ML091240377

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Summary of April 24, 2009 - Category 1 Meeting with Florida Power & Light, Turkey Point, to Discuss Proposed Alternative Source Term License Amendment Request
ML091240377
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 05/27/2009
From: Jason Paige
Plant Licensing Branch II
To:
Paige, Jason, NRR,301-415-5888
Shared Package
ML091240358 List:
References
Download: ML091240377 (2)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 1\1ay 27, 2009 LICENSEE: Florida Power & Light FACILITY: Turkey Point Nuclear Plant, Units 3 and 4 SUB~IECT:

SUMMARY

OF APRIL 24,2009, CATEGORY 1 MEETING WITH FLORIDA POWER & LIGHT, TO DISCUSS TURKEY POINT NUCLEAR PLANTS PROPOSED ALTERNATIVE SOURCE TERM LICENSE AMENDMENT REQUEST On April 24, 2009, a public meeting was held between the Nuclear Regulatory Commission (NRC), and representatives of Florida Power & Light (FPL), Turkey Point, at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, MD. The purpose of this presubmittal meeting was to achieve a common understanding between the Agency and Turkey Point of the proposed scope of the Turkey Point Alternative Source Term (AST) application, gain clarification regarding regulatory positions on specific issues relating to the AST, and understand the level of detail of information expected in the application.

The licensee presented information on the reason for adopting AST, which are to update the Turkey Point Units 3 and 4 accident dose analyses using a consistent basis for all events as described by Regulatory Guide (RG) 1.183 and to support a future extended power uprate (EPU). During the presentation the staff communicated to the licensee examples of good submittals that FPL should review for precedence. The licensee continued with the presentation by stating the specific aspects of the analyses and content of their submittal. A couple of the specific aspects that will be included in the submittal are Turkey Point specific source term inventories calculated using ORIGEN 2, which considers conservative burnup ranges, enrichment ranges, and power levels (bounds both current operating conditions and future EPU operating conditions), updated control room and offsite X/Q values based upon RG 1.194 and RG 1.145 using recent meteorological data, and the loss-of-coolant accident dose contribution from the emergency core cooling system back-leakage to the refueling water storage tank considering the effects of sump pH, back-leakage temperature reduction, and total iodine distribution within the tank.

The staff questioned what version of ORIGEN was used to calculate the source term. This was to determine the specific methodology that was used to calculate the source term and to clarify that the licensee consistently used one version. The licensee indicated that they used ORIGEN 2.1 and the staff was satisfied with this version. The licensee continued the presentation by stating the proposed technical specification changes that will be included in the AST license amendment request (LAR).

The licensee concluded the presentation by communicating to the NRC the planned schedule for the AST and EPU LARs. Turkey Point plans to submit the AST LAR in June 2009 and the EPU LAR in the 2nd quarter of 2010. The staff questioned if the EPU LAR would be submitted after the review of the AST is completed. Turkey Point responded that the EPU would be submitted approximately in June 2010 after the completion of the AST review, assuming a 1 year AST review.

-2 Members of the public were not in attendance. A representative from Turkey Point filled out a Public meeting feedback form and was satisfied with the outcome of the meeting.

A list of meeting attendees is attached. Also, a copy of the licensee's slides can be found in ADAMS, Accession Number ML091160002.

Please direct any inquiries to Jason Paige at 301-415-5888, or Jason.Paige@nrc.gov.

rely,

--r..-J?

