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| | number = ML100700446 | | | number = ML100700446 |
| | issue date = 03/24/2010 | | | issue date = 03/24/2010 |
| | title = Turkey Point, Units 3 & 4 - Request for Additional Information Regarding Request to Adopt the Alternate Source Team (TAC ME1624 & ME1625) | | | title = Request for Additional Information Regarding Request to Adopt the Alternate Source Team (TAC ME1624 & ME1625) |
| | author name = Paige J C | | | author name = Paige J |
| | author affiliation = NRC/NRR/DORL/LPLII-2 | | | author affiliation = NRC/NRR/DORL/LPLII-2 |
| | addressee name = Nazar M | | | addressee name = Nazar M |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555*0001 March 24, 2010 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 TURKEY POINT UNITS 3 AND 4 -REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST TO ADOPT THE ALTERNATE SOURCE TERM (TAC NOS. ME1624 AND ME1625) | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 March 24, 2010 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 |
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| | ==SUBJECT:== |
| | TURKEY POINT UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST TO ADOPT THE ALTERNATE SOURCE TERM (TAC NOS. ME1624 AND ME1625) |
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| ==Dear Mr. Nazar:== | | ==Dear Mr. Nazar:== |
| By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term, as described in Title 10 of the Code of Federal Regulations, Part 50.67, following the guidance provided in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and finds that the information contained in the enclosed Request for Additional Information is needed before we can complete the review. This was discussed with members of the FPL staff and, on March 1, 2010, Mr. Bob Tomonto indicated that a response would be provided within 30 days of the date of this letter. If you have any questions, please contact me at (301) 415-5888. | | |
| rely, ason 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 | | By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term, as described in Title 10 of the Code of Federal Regulations, Part 50.67, following the guidance provided in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. |
| | The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and finds that the information contained in the enclosed Request for Additional Information is needed before we can complete the review. This was discussed with members of the FPL staff and, on March 1, 2010, Mr. Bob Tomonto indicated that a response would be provided within 30 days of the date of this letter. |
| | If you have any questions, please contact me at (301) 415-5888. |
| | rely, f--:- |
| | ason 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 |
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| ==Enclosure:== | | ==Enclosure:== |
| | Request for Additional Information cc w/encl: Distribution via Listserv |
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| | REQUEST FOR ADDITIONAL INFORMATION FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NUMBERS 50-250 and 50-251 By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL, the licensee) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term (AST), as described in Title 10 of the Code of Federal Regulations (10 CFR), Part 50.67, following the guidance provided in Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. To complete its review of the license amendment request (LAR), the Nuclear Regulatory Commission staff requests the following additional information. |
| | : 1. The AST LAR Enclosure 1, Section 10.0 "References," Reference 6 cites "NEI 99-03, Control Room Habitability Guidance, Nuclear Energy Institute, Revision 0, June 2001 and Revision 1, March 2003." NEI 99-03, Revision 0, June 2001 is an acceptable reference, however, Revision 1 has not been reviewed and accepted by the Nuclear Regulatory Commission (NRC). |
| | Provide additional information describing whether or not NEI 99-03, Revision 1 is being relied upon to support the assumptions or methods used in the AST submittal. If NEI 99-03 Revision 1 is being used to support the AST submittal, it will be necessary to submit NEI 99-03 Revision 1 on the docket with a request for NRC staff review. In addition, the licensee will be responsible for addressing questions that may result from that review and the review will have to be completed before the staff completes its review of the AST submittal. If NEI 99-03 Revision 1 is not being relied upon to support the AST submittal, and it is not the licensee's intention for the staff to review it, then it should be removed from the AST submittal as a reference. |
| | : 2. On page 18 of 81 of Numeric Applications, Inc. (NAI)-1396-045 Rev 1, the second paragraph under item 5 states the following: |
| | "The GOTHIC analysis utilized for Turkey Point to demonstrate the level of spray induced mixing in containment included both subdivided and lumped parameter models. |
| | The detailed subdivided models were used to calculate flow patterns produced by the containment sprays and the emergency containment coolers. Gas concentrations from the subdivided models were compared with concentrations in the lumped parameter model and used to determine equivalent mixing flow rates for the lumped model." |
| | Enclosure |
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| | -2 Provide the following additional information: |
| | : a. Describe how many subdivided models were analyzed using GOTHIC, and the differences among each of the subdivided models. |
| | : b. Provide a tabulation of the results (gas concentrations, flow rates) showing the differences within the subdivided models analyzed and show the comparison with results from the lumped parameter model. |
| | : c. Describe how the equivalent mixing flow rates for the lumped model were determined. |
| | : d. Describe the relationship between the equivalent mixing flow rates that were determined for the lumped model with the mixing flow rates in the subdivided models. |
| | : 3. Provide additional information to ensure that the cool-down times assumed in the main steam line break (MSLB), the steam generator tUbe rupture (SGTR), locked rotor (LRA) and rod cluster control assembly (RCCA) ejection accident analyses can be achieved by exclusive reliance on safety-grade equipment. |
| | : 4. For each of the affected accident analyses, MSLB, SGTR LRA and RCCA, provide additional information to describe the basis for the determination of the potential for 30 minutes of steam generator tube bundle uncovery and a description of the actions required to recover the bundles. |
| | : 5. For the fuel-handling accident, gap fractions from NUREG/CR-5009 were used, which are approximately twice those of RG 1.183 to account for high burn-up fuel not meeting the limits described in Footnote 11. In addition, the gap fractions from Table 3 of RG 1.183 were used without the use of any stated correction factors in the evaluation of the LRA and RCCA ejection accident analyses. |
| | Provide additional information, including the basis, describing whether or not correction factors were used to adjust the gap fractions from Table 3 of RG 1.183 to account for high burn-up fuel in the LRA and the RCCA ejection accident analyses. |
| | : 6. LAR Attachment 3, NAI-1396-045 Rev. 1, Table 1.6.3-1 lists the unfiltered make-up flow rate and inleakage as 1000 cubic feet per minute (cfm) during the normal mode of operation. For the waste gas decay tank rupture, Table 2.7.1 lists the unfiltered inleakage as 115 cfm and the makeup flow rate as 1000 cfm for the non-isolated control room implying that the total air exchange would be calculated using 1115 cfm. |
| | Provide additional information to clarify the assumed total air exchange rate for the control room during normal operation. |
| | : 7. TS bases section 3/4.4.5, Applicable Safety Analysis, states that, "No credit for iodine removal is taken for any steam released to the condenser prior to reactor trip and concurrent loss of offsite power." This statement appears to be in conflict with the revised AST analyses crediting a partition factor of 100 for releases through the condenser prior to reactor trip. |
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| Request for Additional Information cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NUMBERS 50-250 and 50-251 By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL, the licensee) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term (AST), as described in Title 10 of the Code of Federal Regulations (10 CFR), Part 50.67, following the guidance provided in Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. To complete its review of the license amendment request (LAR), the Nuclear Regulatory Commission staff requests the following additional information. The AST LAR Enclosure 1, Section 10.0 "References," Reference 6 cites "NEI 99-03, Control Room Habitability Guidance, Nuclear Energy Institute, Revision 0, June 2001 and Revision 1, March 2003." NEI 99-03, Revision 0, June 2001 is an acceptable reference, however, Revision 1 has not been reviewed and accepted by the Nuclear Regulatory Commission (NRC). Provide additional information describing whether or not NEI 99-03, Revision 1 is being relied upon to support the assumptions or methods used in the AST submittal.
| | -3 Provide additional information to clarify whether or not the revised AST analyses credit a partition factor of 100 for releases through the condenser prior to reactor trip. |
| If NEI 99-03 Revision 1 is being used to support the AST submittal, it will be necessary to submit NEI 99-03 Revision 1 on the docket with a request for NRC staff review. In addition, the licensee will be responsible for addressing questions that may result from that review and the review will have to be completed before the staff completes its review of the AST submittal.
