ML24269A129

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Response to Requests for Additional Information Regarding Turkey Point License Amendment Request 277, Updated Spent Fuel Pool Criticality Analysis
ML24269A129
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 09/24/2024
From: Mack K
Florida Power & Light Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24269A128 List:
References
Download: ML24269A129 (1)
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Text

September 24, 2024 L-2024-151 10 CFR 50.90

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001

RE : Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50 -250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41

Response to Requests for Additional Information Regarding : Turkey Point License Amendment Request 277, Updated Spent Fuel Pool Criticality Analysis

References :

1. Florida Power & Light Company letter L-2023-077, License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis, October 11, 2023 (ADAMS Accession No. ML23285A035)

2. US Nuclear Regulatory Commission electronic memorandum dated August 20, 2024, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - SFP LAR (L-2023-LLA-0142) (ADAMS Accession No. ML24234A014)

3. Westinghouse Electric Company letter LTR-NRC-23-23, "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,"

September 22, 2023 (ADAMS Accession No. ML23265A548)

4. Westinghouse Electric Company letter L TR-NRC-24-22, Transmittal of Errata Pages for WCAP-18830-P (Proprietary) and WCAP - 18830-NP (Non-Proprietary), "Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles" June 21, 2024 (ADAMS Accession No. ML24176A192)

5. Westinghouse Electric Company letter LTR-NRC 37 Transmittal of Errata Pages for WCAP-18830-P (Proprietary) and WCAP-18830-NP (Non-Proprietary), "Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles" September 18, 2024 (ADAMS Accession Nos. ML24262A227, ML24262A228, ML24262A229)

In Reference 1, Florida Power & Light Company (FPL) requested amendments to Subsequent Renewed Facility Operating Licenses Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments revise the Turkey Point Technical Specifications (TS) by incorporating changes to TS 3.7.13 "Fuel Storage Pool Boron Concentration," TS 3.7. 14 "Spent Fuel Storage," and TS 4.3 "Fuel Storage" to allow for an updated spent fuel pool cr iticality safety analysis which accounts for the impact on spent fuel storage from a proposed transition to 24-month fuel cycles.

In Reference 2, the NRG requested additional information deemed necessary to complete its review.

In Reference 3, Westinghouse Electric Company, LLC (Westinghouse) submitted WCAP-18830-P/NP, "Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles", upon which Reference 1 was based.

In Reference 4, Westinghouse submitted errata pages to WCAP-18830-P/NP following the discovery of an inadvertent error in the reactivity rankings of a spent fuel category which warranted correction to the corresponding fuel burnup limits. The discovery prompted a re-review of the enrichment, burnup, and allowable decay times for the remaining spent fuel categories which identified two others requiring correction to the burn up coefficients. As a result, the changes proposed in Reference 1 to TS 3. 7.14 Table 3.7.14-1 and Table 3.7.14-2, specifying the fuel burnup coefficients, require revision.

Florida Power & Light Company

9760 SW 344th Street, Homestead, FL 33035 Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Page 2 of 2

Additionally, in Reference 5, Westinghouse submitted errata pages to WCAP-18830-P/NP following the discovery of an inconsistency between the application of their soluble boron model and the corresponding soluble boron methodology described within. Though the correction did not affect the TS markup pages proposed in Reference 1, the enclosed response to request for additional information (RAI) #2 of Reference 2 is based on the soluble boron model correction.

to this letter provides FPL's response to the NRC staff's RAls. Enclosure 2 provides revised TS markup pages, including the corrected TS markup pages for Table 3.7.14-1, Table 3.7.14-2, and Figure 3.7.14-3 of TS 3.7.14. The enclosed TS markup pages supersede and replace in their entirety the corresponding TS markup pages proposed in Reference 1.

contains information that Westinghouse considers to be proprietary in nature. Enclosure 3 provides Westinghouse's Application for Withholding Proprietary Information from Public Disclosure accompanied by an affidavit signed by Westinghouse, the owner of the information, supporting the proprietary withholding request. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, FPL requests that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 1 O CFR Section 2.390 of the Commission's regulations. Correspondence with respect to the proprietary aspects of Enclosure 1 or the supporting Westinghouse affidavit should reference CAW-24-043 and be addressed to Zachary Harper, Senior Manager, Licensing, Westinghouse Electric Company. Enclosure 4 provides a non-proprietary (redacted) version of Enclosure 1.

The information in this RAI response provides additional information that clarifies the application, does not expand the scope of the application as originally noticed, and should not change the NRC staff's originally proposed notice of determination of no significant hazards as published in the Federal Register.

This letter contains no regulatory commitments.

Should you have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 24th day of September 2024.

Kenneth A. Mack Director, Regulatory Affairs Florida Power & Light Company

cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health

Enclosures:

1. Response to Request for Additional Information (proprietary version)
2. Revised Technical Specification markup pages
3. Application for Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390
4. Response to Request for Additional Information (non-proprietary version)

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 2

Turkey Point Technical Specifications Page Markups Pages

(18 pages follow)

Fuel Storage Pool Boron Concentration 3.7.13

3.7 PLANT SYSTEMS

3.7.13 Fuel Storage Pool Boron Concentration

!2350!

