L-2023-110, 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
| ML23240A153 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/25/2023 |
| From: | Strand D Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23240A152 | List: |
| References | |
| L-2023-110 | |
| Download: ML23240A153 (1) | |
Text
FPL.
August25,2023 L-2023-110 10 CFR 50.90 Framatome Inc. Proprietary (Not proprietary when separated from Enclosure 1)
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 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, dated August 26, 2022 (ADAMS Accession No. ML22243A161)
- 2. NRC electronic memorandum dated August 14, 2023, Request for Additional Information - Turkey Point RCP Seal LAR (ADAMS Accession No. ML23226A075)
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. and Attachment 1 provide FPL's response to the request for additional information (RAJ). provides a redacted version of Enclosure 1. Attachment 1 contains extensive proprietary information to an extent that a redacted version would be of no value to the public and therefore, a redacted version of Attachment 1 is not provided. and Attachment 1 contain information that is proprietary to Framatome, Incorporated and an affidavit was prepared for each document. Pursuant to 10 CFR 2.390(a)(4), FPL requests that the proprietary information be withheld from public disclosure. The request is supported by two affidavits signed by Framatome, Incorporated, the owner of the information. The affidavits, provided in Attachments 2 and 3, set 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
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2023-110 Page 2 of 2 2 provides the non-proprietary version of the information. There is no non-proprietary version of Attachment 1 as noted above.
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.
In Reference 1, FPL stated that the RCP seal replacement was scheduled to occur during the Unit 4 2023 Fall refueling outage, scheduled for September 2023. The installation of the RCP replacement seals is now scheduled to occur beginning with the Unit 4 2025 Spring refueling outage, scheduled for March 2025.
Therefore, approval of this LAR is requested within one year of LAR acceptance for review by the NRC.
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 25th day of August 2023.
Sincerely, Dianne Strand General Manager, Regulatory Affairs Florida Power & Light Company Enclosures (2)
Attachments (3) cc:
USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Generating Station USNRC Senior Resident Inspector, Turkey Point Nuclear Generating Station Mr. Clark Eldredge, Florida Department of Health (Enclosure 2 and Attachments 2 and 3 only)
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2023-110 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 ATTACHMENT 2 FRAMATOME AFFIDAVIT For Enclosure 1 to FPL Letter L-2023-110 (2 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 FPL letter L-2023-110, "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", Enclosure 1, hereafter referred to as "This Document."
Information contained in This Document 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 request that the information contained in This Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 1 O 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 August 24, 2023.
Philip A Opsal Manager, Product Licensing Framatome Inc.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2023-110 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 ATTACHMENT 3 FRAMA TOME AFFIDAVIT For the Framatome Qualification Report Document 38-9351062-001 to FPL Letter L-2023-110 (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 Framatome Qualification Report Document 38-9351062-001, hereafter referred to as "This Document."
Information contained in This Document 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 request that 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(c), 6(d), and 6(e) above. This document contains extensive proprietary information to an extent that a redacted version would be on no value to the public. Therefore, a non-proprietary version is not required to be submitted to the NRC per UC 204, Revision 4, "Handling Requests to Withhold Proprietary Information from Public Disclosure", Section 4.2.
- 7.
In accordance with Framatome's policies governing the protection and control of information, proprietary information contained in This Documents 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 August 15, 2023.
Philip A. Opsal Manager, Product Licensing Framatome Inc.
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-2023-110 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project ENCLOSURE 2 (6 pages follow)
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-2023-110 Page 1 of 6 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project NRC Staff Requests for Additional Information (RAls)
- 11.
The LAR submittal dated August 26, 2022, in Attachment 1, provides proprietary information regarding the replacement RCP seals at Turkey Point. Please describe the RCP seal design changes and their improvement over the current Turkey Point RCP seals.
Additionally, the LAR 276 attachment does not provide a discussion of the seal actuation time. Seal action time is affected by the PSDS actuation temperature, initial seal leakoff flow rate, operator actions to cool and depressurize the plant, and other factors. Please discuss in detail how the seal actuation time was determined. Also, make the following information available for staff audit:
FPL Response - RAI 11 The PSDS actuation time is primarily a function of the No. 1 seal leak rate.
