L-2012-318, Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate Amendment 245 and License Condition 3.K.1 on Spent Fuel Pool Cooling System Supplemental Heat Exchanger Structural Design

Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate Amendment 245 and License Condition 3.K.1 on Spent Fuel Pool Cooling System Supplemental Heat Exchanger Structural Design

ML12227A684
Person / Time
Site:	Turkey Point
Issue date:	08/10/2012
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2012-318, TAC ME4907, TAC ME4908
Download: ML12227A684 (16)

Text

L-2012-318 10 CFR 50.90 FPL. AUG 1 0 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Unit 4 Docket No. 50-251 Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate Amendment 245 and License Condition 3.K. 1 on Spent Fuel Pool Cooling System Supplemental Heat Exchanger Structural Design

References:

(1) J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - "Issuance of Amendments Regarding Extended Power Uprate (TAC Nos. ME4907 and ME4908)," Accession No. ML11293A365, June 15, 2012.

(2) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-143), "Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Spent Fuel Pool Cooling System Structural Design (Unit 3)," June 19, 2012.

(3) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-179), "Response to NRC Request for Additional Information Regarding Extended Power Uprate and Unit 3 License Condition 3.J. 1 on Spent Fuel Pool Cooling System Heat Exchanger Design," Accession No. ML12199A010, July 13, 2012.

License conditions 3.J. 1 for Unit 3 and 3.K. 1 for Unit 4 for Renewed Facility Operating Licenses DPR-31 and DPR-4 1, respectively, were issued as part of EPU Amendment Nos. 249 and 245 on June 15, 2012 [Reference 1] and state:

"Prior to completion of the Cycle 26 [27] refueling outage for Unit 3 [4], the licensee shall provide confirmation to the NRC staff that the design and structural integrity evaluations associated with the modifications related to the spent fuel pool supplemental heat exchangers are complete, and that the results demonstrate compliance with appropriate UFSAR and code requirements. As part of the confirmation, the licensee shall provide a summary of the structural qualification results of the piping, pipe supports, supplemental heat exchanger supports, and the inter-tie connection with the existing heat exchanger for the appropriate load combinations along with the margins."

The structural design information required to satisfy license condition 3.J. 1 for Unit 3 was submitted to the NRC via letters L-2012-143 and L-2012-179 on June 19 and July 13, 2012 [Reference 2 and 3].

For Unit 4, the design and structural integrity evaluations associated with the modifications related to the spent fuel pool supplemental heat exchanger have been completed, and the results demonstrate compliance with appropriate UFSAR and code requirements. In accordance with license condition 3.K. 1 of DPR-4 1, a summary of the structural qualification results of the piping, the pipe supports, major valves, supplemental heat exchanger nozzles and supports, and the inter-tie connection with the existing spent fuel pool cooling heat exchanger for the appropriate load combinations along with the design margins is provided in the Attachment to this letter.

Florida Power & Light Company 9760 SW 344 St., Florida City, FL 33035

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Page 2 of 2 In accordance with 10 CFR 50.91 (b)(1), a copy of this letter is being forwarded to the State Designee of Florida.

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 August /e, 2012.

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 Ms. Cindy Becker, Florida Department of Health

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 1 of 14 ATTACHMENT Turkey Point Unit 4 SUPPLEMENTAL RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING EXTENDED POWER UPRATE AMENDMENT 245 AND LICENSE CONDITION 3.K. 1 ON SPENT FUEL POOL COOLING SYSTEM SUPPLEMENTAL HEAT EXCHANGER STRUCTURAL DESIGN

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 2 of 14 Response to Request for Additional Information The following information is provided by Florida Power & Light Company (FPL) to satisfy Unit 4 license condition 3.K.1 that was made in response to a U.S. Nuclear Regulatory Commission (NRC)

Request for Additional Information (RAI). This information is required for the implementation of Extended Power Uprate (EPU) Amendment 245 for Turkey Point Nuclear Plant (PTN) Unit 4 that was issued on June 15, 2012 [Reference 1].