LCO 3.7.13 The fuel storage pool boron concentration shall be 2:: ~ ppm.

APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. Fuel storage pool boron ------------------NOTE-------------------

concentration not within LCO 3.0.3 is not applicable.

limit.

A.1 Suspend movement of fuel Immediately assemblies in the fuel storage pool.

A.2.1 Initiate action to restore fuel Immediately storage pool boron concentration to within limit.

A.2.2 Initiate action to perform a Immediately fuel storage pool verification.

Turkey Point Unit 3 and Unit 4 3.7.13-1 Amendment Nos. 297 and 290

!T his page is for informa t ion o n ly. No changes are proposed for this page.

Fuel Storage Pool Boron Concentration 3.7.13

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.7.13. 1 Verify the fuel storage pool boron concentration is In accordance within limit. with the Surveillance Frequency Control Program

Turkey Point Unit 3 and Unit 4 3.7.13-2 Amendment Nos. 297 and 290 Spent Fuel Storage 3.7.14

3. 7 PLANT SYSTEMS

3.7.14 Spent Fuel Storage

LCO 3.7.14 The combination of initial enrichment, burnup, and cooling time of each fuel assembly stored in the spent fuel pit shall be in accordance with the following :

a. No restrictions on storage of fresh or irradiated fuel assemblies in the cask area storage rack are applicable.
b. Fuel assemblies stored in Region I and II shall be stored in accordance with the requirements of Figures 3. 7.14-1 through 3.7.14-3 with credit for burnup and cooling time taken in determining acceptable placement locations for spent fuel in the two-region spent fuel racks. Fresh and irradiated fuel assemblies in the Region I or Region II racks shall be stored in compliance with the following:
1. any 2x2 array of Region I storage cells containing fuel shall comply with the storage patterns in Figure 3. 7.14-1 and the 3.7. 14 - 1 thro ugh
  • 3.7. 14 1 and 3.7.14*2, as t 7. 14-3 applicable. The reactivity rank of fuel assemblies in the

... 3.....,. 7-_-1.-4--4----.... e 2qx2~ a4rr;ay~ (ri;;a~nkrnde~t~e~rmrjiinffe~d ~an that sho n for the 2x2 u~shin~gf;T~a~b-:$i-3. 7.14 3 ) shall be array.

1-_ _ _ ___ _ ;

2. any 2x2 array of Region II storage cells containing fuel shall:
i. comply with the storage patterns in Figure 3.7.14-2 and 3.7.14-1 t h rough 1---- - ---..lb.Ew:eqWJi:eu:ieAJts-QU...~~ 3.7.14 1 a Ad 3. 7.14 2, as 3.7. 14 - 3 applicable. The reactivity rank of fuel assemblies in the 2x2 array (rank determined usin Tabl 3.7. 14 3 ) shall 3.7. 14-4 eac 1ve han that snown for the 2x2 array,

ii. have the same directional orientation for Metamic inserts in a contiguous group of 2x2 arrays where Metamic inserts are required, and

iii. comply with the requirements of LCO 3.7.14.b.3. for cells adjacent to Region I racks.

3. Any 2x2 array of Region II storage cells that interface with Region I storage cells shall comply with the rules of Figure 3.7.14-3.
4. Any fuel assembly may be replaced with a fuel rod storage basket or non-fuel hardware.

Turkey Point Unit 3 and Unit 4 3.7.14-1 Amendment Nos. 297 and 290 Spent Fuel Storage 3.7.14

LCO 3.7.14 (continued)

5. Storage of Metamic inserts or rod cluster control assemblies (RCCAs) is acceptable in locations designated as empty (water-filled) cells.

APPLICABJLITY : Whene er any fuel assembly is stored in the spent fuel pit.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. A.1 -------------NOTE------------ --

L CO 3.0.3 is not applicable.

Initiate action to move the Immediately noncomplying fuel assembly to an acceptable location.

SURVEILLANCE FREQUENCY

Verify by administrative means the initial Prior to storing the enrichment, burnup, and cooling time of the fuel fuel assembly in assembly is in accordance with the Figure 3. 7. 14-1 Region I or 11 through Figure 3.7. 14-3.

6. Fue,I in Category 1-2, *shall meet the m inimum_ IFBA requirement g iven by th e foll6Wing 'equation :

Minimum li=BA = -22.222 *En 2 + 272.22

  • En - 711.96

w h~re En is equa l to the fresh J-2 enric h ment and greate r than 3.78 weight percent U-235.

