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MONTHYEARL-2014-216, License Amendment Request No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit2014-07-10010 July 2014 License Amendment Request No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit Project stage: Request L-2014-226, License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit - Request for Emergency Approval2014-07-17017 July 2014 License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit - Request for Emergency Approval Project stage: Request ML14203A6182014-07-18018 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 Project stage: RAI ML15131A5752014-07-18018 July 2014 La - Turkey Point 3 and 4 Request for Additional Information - LAR 231 Project stage: RAI ML14203A6142014-07-18018 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 Project stage: RAI ML14203A6202014-07-21021 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393) Project stage: RAI L-2014-232, Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit2014-07-22022 July 2014 Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit Project stage: Response to RAI L-2014-235, License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit - Supplement 1, and Response to Request for Additional Information2014-07-22022 July 2014 License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit - Supplement 1, and Response to Request for Additional Information Project stage: Supplement ML14204A8142014-07-22022 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393) Project stage: RAI L-2014-236, Response to Containment and Ventilation Branch Request for Additional Information, Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Temperature Limit2014-07-24024 July 2014 Response to Containment and Ventilation Branch Request for Additional Information, Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Temperature Limit Project stage: Request ML14208A0102014-07-25025 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393) Project stage: RAI ML14208A0112014-07-26026 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393) Project stage: RAI L-2014-237, Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit2014-07-26026 July 2014 Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit Project stage: Response to RAI ML14216A0722014-07-28028 July 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393) Project stage: RAI ML14209A0312014-07-28028 July 2014 Environmental Assessment and Finding of No Significant Impact Related to the Ultimate Heat Sink Temperature Limit Project stage: Other NRC-2014-0181, Environmental Assessment and Finding of No Significant Impact Related to the Ultimate Heat Sink Temperature Limit (TAC Nos. MF4392 and MF4393)2014-07-28028 July 2014 Environmental Assessment and Finding of No Significant Impact Related to the Ultimate Heat Sink Temperature Limit (TAC Nos. MF4392 and MF4393) Project stage: Other ML14217A0042014-08-0303 August 2014 NRR E-mail Capture - Turkey Point 3 and 4 Request for Additional Information - LAR 231 (TACs MF4392 and MF4393) Project stage: RAI L-2014-259, Response to Containment and Ventilation Branch Request for Additional Information (RAI-5), Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit2014-08-0404 August 2014 Response to Containment and Ventilation Branch Request for Additional Information (RAI-5), Regarding License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit Project stage: Request 2014-07-24
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Category:Letter type:L
MONTHYEARL-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) 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 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, 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 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 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 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 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 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 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) L-2023-086, Request Temporary Suspension of Turkey Point License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation.2023-06-28028 June 2023 Request Temporary Suspension of Turkey Point License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation. L-2023-074, Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update2023-06-0202 June 2023 Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update L-2023-069, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-05-31031 May 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 L-2023-072, Preparation and Scheduling of Operator Licensing Examinations2023-05-22022 May 2023 Preparation and Scheduling of Operator Licensing Examinations L-2023-071, NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal2023-05-22022 May 2023 NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal L-2023-061, 2022 Annual Radiological Environmental Operating Report2023-05-12012 May 2023 2022 Annual Radiological Environmental Operating Report L-2023-062, Cycle 33 Core Operating Limits Report2023-04-27027 April 2023 Cycle 33 Core Operating Limits Report L-2023-060, Radiological Emergency Plan, Revision 752023-04-26026 April 2023 Radiological Emergency Plan, Revision 75 L-2023-054, Submittal of Periodic Reports2023-04-12012 April 2023 Submittal of Periodic Reports L-2023-049, Correction to U4R33 Steam Generator Tube Inspection Report2023-03-30030 March 2023 Correction to U4R33 Steam Generator Tube Inspection Report L-2023-021, Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-03-28028 March 2023 Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update L-2023-028, and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications2023-03-27027 March 2023 and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications L-2023-025, Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-12023-03-15015 March 2023 Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-1 L-2023-029, and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)2023-03-10010 March 2023 and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3) L-2023-040, Response to Requests for Additional Information (Rals) and Requests for Confirmation of Information (Rc Ls) Following Regulatory Audit of Subsequent License Renewal Application2023-03-0303 March 2023 Response to Requests for Additional Information (Rals) and Requests for Confirmation of Information (Rc Ls) Following Regulatory Audit of Subsequent License Renewal Application L-2023-037, Annual Radioactive Effluent Release Report2023-03-0101 March 2023 Annual Radioactive Effluent Release Report L-2023-017, Radiological Emergency Plan Revision 73 and Revision 7 42023-02-17017 February 2023 Radiological Emergency Plan Revision 73 and Revision 7 4 L-2023-010, Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of RPS / ESFAS / Nis2023-02-10010 February 2023 Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of RPS / ESFAS / Nis L-2023-004, Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Huma Factors Results2023-01-17017 January 2023 Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Huma Factors Results L-2022-185, Turkey Points, Units 3 & 4; Seabrook Station; and Point Beach, Units 1 and 2 - Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22022-12-0909 December 2022 Turkey Points, Units 3 & 4; Seabrook Station; and Point Beach, Units 1 and 2 - Supplement to License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2022-181, Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 52022-12-0101 December 2022 Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5 L-2022-182, Emergency Response Data System (Eros) Changes2022-11-17017 November 2022 Emergency Response Data System (Eros) Changes L-2022-180, CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2022-11-0909 November 2022 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums L-2022-168, and Point Beach Units 1 and 2 - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report2022-10-26026 October 2022 and Point Beach Units 1 and 2 - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report L-2022-171, 10 CFR 50.59(d)(2) Summary Report2022-10-20020 October 2022 10 CFR 50.59(d)(2) Summary Report L-2022-167, Submittal of Periodic Reports2022-10-13013 October 2022 Submittal of Periodic Reports L-2022-166, Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement2022-10-0505 October 2022 Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement L-2022-149, U4R33 Steam Generator Tube Inspection Report2022-10-0404 October 2022 U4R33 Steam Generator Tube Inspection Report L-2022-160, Station,, Point Beach Units 1 and 2, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22022-10-0404 October 2022 Station,, Point Beach Units 1 and 2, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 L-2022-148, Florida Power & Light Company, Comments on NRC Inspection Procedure (IP) 71111.21 N.03, Commercial Grade Dedication2022-09-16016 September 2022 Florida Power & Light Company, Comments on NRC Inspection Procedure (IP) 71111.21 N.03, Commercial Grade Dedication L-2022-151, Evacuation Time Estimate Study2022-09-15015 September 2022 Evacuation Time Estimate Study L-2022-142, Revised Diversity and Defense-In-Depth Evaluation (D3), Framatome Document No. 51-9324096-0042022-08-19019 August 2022 Revised Diversity and Defense-In-Depth Evaluation (D3), Framatome Document No. 51-9324096-004 L-2022-136, Response to Request for Additional Information Regarding Turkey Point Unit 3 Cycle 32 Steam Generator Tube Inspection Report2022-08-12012 August 2022 Response to Request for Additional Information Regarding Turkey Point Unit 3 Cycle 32 Steam Generator Tube Inspection Report L-2022-109, Inservice Inspection Program - Owner'S Activity Report (OAR-1)2022-06-27027 June 2022 Inservice Inspection Program - Owner'S Activity Report (OAR-1) L-2022-076, Subsequent License Renewal Application - Appendix E Environmental Report Supplement 22022-06-0909 June 2022 Subsequent License Renewal Application - Appendix E Environmental Report Supplement 2 2024-01-25
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0 FPL 10 CFR 50.90 L-2014-236 July 24, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating License Nos. DPR-31 and DPR-41
Subject:
Response to Containment and Ventilation Branch Request for Additional Information, Regarding License Amendment Request No. 231, Application to Revise Ultimate 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 Sink Temperature 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 for Emergency Approval," July 17, 2014.3. Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information
-LAR 231 (TAC MF4392 and MF4393)," July 22, 2014.In Reference 1, Florida Power & Light Company (FPL) requested an amendment to the Technical 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 limit from I10 0°F to 104'F.In Reference 2, FPL supplemented the July 10, 2014 application requesting the U.S. Nuclear Regulatory Commission (NRC) to review and approve it on an emergency basis.In Reference 3, the NRC Containment and Ventilation Branch (SCVB) staff requested additional information (RAI). The enclosure to this letter provides the FPL response to the RAI.Florida Power & Light Company 00 9760 SW 3 4 4 th St.. Florida City, FL 33035 Florida Power & Light Company License Amendment Request No. 231 Response to SCVB Request for Additional Information L-2014-236 Page 2 of 2 The additional information provided in the enclosure to this letter does not impact the no significant hazards determination and environmental considerations previously provided in Reference 1.There are no new commitments made in this submission.