The PSDS is actuated by temperature. At Turkey Point, when the temperature of the PSDS
[
] reaches [
], the PSDS will actuate. During normal plant operation, the temperature of the of the PSDS is approximately equal to the temperature of the RCP seal injection water (100°F - 130°F). If all seal cooling is lost (e.g., loss of both seal injection and loss of cooling water to the RCP thermal barrier), 547°F reactor coolant from the RCS cold leg (this temperature is also referred to as Tco1ct) will flow upward through the RCP, past the thermal barrier, into the free volume of the RCP main flange assembly and No. 1 seal cavity, and finally past the No. 1 seal and the PSDS. The time required for the 547°F reactor coolant from the RCS cold leg to reach the PSDS is the time required for the "cool" water originally in the No. 1 seal cavity to be purged past the No. 1 seal by the in-flowing reactor coolant. This purge time is directly proportional to the No. 1 seal leak rate.
11a.
Reactor Coolant System (RCS) temperature and pressure response for the loss of seal cooling event.
FPL Response - RAI 11 a At Turkey Point, a loss of seal cooling (LOSC) event is not considered alone as an initiating event because it would require that multiple system failures be postulated, i.e., the loss of seal injection from the chemical and volume control system (CVCS) and the loss of component cooling water (CCW) flow to the thermal barrier. Therefore, LOSC events are only postulated to occur during other events that deterministically lead to a LOSC. These events are a fire event, an extended loss of AC power (ELAP), and events where both a Phase A containment isolation (4 psig containment pressure) and a Phase B containment isolation (20 psig containment pressure) were to occur. Phase A initiates a safety injection which in turn trips the CVCS charging pumps that provide the flow for seal injection, and Phase B isolates CCW flow to the thermal barrier. The analyzed events that could result in both a Phase A and Phase B isolation are a loss of cooling accident (LOCA) and a main steam line break (MSLB) in containment.
For a fire event that results in an LOSC, plant operators would respond in accordance with operating procedures which required that both the reactor and RCPs be manually tripped. The plant cooldown that follows would also be performed in accordance with plant procedures which require that Tcold be stabilized at 547°F until plant cooldown is initiated (Tcold is the temperature
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-2023-110 Page 2 of 6 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project of the RCS cold leg, which is the source of hot reactor coolant flow to the RCP seals). During this time, the RCS pressure would remain below the setpoints of the pressurizer power operated relief valves and safety relief valves. Therefore, a fire event that results in a LOSC does not establish the limiting temperature and pressure conditions for the PSDS.
For the LOCA event, UFSAR Section 14.3 illustrates that the RCS rapidly depressurizes. Cooling to the RCP seals would be lost when the containment pressure reaches the Phase A and Phase B setpoints. However, RCP seal and PSDS performance during the LOCA is inconsequential based on the low RCS pressure and on the quantity of RCS inventory that is already being lost through the RCS break. Therefore, a LOCA event that results in a LOSC does not establish the limiting temperature and pressure conditions for the PSDS.
For the MSLB event, UFSAR Section 14.2.5 illustrates that both RCS pressure and temperature rapidly decrease from their respective normal values. As with the LOCA event, cooling to the RCP seals would be lost when the containment pressure reaches the Phase A and Phase B setpoints. However, since either offsite power or emergency power will be available, plant operators are assumed able to restore RCP seal cooling. Therefore, since RCP seal cooling can be restored during a MSLB event, a PSDS actuation is not credited and the event does not establish the limiting temperature and pressure conditions for the PSDS.
For an ELAP event, the reactor trip, RCP trip and LOSC all occur at the same time. The maximum RCS temperature and pressure that occur during the ELAP are 2400 psia and 561 °F, respectively.
These are the limiting temperature and pressure conditions for the PSDS at Turkey Point.
11 b.
The model of PSDS installed at the plant.
FPL Response - RAI 11 b The PSDS manufacturer (Framatome Jeumont) has not assigned a model number to the PSDS that will be installed at Turkey Point. However, the PSDS supplier (Framatome Inc.) has assigned this PSDS with the following Part Number: 1251140-151.
11c.
Qualification test data for the applicable PSDS model. The test data should include relevant seal temperatures, pressures, and flow rates sufficient for the staff to confirm that the seal will actuate in the assumed timeframe.
FPL Response - RAI 11 c PSDS qualification tests were performed at temperatures, pressures, and No.1 seal leakoff rates that are bounding of the respective conditions at Turkey Point.
The maximum simulated RCS pressure at which PSDS testing was performed was [
].
This pressure bounds the maximum expected RCS pressure that occurs during LOSC events, which is approximately 2385 psig.
The maximum simulated RCS temperature at which PSDS testing was performed was [
].
This temperature bounds the maximum expected RCS cold leg temperature that occurs during LOSC events, which is 561 °F.