License conditions 3.J, 1 for Unit 3 and 3.K. 1 for Unit 4 for Renewed Facility Operating Licenses DPR-31 and DPR-41, respectively, are part of EPU Amendments 249 and 245 that were issued on June 15, 2012 [Reference 1] and state:

"Prior to completion of the Cycle 26 [27] refueling outage for Unit 3 [41, the licensee shall provide confirmation to the NRC staff that the design and structural integrity evaluations associated with the modifications related to the spent fuel pool supplemental heat exchangers are complete, and that the results demonstrate compliance with appropriate UFSAR and code requirements. As part of the confirmation, the licensee shall provide a summary of the structural qualification results of the piping, pipe supports, supplemental heat exchanger supports, and the inter-tie connection with the existing heat exchanger for the appropriate load combinations along with the margins."

The structural design information required to satisfy license condition 3.J. 1 for Unit 3 was submitted to the NRC via letters L-2012-143 and L-2012-179 on June 19 and July 13, 2012 [Reference 2 and 3].

The tables presented on the following pages provide the confirmation required above and summarize the structural qualification results of the piping, the pipe supports, major valves, supplemental heat exchanger nozzles and supports, and the inter-tie connection with the existing spent fuel pool cooling heat exchanger for the appropriate load combinations along with the design margins.

License Condition 3.K.1 Resolution:

Design analyses are complete for Unit 4 and all items comply with applicable UFSAR and code requirements. As part of the analytical efforts for Unit 4, a comprehensive reanalysis, of the applicable portions of the SFP and CCW systems, has been performed. Due to the extent of the piping that is being added, or modified, as a result of the addition (inter-tie) of the supplemental heat exchanger, the entirety of the main process piping, as well as the associated supports, have been fully re-analyzed to verify compliance with appropriate UFSAR and code requirements.

In a number of locations the pipe lines pass through various building walls from areas such as the Spent Fuel Pool to other areas such as the room containing both the existing, and the new supplemental Spent Fuel Pool Cooling Heat exchangers and to locations associated with the connections to the CCW Supply and Return headers. In essentially all situations the wall penetrations containing the subject piping are being grouted. As such, grouted wall penetrations provide certain support, or restraint, of the pipe; and the appropriate effects have been included in the modeling for pipe stress considerations.

The grouted penetrations are considered a structural feature, rather than a support; and no hanger drawing is generated for the penetration. In all cases, the appropriate loading from the piping (at the penetration) has been considered in structural evaluations of the applicable walls to verify that the applicable walls remain in compliance with appropriate UFSAR and code requirements.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 3 of 14 Piping~

The design analysis qualification evaluations of the piping, applicable to the spent fuel pool supplemental heat exchangers, are complete for PTN Unit 4. These analyses demonstrate that the piping as modified, and reconfigured, to add the new spent fuel pool supplemental heat exchanger, are in compliance with the appropriate UFSAR and code requirements.

With respect to piping codes, the construction code for piping at PTN was ASA B31.1-1955 edition as modified by the UFSAR. The UFSAR addresses load combinations and allowable stresses associated with low probability events not explicitly covered by ASA B31.1-1955 edition.

In practice, the 1973 edition of B3 1.1 has been used for piping analysis because that edition prescribes, in equation form, the calculation of stresses resulting from occasional loads, such as seismic events or water/steam hammer loading. PTN Design Standards acknowledge that ASA B31.1-1955 edition was the construction code of record for piping, and also provide the basis for using the methodology of B31.1-1973 edition, through Winter 1976 Addenda Code, for piping qualification at PTN. As such, the PTN Design Standards provide the justification/reconciliation for use of the later B31.1-1973 edition through Winter 1976 Addenda.

Note 1: Stress combinations are based on PTN piping requirements. The individual loadings for these stress loading combinations are as follows:

E = Thermal expansion including anchor displacement effects P = Pressure G= Gravity OBE = Operational Basis Earthquake SSE = Safe Shutdown Earthquake Note 2: Design margin is defined as the ratio of EPU calculated stress divided by the allowable stress. It should be noted that stress levels resulting in design margins less than or equal to 1.0 are acceptable in accordance with B3 1.1 piping codes as modified by the UFSAR for low probability events. The allowable stress levels are well within ultimate stress limits.

