ML24159A265

Correction of Safety Evaluation for Issuance of Amendment Nos. 298 & 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project

ML24159A265
Person / Time
Site:	Turkey Point
Issue date:	06/26/2024
From:	Michael Mahoney Plant Licensing Branch II
To:	Coffey B Florida Power & Light Co
Mahoney, M NRR/DORL 415-3867
References
EPID L-2022-LLA-0128
Download: ML24159A265 (8)

Text

June 26, 2024

Bob Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd.

Juno Beach, FL 33408

SUBJECT:

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 -

CORRECTION OF SAFETY EVALUATION FOR ISSUANCE OF AMENDMENT NOS. 298 AND 291 REGARDING REVISING THE FIRE PROTECTION PROGRAM IN SUPPORT OF REACTOR COOLANT PUMP SEAL REPLACEMENT PROJECT (EPID L-2022-LLA-0128)

Dear Bob Coffey:

On January 22, 2024, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment Nos. 298 and 291 to Renewed Facility Operating Licenses Nos. DPR-31 and DPR-41 for the Turkey Point Nuclear Generating, Unit Nos. 3 and 4, respectively (Agencywide Documents Access and Management System (ADA MS) Accession No. ML23320A306).

Specifically, the amendments were requested in accordance with the units operating licenses, 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 1 x 10-7/year (yr) for core damage frequency and less than 1 x 10-8/yr for large early release frequency. The change is to support replacement of the currently installed reactor coolant pump (RCP) seals with the Framatome RCP hydrostatic seal package equipped with the passive shutdown seal.

An error was identified on page 2 of Amendment 291 to Subsequent Renewed License No.

DPR-41. The refueling outage number referenced in the implementation period (in item 3),

4R33, should have been 4R35.

On page 6 of the safety evaluation (SE), in Section 3.1.1.3, the NRC states, The PSDS supplier has assigned the PSDS [passive shutdown seal] with Part Number 1251149-151. The part number is incorrectly referenced and should be corrected to read 125114 0-151.

On page 8 of the safety evaluation SE, in Section 3.1.1.9, the NRC states:

The Framatome RCP No. 1 and No. 2 seals are similar to the Westinghouse No.

1 and No. 2 seal design, while the No. 3 seal is a Framatome proprietary balanced nose design. The only substantive difference between the currently installed RCP seals and the Framatome RCP seals would be the addition of the PSDS.

B. Coffey

For clarity, this statement is revised to state:

The Framatome RCP No. 1 and No. 2 seals are similar to the previously installed Westinghouse No. 1 and No. 2 seal design, while the No. 3 seal is a Framatome proprietary balanced nose design. The only substantive difference between the currently Westinghouse RCP seals and the Framatome RCP seals would be the addition of the PSDS.

Additionally, on page 10 of the SE, in Section 3.1.2.1, there was an incorrect statement that the licensee submitted a non-risk-informed license amendment request (LAR). The LAR submitted was, in fact, risk-informed. This statement has been corrected.

The NRC concludes that these corrections do no t change the NRC staffs previous conclusions in the SE, nor do they affect the no significant hazards consideration, as published in the Federal Register on December 27, 2022 (87 FR 79359). The enclosure contains corrected page 2 of Amendment 291 for Subsequent Renewed License No. DPR-41 and pages 6, 8, and 10 in the SE for Amendment Nos. 298 and 291. The corrections are denoted by a revision bar in the right margin.

If you have any questions regarding this matter, please contact me at (301) 415-3867 or by email at Michael.Mahoney@nrc.gov.

Sincerely,

/RA/

Michael Mahoney, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-250 and 50-251

Enclosure:

Corrected page 2 of Amendment 291 and SE pages 6, 8, and 10

cc: Listserv

ENCLOSURE

CORRECTED PAGE 2 OF AMENDMENT 291 FOR

SUBSEQUENT RENEWED LICENSE NO. DPR-41

AND

CORRECTED PAGES 6, 8, AND 10 FOR SAFETY EVALUATION

BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO AMENDMENT NOS. 298 AND 291

TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NOS. DPR-31 AND DPR-41

FLORIDA POWER & LIGHT COMPANY

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4

DOCKET NOS. 50-250 AND 50-251

- 2 -

2. Accordingly, by Amendment No. 291, the licensee is authorized to make changes to the fire protection program, as set forth in the application dated August 26, 2022, as supplemented by letters dated May 31, July 27, August 25, and October 31, 2023. The licensee shall make changes as described in the licensees application and supplemental letters and as evaluated in t he NRC staffs safety evaluation issued with this amendment.