| | : 8. The licensee has proposed TS changes to revise limiting condition of operation (LCO) 3.4.8, "RCS [Reactor Coolant System] Specific Activity," APPLICABILITY requirements to specify that the LCO is applicable in MODES 1, 2, 3, and 4 removing MODE 5 from the APPLICABILITY. The licensee asserts and the NRC staff agrees that: |
| If NEI 99-03 Revision 1 is not being relied upon to support the AST submittal, and it is not the licensee's intention for the staff to review it, then it should be removed from the AST submittal as a reference. On page 18 of 81 of Numeric Applications, Inc. (NAI)-1396-045 Rev 1, the second paragraph under item 5 states the following: "The GOTHIC analysis utilized for Turkey Point to demonstrate the level of spray induced mixing in containment included both subdivided and lumped parameter models. The detailed subdivided models were used to calculate flow patterns produced by the containment sprays and the emergency containment coolers. Gas concentrations from the subdivided models were compared with concentrations in the lumped parameter model and used to determine equivalent mixing flow rates for the lumped model." Enclosure
| | "In MODE 5 with the RCS loops filled, the SGs [steam generators] are specified as a backup means of decay heat removal via natural circulation. In this mode, however, due to the reduced temperature of the RCS, the probability of a design basis accident [DBA] involving the release of significant quantities of RCS inventory is greatly reduced. |
| -2 Provide the following additional information: Describe how many subdivided models were analyzed using GOTHIC, and the differences among each of the subdivided models. Provide a tabulation of the results (gas concentrations, flow rates) showing the differences within the subdivided models analyzed and show the comparison with results from the lumped parameter model. Describe how the equivalent mixing flow rates for the lumped model were determined. Describe the relationship between the equivalent mixing flow rates that were determined for the lumped model with the mixing flow rates in the subdivided models. Provide additional information to ensure that the cool-down times assumed in the main steam line break (MSLB), the steam generator tUbe rupture (SGTR), locked rotor (LRA) and rod cluster control assembly (RCCA) ejection accident analyses can be achieved by exclusive reliance on safety-grade equipment. For each of the affected accident analyses, MSLB, SGTR LRA and RCCA, provide additional information to describe the basis for the determination of the potential for 30 minutes of steam generator tube bundle uncovery and a description of the actions required to recover the bundles. For the fuel-handling accident, gap fractions from NUREG/CR-5009 were used, which are approximately twice those of RG 1.183 to account for high burn-up fuel not meeting the limits described in Footnote 11. In addition, the gap fractions from Table 3 of RG 1.183 were used without the use of any stated correction factors in the evaluation of the LRA and RCCA ejection accident analyses.
| | Therefore, monitoring of RCS specific activity is not required. In MODE 5 with the RCS loops not filled, the SGs are not used for decay heat removal; the RCS and SGs are depressurized and primary to secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required. The change to modify the TS 3.4.8 Applicability to include only MODES 1 through 4 retains the necessary constraints to limit the potential radiological consequences of a SGTR or MSLB that may occur during these MODES and is therefore acceptable from a radiological dose perspective." |
| Provide additional information, including the basis, describing whether or not correction factors were used to adjust the gap fractions from Table 3 of RG 1.183 to account for high burn-up fuel in the LRA and the RCCA ejection accident analyses. LAR Attachment 3, NAI-1396-045 Rev. 1, Table 1.6.3-1 lists the unfiltered make-up flow rate and inleakage as 1000 cubic feet per minute (cfm) during the normal mode of operation. | | The cited discussion provides the basis for not requiring the monitoring of RCS specific activity in MODE 5; however the implication is that the monitoring of RCS specific activity is required in MODES 1 though 4. The NRC staff notes that the TS Table 4.4-4 specifies that the sample and analyses required to demonstrate compliance with LCO 3.4.8 are only required to be performed in MODE 1. After transient conditions (Le., reactor trip, plant depressurization, shutdown or startup) that end in MODES 2,3, or 4, the surveillance is not required to be performed. Isotopic spiking and fuel failures are more likely during transient conditions than during steady state plant operations. |
| For the waste gas decay tank rupture, Table 2.7.1 lists the unfiltered in leakage as 115 cfm and the makeup flow rate as 1000 cfm for the non-isolated control room implying that the total air exchange would be calculated using 1115 cfm. Provide additional information to clarify the assumed total air exchange rate for the control room during normal operation. TS bases section 3/4.4.5, Applicable Safety Analysis, states that, "No credit for iodine removal is taken for any steam released to the condenser prior to reactor trip and concurrent loss of offsite power." This statement appears to be in conflict with the revised AST analyses crediting a partition factor of 100 for releases through the condenser prior to reactor trip.
| | Provide additional information to justify why there is an apparent disparity between the modes of applicability (MODES 1, 2, 3, and 4) and the limited mode (MODE 1) under which the surveillance for TS 3.4.8 is required. |
| -3 Provide additional information to clarify whether or not the revised AST analyses credit a partition factor of 100 for releases through the condenser prior to reactor trip. The licensee has proposed TS changes to revise limiting condition of operation (LCO) 3.4.8, "RCS [Reactor Coolant System] Specific Activity," APPLICABILITY requirements to specify that the LCO is applicable in MODES 1, 2, 3, and 4 removing MODE 5 from the APPLICABILITY.
| | : 9. LAR Attachment 3, NAI-1396-045 Rev. 1, Table 1.7.2-1 does not contain values for Xe 135m or Xe-138, which are needed for staff verification of the proposed limiting value of DEX-133. |
| The licensee asserts and the NRC staff agrees that: "In MODE 5 with the RCS loops filled, the SGs [steam generators]
| | Provide additional information documenting the values used to support the proposed limiting value of DEX-133 as well as the basis for their selection. |
| are specified as a backup means of decay heat removal via natural circulation.
| | : 10. What are the heights above ground of all wind direction, wind speed and temperature difference measurements used in the analysis to support the June 25, 2009, AST LAR. |
| In this mode, however, due to the reduced temperature of the RCS, the probability of a design basis accident [DBA] involving the release of significant quantities of RCS inventory is greatly reduced. Therefore, monitoring of RCS specific activity is not required.
| | Page 15 of Attachment 3 to the LAR states that wind speeds are measured at a height of 11.58 meters above ground. Page 16 cites a 10 meter wind speed. Were all measurements made on a single tower and the reference to 10 meters is simply a convenient approximation to data measured at 11.58 meters? NRC staff noted a |
| In MODE 5 with the RCS loops not filled, the SGs are not used for decay heat removal; the RCS and SGs are depressurized and primary to secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required.
| | |
| The change to modify the TS 3.4.8 Applicability to include only MODES 1 through 4 retains the necessary constraints to limit the potential radiological consequences of a SGTR or MSLB that may occur during these MODES and is therefore acceptable from a radiological dose perspective." The cited discussion provides the basis for not requiring the monitoring of RCS specific activity in MODE 5; however the implication is that the monitoring of RCS specific activity is required in MODES 1 though 4. The NRC staff notes that the TS Table 4.4-4 specifies that the sample and analyses required to demonstrate compliance with LCO 3.4.8 are only required to be performed in MODE 1. After transient conditions (Le., reactor trip, plant depressurization, shutdown or startup) that end in MODES 2,3, or 4, the surveillance is not required to be performed.
| | - 4 relatively lower occurrence of winds from the north northeast direction than from the north and easterly directions between 2003 and 2007. To what may this be attributed? |
| Isotopic spiking and fuel failures are more likely during transient conditions than during steady state plant operations.
| | Provide a drawing or provide a reference to an existing docketed drawing, which shows the location of the Turkey Point meteorological tower(s) with respect to plant structures and site features. |
| Provide additional information to justify why there is an apparent disparity between the modes of applicability (MODES 1, 2, 3, and 4) and the limited mode (MODE 1) under which the surveillance for TS 3.4.8 is required. LAR Attachment 3, NAI-1396-045 Rev. 1, Table 1.7.2-1 does not contain values for 135m or Xe-138, which are needed for staff verification of the proposed limiting value of DEX-133. Provide additional information documenting the values used to support the proposed limiting value of DEX-133 as well as the basis for their selection. What are the heights above ground of all wind direction, wind speed and temperature difference measurements used in the analysis to support the June 25, 2009, AST LAR. Page 15 of Attachment 3 to the LAR states that wind speeds are measured at a height of 11.58 meters above ground. Page 16 cites a 10 meter wind speed. Were all measurements made on a single tower and the reference to 10 meters is simply a convenient approximation to data measured at 11.58 meters? NRC staff noted a
| | : 11. Provide additional information describing how the Turkey Point 2003 through 2007 meteorological data were measured, processed, and selected to ensure that the data were appropriate for input into the ARCON96 and PAVAN computer codes. During the 5-year period, highlight any changes in the way in which the data were measured, processed, or selected for inclusion in the files and discuss why the changes were made. Identify each resultant temporal subset that comprises a homogeneous measurement, process, or selection grouping. |
| -relatively lower occurrence of winds from the north northeast direction than from the north and easterly directions between 2003 and 2007. To what may this be attributed?
| | The following specific areas should be addressed further. |
| Provide a drawing or provide a reference to an existing docketed drawing, which shows the location of the Turkey Point meteorological tower(s) with respect to plant structures and site features. Provide additional information describing how the Turkey Point 2003 through 2007 meteorological data were measured, processed, and selected to ensure that the data were appropriate for input into the ARCON96 and PAVAN computer codes. During the 5-year period, highlight any changes in the way in which the data were measured, processed, or selected for inclusion in the files and discuss why the changes were made. Identify each resultant temporal subset that comprises a homogeneous measurement, process, or selection grouping.