Turkey Point Unit 3 and Un it 4 3.7. 14-2 Amendment Nos. 297 and 290 Delete Tab le 3.7. 14 - 1 and insert revised Spent Fuel Sto rage Tab les-3 *. 7. 14 - 1 throug h 3, 7. 14-3 3.7. 14

Coeff. " Fue l Cateaorv 1-3 " 1-4 11-1 11-2 11 -3 11 -4 11-5 A1 5.66439153 ~ 4.7363682 - 7. 7 4060457 -7.63345029 24.4656526 8.5452608 26.2860949 A2 -7.22610116 11~ 84547 5.13978237 10.7798957 -20.3141124 -4.47257395 -18.0738662 A3 2.98646188 -1.806i ~~ 1 -0.360186309 -2.81231555 6.53101471 2.09078914 5.833089 1 A4 -0.287945644 0.11951649 ~ 0.002 1681285 0.29284474 -0.581826027 -0.188280562 -0.5 17 434342 AS -0.558098618 0. 0620559676 ~ 304713673 0.0795058096 -0. 16567 492 0.157548739 -0.061415203 1 AG 0.476169245 0.0236575787 O.O!IBS...44889 -0.0676341983 0.243843226 -0. 0593584027 0. 134626308 A7 -0.117591963 -0.0088144551 -0.02775 ~ 6 0.0335130877 -0.0712130368 0.0154678626 -0.0383060399 AS 0.0095165354 0.0008957348 0.002405718 5' '-:0.0040803875 0.0063998706 -0.0014068318 0.0033419846 A9 -47.1782783 -20.2890089 -21.424984 ~ 6716317 -41.1150 -0.881964768 -12.1780 A10 33.4270029 14.7485847 16.255208 - 10. &M.2224 43.9149156 9.69128392 23.6179517 A1 1 -6. 11257501 -1.22889103 - 1.77941882 5.62580 ~ -9.6599923 -0. 187 40168 -4.10815592 A12 0.490064351 0. 0807808548 0.127321203 -0.539361868 " '-...0.836931842 0.0123398618 0.363908736

Turkey Point Un it 3 and Unit 4 3.7.14-3 Amendment Nos. 297 and 290 Delete Tab le 3.7. 14-2 and insert revised Spent Fuel Storage Tables 3.7. 14-1 throuqh 3,:7. 14-3 3.7. 14 I. y *.!

Turkey Point Unit 3 and Unit 4 3.7.14-4 Amendment Nos. 297 and 290 jNote : This page replaces correspond ing LAR 277 (ML23285A035)TS markup page I Spent Fuel Storage 3.7.14

Table 3.7.14-1 (Page 1 of 1)

Pre-EPU Non-Blanketed Fuel - Coefficients to Calculate the Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) and Cooling time (Ct)

See Notes 1-4 for use of Table 3.7.14-1

Fuel Category

Coeff. 1-3 1-4 11-1 11-2 11-3 11-4 11-5 11-6 A1 46.1221 -15.5280 -2.0590 26.4195 26.4195 -3.7782 -29.0518 -29.0518 A2 -51.4825 13.5960 -2.7964 -23.6884. *23.6884 0.7172 38.3795 38.3795 A3 18.4391 -3.4175 3.0982 6.8587 ~ 2.1165 -13.3538 -13.3538 A4 -2.0048 0.3637 -0.4715 -0.4980 ~ -0.3342 1.6937 1.6937 AS -0.4998 -1.0368 0.2161 -1.4442 -1.4442 0.1433 -0.4574 -0.4574 A6 0.3474 1.3335 -0.3773 1.6753 1.6753 -0.1589 0.5477 0.5477 A7 -0.0487 -0.4940 0.1893 -0.5777 -0.5777 0.0725 -0.1803 -0.1803 AB 0.0000 0.0574 -0.0265 0.0632 ~ -0.0095 0.0184 0.0184

A9 -38.3233 -96.9847 6.7162 -96.0974 -96.0074 -26.9895 -36.7528 -36.7528 A10 24.6155 94.9777 -18.9681 92.2715 92 :2715 23.9367 38.4104 38.4104 A11 -3.5675 -28.3931 10.8797 -25.2863 -25.2863 -2.6264 -5.8631 -5.8631 A12 0.3160 3.0898 -1.2782 2.5516 2.5516 0.1421 0.2201 0.2201

Min. 2.00 1.80 1.75 1.55 1.50 1.30 1.15 1.15 Enrich.

Notes:

1. All relevant uncertainties are explicitly included in the criticality analysis. For instance, no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Category, the assembly burnup must exceed the "minimum burnup" (GWd/MTU) given by the curve fit for the assembly "cooling time " and "initial enrichment." The specific minimum burnup required for each fuel assembly is calculated from the following equation. The equation is applicable at enrichments greater than or equal to the value shown as Minimum Enrichment.