3. This license amendment is effective as of the date of its issuance and shall be implemented by the completion of refueling outage 4R35 (spring 2025) for Unit No. 4.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Subsequent Renewed Facility Operating License and Technical Specifications

Date of Issuance: January 22, 2024

3.1.1.1 RCP Seal Current Design

Westinghouse Model 93 RCPs are currently installed at Turkey Point Unit Nos. 3 and 4. The RCP seal prevents nuclear reactor coolant from exiting the RCP body along the pumps impeller shaft. The licensee installed the current three-stage Flowserve RCP seals for Turkey Point Unit Nos. 3 and 4 during the fall 2015 and spring 2016 refueling outages, respectively. These RCP seals include a passive back-up sealing device, referred to as the Abeyance Seal, which activates upon the complete failure of the three primary seal stages.

3.1.1.2 RCP Seal Proposed Design Modification

In the LAR, the licensee discussed the proposed replacement of the currently installed RCP seals with a three-stage Framatome RCP hydrostatic seal package equipped with the PSDS.

The licensee stated that the replacement Framatome RCP hydrostatic seal package with the PSDS has been evaluated for installation in Turkey Point under the criteria of 10 CFR 50.59.

The licensee stated that no attribute for the installation of the replacement seals has been identified as requiring prior NRC approval. Therefore, this LAR only addresses the change in the Fire PRA supporting the FPP due to the planned installation of the Framatome RCP hydrostatic seal with the PSDS. The licensee stated that operating procedures and operator training will be reviewed for consistency with the conditions and timing evaluated in site-specific analyses and will be revised, as necessary, to support the planned installation of the Framatome RCP hydrostatic seals with the PSDS. The licensee stated that any required procedure changes needed as part of the planned installation of the Framatome RCP hydrostatic seal with the PSDS will be evaluated under 10 CFR 50.59.

3.1.1.3 Framatome RCP Seal Model and Additional Plant Modifications

In its letter dated August 25, 2023, the licensee stated that the PSDS manufacturer has not assigned a model number to the PSDS that is planned to be installed at Turkey Point. The PSDS supplier has assigned the PSDS with Part Number 1251140-151. The licensee also stated that plant modifications to support the planned installation of the Framatome RCP seals with the PSDS would include the configuration of the plant piping to facilitate the required process connections to the RCP seal (i.e., seal leakoff piping and seal bypass). The modifications would also include the installation of instrumentation needed to monitor seal performance and to detect abnormal seal operating conditions (i.e., temperature, pressure, and leakoff flow).

3.1.1.4 RCP Seal Proposed Design and ASME BPV Code to the LAR and Framatome document 152-9348792-000, Reactor Coolant Pump Seal and Seal Housing Procurement Specificat ion for Turkey Point Units 3 and 4, listed in Section 5.0 of the audit summary dated September 25, 2023, provide that the reactor coolant pressure boundary (RCPB) components of the RCP seal assembly are required to be designed, manufactured, and tested in accordance with the ASME BPV Code,Section III, Class 1, 2010 Edition with 2011 Addenda. In the Framatome RCP seal assembly, the lower seal housing is the only component that is classified as part of the RCPB and, as such, will be furnished to meet the ASME BPV Code requirements. Therefore, the planned installation of the Framatome RCP seals will not have an adverse impact on safety margin as they will meet the requirements of the ASME BPV Code,Section III, Class 1, 2010 Edition with the 2011 Addenda, as incorporated by reference in 10 CFR 50.55a.

natural circulation cooldown of the RCS, the RCS temperature would be gradually reduced at a rate within technical specification limits; generally, at a rate of approximately 50°F per hour.

While the operator response is taking place, the hot reactor coolant from the RCS cold leg will begin to flow upward through the RCP, into the RCP seal housing, and through the No. 1 seal.

The reactor coolant will flash after flowing through the No. 1 seal, but its temperature will remain above the actuation temperature of the PSDS. The time required for reactor coolant to reach the downstream side of the No. 1 seal and actuate the PSDS is dependent upon the initial No. 1 seal leak rate. For example, a low initial leak rate will extend the PSDS actuation time while a high initial leak rate will reduce the PSDS actuation time. Even if the No. 1 seals were operating at their lowest leakage limit, the PSDS would actuate prior to any significant reduction in the RCS cold leg temperature from the commencement of the controlled natural circulation cooldown. Therefore, the operator actions taken to initiate a controlled natural circulation cooldown will not affect PSDS actuation.

Operator actions other than commencing a controlled RCS natural circulation cooldown can take place while recovering from an LOSC event that might have an adverse effect on a PSDS that has already actuated (e.g., the restart of an RCP). To account for this possibility, the licensee stated in its letter dated October 31, 2023, that the applicable Turkey Point procedures will be revised to require checking the status of PSDS actuation prior to taking such actions.