Jason C. Paige, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

List of Attendees cc w/encl: Distribution via ListServ

LIST OF ATTENDEES APRIL 24, 2009, MEETING WITH FLORIDA POWER & LIGHT ALTERNATIVE SOURCE TERM REQUEST FOR TURKEY POINT LICENSE AMENDMENT PRE-SUBMITIAL MEETING NAME ORGANIZATION Eva Brown NRC/NRRlDORULPL2-2 Lois James NRC/NRRlDORULPL3-1 Leta Brown NRC/NRRlDRAIAccident Dose Branch Tony Nakanishi NRC/NRRlDSS/Reactor Systems Branch Aleem Boatright NRC/NRRlDRAIAccident Dose Branch Robert Taylor NRC/NRRlDRAIAccident Dose Branch John Parillo NRC/NRRlDRAIAccident Dose Branch Greg Myers Florida Power & Light Liz Abbott Florida Power & Light Mark Pope (by phone) Nuclear Energy Institute Steve Hale Florida Power & Light Brenda Mozafari NRC/NRRlDORULPL2-2 Allen Howe NRC/NRRlDORL Enclosure

  • I=PL.

A.LTERNATIVE SOURCE TERM (AST)

Request for License Amendment Pre-Submittal Meeting Turkey Point Units 3 and 4 April 24, 2009

Turkey Point Units 3 and 4 - Alternative Source Term ATTENDEES FOR FPL

  • Jim Harrell Contractor (Numerical Applications, Inc.)

2

  • I=PL.

Turkey Point Units 3 and 4 - Alternative Source Term PURPOSE OF PRE-SUBMITTAL MEETING

  • Achieve common understanding of the proposed scope of the Turkey Point application
  • ~ain understanding regarding regulatory positions on specific Issues
  • Understand the level of detail of information expected in the application 3
  • I=PL.

Turkey Point Units 3 and 4 - Alternative Source Term AGENDA

  • Scope of Implementation
  • Specific Aspects of Analyses
  • Overview of Licensing Basis Changes
  • Proposed Technical Specification Changes
  • Subm ittal Content
  • Schedules
  • Summary 4
  • FPL.

Turkey Point Units 3 and 4 - Alternative Source Term REASON FOR ADOPTING AST METHODOLGY

  • To update Turkey Point Units 3 and 4 accident dose analyses using a consistent basis for all events as described by Regulatory Guide 1.183
  • To obtain margin for Control Room inleakage
  • FPL.

Turkey Point Units 3 and 4 - Alternative Source Term SCOPE OF IMPLEMENTATION

  • Postulated events analyzed

- Loss-ot-Coolant Accident

- Fuel Handling Accident

-- Sef?arate analysis tor Containment and Fuel Handling BUilding Releases

- Main Steam Line Break

-- No Fuel Damage postulated

-- Pre-Accident and Concurrent Iodine Spikes 6

  • ~PL.

Turkey Point Units 3 and 4 - Alternative Source Term SCOPE OF IMPLEMENTATION

  • Postulated events analyzed (continued)

- Steam Generator Tube Rupture

-- No Fuel Damage postulated

-- Pre-Accident and Concurrent Iodine Spikes

-- Considers pre-trip releases via condenser and post-trip releases via Steam Generator

- Locked Rotor

-- Postulated Fuel Damage

- Rod Cluster Control Assembly Ejection

-- Containment and Secondary Release Events

-- Postulated Fuel Damage 7

  • F=PL.

Turkey Point Units 3 and 4 - Alternative Source Term SCOPE OF IMPLEMENTATION

  • Postulated events analyzed (continued)

- Waste Gas Decay Tank Rupture

-- Utilizes Exclusion Area Boundary Limit of 0.1 rem TEDE consistent with RIS 2006-04

- Spent Fuel Cask Drop

  • Postulated fuel damage 8
  • I=PL.

Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES

  • Turkey Point specific source term inventories calculated using ORIGEN 2

-- Considers conservative burnup ranges, enrichment ranges and power levels

-- Bounds both current operating conditions and future extended power uprate operating conditions (2652 MWt, including calorimetric uncertainties)

  • F=PL.

Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)

  • 10% of the total iodine activity in the EGCS leakage outside containment assumed airborne
  • LOGA dose contribution from the EGCS back-leakage to RWST considers the effects of sump pH, back leakage temperature reduction, and total iodine distribution within the tank
  • Analysis inputs and atmospheric steam releases are set conservatively to bound current plant operating conditions and future extended power uprate operating conditions (2652 MWt, including calorimetric uncertainties) 10
  • FPL.

Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cant)

  • Analyses support implementation of AST at current power level, independent of EPU
  • Preliminary dose analyses support increased Control Room unfiltered inleakage rates

-- Control Room inleakage testing performed in August 2003 indicated less than 10 cfm of unfiltered inleakage

-- Control Room is shared between Units 3 and 4

-- 150 cfm unfiltered inleakage assumed

Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)

Turkey Point AST Evaluation Preliminary Results Event EAB LPZ CR LOCA 5.66 1.54 4.81 FHA - in Containment 0.91 0.20 1.01 FHA - in Fuel Handling Building 0.91 0.20 3.95 MSLB - Pre-accident iodine spike 0.029 0.024 1.49 MSLB - Concurrent iodine spike 0.046 0.041 1.54 SGTR - Pre-accident iodine spike 0.82 0.18 2.85 SGTR - Concurrent iodine spike 0.28 0.07 1.10 All units are rem TEDE 12

  • I=PL.

Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)

Turkey Point AST Evaluation Preliminary Results Event EAB LPZ CR Locked Rotor 0.57 0.60 1.48 RCCA Ejection - Containment 0.88 0.40 2.34 RCCA Ejection - Secondary 0.59 0.56 1.32 Waste Gas Decay Tank Rupture 0.08 0.02 0.04 Spent Fuel Cask Drop 0.26 0.06 2.51 All units are rem TEDE.

13

  • FPL..

Turkey Point Units 3 and 4 - Alternative Source Term SPECIFIC ASPECTS OF THE ANALYSES (cont)

Consideration of High Burnup Rods for Fuel Handling Accident

  • To assure that failure of any offloaded fuel assembly is bounded by the Fuel Handling Accident, all of the rods in a single fuel assembly are conservatively assumed to exceed the burnup limits upon which the Reg. Guide 1.183 gap release fractions are based
  • Guidance of NUREG/CR-5009 is used to determine the conservative gap release fractions

- NUREG/CR-5009 endorses the gap release fractions for fuel handling events outlined in Reg. Guide 1.25 with some modification for higher burnups 14

  • FPL.

Turkey Point Units 3 and 4 - Alternative Source Term OVERVIEW OF ANTICIPATED LICENSING BASIS CHANGES

  • The total effective dose equivalent (TEDE) acceptance criterion of 10CFR50.67(b)(2) replaces the previous whole body and thyroid dose guidelines of 10CFR1 00.11
  • New onsite (Control Room) and offsite atmospheric dispersion factors are developed
  • Dose conversion factors for inhalation and submersion are from Federal Guidance Reports (FGR) Nos. 11 and 12, respectively 15
  • FPL..

Turkey Point Units 3 and 4 - Alternative Source Term OVERVIEW OF ANTICIPATED LICENSING BASIS CHANGES (cont)

  • A bounding value for control room unfiltered air inleakage was established by increasing the inleakage until the dose acceptance criteria for the limiting event (LOCA) was approached
  • A primary coolant specific activity for Dose Equivalent 1 131 that is more restrictive than the current Technical Specification limit is utilized
  • A steam generator tube leakage rate is used that is more restrictive than the current Technical Specification program limit for primary-to-secondary accident induced leakage 16

Turkey Point Units 3 and 4 - Alternative Source Term OVERVIEW OF ANTICIPATED LICENSING BASIS CHANGES (cont)

  • A containment leakage value that is more restrictive than the current Technicaf Specification limit is utilized
  • Sump pH control is provided by sodium tetraborate decahydrate (NaTB) baskets
  • Containment ESF filter units are not credited

- The 1ODIE-bar value is directly converted to dose equivalent Xenon-133, so this change is not required to implement AST 17

  • FPL

Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED PHYSICAL PLANT CHANGES

  • The Control Room Emergencr Intakes are proposed to be relocated to reduce contro room doses and support development of updated control room X/Q values
  • Sodium tetraborate decahydrate (NaTB) baskets are proposed to be added to the containment for pH control 18
  • FPL.

Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES

  • Definition of Dose Equivalent 1-131 in Section 1.10 is revised to reference Federal Guidance Report No. 11 (FGR 11), "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion" 1989, as the source of effective dose conversion factors.
  • Reactor Coolant System (RCS) specific activity limit for dose equivalent lodine-131 (DE 1-131), stated in Limiting Condition for Operation (LCO) 3.4.8.a, is reduced from 1 microcurie per gram to 0.25 microcurie per gram.

19

Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES (cont)

  • Reactor Coolant System specific activity limit for gross radioactivity stated in Limiting Condition for Operation (LCO) 3.4.8.b is changed from 1ODIE-bar to dose equivalent Xenon-133.
  • Terminology used in Limiting Condition for Operation (LCO) 3.7.9 to set the maximum contents of the Waste Gas Decay Tank is clarified to read 'DOSE EQUIVALENT Xe-133.'

20

  • I=PL.

Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES (cont)

  • Maximum allowable containment leakage rate acceptance criterion stated in TS 6.8.4.h, "Containment Leakage Rate Testing Program," is reduced from 0.25%

to 0.20% of containment air weight per day.

  • Maximum allowable primary-to-secondary accident induced leakage rate acceptance criterion stated in TS 6.8.4.j.b.2, "Steam Generator Program," is reduced from 500 gpd to 300 gpd through anyone steam generator.

21

Turkey Point Units 3 and 4 - Alternative Source Term PROPOSED TECHNICAL SPECIFICATION CHANGES (cont)

  • A method for controlling the pH of the post-LOCA containment sump solution using sodium tetraborate decahydrate (NaTB) is being proposed. This passive system will consist of baskets of NaTB in the lower regions of the containment. Appropriate Technical Specifications and Surveillance Requirements are proposed for Section 3/4.6 "Containment Systems."
  • Operability requirements for emergency containment filter units in Section 3/4.6.3 will be deleted.

22

  • FPL

Turkey Point Units 3 and 4 - Alternative Source Term SUBMITTAL CONTENT

  • Licensing Technical Report which presents the analysis assumptions and documents conformance with Reg.

Guide 1.183

  • Analyses key input parameters and results tables
  • Technical Specification changes
  • No Significant Hazards Considerations Evaluation
  • Plant modification descriptions 23

Turkey Point Units 3 and 4 - Alternative Source Term SCHEDULE

  • Planned AST Request for License Amendment (RLA) submittal in June 2009

- AST RLA provides dose analysis to support EPU

  • Planned EPU RLA submittal in 2 nd quarter of 2010

- EPU RLA will reference AST analyses provided in AST RLA

- Second review of dose analyses will not be required for EPU 24

  • FPL.

Turkey Point Units 3 and 4 - Alternative Source Term

SUMMARY

  • Addresses control room inleakage margin
  • Utilizes conservative inputs to bound current operating conditions and planned future extended power uprate operating conditions
  • Can be implemented at current power level
  • Planned submittal in June 2009 25

April 13, 2009 MEMORANDUM TO: Thomas H. Boyce, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing FROM: Jason Paige, Project Manager IRA!

Plant Licensing Branch 11-2 Division of Operating Reactor Licensing

SUBJECT:

TURKEY POINT NUCLEAR PLANT, UNITS 3 AND 4 - FORTHCOMING MEETING WITH FLORIDA POWER & LIGHT COMPANY DATE & TIME: Friday, April 24, 2009 10:00 a.m. - 12:00 p.m.