Note 3: The allowable stress values for the various "stress combination" equations shown are as follows:

Upset: P + G + OBE < 1.2 Sh, where Sh is the basic material allowable stress Faulted: P + G + SSE < 1.0 Sy, where Sy is the yield stress E < Sa, where Sa is the nominal allowable thermal range stress In some cases, as provided for in, and permitted by, the piping code, {e.g., Section 102.3.2, D of B31.1 - 1973 edition through Winter 1976 Addenda}, an alternative load combination can be used for evaluation when there is an exceedance of Sa using the above equation. The code requires that sustained stresses (P + G) < Sh and allows comparison of these stresses combined with thermal range stresses to their combined allowables, i.e., (P + G + E) < Sh + Sa.

The following table (Table 1) provides a summary of the governing stress results from the pipe stress analyses for the main process piping of both the Component Cooling Water (CCW) and Spent Fuel Pool Cooling (SFP) lines.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 4 of 14 Table 1 Turkey Point Unit 4 Spent Fuel Pool Cooling Pipe Stress Summary Piping Analysis Description Stress EPU Stress (psi) Allowable Stress (psi) Design Margin Combination (Note 1)

CCW Piping From Supply Header to Supplemental P+G+OBE 4,135 14,400 0.29 HX 4E208B (also to 4E208A), P+G+SSE 10,189 28,560 0.36 (CCW-11) E 6,383 18,000 0.36 P+G+E 7,564 30,000 0.25 CCW Piping Return Header From Supplemental HX P+G+OBE 10,426 14,400 0.72 4E208B (also from 4E208A), P+G+SSE 18,214 28,440 0.64 (CCW-12) E 21,231 18,000 1.18*

P+G+E 22,150 30,000 0.74 SFP Cooling System Discharge Piping from SFP P+G+OBE 6,752 18,490 0.37 Pump 4P212A, 4P212B, and Emergency SFP Pump P+G+SSE 14,318 24,653 0.58 Discharge to SFP HX 4E208A and 4E208B (SFP-11) E 31,385 27,227 1.15*

P+G+E 34,341 42,635 0.81 SFP Cooling System Piping from SFP HX 4E208A P+G+OBE 11,062 18,490 0.60 and 4E208B Outlet Nozzles to Spent Fuel Pool P+G+SSE 20,975 24,653 0.85 (SFP-12) E 26,608 27,227 0.98 P+G+E 28,150 42,635 0.66 SFP Cooling System Suction Piping from Spent Fuel P+G+OBE 4,874 18,490 0.26 Pool to SFP Pump 4P212A, 4P212B, and Emergency P+G+SSE 7,714 24,653 0.31 SFP Cooling Pump (SFP-13) E 33,301 27,227 1.22*

P+G+E 34,712 42,635 0.81 Note 1: Design margin is defined as the ratio of EPU stress divided by the allowable stress.

• As permitted by ASME Code, exceedance of thermal expansion range allowable stress is evaluated by a comparison to an allowable limit for sustained stresses (P+G) combined with thermal range stresses.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 5 of 14 Pipinig Supports The pipe supports for Unit 4 have been designed per AISC rules as modified by the UFSAR for allowable stresses associated with low probability events. The following methodologies were applied to the ensuing analyses:

1. The applicable elastic stress equations and allowable stress limits of AISC Eighth Edition are utilized.

2. The supports are considered subjected to normal, upset and faulted loads.

3. The primary support loads consider deadweight, thermal, and seismic loads and are derived from the applicable pipe stress evaluations for CCW and SFP piping. The support load combinations address the following combinations:

a. Normal: E+D

b. Upset: E + D + OBE

c. Faulted: E+D+SSE where:

E = Thermal D = Deadweight OBE = Design Earthquake (Operating Basis Earthquake)

SSE = Maximum Potential Earthquake (Safe Shutdown Earthquake)

4. Supports are compared to corresponding stress limits of AISC, as described below:

a. Normal: Sa = 1.0

• S, where S = allowable stress from AISC

b. Upset: Sa = 1.33

• S

c. Faulted: Sa = Y, where Y = allowable Yield Stress per PTN UFSAR Typically, initial qualification efforts consisted of comparing Faulted loadings to Normal allowables without consideration of permissible increases in allowables as indicated above.

