fire protection program changes that may be made without prior NRC approval. One of the criteria for such a change is that the risk increase resulting from the change is less than 1x10-7/year (yr) for Core Damage Frequency (CDF) and less than 1 x 10-8/yr for Large Early Release Frequency (LERF). The plant change to be evaluated is the replacement of the currently installed reactor coolant pump (RCP) seals with the Framatome RCP hydrostatic seal package equipped with the Passive Shutdown Seal (PSDS). FPL's evaluation of the proposed RCP seal replacement against the criteria of SRFOL Paragraph 3.D, concluded that the threshold for self-approval is exceeded and therefore, prior NRC approval is sought.
In Reference 2 the NRC requested additional information deemed necessary to complete its review. provides FPL's response to the request for additional information (RAI). Enclosure 1 contains information that is proprietary to Framatome, Incorporated. Pursuant to 10 CFR 2.390(a)(4), FPL requests that the proprietary information be withheld from public disclosure. The request is supported by an affidavit signed by Framatome, Incorporated, the owner of the information. The affidavit, provided in Attachment 1, sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Correspondence with respect to the proprietary aspects of this information or the supporting Framatome, Incorporated affidavit should be addressed to Mr. Philip Opsal, Manager, Product Licensing for Framatome, 3315 Old Forest Road, Lynchburg, Virginia, 24501. Enclosure 2 provides the non-proprietary version of the information.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2023-069 Page 2 of 2 The information included in this RAI response provides additional information that clarifies the application, does not expand the scope of the application as originally noticed, and should not change the NRC staff's originally proposed no significant hazards consideration determination as published in the Federal Register.
This letter contains no new regulatory commitments.
Should you have any questions regarding this submittal, please contact Mr. Kenneth Mack, Fleet Licensing Manager at 561-904-3635.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 31 st day of May 2023.
Sincerely, Dianne Strand General Manager, Regulatory Affairs Enclosures (2)
Attachments (1) cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Generating Station USNRC Senior Resident Inspector, Turkey Point Nuclear Generating Station Ms. Cindy Becker, Florida Department of Health (Enclosure 2 and Attachment 1 only)
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ATTACHMENT 1 FRAMATOME AFFIDAVIT L-2023-069 to Enclosure 1 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project (3 pages follow)
- 1.
My name is Philip A Opsal. I am Manager, Product Licensing for Framatome Inc. (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
- 3.
I am familiar with the Framatome information contained in Florida Power and Light letter to the NRC, L-2023-069, "Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project" referred to herein as "this Document." Information contained in Enclosure 1 of this Document, identified within balded square brackets, has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the requestthat the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is
made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
- 6.
The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:
(a)
The information reveals details of Framatome's research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.
The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d), and 6(e) above.
- 7.
In accordance with Framatome's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May 31, 2023.
Philip A Opsal
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ENCLOSURE 2 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 L-2023-069 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Response to Request for Additional Information (RAl)
Turkey Point Nuclear Plant Unit 3 and Unit 4 L-2023-069 Page 1 of 7 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project NRC Staff Requests for Additional Information (RAls)
- 1.
Sections 3.1.5 and 3.5 (Operator Action and Defense-In-Depth) of the Turkey Point LAR dated August 26, 2022 (ML22243A162) discuss a required RCP trip time of 16 minutes but does not provide the bases for this assumption. Explain the bases for the RCP trip time of 16 minutes. Explain whether this action is a recovery action or a required postfire manual operator action, and whether this action has been incorporated into appropriate procedures and demonstrated to be feasible and reliable. Discuss if there are any other operator actions which need to be performed along with an RCP trip and if so, what are their impacts and how are they credited in the PRA models.
FPL Response - RAI 1 The basis for the RCP trip time of 16 minutes is addressed separately from this response.
This operator action to trip the RCPs is an action in the main control room, and is therefore, not a recovery action but, a required post-fire operator action taken in the control room.
The Human Reliability Analysis performed to support this action defines its failure rate. The associated human error probability (HEP) is applied to basic event CHFPSTPRCP for the internal events and internal flooding models, and CHFPSTPRCP-F for the fire model for a loss of CCW, and to basic events QHFPSTPRCP and QHFPSTPRCP-F for loss of intake cooling water system. This action is incorporated in operating procedures.