If you have any questions or require additional information, please contact Mr. Robert Tomonto at 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 Kiley Vice President Turkey Point Nuclear Plant
Enclosure:
Response to Request for Additional Information Regarding LAR No. 231, Application to Revise Ultimate Heat Sink Temperature Limit cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health Florida Power & Light Company L-2014-236 Response to SCVB Request for Additional Information Enclosure Page 1 of 8 Response to Request for Additional Information from the Containment and Ventilation Branch Regarding Turkey Point Units 3 and 4 License Amendment Request No. 231 Application to Revise Ultimate Heat Sink Temperature Limit Enclosure Florida Power & Light Company L-2014-236 Response to SCVB Request for Additional Information Enclosure Page 2 of 8 Background By 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 Point Nuclear Generating Station Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to the Turkey Point Technical Specifications (TS), Section 3/4.7.4, "Ultimate Heat Sink." The U.S. Nuclear Regulatory Commission's (NRC) Containment and Ventilation Branch (SCVB) staff reviewed the information provided and determined that additional information is needed to complete the review. The NRC staff request for additional information (RAI) and the FPL response follows.SCVB RAI-1 The LAR does not clearly describe changes in the current methodology for analyzing the component cooling water (CCW) supply cooling water temperature to the emergency containment coolers (ECCs) and residual heat removal (RHR) heat exchanger (HX). In the revision of the Turkey Point Updated Final Safety Analysis Report (UFSAR) dated April 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 the residual 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 the HX3/HX4 computer program to demonstrate that the CCW heat exchangers can remove the necessary post-accident containment heat load for the LOCA and MSLB containment integrity analyses.
" A. Does the HX3/HX4 computer program replace the currently used GOTHIC methodology in the current licensing basis analysis?
If so, please describe in detail how the HX3/HX4 computer program replaces the GOTHIC modeling to determine the revised CCW supply temperature to the ECCs and RHR HX, while considering the limiting values of all of the post-accident CCW HX heat loads. Please include the analysis inputs and assumptions used in the revised method justifying their conservatisms.
FPL Response No, the HX3/HX4 program does not replace the GOTHIC methodology to analyze containment for any over pressurization accident analysis (MSLB and LOCA). The Florida Power & Light Company L-2014-236 Response to SCVB Request for Additional Information Enclosure Page 3 of 8 GOTHIC containment model described in the UFSAR is one integrated model that includes the component models for CCW pumps, CCW heat exchangers and RHR system.Furthermore, no inputs, assumptions, or changes of any kind are required or have been made to the containment analysis as the result of the proposed increase to the allowable ultimate heat sink (UHS) temperature.
The current UFSAR methodology remains the GOTHIC analysis currently described in the UFSAR. All results (reported containment pressure, CCW supply / return temperatures, CCW heat removal capability, and containment building sump temperatures) remain unchanged from the results currently described in the UFSAR.UFSAR Table 14.3.4.3-1, "Containment Analysis Parameters," currently states the intake cooling water (ICW) (UHS) temperature used for containment integrity is 1 00'F. The CCW heat exchanger heat removal capability is defined by the combination of the ICW temperature and the tube fouling factor (or tube resistance).