| | : a. FPL provided two sets of ARCON96 hourly meteorological data files for 2005 and 2006. Files were sent by letter dated July 21, 2009 (e-mail confirmation of receipt dated March 8, 2010, ADAMS Accession No. ML100680672) as part of the current LAR. In addition, files for the same 2-year period were subsequently submitted as part of another, unrelated, LAR by letter dated August 7, 2009 (ML092250585). There appears to be some differences between the two sets of files for the 2005 and 2006 data. Clarify the basis for the apparent differences, which are particularly apparent with respect to the atmospheric stability categorization. Are both sets of data measured at the same location and categorized by temperature difference with height measurements only? In addition, the data provided by letter dated August 7,2009, were for 2002,2005, and 2006, while the data provided previously by letter dated July 21, 2009, for the current LAR is for the period 2003 through 2007. Provide justification that the 2003 through 2007 data are appropriate for use in the current LAR. |
| The following specific areas should be addressed further. FPL provided two sets of ARCON96 hourly meteorological data files for 2005 and 2006. Files were sent by letter dated July 21, 2009 (e-mail confirmation of receipt dated March 8, 2010, ADAMS Accession No. ML 100680672) as part of the current LAR. In addition, files for the same 2-year period were subsequently submitted as part of another, unrelated, LAR by letter dated August 7, 2009 (ML092250585).
| | : b. While the yearly data recovery rate by parameter is generally above 90 percent as recommended by RG 1.23, Rev. 0, "Onsite Meteorological Programs," the recovery rate in 2007 for the upper level wind direction appears to be in the upper 60 percentile. Discuss the impact of this lower recovery rate on calculation of the atmospheric dispersion factors (X/Q values). |
| There appears to be some differences between the two sets of files for the 2005 and 2006 data. Clarify the basis for the apparent differences, which are particularly apparent with respect to the atmospheric stability categorization.
| | : c. The occurrence of atmospheric stability category A in 2004 appears to be approximately 22.5 percent and in the following year, 2005, approximately 4.5 percent. During the other three years, the value ranged between about 6 and 9 percent. To what is this variability attributed? |
| Are both sets of data measured at the same location and categorized by temperature difference with height measurements only? In addition, the data provided by letter dated August 7,2009, were for 2002,2005, and 2006, while the data provided previously by letter dated July 21, 2009, for the current LAR is for the period 2003 through 2007. Provide justification that the 2003 through 2007 data are appropriate for use in the current LAR. While the yearly data recovery rate by parameter is generally above 90 percent as recommended by RG 1.23, Rev. 0, "Onsite Meteorological Programs," the recovery rate in 2007 for the upper level wind direction appears to be in the upper 60 percentile.
| | : 12. Provide one or more scaled figures with all postulated sources and receptors highlighted from which distance and direction inputs can be approximated. Provide the scale of the figure. Explain whether distance inputs into the ARCON96 calculations were directly estimated as horizontal straight line distances. If the distances were not estimated directly as straight line horizontal distances, explain how they were determined. Did the procedure used to estimate the distances account for differences in heights between each source and receptor pair? Were any sources modeled as diffuse releases? |
| Discuss the impact of this lower recovery rate on calculation of the atmospheric dispersion factors (X/Q values). The occurrence of atmospheric stability category A in 2004 appears to be approximately 22.5 percent and in the following year, 2005, approximately 4.5 percent. During the other three years, the value ranged between about 6 and 9 percent. To what is this variability attributed? Provide one or more scaled figures with all postulated sources and receptors highlighted from which distance and direction inputs can be approximated.
| | |
| Provide the scale of the figure. Explain whether distance inputs into the ARCON96 calculations were directly estimated as horizontal straight line distances.
| | -5 |
| If the distances were not estimated directly as straight line horizontal distances, explain how they were determined.
| | : 13. Provide additional information on the following. Table 1.8.1-1 of Attachment 3 suggests that Unit 4 and the southeast emergency intake are more limiting than releases from Unit 3 or to the northeast emergency intake. Provide the basis for this determination (i.e., were calculations made to qualitatively confirm this?). Page 2 of PTN-ENG-SENS 02-052, Rev. 2, "Release/Receptor Combination Table," appears to provide a more inclusive list of potential source and receptor pairs. However, some of the values in the PTN table do not match those in Table 1.8.1-1. Further, the PTN table refers to east and west emergency intakes, whereas references in the proposed revision to the TS and in Attachment 3 refer to southeast and northeast intakes. Does the phrase "credit for dilution allowed" refer to the assumed cross sectional building area of 1254 m2? Provide discussion on why the 4.8 meters from the plant stack to the east emergency intake provided in the PTN table was not the limiting pair? |
| Did the procedure used to estimate the distances account for differences in heights between each source and receptor pair? Were any sources modeled as diffuse releases?
| | : 14. Is the 24 hour temperature swing discussed on page 16 of Attachment 3 the difference between daily maximum and minimum temperatures? How does this swing vary by time of year? Given that the accident is assumed to be of 30-day duration, why should an annual average value be used rather than a more limiting value such as that for the limiting 30-day period? How is the swing temperature used in the calculation? |
| -5Provide additional information on the following.
| | : 15. Page 16 of Attachment 3 discusses the 95th percentile wind speed with respect to calculations for assumed releases from the main steam safety valves (MSSVs) and atmospheric dump valves (ADVs). Per RG 1.194, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants," |
| Table 1.8.1-1 of Attachment 3 suggests that Unit 4 and the southeast emergency intake are more limiting than releases from Unit 3 or to the northeast emergency intake. Provide the basis for this determination (i.e., were calculations made to qualitatively confirm this?). Page 2 of 02-052, Rev. 2, "Release/Receptor Combination Table," appears to provide a more inclusive list of potential source and receptor pairs. However, some of the values in the PTN table do not match those in Table 1.8.1-1. Further, the PTN table refers to east and west emergency intakes, whereas references in the proposed revision to the TS and in Attachment 3 refer to southeast and northeast intakes. Does the phrase "credit for dilution allowed" refer to the assumed cross sectional building area of 1254 m 2? Provide discussion on why the 4.8 meters from the plant stack to the east emergency intake provided in the PTN table was not the limiting pair? Is the 24 hour temperature swing discussed on page 16 of Attachment 3 the difference between daily maximum and minimum temperatures?
| | provide an example of how the wind speed adjustment was calculated to demonstrate that the effluent velocity is at least five times higher than the 95th percentile wind speed. |
| How does this swing vary by time of year? Given that the accident is assumed to be of 30-day duration, why should an annual average value be used rather than a more limiting value such as that for the limiting 30-day period? How is the swing temperature used in the calculation? Page 16 of Attachment 3 discusses the 95th percentile wind speed with respect to calculations for assumed releases from the main steam safety valves (MSSVs) and atmospheric dump valves (ADVs). Per RG 1.194, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants," provide an example of how the wind speed adjustment was calculated to demonstrate that the effluent velocity is at least five times higher than the 95th percentile wind speed. How was the effluent velocity determined for the MSSVs and ADVs and how does it vary as a function of time? Confirm that the effluent release is uncapped and in a vertical upward direction. Regarding the DBAs analyzed in support of this LAR, please confirm that the generated X/a values model the limiting doses and that all credible potential release scenarios were considered, including those due to loss of offsite power or other single failures. What wind speed values were used in developing the joint frequency distributions (JFDs) used as input to the PAVAN computer code calculations?
| | How was the effluent velocity determined for the MSSVs and ADVs and how does it vary as a function of time? Confirm that the effluent release is uncapped and in a vertical upward direction. |
| For example, if two consecutive categories are defined as 1-3 miles per hour (mph) and 4-7 mph, what is the value used to define the upper limit of the lower category (e.g., 3 mph, 3.5 mph, 4 mph)? The choice of wind speed categories used in the PAVAN calculations appears to result in some clustering of the data in the lower categories.
| | : 16. Regarding the DBAs analyzed in support of this LAR, please confirm that the generated X/a values model the limiting doses and that all credible potential release scenarios were considered, including those due to loss of offsite power or other single failures. |
| This may affect the resultant X/a value estimates generated by the PAVAN computer code. NRC Regulatory Issues Summary (RIS) 2006-4, "Experience with Implementation of Alternative Source Terms," states that input to PAVAN should have a large number of wind speed categories at the lower wind speeds in order to produce the best results. Provide a supplement to Section 4, "Atmospheric Dispersion," of Attachment 6 to provide justification for the selection of wind speed categories used in PAVAN calculations considering the recommendation in RIS 2006-4.
| | : 17. What wind speed values were used in developing the joint frequency distributions (JFDs) used as input to the PAVAN computer code calculations? For example, if two consecutive categories are defined as 1-3 miles per hour (mph) and 4-7 mph, what is the value used to define the upper limit of the lower category (e.g., 3 mph, 3.5 mph, 4 mph)? |
| -6Page 16 of Attachment 3 states several conversions were performed to the JFD to result in the file provided in support of the LAR. Provide further discussion of how the was developed in comparison to the hourly data files provided in the ARCON96 format. Other than the JFD, provide a consolidated list of all inputs and assumptions used in the PAVAN calculations.
