ML18136A724
| ML18136A724 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/16/2018 |
| From: | Michael Wentzel Plant Licensing Branch II |
| To: | Hess R Florida Power & Light Co |
| References | |
| L-2017-LLA-0425 | |
| Download: ML18136A724 (4) | |
Text
1 NRR-DMPSPEm Resource From:
Wentzel, Michael Sent:
Wednesday, May 16, 2018 9:48 AM To:
Hess, Robert Cc:
Mack, Jarrett; Hanek, Olga; Czaya, Paul
Subject:
Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 235 (EPID L-2017-LLA-0425)
Dear Mr. Hess:
By application dated December 21, 2017 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML17355A184), Florida Power & Light Company (FPL, the licensee) submitted License Amendment Request No. 235 for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). The proposed amendments would revise the Technical Specifications (TS) pertaining to the Engineered Safety Features Actuation System (ESFAS) instrumentation to resolve non-conservative actions associated with the Containment ventilation isolation and the Control Room ventilation isolation functions. In addition, the amendments would revise the Control Room ventilation isolation function to no longer credit Containment radiation monitoring instrumentation, eliminate redundant radiation monitoring instrumentation requirements, eliminate select core alterations applicability requirements, relocate radiation monitoring and Reactor Coolant System leakage detection requirements within the TS to align with their respective functions, and relocate the Spent Fuel Pool area monitoring requirements to licensee-controlled documents.
The U.S. Nuclear Regulatory Commissions (NRCs) Radiation Protection and Consequences Branch (ARCB) staff is reviewing the application and identified areas where it needs additional information to support its review. The NRC staffs request for additional information (RAI) is provided below. A draft copy of the RAI was provided to your staff on May 4, 2017 (ADAMS Accession No. ML18135A383). Based on a clarification call with you and your staff on May 15, 2018, the NRC staff is withholding issuance of draft ARCB-RAI-3, pending an audit of information available to support this license amendment request. The NRC staff will provide its plan for the audit in the near future. As discussed on the clarification call, the NRC staff requests your response to the RAI within 30 days of the date of this email.
If you have any questions, please contact me at (301) 415-6459 or michael.wentzel@nrc.gov.
Sincerely, Michael Wentzel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 235 FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
2 Regulatory Analysis Basis
- 1.
Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Section 50.67, Accident Source Term, allows licensees seeking to revise their current accident source term in design basis radiological consequence analyses to apply for a license amendment under § 50.90. The application shall contain an evaluation of the consequences of applicable design basis accidents previously analyzed in the safety analysis report. Section 50.67(b)(2) requires that the licensee's analysis demonstrates with reasonable assurance that:
(i)
An individual located at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release, would not receive a radiation dose in excess of 0.25 Sv (25 rem) total effective dose equivalent (TEDE).
(ii)
An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage), would not receive a radiation dose in excess of 0.25 Sv (25 rem) TEDE.
(iii)
Adequate radiation protection is provided to permit access to and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) TEDE for the duration of the accident.
- 2.
NUREG-0800, Standard Review Plan (SRP) Section 15.0.1, "Radiological Consequences Analyses Using Alternative Source Terms," Revision 0, July 2000 (ADAMS Accession No. ML003734190).
- 3.
NRC Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 (ADAMS Accession No. ML003716792).
ARCB-RAI-1 (LOCA)
The proposed change deletes functional unit 9.c, Containment Radioactivity - High, from TS Tables 3.3-2, 3.3-3 and 4.3-2. The NRC staffs review of radiological consequences for the design basis accidents in the Updated Final Safety Analysis Report (UFSAR) determined the loss of coolant accident (LOCA), fuel handling accident (FHA) and rod cluster control assembly (RCCA) ejection accident credit functional unit 9.c to isolate the normal mode of control room emergency ventilation system (CREVS) and establish the recirculation mode.
In regards to the LOCA analysis, the licensee determined that the radiological consequence analysis did not need to be reanalyzed because the safety injection signal will provide a containment ventilation and control room isolation signal within the same time as that assumed in the current analysis of record as reflected in Turkey Points UFSAR; therefore, there is no impact on the LOCA radiological consequences. However, it is not clear to the NRC staff why the timing is the same given the instrumentation differences. Therefore, explain why the timing for the control room isolation signal remains 30 seconds which accounts for the time to reach the signal, the diesel generator start time, load sequencing and damper actuation and positioning time, given the differences between the safety injection instrumentation and the containment radioactivity instrumentation.
ARCB-RAI-2 (RCCA ejection)
The proposed change deletes functional unit 9.c from TS Tables 3.3-2, 3.3-3 and 4.3-2. The NRC staffs review of radiological consequences for the design basis accidents determined the LOCA, FHA and RCCA ejection accident credit functional unit 9.c to isolate the normal mode of CREVS and establish the recirculation mode. In regards to the RCCA ejection accident analysis, Attachment 3, Section 2.1.2, RCCA Ejection - Containment Release Event Analysis, states:
For the new Containment Release cases, the Control Room is isolated on a high radiation reading at the CR [control room] normal intake monitors. A 60 second delay is applied to account for the time to reach the setpoint (30 seconds), signal processing, and damper closure
3 time for the automatic CR isolation case. Previously the isolation conservatively assumed 60 seconds.
In addition, UFSAR Section 14.2.6.4, Dose Evaluation, states that for the containment release, the control room isolation occurs on high radiation on the containment radiation monitors and a 60 second delay time is conservatively applied to this release model. However, UFSAR Table 14.2.6-3, Assumptions used for Rod Ejection Accident dose analysis, states that the time of the control room isolation for the containment release is 30 seconds on a high containment radiation signal.
It is not clear to the NRC staff which time is correct and why the timing is the same given the instrumentation differences. Therefore, explain which delay time is correct and then explain why the timing for the control room isolation signal remains 60 seconds which accounts for the time to reach the setpoint (30 seconds), signal processing, and damper closure time, given the differences between the control room normal intake instrumentation and the containment radioactivity instrumentation.
Hearing Identifier:
NRR_DMPS Email Number:
377 Mail Envelope Properties (CY1PR09MB02518AF91DFA2EBFA0ED78F0E7920)
Subject:
Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 235 (EPID L-2017-LLA-0425)
Sent Date:
5/16/2018 9:47:37 AM Received Date:
5/16/2018 9:47:00 AM From:
Wentzel, Michael Created By:
Michael.Wentzel@nrc.gov Recipients:
"Mack, Jarrett" <Jarrett.Mack@fpl.com>
Tracking Status: None "Hanek, Olga" <Olga.Hanek@fpl.com>
Tracking Status: None "Czaya, Paul" <Paul.Czaya@fpl.com>
Tracking Status: None "Hess, Robert" <Robert.Hess@fpl.com>
Tracking Status: None Post Office:
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