ML15314A492

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NRC-014 - Letter from Michael Kiley, Florida Power & Light, to N.R.C., Response to Containment and Ventilation Branch Request for Additional Information, Regarding License Amendment Request No. 231 (Application to Revise Ultimate Heat Sink
ML15314A492
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 07/24/2014
From:
NRC/OGC
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-250-LA, 50-251-LA, ASLBP 15-935-02-LA-BD01, RAS 28491
Download: ML15314A492 (10)


Text

0FPL10 CFR 50.90L-2014-236July 24, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251Renewed Facility Operating License Nos. DPR-31 and DPR-41

Subject:

Response to Containment and Ventilation Branch Request for AdditionalInformation, Regarding License Amendment Request No. 231, Application to ReviseUltimate Heat Sink Temperature Limit

References:

1. Florida Power & Light Company Letter L-2014-216, "License Amendment Request No.231, Application to Revise Technical Specifications to Revise Ultimate Heat SinkTemperature Limit," July 10, 2014.2. Florida Power & Light Company Letter L-2014-226, "License Amendment Request No.231, Application to Revise Ultimate Heat Sink Temperature Limit -Request forEmergency Approval," July 17, 2014.3. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Requestfor Additional Information -LAR 231 (TAC MF4392 and MF4393)," July 22, 2014.In Reference 1, Florida Power & Light Company (FPL) requested an amendment to theTechnical Specifications (TS) for the Turkey Point Nuclear Plant (Turkey Point), Units 3 and 4.The proposed amendment would revise the ultimate heat sink (UHS) water temperature limitfrom I100°F to 104'F.In Reference 2, FPL supplemented the July 10, 2014 application requesting the U.S. NuclearRegulatory Commission (NRC) to review and approve it on an emergency basis.In Reference 3, the NRC Containment and Ventilation Branch (SCVB) staff requested additionalinformation (RAI). The enclosure to this letter provides the FPL response to the RAI.Florida Power & Light Company 009760 SW 344th St.. Florida City, FL 33035 Florida Power & Light CompanyLicense Amendment Request No. 231Response to SCVB Request for Additional InformationL-2014-236Page 2 of 2The additional information provided in the enclosure to this letter does not impact the nosignificant hazards determination and environmental considerations previously provided inReference 1.There are no new commitments made in this submission.If you have any questions or require additional information, please contact Mr. Robert Tomontoat 305-246-7327.I declare under penalty of perjury that the foregoing is true and correct.Executed on: July 24, 2014.Very truly yours,Michael KileyVice PresidentTurkey Point Nuclear Plant

Enclosure:

Response to Request for Additional Information Regarding LAR No. 231, Applicationto Revise Ultimate Heat Sink Temperature Limitcc: USNRC Regional Administrator, Region IIUSNRC Project Manager, Turkey Point Nuclear PlantUSNRC Senior Resident Inspector, Turkey Point Nuclear PlantMs. Cindy Becker, Florida Department of Health Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 1 of 8Response to Request for Additional Information from theContainment and Ventilation Branch RegardingTurkey Point Units 3 and 4License Amendment Request No. 231Application to Revise Ultimate Heat Sink Temperature LimitEnclosure Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 2 of 8BackgroundBy letter dated July 10, 2014, as supplemented by letter dated July 17, 2014, Florida Power &Light Company (FPL) submitted a license amendment request (LAR) for the Turkey PointNuclear Generating Station Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to theTurkey Point Technical Specifications (TS), Section 3/4.7.4, "Ultimate Heat Sink."The U.S. Nuclear Regulatory Commission's (NRC) Containment and VentilationBranch (SCVB) staff reviewed the information provided and determined that additionalinformation is needed to complete the review. The NRC staff request for additional information(RAI) and the FPL response follows.SCVB RAI-1The LAR does not clearly describe changes in the current methodology for analyzing thecomponent cooling water (CCW) supply cooling water temperature to the emergencycontainment coolers (ECCs) and residual heat removal (RHR) heat exchanger (HX). In therevision of the Turkey Point Updated Final Safety Analysis Report (UFSAR) datedApril 17, 2013, page 14.3.4-25, under the heading, "Noding Structure," the last sentence states:"The recirculation system model uses GOTHIC component models for theresidual heat removal and component cooling water heat exchangers and pumps.Recirculation flow from the sump is modeled as a boundary condition. "Page 13 of 17 of the LAR enclosure (under the heading, "Safety Analysis Scenarios,") states:"The calculation for CCW heat exchanger performance was revised using theHX3/HX4 computer program to demonstrate that the CCW heat exchangers canremove the necessary post-accident containment heat load for the LOCA andMSLB containment integrity analyses. "A. Does the HX3/HX4 computer program replace the currently used GOTHIC methodologyin the current licensing basis analysis? If so, please describe in detail how the HX3/HX4computer program replaces the GOTHIC modeling to determine the revised CCW supplytemperature to the ECCs and RHR HX, while considering the limiting values of all of thepost-accident CCW HX heat loads. Please include the analysis inputs and assumptionsused in the revised method justifying their conservatisms.FPL ResponseNo, the HX3/HX4 program does not replace the GOTHIC methodology to analyzecontainment for any over pressurization accident analysis (MSLB and LOCA). The Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 3 of 8GOTHIC containment model described in the UFSAR is one integrated model that includesthe component models for CCW pumps, CCW heat exchangers and RHR system.Furthermore, no inputs, assumptions, or changes of any kind are required or have beenmade to the containment analysis as the result of the proposed increase to the allowableultimate heat sink (UHS) temperature. The current UFSAR methodology remains theGOTHIC analysis currently described in the UFSAR. All results (reported containmentpressure, CCW supply / return temperatures, CCW heat removal capability, andcontainment building sump temperatures) remain unchanged from the results currentlydescribed in the UFSAR.UFSAR Table 14.3.4.3-1, "Containment Analysis Parameters," currently states the intakecooling water (ICW) (UHS) temperature used for containment integrity is 1 00'F. TheCCW heat exchanger heat removal capability is defined by the combination of the ICWtemperature and the tube fouling factor (or tube resistance). The input values contained inthe accident analysis calculations are I 00°F ICW temperature and a corresponding 0.0030hr-ft2Z-OF/BTU CCW heat exchanger fouling factor. The same heat exchanger heat removalcapability assumed in the accident analysis can be assured with a higher ICW temperatureby maintaining a lower tube fouling factor. The HX3/HX4 computer program is used aspart of the CCW heat exchanger surveillance and testing procedures to maintain thenecessary level of cleanliness (below the administrative limit) to satisfy the required heatremoval capability of the CCW heat exchangers. As can be seen, this value for the tubefouling factor assumed in the accident analysis is higher than the tube fouling factorallowed by the "HX3/HX4 Program Line" shown in the application (FPL letter L-2014-216) Figure 3.5-1 (included below as SCVB RAI-1 Figure 1). The surveillance andmaintenance of the CCW heat exhangers assures that their heat removal capability remainsconservatively bounding of that assumed in the safety analysis over a range of allowableUHS temperatures and associated tube resistance.Figure 3.5-1 in the July 10, 2014 FPL application has a typographical error for the tuberesistance at I 00°F on the HX3/HX4 program line. SCVB RAI- 1 Figure 1 replaces Figure3.5-1. Additionally, the figure has been updated to provide additional clarifyinginformation to assist the NRC staff in understanding the current analyses of record and theanalyses performed for the RAI response. Specifically, the original point labeled as safetyanalyses is clarified to reflect that it is the AFT Fathom thermal-hydraulic model. Theassumptions used in the GOTHIC analysis of record and the GOTHIC sensitivity studies inthe response to this RAI are also included.

Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 4 of 8SCVB RAI-1 Figure 1Tube Resistance LimitsM.0050.0030.0020.0020.0010.002581100"F Umit0.002292104"F Umlt70 75 80 85 90 95 100 105 110ICW Temp (OF)B. Using the current GOTHIC model and the proposed ICW water temperature of 104TF asinput, provide the CCW supply water temperature profiles to the ECCs and RHR HX forthe limiting Double-Ended Pump Suction (DEPS) and Double-Ended Hot Leg (DEHL)Break Loss-of-Coolant Accidents (LOCAs) and Main Steam Line Break (MSLB)accident, and provide the CCW peak temperature values. The analysis should beperformed using the same inputs as in the current analysis, i.e., assuming the worst safetyrelated equipment heat loads, while using the proposed improved CCW HX tuberesistance. If any of the remaining inputs are revised, please justify.FPL ResponseTo provide additional assurance that the accident analysis is not affected, two sensitivitycases were run to demonstrate the impact of a UHS temperature increase with acorresponding reduction in heat exchanger tube resistance (0.002714 hr-ft2 -F/BTU).The results presented below provide the results for the maximum CCW supplytemperature cases for LOCA (DEPS) and MSLB comparing the results from the current Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 5 of 8design basis (100°F UHS temperature with a 0.003 hr-ft2 -F/BTU tube resistance) to thesensitivity case (104'F UHS temperature with a 0.002714 hr-ft2-°F/BTU tube resistance).No other inputs were changed other than UHS temperature and tube resistance.The CCW temperature profile for the DEHL break is not provided since this is not thelimiting event for containment integrity and is analyzed only to the end of blowdown (25seconds) and poses no challenge to CCW heat removal capability. The conclusions fromthe results for the DEPS break discussed below are applicable to the DEHL.LOCA (DEPS) CCW Maximum Supply Temperature GOTHIC CaseSCVB RAI- 1 Figure 2 presents the CCW supply temperature profile for LOCA.Although there are small temperature differences this temperature profile demonstratesthe CCW heat removal performance remains essentially the same at 1040F ICWtemperatures when the tube resistance is reduced to 0.002714 hr-ft2-°F/BTU.SCVB RAI-1 Figure 2CCW10OF ICW104F ICW170,, 160 ..............16 --- iER 140 ..........130Supply Temperature0 2000 4000 6000 8000Time (sec)10000 Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 6 of 8Additionally, since the licensing basis GOTHIC model is an integrated thermal hydraulic modeladditional containment parameters are available from this sensitivity case run. Peak containmentpressure and temperature results are included with the peak CCW temperature in the table below.ICW Temperature (°F) 100 104Peak Containment Pressure (psig) 50.61 50.61Peak Containment Temperature (°F) 275.8 275.8Peak Sump Temperature (°F) 236.6 236.6Peak CCW supply Temperature (°F) 158.6 158.5As shown, there is no significant change in the peak values. Note, the inputs used for this caseensure CCW supply temperatures are maximized; however, this will result in a lowercontainment pressure because more heat is removed from containment and transferred into theCCW system. Nevertheless, a similar insignificant impact is expected for the UFSAR limitingcontainment response licensing basis analysis.MSLB Maximum CCW Supplv Temperature CaseSCVB RAI-1 Figure 3 presents the CCW supply temperature profile for MSLB. Although thereare small temperature differences this temperature profile demonstrates the CCW heat removalperformance remains essentially the same at 104'F ICW temperatures when the tube resistance isreduced to 0.002714 hr-ft2-F/BTU.

Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 7 of 8SCVB RAI-1 Figure 3SLB: CCW100 degF ICW104 degF ICW1601,50-i-I140120 /.E .~/ -Supply TemperatureTemperatureTemperature0 200 400 600Time (sec)For consistency we are also providing the respective peak containment pressure and temperatureresults corresponding to this case. They are included with the peak CCW temperature in thetable below.ICW Temperature (OF) 100 104Peak Containment Pressure (psig) 53.14 53.16Peak Containment Temperature (°F) 279.0 279.0Peak CCW supply Temperature (°F) 152.7 153.1Similarly, these results also demonstrate negligible changes between the reported results fromthe analysis of record.ConclusionIncreasing the ICW temperature to 1040F while reducing the CCW heat exchanger fouling factorto 0.002714 hr-ft2-OF/BTU provides insignificant changes to the containment peak pressure and Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 8 of 8containment peak saturation temperatures. The results have either the same or slight changes-some up, some down-from the previously reported results. These minor temperature changesprovide essentially no impact to the containment peak pressure and peak temperature response.It is concluded that small temperature variations within the CCW supply water have aninsignificant impact on the containment response. The ICW temperature increase / reducedfouling factor tradeoff results in CCW heat removal performance that is essentially the same,providing an acceptable response for the GOTHIC containment model. Therefore, the currentresults provided in the UFSAR remain valid for the increase in ICW temperature to 104'F.SCVB RAI-2The Turkey Point UFSAR Revision dated April 17, 2013, Sectionl4.3.4.3.3, "Description ofAnalysis," states that the containment response for a LOCA or MSLB accident is performedusing GOTHIC computer code. The UFSAR Table 14.3.4.3-1, "Containment AnalysisParameters," provided the intake cooling water (ICW) temperature used for containmentintegrity as 1 00TF, which is proposed to be revised to 104'F as an input to the analysis. TheTable does not explicitly state the assumed value of the CCW supply water temperature to theEECs and RHR HX in the GOTHIC analysis.Please confirm that based on the proposed ICW temperature of 104TF, and the revised worstvalue of the CCW supply water temperature (to be stated in response to this RAI) to RHR HXand ECCs, all current containment analyses for containment peak pressure and temperatureresponse and for containment heat removal are not affected and will remain as the licensingbasis.FPL ResponseAs stated in the response to SCVB RAI-1, these sensitivities validate that containment responsewould result in an insignificant change to the results presented in the UFSAR. The results of thesensitivity analysis show that the use of 104'F ICW temperature with a reduced fouling factor of0.002714 hr-ft2-F/BTU has an insignificant impact on the peak calculated containment pressure,and containment temperature. Thus, CCW heat removal performance remains essentially thesame at the 104°F ICW temperature when the fouling factor is reduced to 0.002714 hr-ft -°F/BTU. The current containment analyses for containment peak pressure, temperature and heatremoval are not affected and will remain as the licensing basis.

0FPL10 CFR 50.90L-2014-236July 24, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251Renewed Facility Operating License Nos. DPR-31 and DPR-41

Subject:

Response to Containment and Ventilation Branch Request for AdditionalInformation, Regarding License Amendment Request No. 231, Application to ReviseUltimate Heat Sink Temperature Limit

References:

1. Florida Power & Light Company Letter L-2014-216, "License Amendment Request No.231, Application to Revise Technical Specifications to Revise Ultimate Heat SinkTemperature Limit," July 10, 2014.2. Florida Power & Light Company Letter L-2014-226, "License Amendment Request No.231, Application to Revise Ultimate Heat Sink Temperature Limit -Request forEmergency Approval," July 17, 2014.3. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Requestfor Additional Information -LAR 231 (TAC MF4392 and MF4393)," July 22, 2014.In Reference 1, Florida Power & Light Company (FPL) requested an amendment to theTechnical Specifications (TS) for the Turkey Point Nuclear Plant (Turkey Point), Units 3 and 4.The proposed amendment would revise the ultimate heat sink (UHS) water temperature limitfrom I100°F to 104'F.In Reference 2, FPL supplemented the July 10, 2014 application requesting the U.S. NuclearRegulatory Commission (NRC) to review and approve it on an emergency basis.In Reference 3, the NRC Containment and Ventilation Branch (SCVB) staff requested additionalinformation (RAI). The enclosure to this letter provides the FPL response to the RAI.Florida Power & Light Company 009760 SW 344th St.. Florida City, FL 33035 Florida Power & Light CompanyLicense Amendment Request No. 231Response to SCVB Request for Additional InformationL-2014-236Page 2 of 2The additional information provided in the enclosure to this letter does not impact the nosignificant hazards determination and environmental considerations previously provided inReference 1.There are no new commitments made in this submission.If you have any questions or require additional information, please contact Mr. Robert Tomontoat 305-246-7327.I declare under penalty of perjury that the foregoing is true and correct.Executed on: July 24, 2014.Very truly yours,Michael KileyVice PresidentTurkey Point Nuclear Plant