| | : 18. The choice of wind speed categories used in the PAVAN calculations appears to result in some clustering of the data in the lower categories. This may affect the resultant X/a value estimates generated by the PAVAN computer code. NRC Regulatory Issues Summary (RIS) 2006-4, "Experience with Implementation of Alternative Source Terms," |
| A copy of the summary pages of the PAVAN outputs is acceptable to show inputs. For TS 3/4.7.5 "Control Room Emergency Ventilation System," the action statement for modes 1, 2, 3, and 4 states, "with the Control Room Emergency Ventilation System inoperable, suspend all movement of fuel in the spent fuel pool and restore the inoperable system to OPERABLE status within 84 hours ..." Provide a discussion describing what action will be taken to mitigate the consequences of a DBA that may occur during the 84 hours when the system is inoperable.
| | states that input to PAVAN should have a large number of wind speed categories at the lower wind speeds in order to produce the best results. Provide a supplement to Section 4, "Atmospheric Dispersion," of Attachment 6 to provide justification for the selection of wind speed categories used in PAVAN calculations considering the recommendation in RIS 2006-4. |
| The discussion should include details describing how compliance with Appendix A to 10 CFR Part 50 GDC 19, "Control Room" will be maintained.
| | |
| The discussion should also state whether the 84 hours are factored into the calculated dose of the licensing basis analyses of DBA consequences.
| | -6 |
| March 24, 2010 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 TURKEY POINT UNITS 3 AND 4 -REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST TO ADOPT THE ALTERNATE SOURCE TERM (TAC NOS. ME1624 AND ME1625)
| | : 19. Page 16 of Attachment 3 states several conversions were performed to the JFD to result in the file provided in support of the LAR. Provide further discussion of how the ~IFD was developed in comparison to the hourly data files provided in the ARCON96 format. |
| | Other than the JFD, provide a consolidated list of all inputs and assumptions used in the PAVAN calculations. A copy of the summary pages of the PAVAN outputs is acceptable to show inputs. |
| | : 20. For TS 3/4.7.5 "Control Room Emergency Ventilation System," the action statement for modes 1, 2, 3, and 4 states, "with the Control Room Emergency Ventilation System inoperable, suspend all movement of fuel in the spent fuel pool and restore the inoperable system to OPERABLE status within 84 hours ..." Provide a discussion describing what action will be taken to mitigate the consequences of a DBA that may occur during the 84 hours when the system is inoperable. The discussion should include details describing how compliance with Appendix A to 10 CFR Part 50 GDC 19, "Control Room" will be maintained. The discussion should also state whether the 84 hours are factored into the calculated dose of the licensing basis analyses of DBA consequences. |
| | |
| | March 24, 2010 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 |
| | |
| | ==SUBJECT:== |
| | TURKEY POINT UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST TO ADOPT THE ALTERNATE SOURCE TERM (TAC NOS. ME1624 AND ME1625) |
|
| |
|
| ==Dear Mr. Nazar:== | | ==Dear Mr. Nazar:== |
| By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term, as described in Title 10 of the Code of Federal Regulations, Part 50.67, following the guidance provided in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and finds that the information contained in the enclosed Request for Additional Information is needed before we can complete the review. This was discussed with members of the FPL staff and, on March 1, 2010, Mr. Bob Tomonto indicated that a response would be provided within 30 days of the date of this letter. If you have any questions, please contact me at (301) 415-5888. | | |
| 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 | | By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term, as described in Title 10 of the Code of Federal Regulations, Part 50.67, following the guidance provided in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. |
| | The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and finds that the information contained in the enclosed Request for Additional Information is needed before we can complete the review. This was discussed with members of the FPL staff and, on March 1, 2010, Mr. Bob Tomonto indicated that a response would be provided within 30 days of the date of this letter. |
| | If you have any questions, please contact me at (301) 415-5888. |
| | 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:== | | ==Enclosure:== |
|
| |
| Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION: | | Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION: |
| PUBLIC RidsOgcRp RidsNrrDorlDpr LPL2-2 R1F RidsAcrsAcnw_MailCTR Resource RidsNrrDraAadb RidsNrrPMTurkey Point RidsRgn2MailCenter KMiller, NRR RidsNrrLABClayton (Hard Copy) RidsNrrDorlLpl2-2 RidsNrrDssScvb ADAMS Accession Number' ML NRR-088 OFFICE LPL2-2/PM LPL2-2/LA SCVB/BC MDB/BC LPL2-2/BC(A) | | PUBLIC RidsOgcRp RidsNrrDorlDpr LPL2-2 R1F RidsAcrsAcnw_MailCTR Resource RidsNrrDraAadb RidsNrrPMTurkey Point RidsRgn2MailCenter KMiller, NRR RidsNrrLABClayton (Hard Copy) RidsNrrDorlLpl2-2 RidsNrrDssScvb ADAMS Accession Number' ML100700446 NRR-088 SCVB/BC OFFICE LPL2-2/PM LPL2-2/LA MDB/BC LPL2-2/BC(A) |
| NAME JPaige BClayton RDennig* TTate* DBroaddus DATE 03/12/10 03/11/10 02/03/2010 02/3/2010 03/24/10 *vla OFFICIAL RECORD COPY}} | | NAME JPaige BClayton RDennig* TTate* DBroaddus DATE 03/12/10 03/11/10 02/03/2010 02/3/2010 03/24/10 |
| | *vla memo OFFICIAL RECORD COPY}} |
Letter Sequence RAI |
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TAC:ME1624, Administratively Control Containment Penetrations, TSTF-68, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed) TAC:ME1625, Administratively Control Containment Penetrations, TSTF-68, Revise Containment Requirements During Handling Irradiated Fuel and Core Alterations (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Results
Other: L-2011-540, Safety Evaluation Report Review Supporting Fuel Storage Criticality Amendments 246 and 242, L-2012-118, Response to NRC ITSB RAI Regarding Clean TS Changes for EPU LAR No. 205 and Incorporation of Amendments 247 and 243 TS Changes on Relocation of Cycle Specific Parameters to the Core Operating Limits Report, L-2012-263, CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems in Light Water Nuclear Power Reactors - 30 Day Special Report, L-2012-293, FPL Review Comments on Extended Power Uprate Safety Evaluation Report, L-2012-426, Extended Power Uprate Cycle 26 Startup Report, ML110960521, ML110960523, ML112280292, ML12074A248, ML12074A251, ML12122A162, NRC-2011-0094, Federal Register Notice, Notice of Consideration Regarding Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information.