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-2023-110 Page 3 of 6 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project During normal plant operation, No. 1 seal leak rates of approximately 1.8 gpm are expected while abnormal leak rates as high as 6 gpm are permitted before an RCP must be tripped. These leak rates are bounded by the high flow qualification testing that was performed with seal leak rates of
[
]. At these high flow rates, the PSDS was shown to have actuated and sealed as designed.
In audit discussions with NRC Staff on June 29, 2023, it was requested that citations to these proprietary values from Framatome Report 38-9351062-001 be provided. The relevant pages are extracted from the report and included in Attachment 1.
11d.
The PRA appears to include failure modes for the Framatome seals different from those assumed for the N9000 seal. In particular, seal leakoff line isolation is assumed to result in a rapid failure of the seal plus actuation of the safety seal before the RCPs are tripped. The LAR attachment discusses changes to the seal leakoff system to reduce the impact of the event. Discuss other plant modifications that were needed to install the Framatome seals with PSDS.
FPL Response - RAI 11 d Other plant modifications to be performed to support the installation of the Framatome seals with the PSDS are limited to the reconfiguration of plant piping to facilitate the required process connections to the seals (seal leakoff piping and seal bypass piping), and installation of the instrumentation required to monitor seal performance and detect abnormal seal operating conditions (temperature, pressure and leakoff flow). These changes will restore the seal leakoff and seal monitoring to the configuration that existed prior to the Flowserve seal installation.
- 12.
In LAR section 3.1.5, Operator Action, the licensee states that the current required time for the operator to trip the RCPs following a LOSC event was established as 20 minutes to protect the RCP seals from damage. The licensee proposed that for the replacement Framatome RCP seals, the available operator time to trip RCPs is 16 minutes during a LOSC event. The change in the RCP trip time on a LOSC event would affect the Human Error Probability values, which are inputs to the Fire probabilistic risk assessment model. In LAR section 2.1, the licensee states that the current operator action time of 20 minutes was previously approved by the NRC (Reference 5 of the LAR, ML19064A903).
The associated NRC safety evaluation report (SER) indicated that the approval was based, in part, on the data of the RCP trip time in LOSC conditions applicable to the Flowserve RCP seals, which are similar to the current RCP seals at Turkey Point. Specifically, The SER (page
- 10) quoted the following licensee's statement as part of the basis for approval: "the licensee further stated that the time available to trip the RCPs following a loss of seal cooling is 20 minutes, whereas the time available assumed in the Flowserve topical report (TR) is 60 minutes, and that assuming a shorter time for operators to recognize the need and trip the RCPs results in increases in the calculated failure probability, which in turn increases the calculated core damage frequency (CDF) and LERF values," and is conservative.
Provide a discussion to justify that the reduction in time to trip the RCPs during a LOSC from 20 minutes to 16 minutes, to be implemented for the replacement Framatome RCP seals, is acceptable for protecting the RCP seals from damage at TP.
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-2023-110 Page 4 of6 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project FPL Response - RAI 12 The current Flowserve RCP seals are assumed to continue to perform their function if the RCPs are tripped and if the controlled bleed-off is isolated within 20 minutes of a loss of RCP seal cooling event. The 20- minute operator action time for tripping the RCPs is described in WCAP 16175-P-A and that assumption was included in the Turkey Point Fire PRA model. The NRC approved the use of the WCAP 16175-P-A PRA model assumptions for the Turkey Point Fire PRA model.
The current Flowserve seals are being replaced with Framatome seals. Due to the change in seal design the operator action time has changed. For the replacement Framatome RCP seals, an available 16-minute operator action time to trip the RCPs during a loss of seal cooling event is established to ensure that the PSDS will reliably seal the leak path between the RCP shaft and the RCP lower seal housing. For the PSDS to establish a reliable seal, the RCPs must be manually tripped, and the RCP coast down must be complete prior PSDS actuation. Therefore, the operator response time plus the RCP coast down time must be less than the PSDS actuation time.
The operator action time to trip the RCPs following a loss of seal cooling is a Time Sensitive Action (TSA) related to a fire response. TSAs are proceduralized, trained on with the response time validated to ensure that the action can be completed in the assumed time frame. The validation time for the operator response to trip the RCPs following a loss of seal cooling is 6.17 minutes. This time is much less than the 16 minutes assumed in the Fire PRA evaluation.
Based on the above discussion the 16-minute operator action time is acceptable, with margin, to ensure that the leak limiting function of the Framatome RCP seal package will be maintained following a loss of RCP seal cooling event.
12a.
NU REG-1764 section 4.2 provides criteria regarding the conduct of task analysis, including analyses regarding how personnel will both know when action is necessary and that it is performed correctly. However, the LAR does not provide any discussion of the results of any task analysis for the proposed change.