Enclosure:

Response to Request for Additional Information Regarding LAR No. 231, Applicationto Revise Ultimate Heat Sink Temperature Limitcc: USNRC Regional Administrator, Region IIUSNRC Project Manager, Turkey Point Nuclear PlantUSNRC Senior Resident Inspector, Turkey Point Nuclear PlantMs. Cindy Becker, Florida Department of Health Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 1 of 8Response to Request for Additional Information from theContainment and Ventilation Branch RegardingTurkey Point Units 3 and 4License Amendment Request No. 231Application to Revise Ultimate Heat Sink Temperature LimitEnclosure Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 2 of 8BackgroundBy letter dated July 10, 2014, as supplemented by letter dated July 17, 2014, Florida Power &Light Company (FPL) submitted a license amendment request (LAR) for the Turkey PointNuclear Generating Station Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to theTurkey Point Technical Specifications (TS), Section 3/4.7.4, "Ultimate Heat Sink."The U.S. Nuclear Regulatory Commission's (NRC) Containment and VentilationBranch (SCVB) staff reviewed the information provided and determined that additionalinformation is needed to complete the review. The NRC staff request for additional information(RAI) and the FPL response follows.SCVB RAI-1The LAR does not clearly describe changes in the current methodology for analyzing thecomponent cooling water (CCW) supply cooling water temperature to the emergencycontainment coolers (ECCs) and residual heat removal (RHR) heat exchanger (HX). In therevision of the Turkey Point Updated Final Safety Analysis Report (UFSAR) datedApril 17, 2013, page 14.3.4-25, under the heading, "Noding Structure," the last sentence states:"The recirculation system model uses GOTHIC component models for theresidual heat removal and component cooling water heat exchangers and pumps.Recirculation flow from the sump is modeled as a boundary condition. "Page 13 of 17 of the LAR enclosure (under the heading, "Safety Analysis Scenarios,") states:"The calculation for CCW heat exchanger performance was revised using theHX3/HX4 computer program to demonstrate that the CCW heat exchangers canremove the necessary post-accident containment heat load for the LOCA andMSLB containment integrity analyses. "A. Does the HX3/HX4 computer program replace the currently used GOTHIC methodologyin the current licensing basis analysis? If so, please describe in detail how the HX3/HX4computer program replaces the GOTHIC modeling to determine the revised CCW supplytemperature to the ECCs and RHR HX, while considering the limiting values of all of thepost-accident CCW HX heat loads. Please include the analysis inputs and assumptionsused in the revised method justifying their conservatisms.FPL ResponseNo, the HX3/HX4 program does not replace the GOTHIC methodology to analyzecontainment for any over pressurization accident analysis (MSLB and LOCA). The Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 3 of 8GOTHIC containment model described in the UFSAR is one integrated model that includesthe component models for CCW pumps, CCW heat exchangers and RHR system.Furthermore, no inputs, assumptions, or changes of any kind are required or have beenmade to the containment analysis as the result of the proposed increase to the allowableultimate heat sink (UHS) temperature. The current UFSAR methodology remains theGOTHIC analysis currently described in the UFSAR. All results (reported containmentpressure, CCW supply / return temperatures, CCW heat removal capability, andcontainment building sump temperatures) remain unchanged from the results currentlydescribed in the UFSAR.UFSAR Table 14.3.4.3-1, "Containment Analysis Parameters," currently states the intakecooling water (ICW) (UHS) temperature used for containment integrity is 1 00'F. TheCCW heat exchanger heat removal capability is defined by the combination of the ICWtemperature and the tube fouling factor (or tube resistance). The input values contained inthe accident analysis calculations are I 00°F ICW temperature and a corresponding 0.0030hr-ft2Z-OF/BTU CCW heat exchanger fouling factor. The same heat exchanger heat removalcapability assumed in the accident analysis can be assured with a higher ICW temperatureby maintaining a lower tube fouling factor. The HX3/HX4 computer program is used aspart of the CCW heat exchanger surveillance and testing procedures to maintain thenecessary level of cleanliness (below the administrative limit) to satisfy the required heatremoval capability of the CCW heat exchangers. As can be seen, this value for the tubefouling factor assumed in the accident analysis is higher than the tube fouling factorallowed by the "HX3/HX4 Program Line" shown in the application (FPL letter L-2014-216) Figure 3.5-1 (included below as SCVB RAI-1 Figure 1). The surveillance andmaintenance of the CCW heat exhangers assures that their heat removal capability remainsconservatively bounding of that assumed in the safety analysis over a range of allowableUHS temperatures and associated tube resistance.Figure 3.5-1 in the July 10, 2014 FPL application has a typographical error for the tuberesistance at I 00°F on the HX3/HX4 program line. SCVB RAI- 1 Figure 1 replaces Figure3.5-1. Additionally, the figure has been updated to provide additional clarifyinginformation to assist the NRC staff in understanding the current analyses of record and theanalyses performed for the RAI response. Specifically, the original point labeled as safetyanalyses is clarified to reflect that it is the AFT Fathom thermal-hydraulic model. Theassumptions used in the GOTHIC analysis of record and the GOTHIC sensitivity studies inthe response to this RAI are also included.

Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 4 of 8SCVB RAI-1 Figure 1Tube Resistance LimitsM.0050.0030.0020.0020.0010.002581100"F Umit0.002292104"F Umlt70 75 80 85 90 95 100 105 110ICW Temp (OF)B. Using the current GOTHIC model and the proposed ICW water temperature of 104TF asinput, provide the CCW supply water temperature profiles to the ECCs and RHR HX forthe limiting Double-Ended Pump Suction (DEPS) and Double-Ended Hot Leg (DEHL)Break Loss-of-Coolant Accidents (LOCAs) and Main Steam Line Break (MSLB)accident, and provide the CCW peak temperature values. The analysis should beperformed using the same inputs as in the current analysis, i.e., assuming the worst safetyrelated equipment heat loads, while using the proposed improved CCW HX tuberesistance. If any of the remaining inputs are revised, please justify.FPL ResponseTo provide additional assurance that the accident analysis is not affected, two sensitivitycases were run to demonstrate the impact of a UHS temperature increase with acorresponding reduction in heat exchanger tube resistance (0.002714 hr-ft2 -F/BTU).The results presented below provide the results for the maximum CCW supplytemperature cases for LOCA (DEPS) and MSLB comparing the results from the current Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 5 of 8design basis (100°F UHS temperature with a 0.003 hr-ft2 -F/BTU tube resistance) to thesensitivity case (104'F UHS temperature with a 0.002714 hr-ft2-°F/BTU tube resistance).No other inputs were changed other than UHS temperature and tube resistance.The CCW temperature profile for the DEHL break is not provided since this is not thelimiting event for containment integrity and is analyzed only to the end of blowdown (25seconds) and poses no challenge to CCW heat removal capability. The conclusions fromthe results for the DEPS break discussed below are applicable to the DEHL.LOCA (DEPS) CCW Maximum Supply Temperature GOTHIC CaseSCVB RAI- 1 Figure 2 presents the CCW supply temperature profile for LOCA.Although there are small temperature differences this temperature profile demonstratesthe CCW heat removal performance remains essentially the same at 1040F ICWtemperatures when the tube resistance is reduced to 0.002714 hr-ft2-°F/BTU.SCVB RAI-1 Figure 2CCW10OF ICW104F ICW170,, 160 ..............16 --- iER 140 ..........130Supply Temperature0 2000 4000 6000 8000Time (sec)10000 Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 6 of 8Additionally, since the licensing basis GOTHIC model is an integrated thermal hydraulic modeladditional containment parameters are available from this sensitivity case run. Peak containmentpressure and temperature results are included with the peak CCW temperature in the table below.ICW Temperature (°F) 100 104Peak Containment Pressure (psig) 50.61 50.61Peak Containment Temperature (°F) 275.8 275.8Peak Sump Temperature (°F) 236.6 236.6Peak CCW supply Temperature (°F) 158.6 158.5As shown, there is no significant change in the peak values. Note, the inputs used for this caseensure CCW supply temperatures are maximized; however, this will result in a lowercontainment pressure because more heat is removed from containment and transferred into theCCW system. Nevertheless, a similar insignificant impact is expected for the UFSAR limitingcontainment response licensing basis analysis.MSLB Maximum CCW Supplv Temperature CaseSCVB RAI-1 Figure 3 presents the CCW supply temperature profile for MSLB. Although thereare small temperature differences this temperature profile demonstrates the CCW heat removalperformance remains essentially the same at 104'F ICW temperatures when the tube resistance isreduced to 0.002714 hr-ft2-F/BTU.