|
MONTHYEARL-2009-133, License Amendment Request 196 Alternative Source Term and Conforming Amendment2009-06-25025 June 2009 License Amendment Request 196 Alternative Source Term and Conforming Amendment Project stage: Request ML0920205292009-07-22022 July 2009 Supplemental Information Needed for Acceptance of Requested Licensing Action Alternate Source Term Amendment Request (LAR 196) (Tac Nos. ME1624 and ME1625) Project stage: Acceptance Review ML0922206962009-08-18018 August 2009 Supplemental Information Needed for Acceptance of Requested Licensing Action Alternate Source Term Amendment Request (LAR 196) Project stage: Acceptance Review L-2009-195, Response to Request for Additional Information on Proposed Amendments to Revise the Technical Specifications to Adopt Alternative Source Term2009-08-26026 August 2009 Response to Request for Additional Information on Proposed Amendments to Revise the Technical Specifications to Adopt Alternative Source Term Project stage: Response to RAI ML0926005302009-09-25025 September 2009 Acceptance Letter Regarding the Alternative Source Term License Amendment Request Project stage: Acceptance Review ML0935006652009-12-17017 December 2009 RAI, Regarding Alternative Source Term Project stage: RAI L-2010-021, Turkey Points, Units 3 & 4, Response to Request for Additional Information Regarding Alternative Source Term Amendment Request2010-02-10010 February 2010 Turkey Points, Units 3 & 4, Response to Request for Additional Information Regarding Alternative Source Term Amendment Request Project stage: Response to RAI ML1005603882010-02-25025 February 2010 Request for Additional Information Regarding Request to Adopt the Alternate Source Term Project stage: RAI L-2010-048, Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 1962010-03-15015 March 2010 Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 Project stage: Response to RAI ML1007004462010-03-24024 March 2010 Request for Additional Information Regarding Request to Adopt the Alternate Source Team (TAC ME1624 & ME1625) Project stage: RAI L-2010-065, Response to Request for Additional Information (RAI) Regarding Alternative Source Tear (AST) License Amendment Request (LAR) 1962010-04-14014 April 2010 Response to Request for Additional Information (RAI) Regarding Alternative Source Tear (AST) License Amendment Request (LAR) 196 Project stage: Response to RAI L-2010-083, Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST)2010-05-21021 May 2010 Supplement to License Amendment Request (LAR) 196 and 3/24/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) Project stage: Supplement L-2010-121, Revised Meteorological Data for 2005-2009 Supporting Alternative Source Term and Conforming License Amendment Request 1962010-06-11011 June 2010 Revised Meteorological Data for 2005-2009 Supporting Alternative Source Term and Conforming License Amendment Request 196 Project stage: Request L-2010-131, Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 1962010-06-23023 June 2010 Response to 5/28/2010 Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) 196 Project stage: Request L-2010-137, Revised Radiological Dose Consequences for Alternative Source Term and Conforming License Amendment Request 1962010-06-25025 June 2010 Revised Radiological Dose Consequences for Alternative Source Term and Conforming License Amendment Request 196 Project stage: Request ML1024400682010-08-27027 August 2010 Acceptance Review: Fuel Storage Criticality Analysis LAR (ME4470 and ME4471) Project stage: Acceptance Review L-2010-136, Revised Meteorological Data for 2005-2009 with T Bias Supporting Alternative Source Term and Conforming License Amendment Request 1962010-09-0202 September 2010 Revised Meteorological Data for 2005-2009 with T Bias Supporting Alternative Source Term and Conforming License Amendment Request 196 Project stage: Request ML1024602052010-09-0303 September 2010 E-mail Acceptance Review TSTF-448 Project stage: Acceptance Review L-2010-197, Response to Request for Additional Information Regarding Alternative Source Term License Amendment Request (LAR) 196 and Proposed Changes to Technical Specification (TS) 3/4.7.5 on Control Room Emergency Ventilation System2010-09-15015 September 2010 Response to Request for Additional Information Regarding Alternative Source Term License Amendment Request (LAR) 196 and Proposed Changes to Technical Specification (TS) 3/4.7.5 on Control Room Emergency Ventilation System Project stage: Response to RAI L-2010-226, Summary of NRC Public Meeting Discussion on Meteorological Data for Alternative Source Term and Conforming License Amendment Request 1962010-10-13013 October 2010 Summary of NRC Public Meeting Discussion on Meteorological Data for Alternative Source Term and Conforming License Amendment Request 196 Project stage: Meeting ML1035601692010-10-21021 October 2010 License Amendment Request for Extended Power Uprate (LAR 205) Project stage: Request L-2010-160, Supplement to the Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 Regarding the EPU Related System Impact Study (SIS)2010-10-29029 October 2010 Supplement to the Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 Regarding the EPU Related System Impact Study (SIS) Project stage: Supplement L-2010-293, Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) No. 196 and Meteorological Data Sensitivity2010-12-14014 December 2010 Response to Request for Additional Information (RAI) Regarding Alternative Source Term (AST) License Amendment Request (LAR) No. 196 and Meteorological Data Sensitivity Project stage: Response to RAI ML1035601832010-12-14014 December 2010 License Amendment Request for Extended Power Uprate, Attachment 07; Supplemental Environmental Report Project stage: Supplement ML1035601742010-12-14014 December 2010 License Amendment Request for Extended Power Uprate, Attachment 1; Descriptions and Technical Justifications for the Renewed Operating License, Technical Specifications, and Licensing Basis Changes Project stage: Request ML1028710232010-12-16016 December 2010 Summary of Meeting with Florida Power & Light Company to Discuss Turkey Point, Units 3 and 4, Alternative Source Term License Amendment Request Project stage: Meeting L-2010-303, Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Equivalent Margin Analysis (EMA)2010-12-21021 December 2010 Supplemental Response to NRC Request for Additional Information Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Equivalent Margin Analysis (EMA) Project stage: Supplement ML1036400512010-12-26026 December 2010 Logbook Entry for 12/26/2010 Project stage: Request ML1036400522010-12-27027 December 2010 Logbook Entry for 12/27/2010 Project stage: Request L-2011-004, Response to NRC Request for Additional Information Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Mechanical/Civil Engineering Issues2011-01-0707 January 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Mechanical/Civil Engineering Issues Project stage: Response to RAI ML1103101842011-01-12012 January 2011 Crocodile Log Book 1/12/2011 Project stage: Request ML1035500302011-01-19019 January 2011 Summary of Meeting with Florida Power & Light Company, Regarding Turkey Point, Units 3 & 4, Spent Fuel Criticality Analysis License Amendment Request Project stage: Meeting L-2011-027, Response to NRC Request for Additional Information (RAI) Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Fire Protection Issues2011-02-22022 February 2011 Response to NRC Request for Additional Information (RAI) Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Fire Protection Issues Project stage: Response to RAI L-2011-030, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Human Performance Issues - Round 12011-03-0303 March 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Human Performance Issues - Round 1 Project stage: Response to RAI ML1107000212011-03-11011 March 2011 Acceptance for Review of License Amendment Request for Extended Power Uprate Project stage: Acceptance Review L-2011-102, Response to NRC Request for Additional Information (RAI) Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Unit 3 Mechanical/Civil Engineering Issues2011-03-25025 March 2011 Response to NRC Request for Additional Information (RAI) Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Unit 3 Mechanical/Civil Engineering Issues Project stage: Response to RAI L-2011-081, Response to NRC Request for Additional Information (RAI) Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Electrical Engineering Branch Issues2011-03-31031 March 2011 Response to NRC Request for Additional Information (RAI) Regarding Extended Power Uprate (EPU) License Amendment Request (LAR) No. 205 and Electrical Engineering Branch Issues Project stage: Response to RAI ML1108907262011-03-31031 March 2011 Slides for Turkey Point, 3 and 4, Regarding Extended Power Uprate and Spent Fuel Criticality Project stage: Request ML11095A0122011-04-21021 April 2011 Summary of Public Meeting with Florida Power & Light Company, on Turkey Points, Units 2 and 4 Extended Power Uprate License Amendment Request Currently Under Review (TAC Nos. ME4907 and ME4908) Project stage: Meeting L-2011-153, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Instrumentation and Controls Issues2011-04-22022 April 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Instrumentation and Controls Issues Project stage: Response to RAI L-2011-084, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Containment and Ventilation Issues2011-04-28028 April 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Containment and Ventilation Issues Project stage: Response to RAI L-2011-142, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Health Physics and Human Performance Issues2011-04-29029 April 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Health Physics and Human Performance Issues Project stage: Response to RAI NRC-2011-0094, Federal Register Notice, Notice of Consideration Regarding Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information.2011-05-0202 May 2011 Federal Register Notice, Notice of Consideration Regarding Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information. Project stage: Other ML1109605232011-05-0202 May 2011 Federal Register Notice, Notice of Consideration Regarding Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information. Project stage: Other ML1109605212011-05-0606 May 2011 Letter, Notice of Consideration of Issuance of Amendment to Facility Operating License and Opportunity for a Hearing and Order Imposing Procedures for Document Access to Sensitive Unclassified Non-Safeguards Information Project stage: Other L-2011-141, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Reactor Systems Issues2011-05-11011 May 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Reactor Systems Issues Project stage: Response to RAI L-2011-170, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Nuclear Performance and Code Review Issues2011-05-19019 May 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Nuclear Performance and Code Review Issues Project stage: Response to RAI L-2011-154, Response to NRC Request for Additional Information Regarding Fuel Storage Criticality Analysis License Amendment Request No. 2072011-05-20020 May 2011 Response to NRC Request for Additional Information Regarding Fuel Storage Criticality Analysis License Amendment Request No. 207 Project stage: Response to RAI L-2011-210, Regarding Supplementary Information Related to Fpl'S Response to NRC Request for Additional Information (RAI) IHPB-1.52011-06-0707 June 2011 Regarding Supplementary Information Related to Fpl'S Response to NRC Request for Additional Information (RAI) IHPB-1.5 Project stage: Supplement ML11174A1652011-06-21021 June 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Instrumentation and Controls Issues Project stage: Response to RAI 2010-06-25
[Table View] |
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Category:Letter