Bu : (A1 + Ai"En + A:l"En 2 + A4*En3)

  • exp [ - (A5 + As"En + A7En 2 + As"En 3)*Ct] +As+ A1o"En + A11"En2 +

A12*En3

2. Initial enrichment, En, is the nominal 235U enrichment up to 4.0 wt.%.

3. Cooling time, Ct, is in years. Decay (cooling) time credit of 15 years may be used for enrichments less than 2.0 wt.%. Decay (cooling) time credit between 15 and 25 years, inclusive, may be used for any enrichment between 2.0 and 4.0 wt.%, inclusive. An assembly with a cooling time greater than 25 years must use 25 years.

4. This table applies only for pre-EPU non-blanketed fuel assemblies. If a non-blanketed assembly is depleted at EPU conditions, none of the burnup accrued at EPU conditions can be credited (i.e., only burnup accrued at pre-EPU conditions may be used as burnup credit).

jNote : This page replaces c0rrespond ing LAR 277 (ML23285A035 )TS markup page I Spent Fuel Storage 3.7.14

Table 3.7.14-2 (Page 1 of 1)

Mid-Enriched Blanketed Fuel - Coefficients to Calculate the Minimum Required Fuel Assembly Bumup (Bu) as a Function of Enrichment (En) and Cooling time (Ct)

See Notes 1-4 for use of Table 3.7.14-2

Fuel Category Coeff. 1-3 1-4 11-1 11-2 11-3 11-4 11-5 11-6

A1 -14.0214 0.7356 - 10.3764 0.3023 -13.6425 -1.9201 -15.6064 16.2892 A2 11.4137 -1.1927 7.6199 -3.1468 13.5164 2.9502 16.3820 -17.6207 A3 -2.7518 1.4318 -1.2005 2.3278 -2.5923 0.3686 -3.6279 7.2596 A4 0.2743 -0.1832 0.0789 -0.2523. 0.1973 -0.0636 0.31 14 -0.7399 AS 2.6 169 -0.0485 4.8088 0.2364 -0.1211 -0.3267 -0.2816 -0.4164 A6 -2.1487 0.0236 -3.8345 -0.0738 0.1969 0.3766 0.3303 0.5335 A7 0.5878 0.0034 1.0085 -0.0001 -0.0571 -0.1090 -0.0953 -0.1669 AB -0.0522 -0.0004 -0.0863 0.0016 0.0050 0.0099 0.0087 0.0160 A9 -27.8139 -51.8296 -29.1782 -57.7979 -41.6737 -51,9429 -40.4692 -67.4031 A10 15.7630 41.0704 21.6958 55.4896 42.2351 52.1289 41.5363 74.8527 A11 -0.7370 -8.3986 -3.2089 -13.5089 -8.9287 -11.9184 -8.8545 -19.0424 A12 -0.0324 0.7265 0.2488 1.2360 0.7680 1.0595 0.7866 1.7507

Min. 2.00 1.75 1.75 1.55 1.35 1.30 1.30 1.15 Enrich.

Notes:

1. All relevant uncerta inties a re explicitly included in the criticality analysis. For instance, no additional allowance for burnup uncerta inty or enrichment uncerta inty is required. For a fuel assembly to meet the requirements of a Fuel Category, the assembly burnup must exceed the "minimum burnup " (GWd/MTU) given by the curve fit for the assembly "cooling time " and "initial enrichmen t." The specific minimum burnup required for each fuel assembly is calculated f rom the following equation. The equation is applicable at enrichments greater than or equal to the value shown as Minimum Enrichment.

Bu = (A1 + A2"En + A:i* En 2 + A4* En 3)

  • exp [ * (A5 + Ae* En + A1
  • En 2 + As*En 3)"Ct] + A9 + A10* En + A11*En2 +

A12* En 3

2. Initial enrichment, En, is the nominal 235 U enrichment up to 5.0 wt.%. Axial blanket material is not considered when determining enrichment.

3. Cooling time, Ct, is in yea rs. No decay (cooling) time credit may be used for enrichments less than 2.0 wt.%.

Decay (cooling) time credit between O and 25 years, inclusive, may be used for any enrichment between 2.0 and 5.0 wt.%, inclusive. An assembly w ith a coo li ng time greater than 25 years must use 25 years.

4. This table applies only for assemblies with a blanket enr ichments 2.6 wt% 235 U.

Spent Fuel Storage 3.7.14

Table 3.7.14-3 (Page 1 of 1)

Non-Blanketed Fuel - Coefficients to Calculate the Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) and Cooling t ime (Ct)

See Notes 1-6 for use of Table 3.7.14-3

Fuel Category Coeff. 1-3 1-4 11-1 11-2 11-3 11-4 11-5 11-6 A1 32.2479 -4.1991 12.9596 -8.7984 1.2361 -13.6999 -14.1352 29.7195 A2 -32.5873 0.5751 -16.0005 17.5883 3.9352 13.5880 13.4387 -32.1725 A3 10.8045 1.2741 6.3237 - 6.8331 -1.1864 -2.6470 -2.3109 12.1689 A4 -1.0774 -0.1682 -0.6838 0.8117 0.1753 0.2090 0.1692 -1.2477 A5 - 0.9953 -0.9249 -0.5872 0.0832 0.0667 0.2213 -0.4392 -0.5875