By meeting the Normal allowables, with Faulted loadings, the underlying evaluations are implicitly addressed and acceptable. Also, the general practice for designing new supports, by FPL standards, is to design the support for a Normal load increased by 25% above the calculated load, or the Upset or the Faulted load increased by 10% above the calculated load. This practice was also often utilized in evaluation of existing supports providing additional conservatism.

The following table (Table 2) provides a summary of results from the applicable pipe support analyses for the main process piping of both the Component Cooling Water (CCW) and Spent Fuel Pool Cooling (SFP) lines.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 6 of 14 Table 2 Turkey Point Unit 4 SFP Cooling Piping Supports Piping Stress Pipe Support Support Governing Margin Design System Problem No. Calc No. Loading Factor Margin No. Condition (Note 1) (Note 2)

Component Cooling Water CCW-0001 I SR-702 CCW-00107 Faulted 1.12 0.89 4-ACH-202 CCW-00105 Faulted 1.79 0.56 4-ACH-203 CCW-00106 Faulted 1.22 0.82 4-ACH-225 CCW-00100 Faulted 4.73 0.21 4-ACH-257 CCW-00101 Normal 1.32 0.76 4-ACH-258 CCW-00102 Faulted 1.17 0.85 4-ACH-259 CCW-00103 Normal 3.2 0.31 4-ACH-260 CCW-00104 Faulted 1.2 0.83 CCW-00012 4-ACH-198 CCW-00110 Faulted 1.25 0.80 4-ACH-199 CCW-001 11 Faulted 1.40 0.71 4-ACH-200 CCW-001 12 Faulted 2.82 0.35 4-ACH-216 CCW-00 117 Faulted 1.07 0.93 4-ACH-217 CCW-00118 Faulted 1.88 0.53 4-ACH-218 CCW-00119 Faulted 1.19 0.84 4-ACH-261 CCW-001 14 Faulted 1.22 0.82 4-ACH-263 CCW-00115 Faulted 1.12 0.89 SR-687 CCW-00121 Faulted 1.16 0.86

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 7 of 14 Table 2 (continued)

Turkey Point Unit 4 SFP Cooling Piping Supports Piping Stress Pipe Support Support Governing Margin Design System Problem No. No. Calc No. Loading Factor Margin Condition (Note 1) (Note 2)

Spent Fuel Pool Cooling SFP-0001 I H-695-01 SFP-00121 Faulted 1.05 0.95 H-695-02 SFP-00122 Normal 1.18 0.85 H-695-04 SFP-00124 Faulted 1.66 0.60 H-695-07 SFP-00127 Faulted 1.13 0.89 H-695-08 SFP-00151 Normal 1.92 0.52 H-695-09 SFP-00152 Normal 5.88 0.17 SFP-00012 H-117-01 SFP-00143 Normal 1.15 0.87 H-117-02 SFP-00144 Faulted 1.90 0.53 H-I 17-03 SFP-00145 Faulted 1.27 0.79 H-I 17-04 SFP-00146 Faulted 2.09 0.48 H-1 17-05 SFP-00147 Normal 2.00 0.50 H-696-01 SFP-00128 Faulted 1.60 0.63 H-696-02 SFP-00129 Normal 1.04 0.96 H-696-03 SFP-00130 Normal 1.77 0.56 H-696-04 SFP-00131 Normal 2.20 0.45 H-696-05 SFP-00132 Faulted 1.05 0.95 H-696-08 SFP-00134 Normal 4.39 0.23 H-696-09 SFP-00135 Faulted 1.13 0.88 H-696-10 SFP-00135 Faulted 1.13 0.88 H-696-11 SFP-00135 Faulted 1.13 0.88 H-696-12 SFP-00135 Faulted 1.13 0.88 H-696-13 SFP-00135 Faulted 1.13 0.88 H-696-14 SFP-00142 Normal 1.59 0.63 H-696-15 SFP-00135 Faulted 1.13 0.88 SFP-00013 H- 119-01 SFP-00120 Faulted 2.03 0.49 H-I 19-02 SFP-00 119 Faulted 1.03 0.97 H-694-03 SFP-00112 Normal 1.84 0.54 H-694-09 SFP-001 16 Faulted 1.15 0.87 H-694-10 SFP-00 117 Faulted 1.08 0.93 H-694-11 SFP-001 18 Normal 23.1 0.04

_____ I_____ 1

_______ .1

_____ t ____ I____ I_____

Note 1: Margin factor is defined as the ratio of the Code allowable stress, or allowable load, divided by the EPU calculated stress, or load as applicable.