MONTHYEARML24023A0342024-02-0505 February 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0038 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML23341A2102024-01-22022 January 2024 LTR-23-0216-1 - Closure Letter - 2.206 Petition for License Renewal Plant Reactor Pressure Vessel Embrittlement ML23320A3062024-01-22022 January 2024 Issuance of Amendment Nos. 298 and 291 Regarding Revising the Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project L-2024-007, Inservice Inspection Program Owner'S Activity Report (OAR-1)2024-01-18018 January 2024 Inservice Inspection Program Owner'S Activity Report (OAR-1) L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-166, Turkey Points Units 3 and 4, Correction to the 2022 Annual Radioactive Effluent Release Report2023-12-0606 December 2023 Turkey Points Units 3 and 4, Correction to the 2022 Annual Radioactive Effluent Release Report ML23340A0332023-12-0101 December 2023 FPL to Fws, Comments Submitted by Florida Power and Light on the Species Status Assessment Accompanying the September 20, 2023 Proposed Threatened Species Status with Section 4(d) Rule for the Miami Cave Crayfish L-2023-172, Supplement to Exemption Request Regarding Enhanced Weapons. Firearms Background Checks. and Security Event Notifications Final Rule2023-11-29029 November 2023 Supplement to Exemption Request Regarding Enhanced Weapons. Firearms Background Checks. and Security Event Notifications Final Rule L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, ML23333A0152023-11-27027 November 2023 Attachment G - Arcadis Memo Re FPL Year 4 Raasr Final (June 2, 2023, Appended to Derm letter)-1 ML23333A0102023-11-27027 November 2023 Attachment B - 11/07/2022 - Waterkeeper Scoping Comments-1 L-2023-146, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles2023-11-15015 November 2023 License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles IR 05000250/20230032023-11-0909 November 2023 Integrated Inspection Report 05000250/2023003 and 05000251/2023003 ML23310A1342023-11-0404 November 2023 10 CFR 2.206 Petition - LTR-23-0216-1 Petition Amendment; Turkey Point Subsequent Renewal with Petitioner 11/04/2023 ML24016A2622023-10-25025 October 2023 Subsequent License Renewal Updated List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected Project L-2023-077, License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis2023-10-11011 October 2023 License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published IR 05000250/20230102023-09-29029 September 2023 Biennial Problem Identification and Resolution Inspection Report 05000250/2023010 and 05000251/2023010 ML23234A1922023-09-27027 September 2023 Issuance of Amendment Nos. 297 and 290 Regarding Conversion to Improved Standard Technical Specifications ML23265A5492023-09-22022 September 2023 Transmittal of WCAP-18830-P/NP Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles to Support a License Amendment Request from FPL - License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis ML23243A9522023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application ML23243A9542023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application ML23243A9532023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application ML23243A9552023-09-0808 September 2023 Notice of Availability of the Draft Environmental Impact Statement for the Turkey Point Nuclear Generating Unit Numbers 3 and 4 Subsequent License Renewal Application - Tribe- Section 106 Letters ML23199A2352023-09-0505 September 2023 Letter to EPA-Turkey Point Nuclear Generating Station, Units 3 and 4 - Notice of Availability of Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal ML23199A2482023-09-0505 September 2023 Ltr to Florida Power and Light Co - Turkey Point Nuclear Generating Units 3 and 4 - Notice of Availability of Draft Site-Specific Environmental Impact Statement for Subsequent License Renewal 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 Project2023-08-25025 August 2023 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 IR 05000250/20230052023-08-21021 August 2023 Updated Inspection Plan for Turkey Point, Units 3 & 4 (Report 05000250/2023005 and 05000251/2023005) L-2023-115, Inservice Inspection Program Owner'S Activity Report (OAR-1)2023-08-21021 August 2023 Inservice Inspection Program Owner'S Activity Report (OAR-1) L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update IR 05000250/20230022023-08-14014 August 2023 Integrated Inspection Report 05000250/2023002 and 05000251/2023002 L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 ML23242A0922023-08-0606 August 2023 Request for Withholding Information from Public Disclosure for Turkey Point Nuclear Generating Unit Nos. 3 and 4 ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment ML23198A2702023-08-0303 August 2023 Issuance of the Site-Specific Environmental Impact Statement Scoping Process Summary Report Associated with the Turkey Point Nuclear Generating Unit Numbers 3 and 4, Subsequent License Renewal Application, Environmental Report Supplement 2 L-2023-094, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-07-27027 July 2023 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 ML23178A1872023-07-25025 July 2023 Review of the Spring 2022 Steam Generator Tube Inspections During Refueling Outage No. 33 ML23188A1242023-07-20020 July 2023 Acknowledgment of Temporary Suspension Request for License Request for License Amendment Request Reactor Protection System, Engineered Safety Features System, and Nuclear Instrumentation System ML23200A0672023-07-18018 July 2023 Tp 2023 RQ Inspection Notification Letter ML23173A0812023-07-17017 July 2023 Supplement to Regulatory Audit Plan in Support of Review of License Amendment Request Supporting Digital Instrumentation & Control Modernization Project (EPID L-2022-LLA-0105) - Non-Proprietary L-2023-087, Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452)2023-06-29029 June 2023 Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452) 2024-02-05
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARIR 05000250/20240102024-01-0505 January 2024 Focused Engineering Inspection 05000250/2024010 and 05000251/2024010 ML23226A0752023-08-14014 August 2023 NRR E-mail Capture - Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - RCP LAR (L-2022-LLA-0128) ML23173A1522023-06-22022 June 2023 Request for Additional Information NextEra Fleet Emergency Plan Amendment Request ML23129A8322023-05-0505 May 2023 NRR E-mail Capture - Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - RCP LAR (L-2022-LLA-0128) ML23038A1892023-02-0303 February 2023 RP RFI April 2023 ML22311A5582022-11-22022 November 2022 Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment Request for Cep ML22311A4752022-11-0707 November 2022 NRR E-mail Capture - Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - ITS IR 05000250/20234012022-10-19019 October 2022 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000250/2023401 and 05000251/2023401 ML22255A0502022-09-15015 September 2022 Supplemental Information Needed for Acceptance of Requested Licensing Action License Amendment Request to Replace Instrumentation with Digital Systems ML22229A5332022-08-18018 August 2022 Notification of Target Set Inspection and Request for Information (NRC Inspection Report No. 05000250 2022402 and 05000251 2022402) ML22181A0562022-06-30030 June 2022 NRR E-mail Capture - Request for Additional Information - Turkey Point U3 Sgtir (L-2022-LRO-0070) ML22081A0292022-03-21021 March 2022 NRR E-mail Capture - Turkey Point Nuclear Generating Unit No. 3 - Request for Additional Information - Icw Alternative ML22068A2352022-03-17017 March 2022 Licensed Operator Positive Fitness-For-Duty Test ML22074A0932022-03-14014 March 2022 RP RFI March 2022 ML21342A2932021-12-21021 December 2021 Supplemental Information Needed for Acceptance of Requested License Amendment Request Concerning Technical Specification Conversion to NUREG-1431, Revision 5 ML21298A0572021-10-25025 October 2021 NRR E-mail Capture - Final: Tpn Request for Additional Information - Round 2 Concerning Relief Request 10 - Extension EPID: L-2021-LLR-0077 ML21291A1272021-10-14014 October 2021 NRR E-mail Capture - Request for Additional Information - Fifth Ten-Year Inservice Inspection Interval Relief Request No.10 - Extension (L-2021-LLR-0077) ML21270A1652021-09-27027 September 2021 NRR E-mail Capture - Turkey Point Request for Additional Information Concerning Full Spectrum LOCA Methodology - EPID L-2021-LLA-0070 ML21252A2142021-09-0101 September 2021 NRR E-mail Capture - Final: Turkey Point Units 3 and 4 - Request for Additional Information Concerning Relief Requests 8 and 9 ML21238A3282021-08-26026 August 2021 RP RFI October 2020 ML20315A0182020-11-10010 November 2020 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML20149K6262020-05-27027 May 2020 NRR E-mail Capture - Turkey Point Unit 4 - Request for Additional Information Concerning 2019 Steam Generator Tube Inspections ML20122A1172020-05-0101 May 2020 NRR E-mail Capture - Final: Turkey Point Units 3 and 4 Request for Additional Information Concerning Emergency Action Level Scheme Change (EPID L-2019-LLA-0271) (FPL: L-2019-203) ML20104B2232020-04-0909 April 2020 NRR E-mail Capture - Action: Turkey Point Unit 3 - Request for Additional Information Concerning Deferral of Steam Generator Inservice Inspections ML20084G5622020-03-20020 March 2020 NRR E-mail Capture - Turkey Point Containment Radiation Monitors Request for Additional Information ML20028C7372019-12-0202 December 2019 Notification of Inspection and Request for Information ML19184A1002019-07-0303 July 2019 NRR E-mail Capture - Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 266 ML19101A3312019-04-11011 April 2019 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 11 (EPID No. L-2018-RNW-0002) - Enclosure ML19087A2112019-03-28028 March 2019 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 10 (EPID No. L-2018-RNW-0002) - Enclosure ML19073A0042019-03-14014 March 2019 Safety RAIs - Set 10 - Draft ML19053A6122019-02-22022 February 2019 Response Date Extension for RAIs Set 8, Revision 1, for the Safety Review of the Turkey Point Subsequent License Renewal Application ML19037A3982019-02-0606 February 2019 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 9 (EPID No. L-2018-RNW-0002) - Enclosure ML19032A3972019-02-0101 February 2019 SLRA Request for Additional Information RAIs 3.5.2.2.2.6 Revision 1 Set 8 Final ML19016A2332019-01-16016 January 2019 NRR E-mail Capture - Request for Additional Information - Turkey Point LAR 265 PRA - NFPA RCP Seals - EPID L-2018-LLA-0280 ML18341A0042019-01-15015 January 2019 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 8 (EPID No. L-2018-RNW-0002) - E-Mail ML18341A0052019-01-15015 January 2019 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 8 (EPID No. L-2018-RNW-0002) - Enclosure ML18348A5852018-12-13013 December 2018 Emergency Preparedness Inspection and Request for Information ML18318A4332018-11-19019 November 2018 Supplemental Information Needed for Acceptance of License Amendment Request to Revise NFPA 805 License Condition for Reactor Coolant Pump Seals ML18292A7462018-10-31031 October 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application; Set 7 (EPID No. L-2018-RNW-0002) - Enclosure ML18269A2282018-10-0404 October 2018 Request for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 6 (EPID No. L-2018-RNW-0002) - Enclosure ML18269A2102018-10-0101 October 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 4 (EPID L-2018-RNW-0002) - Enclosure ML18243A0072018-09-17017 September 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 3 (EPID No. L-2018-RNW-0002) - Email ML18243A0062018-09-17017 September 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application; Set 3 (EPID No. L-2018-RNW-0002) - Enclosure 1 ML18259A0002018-09-17017 September 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application; Set 3 (EPID No. L-2018-RNW-0002) - Enclosure 2 ML18248A1592018-09-15015 September 2018 Requests for Additional Information for the Turkey Point Subsequent License Renewal Application - Environmental Set 3 (EPID No. L-2018-LNE-0001) - Email ML18248A1602018-09-15015 September 2018 Requests for Additional Information for the Turkey Point Subsequent License Renewal Application - Environmental Set 3 (EPID No. L-2018-LNE-0001) - Enclosure ML18232A5132018-08-20020 August 2018 SLRA Safety RAIs - Set 2 - RAIs ML18232A5142018-08-20020 August 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 2 ML18232A5462018-08-20020 August 2018 Safety RAIs - Set 2 - Draft ML18218A2002018-08-0606 August 2018 Requests for Additional Information for the Safety Review of the Turkey Point Subsequent License Renewal Application - Set 1 (EPID No. L-2018-RNW-0002) - Enclosure 2024-01-05
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 March 24, 2010 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
TURKEY POINT UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST TO ADOPT THE ALTERNATE SOURCE TERM (TAC NOS. ME1624 AND ME1625)
Dear Mr. Nazar:
By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term, as described in Title 10 of the Code of Federal Regulations, Part 50.67, following the guidance provided in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000.