The additional operator action associated with a trip of an RCP with the installed replacement Framatome seal is:
- FTlSEALCLG-LOCAL (fail to isolate seal cooling prior to spurious initiation of seal cooling subsequent to initial loss of cooling), new action, 0.01 screening value, detailed HEP to be developed in conjunction with the review and update of associated procedures for RCP seal replacement. System Time Window (Tsw) is 59 minutes. This action is to support isolation of CCW/seal injection to prevent spurious operation post seal actuation.
The FTISEALCLG-LOCAL is the only new operator action added to the model.
- 2.
Section 3.3 (Risk Analysis Results) of the LAR reports the total core damage frequency (CDF) for full power internal events, internal flood, and fire probabilistic risk assessment (PRA) for U3 and U4 as 8.01 E-5 and 7.82E-5, respectively. However, there is no estimate for seismic and other external hazards. Provide seismic and other external hazard contributions to CDF/LERF, or alternately provide a justification for why the Regulatory Guide 1.174, "An Approach For Using Probabilistic Risk Assessment In Risk-Informed Decisions On Plant-Specific Changes To The Licensing Basis," Revision 3, guidelines are met without quantitative contributions from those hazards. Provide a discussion for how, after taking uncertainty into account for the addition of seismic and other external hazards, the total CDF and LERF will not exceed the RG 1.17 4 acceptance guidelines.
FPL Response - RAI 2 The response to this RAI will be provided at a future date as described in Reference 1.
- 3.
Appendix A of Attachment 1 of the LAR uses the fire CDF and LERF to determine the internal events/flooding delta CDF and LERF. The LAR indicates that fire induced failures of systems to prevent
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 L-2023-069 Page 2 of 7 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project the loss of the RCP seals are larger than random failures; thus, extrapolating internal events/flooding delta CDF and LERF from fire is conservative.
However, the NRC staff notes that other fire damage in general plays a role in these scenarios, and thus, comparing the fire induced failure of systems relevant to loss of the RCP seals is only one factor, and perhaps not the dominant factor. Therefore, the NRC staff does not have sufficient information to determine whether the delta risk from internal events/flooding being derived from fires only would be an acceptable approach. As a result, provide a calculation of internal events/flooding delta CDF/LERF which relies only on the internal events/flooding PRA model, and is not extrapolated from the fire PRA model.
FPL Response - RAI 3 The response to this RAI will be provided at a future date as described in Reference 1.
- 4.
Indicate whether any upgrades have been made to the PRA since the last peer review of either corresponding hazard.
FPL Response - RAI 4 There have been no upgrades made to the Turkey Point internal events or fire PRA models since the last peer review. Each model change that has been made has been reviewed in accordance with the PRA model maintenance procedure. Each review noted that there were no new methods that were implemented as part of these model updates.
- 5.
Indicate whether the IE/flooding model of record identified in Appendix A of Attachment 1 to the LAR is the latest version of this PRA and includes the proposed RCP seal change described in the LAR. If not, indicate why the CDF and LERF of these hazards is acceptable, or otherwise provide quantitative risk values which incorporates the proposed seal changes.
FPL Response - RAI 5 The response to this RAI will be provided at a future date as described in Reference 1.
- 6.
In the uncertainty matrix, Table C-4 of Attachment 1 to the LAR, task no. 5, it is stated that a reactor trip alone is assumed as the initiator for all fires that are quantified in the fire PRA. However, the NRC staff acknowledges that other initiators may arise from fire (e.g., loss of offsite power (LOOP)) that have the potential to be more severe. Provide an updated fire CDF/LERF which incorporates these other potential initiators, or a justification for excluding them.
FPL Response - RAI 6 A fire-related reactor trip initiating event (3/4ZZFIRE) was added to the model for use in the fire PRA (FPRA) quantification. Where applicable, logic was added to the FPRA model to capture fire-related failures that could induce other initiating events. This new logic was added to the FPRA fault tree at a level that would allow FPRA quantification to account for the impacts of both the assumed reactor trip as well as any additional fire-induced initiating events.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2023-069 Page 3 of7 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project The mapping of PRA components was performed on the basic-event-to-component level and not the basic event/component-to-initiating event level. Failure of components will thus propagate through the fault tree to the applicable initiating event logic.
NOTE:
A similar issue was evaluated during the NFPA 805 LAR review with respect to the disposition of FPRA peer review Facts and Observations (F&Os). There are no changes associated with the RCP seal modification that would alter the treatment addressed in the NFPA 805 LAR. References 2 and 3 provide the letter issuing the RAls and the RAI responses. The final disposition of the F&Os is contained in Reference 4.
- 7.