Note 2: Design margin is defined as the ratio of EPU calculated stress, or load, divided by the allowable stress, or load.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 8 of 14 Supplemental SFP Heat Exchanger Support Platform The Unit 4 supplemental SFP Heat Exchanger is supported by a new steel platform that is being installed inside the existing SFP Heat Exchanger Room. The platform is designed as a Class I structure. The platform will be attached to the existing concrete walls and floor slab of the room using post-installed expansion anchors. As this is a new structure, it is being designed with a later Edition of the AISC and ACI codes. The steel members of the platform have been designed in accordance with the AISC Ninth Edition, Allowable Stress Design (ASD) rules. The applicable concrete items such as walls and the floor slab have been designed and evaluated in accordance with applicable ACI 318-05 rules. Expansion anchors have been designed utilizing the standard methodology and criteria developed and used for Turkey Point.

The following methodologies were applied to the ensuing analyses:

.1. The applicable elastic stress equations and allowable stress limits of AISC Ninth Edition utilizing ASD rules are utilized.

2. The Heat Exchanger platform (support structure) is considered subjected to normal and seismic loads.

3. The loading considered deadweight, thermal, applicable support loads, heat exchanger nozzle loads, and seismic loads.

In accordance with the UFSAR, this Class I structure is designed to satisfy the applicable load cases as follows:

DY=1.25D + 1.25E (for OBE)

(DY=I.0D + L.OE' (for SSE) where:

Y = required yield strength of the material.

D = dead load of structure and equipment plus any other permanent loads contributing stress, such as soil or hydrostatic loads. In addition, a portion of "live load" is added when such load is expected to be present when the unit is operating. An allowance is also made for future permanent loads.

E = design earthquake load.

F= maximum earthquake load.

(D= 0.90 for fabricated structural steel.

(D= 0.90 for reinforced concrete in flexure.

(D= 0.85 for tension, shear, bond, and anchorage in reinforced concrete.

The following table (Table 3) provides a summary of results from the platform analyses:

Table 3 Turkey Point Unit 4 Supplemental SFP Heat Exchanger Supports Maximum member interaction = 0.70 (Enveloped OBE & SSE loads)

Maximum connection interaction = 0.86 (Enveloped OBE & SSE loads)

Maximum anchor bolt interaction = 0.91 (Enveloped OBE & SSE loads)

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 9 of 14 Supplemental SFP HX Nozzles and Valves The main process lines servicing the new supplemental spent fuel pit heat exchanger (4E208B) for Turkey Point Unit 4 consist of the Spent Fuel Pool (SFP) Cooling System and the Component Cooling Water (CCW) System. Each system has a single inlet and a single outlet connection to the supplemental heat exchanger; therefore a total of four main process connections.

The SFP Cooling System removes the decay heat generated by the radioactive spent nuclear fuel assemblies that are stored in the SFP during normal plant operations and refueling operations. SFP cooling pumps take suction from the SFP, circulate the water through the tube side of the SFP heat exchanger and return the water back to the SFP. The shell side of the heat exchanger is cooled by the CCW System. The CCW System is a closed loop with fluid being continuously circulated through the system by the CCW pumps. The CCW System is the heat sink for safety-related components and for non-safety-related components that are in potentially radioactive systems.

For the SFP inlet line to the new heat exchanger, an isolation valve is being provided in proximity to the heat exchanger, and an isolation valve is being added on the discharge line from pump 4P212A. For the SFP outlet line, only a flow adjustment valve is being provided on the return line to the SFP. For the CCW inlet line, a single isolation valve is being added. For the CCW outlet line, both an isolation valve and a flow adjustment valve are being added.