The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and finds that the information contained in the enclosed Request for Additional Information is needed before we can complete the review. This was discussed with members of the FPL staff and, on March 1, 2010, Mr. Bob Tomonto indicated that a response would be provided within 30 days of the date of this letter.
If you have any questions, please contact me at (301) 415-5888.
rely, f--:-
ason 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:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNITS 3 AND 4 DOCKET NUMBERS 50-250 and 50-251 By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL, the licensee) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term (AST), as described in Title 10 of the Code of Federal Regulations (10 CFR), Part 50.67, following the guidance provided in Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000. To complete its review of the license amendment request (LAR), the Nuclear Regulatory Commission staff requests the following additional information.
- 1. The AST LAR Enclosure 1, Section 10.0 "References," Reference 6 cites "NEI 99-03, Control Room Habitability Guidance, Nuclear Energy Institute, Revision 0, June 2001 and Revision 1, March 2003." NEI 99-03, Revision 0, June 2001 is an acceptable reference, however, Revision 1 has not been reviewed and accepted by the Nuclear Regulatory Commission (NRC).
Provide additional information describing whether or not NEI 99-03, Revision 1 is being relied upon to support the assumptions or methods used in the AST submittal. If NEI 99-03 Revision 1 is being used to support the AST submittal, it will be necessary to submit NEI 99-03 Revision 1 on the docket with a request for NRC staff review. In addition, the licensee will be responsible for addressing questions that may result from that review and the review will have to be completed before the staff completes its review of the AST submittal. If NEI 99-03 Revision 1 is not being relied upon to support the AST submittal, and it is not the licensee's intention for the staff to review it, then it should be removed from the AST submittal as a reference.
- 2. On page 18 of 81 of Numeric Applications, Inc. (NAI)-1396-045 Rev 1, the second paragraph under item 5 states the following:
"The GOTHIC analysis utilized for Turkey Point to demonstrate the level of spray induced mixing in containment included both subdivided and lumped parameter models.
The detailed subdivided models were used to calculate flow patterns produced by the containment sprays and the emergency containment coolers. Gas concentrations from the subdivided models were compared with concentrations in the lumped parameter model and used to determine equivalent mixing flow rates for the lumped model."
Enclosure
-2 Provide the following additional information:
- a. Describe how many subdivided models were analyzed using GOTHIC, and the differences among each of the subdivided models.
- b. Provide a tabulation of the results (gas concentrations, flow rates) showing the differences within the subdivided models analyzed and show the comparison with results from the lumped parameter model.
- c. Describe how the equivalent mixing flow rates for the lumped model were determined.
- d. Describe the relationship between the equivalent mixing flow rates that were determined for the lumped model with the mixing flow rates in the subdivided models.
- 3. Provide additional information to ensure that the cool-down times assumed in the main steam line break (MSLB), the steam generator tUbe rupture (SGTR), locked rotor (LRA) and rod cluster control assembly (RCCA) ejection accident analyses can be achieved by exclusive reliance on safety-grade equipment.
- 4. For each of the affected accident analyses, MSLB, SGTR LRA and RCCA, provide additional information to describe the basis for the determination of the potential for 30 minutes of steam generator tube bundle uncovery and a description of the actions required to recover the bundles.
- 5. For the fuel-handling accident, gap fractions from NUREG/CR-5009 were used, which are approximately twice those of RG 1.183 to account for high burn-up fuel not meeting the limits described in Footnote 11. In addition, the gap fractions from Table 3 of RG 1.183 were used without the use of any stated correction factors in the evaluation of the LRA and RCCA ejection accident analyses.
Provide additional information, including the basis, describing whether or not correction factors were used to adjust the gap fractions from Table 3 of RG 1.183 to account for high burn-up fuel in the LRA and the RCCA ejection accident analyses.
- 6. LAR Attachment 3, NAI-1396-045 Rev. 1, Table 1.6.3-1 lists the unfiltered make-up flow rate and inleakage as 1000 cubic feet per minute (cfm) during the normal mode of operation. For the waste gas decay tank rupture, Table 2.7.1 lists the unfiltered inleakage as 115 cfm and the makeup flow rate as 1000 cfm for the non-isolated control room implying that the total air exchange would be calculated using 1115 cfm.
Provide additional information to clarify the assumed total air exchange rate for the control room during normal operation.
- 7. TS bases section 3/4.4.5, Applicable Safety Analysis, states that, "No credit for iodine removal is taken for any steam released to the condenser prior to reactor trip and concurrent loss of offsite power." This statement appears to be in conflict with the revised AST analyses crediting a partition factor of 100 for releases through the condenser prior to reactor trip.
-3 Provide additional information to clarify whether or not the revised AST analyses credit a partition factor of 100 for releases through the condenser prior to reactor trip.
- 8. The licensee has proposed TS changes to revise limiting condition of operation (LCO) 3.4.8, "RCS [Reactor Coolant System] Specific Activity," APPLICABILITY requirements to specify that the LCO is applicable in MODES 1, 2, 3, and 4 removing MODE 5 from the APPLICABILITY. The licensee asserts and the NRC staff agrees that:
"In MODE 5 with the RCS loops filled, the SGs [steam generators] are specified as a backup means of decay heat removal via natural circulation. In this mode, however, due to the reduced temperature of the RCS, the probability of a design basis accident [DBA] involving the release of significant quantities of RCS inventory is greatly reduced.
Therefore, monitoring of RCS specific activity is not required. In MODE 5 with the RCS loops not filled, the SGs are not used for decay heat removal; the RCS and SGs are depressurized and primary to secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required. The change to modify the TS 3.4.8 Applicability to include only MODES 1 through 4 retains the necessary constraints to limit the potential radiological consequences of a SGTR or MSLB that may occur during these MODES and is therefore acceptable from a radiological dose perspective."
The cited discussion provides the basis for not requiring the monitoring of RCS specific activity in MODE 5; however the implication is that the monitoring of RCS specific activity is required in MODES 1 though 4. The NRC staff notes that the TS Table 4.4-4 specifies that the sample and analyses required to demonstrate compliance with LCO 3.4.8 are only required to be performed in MODE 1. After transient conditions (Le., reactor trip, plant depressurization, shutdown or startup) that end in MODES 2,3, or 4, the surveillance is not required to be performed. Isotopic spiking and fuel failures are more likely during transient conditions than during steady state plant operations.
Provide additional information to justify why there is an apparent disparity between the modes of applicability (MODES 1, 2, 3, and 4) and the limited mode (MODE 1) under which the surveillance for TS 3.4.8 is required.