Florida Power & Light CompanyResponse to SCVB Request for Additional InformationL-2014-236EnclosurePage 7 of 8SCVB RAI-1 Figure 3SLB: CCW100 degF ICW104 degF ICW1601,50-i-I140120 /.E .~/ -Supply TemperatureTemperatureTemperature0 200 400 600Time (sec)For consistency we are also providing the respective peak containment pressure and temperatureresults corresponding to this case. They are included with the peak CCW temperature in thetable below.ICW Temperature (OF) 100 104Peak Containment Pressure (psig) 53.14 53.16Peak Containment Temperature (°F) 279.0 279.0Peak CCW supply Temperature (°F) 152.7 153.1Similarly, these results also demonstrate negligible changes between the reported results fromthe analysis of record.ConclusionIncreasing the ICW temperature to 1040F while reducing the CCW heat exchanger fouling factorto 0.002714 hr-ft2-OF/BTU provides insignificant changes to the containment peak pressure and Florida Power & Light Company L-2014-236Response to SCVB Request for Additional Information EnclosurePage 8 of 8containment peak saturation temperatures. The results have either the same or slight changes-some up, some down-from the previously reported results. These minor temperature changesprovide essentially no impact to the containment peak pressure and peak temperature response.It is concluded that small temperature variations within the CCW supply water have aninsignificant impact on the containment response. The ICW temperature increase / reducedfouling factor tradeoff results in CCW heat removal performance that is essentially the same,providing an acceptable response for the GOTHIC containment model. Therefore, the currentresults provided in the UFSAR remain valid for the increase in ICW temperature to 104'F.SCVB RAI-2The Turkey Point UFSAR Revision dated April 17, 2013, Sectionl4.3.4.3.3, "Description ofAnalysis," states that the containment response for a LOCA or MSLB accident is performedusing GOTHIC computer code. The UFSAR Table 14.3.4.3-1, "Containment AnalysisParameters," provided the intake cooling water (ICW) temperature used for containmentintegrity as 1 00TF, which is proposed to be revised to 104'F as an input to the analysis. TheTable does not explicitly state the assumed value of the CCW supply water temperature to theEECs and RHR HX in the GOTHIC analysis.Please confirm that based on the proposed ICW temperature of 104TF, and the revised worstvalue of the CCW supply water temperature (to be stated in response to this RAI) to RHR HXand ECCs, all current containment analyses for containment peak pressure and temperatureresponse and for containment heat removal are not affected and will remain as the licensingbasis.FPL ResponseAs stated in the response to SCVB RAI-1, these sensitivities validate that containment responsewould result in an insignificant change to the results presented in the UFSAR. The results of thesensitivity analysis show that the use of 104'F ICW temperature with a reduced fouling factor of0.002714 hr-ft2-F/BTU has an insignificant impact on the peak calculated containment pressure,and containment temperature. Thus, CCW heat removal performance remains essentially thesame at the 104°F ICW temperature when the fouling factor is reduced to 0.002714 hr-ft -°F/BTU. The current containment analyses for containment peak pressure, temperature and heatremoval are not affected and will remain as the licensing basis.