A6 0.9362 0.8428 0.5836 -0.1491 -0.1430 -0.1129 0.4624 0.7692 A7 -0.2713 -0.2310 -0. 1721 0.0770 0.0840 0.0290 -0.1343 -0.2522 AB 0.0260 0.0205 0.0169 -0.0095 -0.0112 -0.0025 0.0125 0.0250 A9 -55.7079 -31.2188 -30.7329 -33.6356 -42.2030 -34.7146 -39.4591 -73.5056 A10 40.9920 22.8793 22.0019 18.4614 34.1725 34.4020 41.0322 80.5849 A11 -8.4183 -2.8703 -3.2299 0.7440 -4.6731 -6.5830 -8.2273 -20.9293 A12 0.7732 0.1971 0.2932 -0.2665 0.2560 0.6009 0.7495 2.0012

Min. 2.0 1.75 1.75 1.55 1.35 1.30 1.30 1.15 Enrich.

Notes:

1. All relevant uncertainties are explicitly included in the criticality analysis. No additional allowance for burnup uncertainty or enrichment uncertainty is requ ired. For a fuel assembly to meet the requ irements of a Fuel Category, the assembly burnup must exceed the "minimum burn up" (GWd/MTU) given by the curve fit for the assembly "cooling time " and "initial enrichment." The specific minimum burnup required for each fuel assembly is calculated from the follo w ing equation. The equation is applicable at enrichments greater than or equa l to the value shown as Minimum Enrichmen t.

Bu = (A1 + Ai* En + A3* En2 + A4* En 3) " exp [ *{As+ A6"En + A1*En 2 + Ae *En 3)*Ct] + A9 + A1o* En + A11 "En2 +

A12* En 3

2. Initial enrichment, En, is the nominal 235 U enrichment up to 5.0 wt.%. Axial blanket material is not considered when determining enrichment. No decay (cooling) time credit may be used for enrichments less than 2.0 wt.%.

Decay (cooling) time credit between O and 25 years, inclusive, may be used for any enrichment between 2.0 and 5.0 wt.%, inclusive.

3. Cooling time, Ct, is in years. Any cooling time between O years and 25 years may be used. An assembly with a cooling time greater than 25 years must use 25 years.

4. Category 1-1 is fresh unburned fuel up to 5.0 wt% 235 U enrichment.

5. Category 1-2 is fresh unburned fuel that obeys the IFBA requirements from Table 5-1.

6. This table applies for all non-blanketed assemblies.

Spent Fuel Storage 3.7.14

!3.7. 14 -:4 Table 3.7. 14 3 (page 1 of 1)

Fuel Categories Ranked by Reactivity See Notes 1-5 for use of Table 3.7. 14-3

1-1 High Reactivity Region I 1-3 1-2

1-4 Low Reactivity

11-1 High Reactivity 11-2 Region II 11-3 11-4

It-::.. 11-5 Low Reactivity

~ Add a row at the bottom of Region II', place " 11 - 6" in midd le col umn, ~nd sh ift "Low Reactivity "

Notes: down to a lign w ith th is new 11 -6 row.

1. Fuel Category is ranked by decreasing order of reactivity without regard for any reactivity-reducing mechanisms, e.g., Category 1-2 is less reactive than Category 1-1, etc. The more reactive fuel categories require compensatory measures to be placed in Regions I and II of the spent fuel pit, e.g., use of water filled cells, Metamic inserts, or full length RCCAs.
2. Any higher numbered fuel category can be used in place of a lower numbered fuel category from the same Region.

3. Category 1-1 is fresh unburned fuel up to 5.0 wt% U-235 enrichment.

4. Category 1-2 is fresh unburned fuel that obeys the Integral Fuel Burnable Adsorber (IFBA) requirements of Table 3.7. 14-4.

5. All Categories except 1-1 nd 1-2 are determined from Tables 3.7. 14 1 esnd 3.7.14 2.

3.7. 14-1 through 3.7.14-3

LCO 3.. T. 14.. b. 6.

Turkey Point Unit 3 and Unit 4 3.7. 14-5 Amendment Nos. 297 and 290 Spent Fuel Storage IDe)ele TaPle 3.7.14-4 3.7.14

Table 3.7. 14-4 (page 1 of 1)

IFBA Requirements for Fuel Category 1-2

Minimum Required Number of IFBA Pins

Enr. s 4.3 0

4.3 < Enr. s 4.4 32

4.4 < Enr. s 4.7

4.7 < Enr. s 5.0

Turkey Point Unit 3 and Unit 4 3.7. 14-6 Amendment Nos. 297 and 290 Spent Fuel Storage 3.7.14

Figure 3.7. 14-1 (page 1 of 1)

Allowable Region I Storage Arrays See Notes 1-8 for use of Figure 3.7.14-1

DEFINITION ILLUSTRATION

Array I-A Checkerboard pattern of Category 1-1 assemblies and empty (water-filled) cells.