The attached Tables 4-7 provide the stress results for the heat exchanger nozzle loads and valve accelerations. The results are provided for each applicable piping stress analysis calculation, as each calculation contains both nozzle load tabulations and valve acceleration tabulations.

The nozzle load tabulations are enveloped loads considering combinations of load cases to conservatively bound nozzle loading conditions. As such, the nozzle loads contained within the attached tables are beyond the calculated loadings that would occur under any postulated scenario of simultaneous loading conditions. The loadings presented in the attached tables do include the loadings from the Maximum Hypothetical Earthquake (i.e., SSE equivalent loading). In all cases the calculated nozzle loads are low compared to the allowable nozzle loading derived from the Engineering Specification used for procurement of the supplemental spent fuel pit heat exchanger.

The valve acceleration tabulations are also enveloped loads considering combinations of load cases to conservatively bound nozzle loading conditions. As such, the valve accelerations contained within the attached tables are beyond the calculated loadings that would occur under any postulated loading condition. The loadings presented in the attached tables do include consideration of the effects from the Maximum Hypothetical Earthquake (i.e., SSE equivalent loading). In all cases the calculated valve accelerations are low compared to the allowable valve accelerations (derived as the acceleration levels utilized in the seismic qualification evaluations of the valves). The valve accelerations utilized for the valve evaluations were generally at least 3g's in each horizontal direction and 2 g's in the vertical direction.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 10 of 14 Table 4 Piping Analysis: SFP-11

Description:

Discharge Piping from SFP Pump 4P212A, 4P212B, & Emergency SFP Pump Discharge to SFP Heat Exchangers 4E208A & 4E208B NOZZLE LOAD TABULATION - SUPPLEMENTAL SPENT FUEL PIT HEAT EXCHANGER Mx (ft-lb) Mz (ft-lb)

Equipment Nozzle Fy (1b) (Circumferential (Longitudinal (Axial) Moment) Moment)

HEAT EXCHANGER 4E208B 874 3157 1903 SFP INLET NOZZLE Allowable Loads 5395 8850 11506 for 10" Nozzle Y = parallel to Heat Exchanger Nozzle and vertical; X = parallel to Heat Exchanger centerline (in plant East-West direction) and the other axis (Z) by right hand rule.

Valve Acceleration Tabulation Valve Valve Acceleration (g) Allowable Valve Acceleration (g) Design Margin Valve Description Tag No.

X Y Z X Y Z X Y Z SFPPump4P212B 4-908E 0.232 0.387 0.537 3 2 3 0.08 0.19 0.18 Discharge Isolation Valve SFPHX4E2O8ASFP 4-826 0.176 0.176 0.111 3 2 3 0.06 0.09 0.04 Inlet Isolation Valve SFP HX 4E208B SFP 4-919 0.642 0.122 0.214 3 2 3 0.21 0.06 0.07 Inlet Isolation Valve X = plant East-West direction; Y = Vertical; Z = plant North-South direction Design margin is defined as the ratio of calculated valve acceleration divided by the allowable valve acceleration.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 11 of 14 Table 5 Piping Analysis: SFP-12

Description:

Piping from SFP Heat Exchanger 4E208A and 4E208B Outlet Nozzles to Spent Fuel Pool NOZZLE LOAD TABULATION - SUPPLEMENTAL SPENT FUEL PIT HEAT EXCHANGER Fy (lb) Mx (ft-lb) Mz (ft-Ib)

Equipment Nozzle (Axial) (Circumferential (Longitudinal Moment) Moment)

HEAT EXCHANGER 4E208B 1372 2227 8381 SFP OUTLET NOZZLE Allowable Loads 5395 8850 11506 for 10" Nozzle Y = parallel to Heat Exchanger Nozzle and vertical; X = parallel to Heat Exchanger centerline (in plant east-west direction) and the other axis (Z) by right hand rule.