3.1.1.9 Framatome RCP Seal and Operational Aspects

Based on operating experience, the currently installed RCP seals at Turkey Point are performing satisfactorily. The Framatome RCP No. 1 and No. 2 seals are similar to the previously installed Westinghouse No. 1 and No. 2 seal design, while the No. 3 seal is a Framatome proprietary balanced nose design. The only substantive difference between the Westinghouse RCP seals and the Framatome RCP seals would be the addition of the PSDS.

The Framatome RCP seals are an industry-accepted design installed in multiple nuclear power plants. The Framatome RCP seals are intended to provide improved performance through multiple operating cycles at Turkey Point.

3.1.1.10 Licensees Justification for Reduction in Time to Trip RCPs

In its letter dated August 25, 2023, the licensee justified the reduction in time to trip the RCPs during an LOSC event from 20 minutes to 16 minutes. The licensee stated that the currently installed RCP seals are assumed to continue to perform their function if the RCP trips and if the controlled bleed-off is isolated within 20 minutes of an LOSC event. For the proposed replacement Framatome RCP seals, an available 16-minute operator action time to trip the RCPs during an LOSC event is established to ensure that the PSDS will reliably seal the leak path between the RCP shaft and RCP lower housing. For the PSDS to establish a reliable seal, the RCPs must be manually tripped, and the RCP coastdown must be complete prior to PSDS actuation. Therefore, the operator response time plus the RCP coastdown time must be less than the PSDS actuation time.

The licensee stated that the operator action time to trip RCPs following an LOSC event is a proceduralized time-sensitive action related to a fire response. At Turkey Point, operators are trained to ensure that this action can be completed in the assumed time frame. The licensee reported that the validation time for the operator response to trip the RCPs following an LOSC

an LOSC was established at 20 minutes. The proposed change in the RCP seal design would reduce the time available to verify that the RCPs are tripped in the event of a complete loss of RCP seal cooling to 16 minutes.

In accordance with the guidance provided in Chapter 18 of the SRP, the NRC staff used a graded approach to evaluate the HFE considerations related to the changes described in the LAR. The NRC staff used a qualitative approach under NUREG-1764 in determining the risk significance of the proposed change and the corresponding level of review. In accordance with the generic risk categories established in Appendix A, Generic Human Actions that are Risk-important, to NUREG-1764, the operator actions associated with RCP seal cooling are classified as risk-important human actions. RCP trip on an LOSC is listed on Table A.2, Generic PWR [pressurized-water reactor] Human Actions That Are Risk-Important, which is the Group 1 risk-important qualitative list of items for PWRs. The initial qualitative screening per NUREG-1764, section 2.4.3.2, Generic HA [human action] Method (Method 2), would be Level I, but was reduced to the Level II review based upon the factors described in NUREG-1764, section 2.3.5.2, Adjusting the Level of Human Factors Engineering Review.

In conducting this qualitative assessment, key areas of consideration included the following:

whether the requested change would introduce new human actions.

whether the requested change would give personnel a new functional responsibility that differs from their normal responsibilities.

whether the requested change would signific antly modify the way in which personnel perform their tasks.

whether the requested changed change would create a new context for task performance; and whether the requested change would significantly change any of the following:

o the human-system interfaces used by personnel to perform the task.

o the procedures that personnel use to perform the task; or o the training associated with the task.

Based upon the information provided in the LAR, as supplemented, as detailed later in this evaluation, the NRC staff determined that significant changes were not expected to occur within these areas. From this qualitative assessment, the NRC staff then concluded that the review could be reduced to the Level II review. Using the screening and review guidance of NUREG-1764, the NRC staff subsequently determined that the appropriate Level II review criteria included deterministic, analysis, design, and human action verification criteria. The relevant Level II review criteria are considered in the subsequent portions of this evaluation.

3.1.2.2 General Deterministic Review Criteria

Section 4.1, General Deterministic Review Cr iteria, of NUREG-1764 provides review guidance for verifying that certain deterministic aspects of the change have been appropriately considered by the licensee. The criteria of this section include confirming that the licensee has provided adequate assurance that the change meets current regulations, except where specific exemptions are requested under 10 CFR 50.12. Additionally, criteria are also included for confirming that the licensee has provided adequate assurance that the change does not compromise defense-in-depth as it relates to the preservation of defenses against human errors.

B. Coffey

SUBJECT:

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 -

CORRECTION OF SAFETY EVALUATION FOR ISSUANCE OF AMENDMENT NOS. 298 AND 291 REGARDING REVISING THE FIRE PROTECTION PROGRAM IN SUPPORT OF REACTOR COOLANT PUMP SEAL REPLACEMENT PROJECT (EPID L-2022-LLA-0128) DATED JUNE 26, 2024

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ADAMS Accession No.: ML24159A265 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DORL/LPL2-2/BC NAME MMahoney ABaxter DWrona DATE 06/07/2024 06/17/2024 06/26/2024 OFFICE NRR/DORL/LPL2-2/PM NAME MMahoney DATE 06/26/2024