The input values contained in the accident analysis calculations are I 00°F ICW temperature and a corresponding 0.0030 hr-ft 2 Z-OF/BTU CCW heat exchanger fouling factor. The same heat exchanger heat removal capability assumed in the accident analysis can be assured with a higher ICW temperature by maintaining a lower tube fouling factor. The HX3/HX4 computer program is used as part of the CCW heat exchanger surveillance and testing procedures to maintain the necessary level of cleanliness (below the administrative limit) to satisfy the required heat removal capability of the CCW heat exchangers.
As can be seen, this value for the tube fouling factor assumed in the accident analysis is higher than the tube fouling factor allowed 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 and maintenance of the CCW heat exhangers assures that their heat removal capability remains conservatively bounding of that assumed in the safety analysis over a range of allowable UHS temperatures and associated tube resistance.
Figure 3.5-1 in the July 10, 2014 FPL application has a typographical error for the tube resistance at I 00°F on the HX3/HX4 program line. SCVB RAI- 1 Figure 1 replaces Figure 3.5-1. Additionally, the figure has been updated to provide additional clarifying information to assist the NRC staff in understanding the current analyses of record and the analyses performed for the RAI response.
Specifically, the original point labeled as safety analyses is clarified to reflect that it is the AFT Fathom thermal-hydraulic model. The assumptions used in the GOTHIC analysis of record and the GOTHIC sensitivity studies in the response to this RAI are also included.
Florida Power & Light Company Response to SCVB Request for Additional Information L-2014-236 Enclosure Page 4 of 8 SCVB RAI-1 Figure 1 Tube Resistance Limits M.005 0.003 0.002 0.002 0.001 0.002581 100"F Umit 0.002292 104"F Umlt 70 75 80 85 90 95 100 105 110 ICW Temp (OF)B. Using the current GOTHIC model and the proposed ICW water temperature of 104TF as input, provide the CCW supply water temperature profiles to the ECCs and RHR HX for the 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 be performed using the same inputs as in the current analysis, i.e., assuming the worst safety related equipment heat loads, while using the proposed improved CCW HX tube resistance.
If any of the remaining inputs are revised, please justify.FPL Response To provide additional assurance that the accident analysis is not affected, two sensitivity cases were run to demonstrate the impact of a UHS temperature increase with a corresponding reduction in heat exchanger tube resistance (0.002714 hr-ft 2 -F/BTU).The results presented below provide the results for the maximum CCW supply temperature cases for LOCA (DEPS) and MSLB comparing the results from the current Florida Power & Light Company Response to SCVB Request for Additional Information L-2014-236 Enclosure Page 5 of 8 design basis (100°F UHS temperature with a 0.003 hr-ft 2 -F/BTU tube resistance) to the sensitivity case (104'F UHS temperature with a 0.002714 hr-ft 2-°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 the limiting event for containment integrity and is analyzed only to the end of blowdown (25 seconds) and poses no challenge to CCW heat removal capability.
The conclusions from the results for the DEPS break discussed below are applicable to the DEHL.LOCA (DEPS) CCW Maximum Supply Temperature GOTHIC Case SCVB RAI- 1 Figure 2 presents the CCW supply temperature profile for LOCA.Although there are small temperature differences this temperature profile demonstrates the CCW heat removal performance remains essentially the same at 104 0 F ICW temperatures when the tube resistance is reduced to 0.002714 hr-ft 2-°F/BTU.SCVB RAI-1 Figure 2 CCW 10OF ICW 104F ICW 170 ,, 160 ..............
16 --- i ER 140 ..........