Array 1-8 Category 1-4 assembly in every cell. ~

llilHJ Array 1-C Combination of Category 1-2 and 1-4 assemblies. Each ~ ~

Category 1-2 assembly shall contain a full length RCCA. 4 llilHJ

~

Array 1-D Category 1-3 assembly in every cell. One of every four [iiiiiJ assemblies contains a full length RCCA. [iiiiiJ

Notes :

1. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.
2. Category 1-1 is fresh unburned fuel up to 5.0 wt% U-235 enrichment. !LCQ 3.7.. 14.b.6.

3. Category 1-2 is fresh unburned fuel that obeys the IFBA requirements in Teele 3.7.14 4.

4. Categories 1-3 and 1-4 are determined from Tables 3.7. 14 1 and 3.7. 14=2. !3.7. 14 - 1 th rough 3.7. 14 - 3 !

5. Shaded cells indicate that the fuel assembly contains a full length RCCA.

6. X indicates an empty (water-filled) cell.

7. Attributes for each 2x2 array are as stated in the definition. Diagram is for illustrative purposes only.

8. An empty (water-filled) cell may be substituted for any fuel containing cell in all storage arrays.

Turkey Point Unit 3 and Unit 4 3.7.14-7 Amendment Nos. 297 and 290 Spent Fuel Storage 3.7.14

Figure 3.7.14-2 (page 1 of 1)

Allowable Region II Storage Arrays See Notes 1-6 for use of Figure 3.7.14-2

DEFINITION ILLUSTRATION

Array II-A 11-1 11-1 X 11-1 Category 11-1 assembly in three of every four cells; X 11-1 11-1 11-1 one of every four cells is empty (water-filled);

the cell diagonal from the empty cell contains a Metamic insert or full length RCCA.

Array 11-B 11-3 11-5 11-3 11-5 Checkerboard pattern of Category 11-3 and 11-5 assemblies 11-5 11-3 11-5 11-3 With ve four cells containing a Metamic insert or full length RCCA..----------.....

Un-capitaliz~ "with" and "cells" 11-4 11-4 sse ly in every cell with two of every four 11-4 11-4 Metamic insert or full length RCCA. 11-4 11-4 11-4 11-4

Arra II-11-2 11-2 n~ II-6 Cate 11-2 assembly in every cell with three of every four 11-2 11-2 Cells containing a Metamic insert or full length RCCA.

0--(i I II-6 Array 11-E Notes: Category 11-6 assembly in every cell with on¢ of every four cells containing a,Melamie

  • insert or full length RCCA.
1. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.

2. Fuel categories are determined from Tables 3.7.14 1 aAel 3.7.14 2. j3.7.14-1 through 3.7'. 14-3 j

3. Shaded cells indicate that the cell contains a Metamic insert or the fuel assembly contains a full length RCCA.

4. X indicates an empty (water-filled) cell.
5. Attributes for each 2x2 array are as stated in the definition. Diagram is for illustrative purposes only.

6. An empty (water-filled) cell may be substituted for any fuel containing cell in all storage arrays.

Turkey Point Unit 3 and Unit 4 3.7.14-8 Amendment Nos. 297 and 290 Spent,Fuel Storage De lete Figur~ 3. 7. 14 - 3 and in~ert rev i$ e<:I 3.7.14 Figure 3. 7.1~ - 3

Figure 3. 7.14-3 (page 1 of 1)

Interface Restrictions Between Region I and Region II Arrays See Notes 1-8 for use of Figure 3.7.14-3

ILLUSTRATION

Region I Rack Array II-A, as fined in 1-4 1-4 1-4 1-4 Figure 3.7.14-2, hen placed on 1-4 1-4 1-4 1-4 The interface with egion I shall 11-1 X 11-1 X have the empty cell I the row 11-1 11-1 11-1 11-1 adjacent to the Region rack. Array II-A

Region I Rack Region I Rack Region I Rack Arrays 11-8, 11-C and 11-D, as 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 defined in Figure 3.7.14-2, when 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4 placed on the interface with Region 11-3 11-5 11-4 11-4 11-4 11-4 11-2 11-2 11-2 11-2 I shall have an insert in every cell in 11-5 11-3 11-4 11-4 11-4 11-4 11-2 11-2 11-2 11-2 the row adjacent to the Region I Array 11-C Array 11-D rack.

~:

1. In all arrays, an assembly of lower reactivity can repla an assembly of higher reactivity.

2. Fuel categories are determined from Tables 3.7.14-1 and 7.14-2.

3. Shaded cells indicate that the cell contains a Metamic insert or e fuel assembly contains a full length RCCA.
4. X indicates an empty (water-filled) cell.

5. Attributes for each 2x2 array are as stated in the definition. Diagram is fo illustrative purposes only.

Region I Array 1-8 is depicted as the example; however, any Region I array

  • allowed provided that
a. For Array 1-D, the RCCA shall be in the row adjacent to the Region II
b. Array I-A shall not interface with Array 11-D.