Valve Acceleration Tabulation X = plant East-West direction; Y = Vertical; Z = plant North-South direction Design margin is defined as the ratio of calculated valve acceleration divided by the allowable valve acceleration.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 12 of 14 Table 6 Piping Analysis: CCW-11

Description:

CCW Piping from Supply Header to Supplemental Heat Exchanger 4E208B (also to 4E208A)

NOZZLE LOAD TABULATION - SUPPLEMENTAL SPENT FUEL PIT HEAT EXCHANGER Mx (ft-lb) Mz (ft-lb)

Equipment Nozzle Fy (ib) (Circumferential (Longitudinal (Axial) Moment) Moment)

HEAT EXCHANGER 4E208B 2353 866 CCW INLET NOZZLE AllowableLoads 5395 8850 11506 for 10" Nozzle Y = parallel to Heat Exchanger Nozzle and vertical; X = parallel to Heat Exchanger centerline (in plant East-West direction) and the other axis (Z) by right hand rule.

Valve Acceleration Tabulation Description Valve Valve Acceleration (g) Allowable Valve Acceleration (g) Design Margin Valve Description Tag No.

X Y Z X Y Z X Y Z SFP HX 4E208B CCW Inlet 4-779 0.148 0.104 0.615 3 2 3 0.05 0.05 0.21 Isolation Valve X = plant East-West direction; Y = Vertical; Z = plant North-South direction Design margin is defined as the ratio of calculated valve acceleration divided by the allowable valve acceleration.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 13 of 14 Table 7 Piping Analysis: CCW-12

Description:

CCW Piping Return Header from Supplemental Heat Exchanger 4E208B (also from 4E208A)

NOZZLE LOAD TABULATION - SUPPLEMENTAL SPENT FUEL PIT HEAT EXCHANGER Fy (Ib) Mx (ft-lb) Mz (ft-lb)

Equipment Nozzle (Circumferential (Longitudinal (Axial) Moment) Moment)

HEAT EXCHANGER 4E208B 964 1966 2257 CCW OUTLET NOZZLE AllowableLoads 5395 8850 11506 for 10" Nozzle Y = parallel to Heat Exchanger Nozzle and vertical; X = parallel to Heat Exchanger centerline (in plant East-West direction) and the other axis (Z) by right hand rule.

Valve Acceleration Tabulation Valve Valve Acceleration (g) Allowable Valve Acceleration (g) Design Margin Valve Description Tag No.

X Y Z X Y Z X Y Z SFP HX 4E208B CCW Outlet 4-775B 0.186 0.098 0.354 3 3 3 0.06 0.03 0.12 Throttle Valve SFP HX 4E208B CCW Outlet 4-776B 0.145 0.102 0.347 3 2 3 0.05 0.05 0.12 Isolation Valve X = plant East-West direction; Y = Vertical; Z = plant North-South direction Design margin is defined as the ratio of calculated valve acceleration divided by the allowable valve acceleration.

Turkey Point Unit 4 L-2012-318 Docket No. 50-251 Attachment Page 14 of 14 Conclusion In accordance with the requirements of license condition 3.K. 1 for Unit 4, FPL has provided assurance that the design and structural integrity evaluations associated with the modifications related to the spent fuel pool supplemental heat exchangers are complete and that the results demonstrate compliance with the appropriate UFSAR and code requirements. A summary of the structural qualification results of the piping, the pipe supports, major valves, and supplemental heat exchanger nozzles and supports for appropriate load combinations along with the associated design margins has also been provided. Due to the extent of the piping that is being added or modified as a result of the addition (inter-tie) of the supplemental heat exchanger, the entire main process piping and associated supports has been re-analyzed to assure compliance with the appropriate UFSAR and code requirements.

References

1. J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - "Issuance of Amendments Regarding Extended Power Uprate (TAC Nos. ME4907 and ME4908)," Accession No. ML11293A365, June 15, 2012.

2. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-143), "Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Spent Fuel Pool Cooling System Structural Design (Unit 3),"

June 19, 2012.

3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-179), "Response to NRC Request for Additional Information Regarding Extended Power Uprate and Unit 3 License Condition 3.J. 1 on Spent Fuel Pool Cooling System Heat Exchanger Design," Accession No. ML12199A010, July 13, 2012.