LOCATION: U.S. Nuclear Regulatory Commission (NRC)

One White Flint North 11555 Rockville Pike, Room 0-6B6 Rockville, Maryland PURPOSE: The purpose of this pre-submittal meeting is to achieve a common understanding between the NRC and Florida Power & Light (FPL) of the proposed scope of the Turkey Point Alternative Source Term (AST) application, gain clarification regarding regulatory positions on specific issues relating to the AST, and understand the level of detail of information expected in the application.

CATEGORY 1:

  • This is a Category 1 meeting. The public is invited to observe this meeting and will have one or more opportunities to communicate with the NRC after the business portion but before the meeting is adjourned.

Members of the public who wish to attend are encouraged to telephone or e-mail the contact listed below.

MEETING CONTACTS: Jason Paige, NRR Brenda Mozafari, NRR 301-415-5888 301-415-2020 jason. paige@nrc.gov brenda.mozafari@nrc.gov

'Commission's Policy Statement on "Enhancing Public Participation in NRC Meetings" (67 FR 36920), May 28, 2002, The NRC provides reasonable accommodation to individuals with disabilities where appropriate, If you need a reasonable accommodation to participate in a meeting, or need a meeting notice or a transcript or other information from a meeting in another format (e,g" Braille, large print), please notify the NRC's meeting contact. Determinations on requests for reasonable accommodation will be made on a case-by-case basis,

-2 PARTICIPANTS: Participants from the NRC include members of the Office of Nuclear Reactor Regulation (NRR).

NRC FPL J. Paige, NRR T. Boyce, NRR E. Abbott, FPL B. Tomonto, FPL R. Taylor, NRR B. Mozafari, NRR G. Myers, FPL L. Brown, NRR J. Harrell, FPL Docket Nos. 50-250 and 50-251

Enclosure:

Agenda cc w/enclosure: Distribution via Listserv

AGENDA FORTHCOMING MEETING WITH FLORIDA POWER & LIGHT TURKEY POINT NUCLEAR PLANT, UNITS 3 AND 4 Meeting on Friday. April 24. 2009 10:00 a.m. - 12:00 p.m.

  • Introductions
  • Scope of Implementation
  • Specific Aspects of the Analyses
  • Overview of Changes to the Licensing Basis
  • Proposed Technical Specification Changes
  • Submittal Content
  • Schedules
  • Summary
  • Public Participation and Adjournment Enclosure

- 2 Members of the public were not in attendance. A representative from Turkey Point filled out a Public meeting feedback form and was satisfied with the outcome of the meeting.

A list of meeting attendees is attached. Also, a copy of the licensee's slides can be found in ADAMS, Accession Number ML091160002.

Please direct any inquiries to Jason Paige at 301-415-5888, or Jason.Paige@nrc.gov.

Sincerely, IRA!

Jason C. Paige, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosure:

List of Attendees cc w/encl: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL2-2 r/f RidsNrrDorlLpl2-2 RidsNrrPMTurkeyPoint RidsOgcRp RidsNrrPMEBrown RidsNrrLABClayton TAlexion, NRR JAdams, EDO RidsAcrsAcnw_MaiICT Rids NrrDorlLpl3-1 TNakanishi, NRR RidsNrrDraAadb RidsRgn2MailCenter JParillo, I\lRR RidsNrrPMBMozafari CTucci, NRR ABoatright, NRR RidsNrrDorl LBrown, NRR ADAMS Accession Nos.

Package: ML091240358 Summary Accession No.: ML091240377 Meeting Notice Accession No.: ML091030221 Licensee's Handout Accession No ... ML091160002 NRC-001 OFFICE LPL2-2/PM LPL2-2/PM LPL2-2/LA AADB/BC LPL2-2/BC NAME JPaige BMozafari BClayton RTaylor TBoyce DATE OS/27/09 OS/20/09 05/14/09 OS/20/09 OS/27/09 OFFICIAL RECORD COpy