Section E.2.1.3 of Attachment 1 to the LAR, indicates that the MGR response is 100% effective, yet there is still the possibility of having an alarm that is silenced by the MGR or not properly investigated, which is reflected in the MGR and plant personnel fault trees. In the application of the methodology presented, this affects the probability listed in Table E-4 for 112. The probability of personnel not present in the room should not be 0. The probability should be dictated by the MGR response failure probability.
The MGR response is independent of the ability for the system to provide advance warning or prompt warning. Provide further justification for the choice of MGR response and how it was determined that the probability of personnel present in the room is 100%. Alternately, adjust the credit in the table below.
(The relevant portion of Table E 112 is provided below).
Table E 172 Cale Using NUREG-2230 (Cable Sp1-eculi11g Room - Jn-Cal>inet Detection)
Pammetel' Value Probability of personnel not present in room 0
.Justifieation As specified in NUREG2180, given a failure of the VEWFD system to provide sufficient advance warning, the VEWFD system will still provide prompt detection functions. Therefore, in this case, the incipient detector within the electrical cabinet is considered as personnel always present in the room for NUREG-2230.
The evaluation associated with Appendix E of LAR Attachment 1 (Reference 5) addresses the fire modeling associated with electrical panels in the cable spreading room for which incipient detection is provided and for which the methodologies of NUREG-2180 and NUREG-2230 are applied.
The assumption of personnel present in the room is based on the NUREG-2180 methodology.
As documented in Section 11.2 of NUREG-2180,
[... ] "112" represents sequences F - I from Figure 11-1. That is, given a failure of the VEWFD system to provide sufficient advance warning, the VEWFD system will still provide prompt detection functions. Time to detection is assumed to be at ignition.
This analysis interprets a prompt alert as representative of personnel in the area given the "alert" of the fire and results in a 100% successful first detection in NUREG-2230. This is representative of the use of a 1.0 success value for prompt detection (See Figure 2 below) in the example detection-suppression
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 L-2023-069 Page 4 of 7 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project event presented in Figure 12-2 of NUREG-2180 for the parameter 112. As described in NUREG/CR-6850, a value of 1.0 may be assumed for prompt detection in cases where a continuous fire watch is present.
This is also representative of the 1.0 success used in the automatic detection branch (See Figure 1 below) and the use of a zero-detection time for the 112 detection-suppression event tree used in the NUREG-2180 Excel worksheets.
Event Tree For 112 Ai...tcmitrc Manual i!
fire EndSlate Pi(IIO!Js IJ<!e<Mo I I
I 5'Wes,;;co)
~""10<1 Dclecti.oo r,:.oo Fire8.'ll)i300
OK 1000 ~ l°OOE*OO 100E*OO IOOOE*OO G
OK I OOE*OO l°OOE*OO 11 OK 1.00E*OO I
llS t OOE*OO OOOE*OO l°OOE*OO J
OK 1 OOE*OO OOOE*OO IOOOE*OO K
OK t OOE*OO IOOOE*OO L
OK 1 OOEtOO M
tlS OOOE*OO 100£*00 II llS OOOE*OO Toti!
t OOE*OO Figure 3: Event Tree for 112, NUREG-2180 Event Tree Spreadsheet for In-Cabinet Fire Detection
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 L-2023-069 Page 5 of 7 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project Prompt Automatic Manual B
C End Pr(non-Fire (I)
Deteclionjsuppression Detection I Fixed I Fire Brigade State suppression) g Detection
(/)
Fl PD AD AS MD MF FB 1.0 1.0 1.0 I 0.0 F
OK 1.0 I
0.0 G
OK 1.0 I 0.691 H
OK 0.309 I
NS 3.1E-01 0.0 I 0.0 J
OK 1.0 0.0 I 0.0 K
OK 1.0 I 0.691 L
OK 0.309 M
NS 0.0 1.0 N
NS 0.0 Total 3.1E-01 Figure 4: Figure 12-2 of NUREG-2180. Case 1, detection suppression event tree (112)
- 8.
Page 22 of Attachment 5 to the LAR references a ((
)) regarding corrosion resistance testing for the sealing ring. It further indicates that the results of the testing program show ((
)) Explain how the ((
)) represent the operating conditions of the plant.
FPL Response - RAI 8 Radiation and chemical testing parameters used in qualification of the ((
)) are outlined in Reference 6. The range of radiation and reactor coolant chemistry parameters at Turkey Point are found in Reference 7. The table below compares the two sets of parameters:
Test Condition Turkey Point Reactor Coolant Parameters pH rr 11 4.5-10.2 Boron rr 11
- , 2350 oom Lithium rr 11 0-3.5 oom Temperature rr
))
572°F Radiation rr
))
298,944 Rad
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2023-069 Page 6 of?
Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project Note that not all parameters used during testing bound the full range of reactor coolant chemistry conditions at Turkey Point. However, the intent of the testing is to prove that the ((
)) is not sensitive to the radiation and chemistry parameters experienced during normal operation.
A follow-up question was provided regarding the source of the ((
of the ((
by combining the total number of actuation tests from ((
)) used in the calculation
)). This value was obtained
)) of Reference 8.
- 9.
Page 21 of Attachment 3 to the LAR, indicates that the expected accident temperature environment at the ((
)) would be ((
)). Provide the justification that the expected accident temperature environment at the plant would not exceed ((
)).
FPL Response - RAI 9 to the LAR (Reference 5) considers extended station blackout (SBO), extended loss of alternating current power (ELAP), and loss of all RCP seal cooling events. During these events, the reactor and RCPs are either automatically or manually tripped and no seal cooling is available to the RCP seals. Without seal cooling, reactor coolant from the RCS cold leg will flow into the RCP seal housings and through the seals. Therefore, the expected accident temperature environment at the ((
)).
The temperature of the RCS cold leg is predicated by the steam generator (SG) secondary side conditions and will correspond to the SG atmospheric relief pressure. Turkey Point utilizes the Westinghouse Owner's Group Emergency Response Guidelines to form the foundation of their emergency response procedures and as part of the reactor trip response, operators are directed to maintain RCS cold leg temperature at 547°F, which corresponds to the saturation temperature of the atmospheric relief valves' pressure setpoint. This is the lowest temperature that is expected for the post trip condition ((
)) Higher RCS cold leg temperatures that may exist during these scenarios result in ((
))
- 10. Section 3.5 of Attachment 1 to the LAR presents failures to actuate, remain sealed, and spurious actuation of the PSDS as time dependent failure rate frequencies. However, the development and evaluation of the failure modes for the PSDS is presented in Attachment 3 to the LAR, as per demand failures. Explain the rationale and justification for the inconsistency of units.
FPL Response - RAI 10 The units specified in Section 3.5 are incorrect, the seal failure configurations and the associated failure modes are demand failure contributions to the seal failure value used in the PRA model. The values specified are per demand, consistent with the derived numbers in Attachments 3, 5 and 7 of the LAR (Reference 5). The failure to remain sealed failure mode (LAR Attachment 5), when calculated based on hours of operation and using ((
)) would be an hourly failure rate which is multiplied by 24 to obtain the total failure rate over the mission time. However, the failure to remain sealed, when calculated based on specific failure modes, is a demand failure. The failure modes are associated with overpressure due to RCS relief valve random failure probabilities, failure due to material
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Response to Request for Additional Information (RAI)
Turkey Point Nuclear Plant Unit 3 and Unit 4 L-2023-069 Page 7 of7 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project defects, or assembly errors impacting the seal when post seal actuation conditions are imposed on the PSDS.
References
- 9.
NRC electronic memorandum, May 5, 2023, Turkey Point Nuclear Generating Unit Nos. 3 and 4 -
Request for Additional Information - RCP LAR (L-2022-LLA-0128) (ADAMS Accession No. ML23129A832)
- 10. Letter from NRC to FPL, "Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants," March 15, 2013 (ADAMS Accession No. ML13038A310)
- 11. Letter from FPL to NRC, "Response to Request for Additional Information for License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 edition)," March 18, 2013 (ADAMS Accession No. ML13099A441)
- 12. Nuclear Regulatory Commission, "Record of Review, Dispositions to Turkey Point PRA Facts and Observations," February 23, 2015 (ADAMS Accession No. ML15054A037)
- 13. Letter from FPL to NRC, "License Amendment Request 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project, August 26, 2022 (ADAMS Accession No. ML22243A162)
- 14. Framatome Document No. 58-9346861, Revision 0, "Report of the Aging and Corrosion Resistance Tests of the ((
))"
- 15. Framatome Document No. 152-9348792-000, "Reactor Coolant Pump Seal and Seal Housing Procurement Specification for Turkey Point Units 3 and 4 (SPEC-M-241 Revision O)"
- 16. Framatome Document No. 38-9351062 Revision 1, "Passive Shutdown Seal ((
J] for Reactor Coolant Pump ((
))"