6. If no fuel is stored adjacent to Region II in Region I, then the interface restrictions are no

7. Figure 3.7.14-3 is applicable only to the Region I - Region II interface. There are no restrictio s for the interfaces with the cask area rack.

8. An empty (water-filled) cell may be substituted for any fuel containing cell in all storage arrays.

Turkey Point Unit 3 and Unit 4 3.7. 14-9 Amendment Nos. 297 and 290 Spent Fuel Storage 3.7.14

Figure 3.7.14-3 (page 1 of 2)

Interface Restrictions Between Region I and Region II Arrays See Notes 1-13 for use of Figure 3.7. 14-3

Array I-A - Region II

Array 1-A Array 1-A Array 1-A X 1-1 X 1-1 X 1-1 X 1-1 X 1-1 X 1-1

1-1 X 1-1 X 1-1 X 1-1 X 1-1 X 1-1 X

11-1 X 11-1 X 11-4 11-4 11-4 11-4 11-6 11-6 11-6 11-6

11-1 11-1 11-1 11-1 11-4 11-4 11-4 11-4 11-6 11-6 11-6 11-6

Array 11-A Array 11-C Array 11-E

Array 1 Region II

Array 1-B Array 1-B

1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4

1-4 1-4 1-4 1-4 1-4 1-4 1-4 1-4

11-1 X 11-1 X 11-2 11-2 11-2 11-2

11-1 11-1 11-1 11-1 11-2 11-2 11-2 11-2 Array II-A Array 11-D

Array 1-D - Region II

Array 1-D Array 1-D Array 1-D Array 1-D Arrayl-D

1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3

1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3

11-1 X 11-1 X 11-3 11-5 11-3 11-5 11-3 11-5 11-3 11-5 11-3 11-5 11-3 11-5 11-4 11-4 11-4 11-4

11-1 11 -1 11-1 11-1 11-5 11-3 11-5 11-3 11-5 11-3' 11-5 11-3 11-5 11-3 11-5 11-3 11-4 11-4 11-4 11-4 Array II-A Array 11-B Array 11-B Array 11-B Array 11-C

Array 1-D Array 1-D Array 1-D Array 1-D

1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3

1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3

11-4 11-4 11-4 11-4 11-4 11-4 11-4 11-4 11~2 11-2 11~2 11-2 11-2 11-2 11-2 11-2

11-4 11-4 11-4 11-4 11-4 11-4 11-4 11-4 11-2 11-2 11-2 11-2 11-2 11-2* 11-2 11-2 Array 11-C Array 11-C Array 11-D Array 11-D Spent Fuel Storage 3.7.14

Figure 3.7.14-3 (page 2 of 2)

Interface Restrictions Between Region I and Region II Arrays See Notes 1-13 for use of Figure 3.7. 14-3

Notes :

1. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.
2. Fuel categories are determined from Tables 3.7.14-1 through 3.7. 14-3.
3. Region I shaded cells indicate that the fuel assembly contains a full length RCCA.
4. Region II shaded cells indicate that the cell contains a Metamic insert or the fuel assembly contains a full length RCCA.
5. X indicates an empty (water-filled) cell.
6. Region I and Region II storage cells do not necessarily align across the interface as shown in the figure. There are no restrictions associated with cell alignment across the interface.
7. If no fuel is stored adjacent to Region II in Region I, then the interface restrictions are not applicable.
8. Array I-A is subject to the following restrictions:
a. Array I-A shall not interface with Array 11-B or 11-0.
b. Array I-A-Array II-A Interface: The Array II-A empty cell shall be placed on the interface.
c. Array 1-A - Array 11-C Interface: All required Metamic inserts or RCCAs must be placed along the interface.
d. Array I-A-Array 11-E Interface: All required Metamic inserts or RCCAs must be placed along the interface.
9. Array 1-B is subject to the following restrictions:
a. Array 1 Array II-A Interface: The Array II-A empty cell shall be placed on the interface.
b. Array 1-8 -Array 11-0 Interface : The Array 11-0 assemblies on the interface must all contain Metamic inserts or RCCAs.

c. There are no restrictions for Arrays 11-8, 11-C or 11-E with Array 1-8.

10. The same restrictions noted for Array 1-B apply to Array 1-C, with no additional restrictions on the Region I side regarding Fuel Categories 1-2 and 1-4.
11. Array 1-0 is subject to the following restrictions :
a. Array 1 Array II-A Interface : The Array II-A empty cell shall be placed on the interface.
b. Array 1 Array 11-8 Interface: A storage cell on the interface in each storage array must contain a Metamic insert or RCCA on at least one side of the interface.
c. Array 1 Array 11-C Interface: A storage cell on the interface in each storage array must contain a Metamic insert or RCCA on at least one side of the interface.

d. Array 1 Array 11-0 Interface: Either all Array 11-0 cells on the interface must contain Metamic inserts or RCCAs, or each Region I storage array and each Region II storage array must contain a Metamic insert or RCCA in a storage cell on the interface.

e. Array 1 Array 11-E Interface : No interface restrictions.