- 9. LAR Attachment 3, NAI-1396-045 Rev. 1, Table 1.7.2-1 does not contain values for Xe 135m or Xe-138, which are needed for staff verification of the proposed limiting value of DEX-133.
Provide additional information documenting the values used to support the proposed limiting value of DEX-133 as well as the basis for their selection.
- 10. What are the heights above ground of all wind direction, wind speed and temperature difference measurements used in the analysis to support the June 25, 2009, AST LAR.
Page 15 of Attachment 3 to the LAR states that wind speeds are measured at a height of 11.58 meters above ground. Page 16 cites a 10 meter wind speed. Were all measurements made on a single tower and the reference to 10 meters is simply a convenient approximation to data measured at 11.58 meters? NRC staff noted a
- 4 relatively lower occurrence of winds from the north northeast direction than from the north and easterly directions between 2003 and 2007. To what may this be attributed?
Provide a drawing or provide a reference to an existing docketed drawing, which shows the location of the Turkey Point meteorological tower(s) with respect to plant structures and site features.
- 11. Provide additional information describing how the Turkey Point 2003 through 2007 meteorological data were measured, processed, and selected to ensure that the data were appropriate for input into the ARCON96 and PAVAN computer codes. During the 5-year period, highlight any changes in the way in which the data were measured, processed, or selected for inclusion in the files and discuss why the changes were made. Identify each resultant temporal subset that comprises a homogeneous measurement, process, or selection grouping.
The following specific areas should be addressed further.
- a. FPL provided two sets of ARCON96 hourly meteorological data files for 2005 and 2006. Files were sent by letter dated July 21, 2009 (e-mail confirmation of receipt dated March 8, 2010, ADAMS Accession No. ML100680672) as part of the current LAR. In addition, files for the same 2-year period were subsequently submitted as part of another, unrelated, LAR by letter dated August 7, 2009 (ML092250585). There appears to be some differences between the two sets of files for the 2005 and 2006 data. Clarify the basis for the apparent differences, which are particularly apparent with respect to the atmospheric stability categorization. Are both sets of data measured at the same location and categorized by temperature difference with height measurements only? In addition, the data provided by letter dated August 7,2009, were for 2002,2005, and 2006, while the data provided previously by letter dated July 21, 2009, for the current LAR is for the period 2003 through 2007. Provide justification that the 2003 through 2007 data are appropriate for use in the current LAR.
- b. While the yearly data recovery rate by parameter is generally above 90 percent as recommended by RG 1.23, Rev. 0, "Onsite Meteorological Programs," the recovery rate in 2007 for the upper level wind direction appears to be in the upper 60 percentile. Discuss the impact of this lower recovery rate on calculation of the atmospheric dispersion factors (X/Q values).
- c. The occurrence of atmospheric stability category A in 2004 appears to be approximately 22.5 percent and in the following year, 2005, approximately 4.5 percent. During the other three years, the value ranged between about 6 and 9 percent. To what is this variability attributed?
- 12. Provide one or more scaled figures with all postulated sources and receptors highlighted from which distance and direction inputs can be approximated. Provide the scale of the figure. Explain whether distance inputs into the ARCON96 calculations were directly estimated as horizontal straight line distances. If the distances were not estimated directly as straight line horizontal distances, explain how they were determined. Did the procedure used to estimate the distances account for differences in heights between each source and receptor pair? Were any sources modeled as diffuse releases?
-5
- 13. Provide additional information on the following. Table 1.8.1-1 of Attachment 3 suggests that Unit 4 and the southeast emergency intake are more limiting than releases from Unit 3 or to the northeast emergency intake. Provide the basis for this determination (i.e., were calculations made to qualitatively confirm this?). Page 2 of PTN-ENG-SENS02-052, Rev. 2, "Release/Receptor Combination Table," appears to provide a more inclusive list of potential source and receptor pairs. However, some of the values in the PTN table do not match those in Table 1.8.1-1. Further, the PTN table refers to east and west emergency intakes, whereas references in the proposed revision to the TS and in Attachment 3 refer to southeast and northeast intakes. Does the phrase "credit for dilution allowed" refer to the assumed cross sectional building area of 1254 m2? Provide discussion on why the 4.8 meters from the plant stack to the east emergency intake provided in the PTN table was not the limiting pair?
- 14. Is the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> temperature swing discussed on page 16 of Attachment 3 the difference between daily maximum and minimum temperatures? How does this swing vary by time of year? Given that the accident is assumed to be of 30-day duration, why should an annual average value be used rather than a more limiting value such as that for the limiting 30-day period? How is the swing temperature used in the calculation?
- 15. Page 16 of Attachment 3 discusses the 95th percentile wind speed with respect to calculations for assumed releases from the main steam safety valves (MSSVs) and atmospheric dump valves (ADVs). Per RG 1.194, "Atmospheric Relative Concentrations for Control Room Radiological Habitability Assessments at Nuclear Power Plants,"
provide an example of how the wind speed adjustment was calculated to demonstrate that the effluent velocity is at least five times higher than the 95th percentile wind speed.
How was the effluent velocity determined for the MSSVs and ADVs and how does it vary as a function of time? Confirm that the effluent release is uncapped and in a vertical upward direction.
- 16. Regarding the DBAs analyzed in support of this LAR, please confirm that the generated X/a values model the limiting doses and that all credible potential release scenarios were considered, including those due to loss of offsite power or other single failures.
- 17. What wind speed values were used in developing the joint frequency distributions (JFDs) used as input to the PAVAN computer code calculations? For example, if two consecutive categories are defined as 1-3 miles per hour (mph) and 4-7 mph, what is the value used to define the upper limit of the lower category (e.g., 3 mph, 3.5 mph, 4 mph)?
- 18. The choice of wind speed categories used in the PAVAN calculations appears to result in some clustering of the data in the lower categories. This may affect the resultant X/a value estimates generated by the PAVAN computer code. NRC Regulatory Issues Summary (RIS) 2006-4, "Experience with Implementation of Alternative Source Terms,"
states that input to PAVAN should have a large number of wind speed categories at the lower wind speeds in order to produce the best results. Provide a supplement to Section 4, "Atmospheric Dispersion," of Attachment 6 to provide justification for the selection of wind speed categories used in PAVAN calculations considering the recommendation in RIS 2006-4.
-6
- 19. Page 16 of Attachment 3 states several conversions were performed to the JFD to result in the file provided in support of the LAR. Provide further discussion of how the ~IFD was developed in comparison to the hourly data files provided in the ARCON96 format.
Other than the JFD, provide a consolidated list of all inputs and assumptions used in the PAVAN calculations. A copy of the summary pages of the PAVAN outputs is acceptable to show inputs.
- 20. For TS 3/4.7.5 "Control Room Emergency Ventilation System," the action statement for modes 1, 2, 3, and 4 states, "with the Control Room Emergency Ventilation System inoperable, suspend all movement of fuel in the spent fuel pool and restore the inoperable system to OPERABLE status within 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> ..." Provide a discussion describing what action will be taken to mitigate the consequences of a DBA that may occur during the 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> when the system is inoperable. The discussion should include details describing how compliance with Appendix A to 10 CFR Part 50 GDC 19, "Control Room" will be maintained. The discussion should also state whether the 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> are factored into the calculated dose of the licensing basis analyses of DBA consequences.
March 24, 2010 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
TURKEY POINT UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST TO ADOPT THE ALTERNATE SOURCE TERM (TAC NOS. ME1624 AND ME1625)
Dear Mr. Nazar:
By letter dated June 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092050277), Florida Power and Light Company (FPL) requested an amendment to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point, Units 3 and 4. The proposed changes would revise the Turkey Point licensing bases to adopt the alternative source term, as described in Title 10 of the Code of Federal Regulations, Part 50.67, following the guidance provided in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000.
The U.S. Nuclear Regulatory Commission staff has reviewed your submittal and finds that the information contained in the enclosed Request for Additional Information is needed before we can complete the review. This was discussed with members of the FPL staff and, on March 1, 2010, Mr. Bob Tomonto indicated that a response would be provided within 30 days of the date of this letter.
If you have any questions, please contact me at (301) 415-5888.
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:
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsOgcRp RidsNrrDorlDpr LPL2-2 R1F RidsAcrsAcnw_MailCTR Resource RidsNrrDraAadb RidsNrrPMTurkey Point RidsRgn2MailCenter KMiller, NRR RidsNrrLABClayton (Hard Copy) RidsNrrDorlLpl2-2 RidsNrrDssScvb ADAMS Accession Number' ML100700446 NRR-088 SCVB/BC OFFICE LPL2-2/PM LPL2-2/LA MDB/BC LPL2-2/BC(A)
NAME JPaige BClayton RDennig* TTate* DBroaddus DATE 03/12/10 03/11/10 02/03/2010 02/3/2010 03/24/10
- vla memo OFFICIAL RECORD COPY