130 Supply Temperature 0 2000 4000 6000 8000 Time (sec)10000 Florida Power & Light Company Response to SCVB Request for Additional Information L-2014-236 Enclosure Page 6 of 8 Additionally, since the licensing basis GOTHIC model is an integrated thermal hydraulic model additional containment parameters are available from this sensitivity case run. Peak containment pressure and temperature results are included with the peak CCW temperature in the table below.ICW Temperature
(°F) 100 104 Peak Containment Pressure (psig) 50.61 50.61 Peak Containment Temperature
(°F) 275.8 275.8 Peak Sump Temperature
(°F) 236.6 236.6 Peak CCW supply Temperature
(°F) 158.6 158.5 As shown, there is no significant change in the peak values. Note, the inputs used for this case ensure CCW supply temperatures are maximized; however, this will result in a lower containment pressure because more heat is removed from containment and transferred into the CCW system. Nevertheless, a similar insignificant impact is expected for the UFSAR limiting containment response licensing basis analysis.MSLB Maximum CCW Supplv Temperature Case SCVB RAI-1 Figure 3 presents the CCW supply temperature profile for MSLB. Although there are small temperature differences this temperature profile demonstrates the CCW heat removal performance remains essentially the same at 104'F ICW temperatures when the tube resistance is reduced to 0.002714 hr-ft 2-F/BTU.
Florida Power & Light Company Response to SCVB Request for Additional Information L-2014-236 Enclosure Page 7 of 8 SCVB RAI-1 Figure 3 SLB: CCW 100 degF ICW 104 degF ICW 160 1,50-i-I 140 120 /.E .~/ -Supply Temperature Temperature Temperature 0 200 400 600 Time (sec)For consistency we are also providing the respective peak containment pressure and temperature results corresponding to this case. They are included with the peak CCW temperature in the table below.ICW Temperature (OF) 100 104 Peak Containment Pressure (psig) 53.14 53.16 Peak Containment Temperature
(°F) 279.0 279.0 Peak CCW supply Temperature
(°F) 152.7 153.1 Similarly, these results also demonstrate negligible changes between the reported results from the analysis of record.Conclusion Increasing the ICW temperature to 104 0 F while reducing the CCW heat exchanger fouling factor to 0.002714 hr-ft 2-OF/BTU provides insignificant changes to the containment peak pressure and Florida Power & Light Company L-2014-236 Response to SCVB Request for Additional Information Enclosure Page 8 of 8 containment peak saturation temperatures.
The results have either the same or slight changes-some up, some down-from the previously reported results. These minor temperature changes provide 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 an insignificant impact on the containment response.
The ICW temperature increase / reduced fouling factor tradeoff results in CCW heat removal performance that is essentially the same, providing an acceptable response for the GOTHIC containment model. Therefore, the current results provided in the UFSAR remain valid for the increase in ICW temperature to 104'F.SCVB RAI-2 The Turkey Point UFSAR Revision dated April 17, 2013, Sectionl4.3.4.3.3, "Description of Analysis," states that the containment response for a LOCA or MSLB accident is performed using GOTHIC computer code. The UFSAR Table 14.3.4.3-1, "Containment Analysis Parameters," provided the intake cooling water (ICW) temperature used for containment integrity as 1 00TF, which is proposed to be revised to 104'F as an input to the analysis.
The Table does not explicitly state the assumed value of the CCW supply water temperature to the EECs and RHR HX in the GOTHIC analysis.Please confirm that based on the proposed ICW temperature of 104TF, and the revised worst value of the CCW supply water temperature (to be stated in response to this RAI) to RHR HX and ECCs, all current containment analyses for containment peak pressure and temperature response and for containment heat removal are not affected and will remain as the licensing basis.FPL Response As stated in the response to SCVB RAI-1, these sensitivities validate that containment response would result in an insignificant change to the results presented in the UFSAR. The results of the sensitivity analysis show that the use of 104'F ICW temperature with a reduced fouling factor of 0.002714 hr-ft 2-F/BTU has an insignificant impact on the peak calculated containment pressure, and containment temperature.
Thus, CCW heat removal performance remains essentially the same 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 heat removal are not affected and will remain as the licensing basis.