Please provide a description of any task analysis conducted for operator actions affected by the proposed change, including whether the results of any such analysis was that operator tasks would remain unchanged.
FPL Response - RAI 12a The action to trip the RCPs, which is only credited to occur from the control room, is currently proceduralized and frequently trained. Revisions to procedures for the RCP seal replacement are limited to those associated with changes in nomenclature or equipment IDs associated with key parameters that are monitored to assess the need for an RCP trip. The update of plant procedures to reflect the changes associated with this modification are controlled by PTN procedures which require that recommended procedure changes be identified in the Engineering Change package. Operations personnel review these recommended changes and initiate procedure changes for incorporation in conjunction with implementation of the plant modification.
Operations training personnel review the design modification including the associated procedure changes and revise the appropriate operator lesson plans.
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-2023-110 Page 5 of 6 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project The change in the seal configuration does not alter the method, the conditions and the priority of tripping the RCPs. The existing development for the human failure event modeling for failure to trip the RCPs includes and addresses the factors specified in NUREG-1764 such as staffing, tasks, human-system interface, availability, accessibility, and training; and has been Peer Reviewed and found to meet, at Capability Category II, the associated requirements of the ASME/ANS PRA Standard. The primary impact of the RCP seal replacement on the human reliability analysis (HRA) is associated with the reduction in the system time window (Tsw). All other inputs to the HRA remain consistent with the current modeling. Therefore, the NUREG-1764 parameters are not directly impacted by the modification with the exception of the system time window duration. Since the total response time modeled (consisting of delay, cognitive and execution times) for this action is significantly shorter than the reduced system time window, the impact of the modification on the HEP is negligible. The total delay, cognitive and execution time for this action, based on input from operator interviews, including a 5-minute additional delay for the value used in the Fire PRA, is less than 12 minutes. The system time window for the new seal configuration is 16 minutes.
12b.
NUREG-1764 section 4.2 provides criteria regarding staffing, including analyses of effects of the changes in human actions upon the number, qualifications, and staffing levels of operations personnel. However, the LAR does not provide any discussion of the results of any staffing-related analysis for the proposed change.
Please provide a description of any staffing-related analysis conducted in support of the proposed change, including whether the results of any such analysis was that operator staffing levels would remain unchanged.
FPL Response - RAI 12b See Response to Question 12a above.
12c.
NUREG-1764 section 4.3 provides criteria regarding modifications to human-system interfaces (HSls) as they relate to changes in operator task requirements. However, the LAR does not provide any discussion of modifications to HSls.
Please provide a description of any modifications to HSls (e.g., indications and controls located in the main control room) that will be made in conjunction with the proposed change, including whether no modifications to HSls will occur in conjunction with the proposed change.
FPL Response - RAI 12c See Response to Question 12a above.
12d.
NUREG-1764 section 4.3 provides criteria regarding modifications to operator training as it relates to operator task requirements. However, the LAR does not describe the operator training that will be conducted for the manual operator actions affected by the proposed change.
Please provide a description of the operator training that is conducted for the manual operator actions that are discussed in the LAR, as well as whether any modifications to the operator training program will occur in conjunction with the proposed change.
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-2023-110 Page 6 of 6 License Amendment Request, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project FPL Response - RAI 12d See Response to Question 12a above.
12e.
NUREG-1764 section 4.4 provides criteria regarding the availability and accessibility of all required components. However, the LAR does not discuss whether the availability and accessibility of those indications and controls needed to support operator actions will be affected by the proposed change.
Please provide a description of any effects on the availability and accessibility of required indications and controls that will occur in conjunction with the proposed change, including whether no such components will be affected.
FPL Response - RAI 12e See Response to Question 12a above.
12f.
NUREG-1764 section 4.4 provides criteria regarding walkthrough activities conducted for human actions to determine that procedures are accurate and usable, that the training program appropriately addressed the changes, and that the human actions can be completed within the required time. In Section 3.1.5 of the LAR, FPL stated the following:
The change in RCP seal design reduces the time available to verify the RCPs are tripped in the event of a complete loss of RCP seal cooling to 16 minutes.
Please provide a description of the results of the full validation of the new time critical operator action for verification of RCP cooling. As part of this, please include details regarding the following:
Measures included to create realistic scenario conditions; Any issues identified with procedural completeness, technical accuracy, and usability; Any training program issues identified; Whether the credited operator actions could be completed within the allowed time and whether adequate margin exists between the time required and time allowed; Whether any complicating factors that might be expected to affect the crews' ability to perform the credited operator actions were included; and How many complete crews of operators participated in the walkthrough scenarios.