12. This Figure is only applicable to the Region I -Region II interface. There are no restrictions for the interfaces with the Cask Area Rack.
13. An empty (water-filled) cell may be substituted for any fuel containing cell in all storage arrays.

Design Features 4.0

4.0 DESIGN FEATURES

4.1 Site Location

The site is approximately 25 miles south of Miami, 8 miles east of Florida City and 9 miles southeast of Homestead, Flo rida.

4.2 Reactor Core

4.2.1 Fuel Assemblies

The reactor shall contain 157 fuel assemblies. Each assembly shall consist of a matrix of Zirca loy-4, ZIRLO, or Optimized ZIRLO' fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U02) as fuel mater ial.

Limited substitutions of stainless steel filler rods for fuel rods, or by vacant rod positions, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with appl icable NRC staff approved codes and methods.

4.2.2 Control Rod Assemblies

The reactor core shall contain 45 control rod assemblies. The control material shall be silver indium cadm ium, as approved by the NRC.

4.3 Fuel Storage

4.3.1 Criticality

4.3.1.1 The spent fuel storage racks are des igned and shall be maintained with :

a. Fue l assemblies having a maximum U-235 enrichment of 5.0 weight percent, !55o I
b. kett::; 0.95 if fully flooded with water borated to -50& ppm, which includes an allowance for biases and uncertainties as described in Section 9.5 of the UFSAR,

C. kett::; 1.0 if fully flooded with unborated water, which includes an allowance for biases and uncertainties as described in Section 9.5 of the UFSAR,

d. A nominal 10.6 inch center to center distance between fuel assemblies placed in Region I of the fuel storage racks,

e. A nominal 9.0 inch center to center distance between fuel assemblies placed in Region II of the fuel storage racks,

Turkey Point Unit 3 and Unit 4 4.0-1 Amendment Nos. 297 and 290

!This page is for information only. No changes are proposed for this page.

Design Features 4.0

4.0 DESIGN FEATURES

4.3 Fuel Storage (continued)

f. A nominal 10.1 inch center to center distance in the east-west direction and a nominal 10. 7 inch center to center distance in the north-south direction for the cask area storage rack,

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.5 weight percent if the assemblies contain no burnable adsorber rods,
b. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent if the assemblies contain at least 16 integral fuel burnable adsorber rods.
c. A nominal 21 inch center to center distance between fuel assemblies placed in the storage racks to assure kett ~ 0.98 for optimum moderation conditions, and
d. A nominal 21 inch center to center distance between fuel 0.95 for assemblies placed in the storage racks to assure kett ~

fully flooded conditions.

4.3.2 Drainage

The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below a level of 6 feet above the fuel assemblies in the storage racks.

4.3.3 Capacity

The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1535 fuel assemblies.

Turkey Point Unit 3 and Unit 4 4.0-2 Amendment Nos. 297 and 290 Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 3

Application for Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390

(3 pages follow)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CA W-24-043 Page 1 of3

Commonwealth of Pennsylvania:

County of Butler:

(1) I, Zachary Harper, Senior Manager, Licensing, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary po1tions of L-2024-151 Enclosure 1 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouse's knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Neve1theless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

      • This record was final approved on 09/18/2024 17:41 :59. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CA W-24-043 Page 2 of3

(5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects ofa process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process ( or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure ofresources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

( d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means oflower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.

      • This record was final approved on 09/18/2024 17:41 :59. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CA W-24-043 Page 3 of3

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of pe1jury that the foregoing is true and correct.

Executed on: 9/17/2024 Signed electronically by Zachary Harper

      • This record was final approved on 09/18/2024 17:41 :59. (This statement was added by the PRIME system upon its validation)

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 1 of 10

[Non-Proprietary Information)

In Reference 1, Florida Power & Light Company (FPL) requested amendments to Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments revise the Turkey Point Technical Specifications (TS) by incorporating changes to TS 3.7.13 "Fuel Storage Pool Boron Concentration," TS 3.7.14 "Spent Fuel Storage," and TS 4.3 "Fuel Storage" to allow for an updated spent fuel pool criticality safety analysis which accounts for the impact on the spent fuel from a proposed transition to 24-month fuel cycles.

In Reference 2, the NRC requested additional information (RAls) deemed necessary to complete its review, as indicated below. FPL's response follows:

Section 4.1.2.2.6 of WCAP-18830-P for the Turkey Point Nuclear Generating Units 3 and 4 fuel storage criticality analysis for 24 months discusses burnable absorber usage and its consideration in the criticality analysis. With regard to wet annular burnable absorber (WABA) considerations, Section 4.1.2.2.6 states WABA was used in Pre-EPU operation, which is covered by Criticality Fuel Designs 1 and 2, and it is assumed that all conservative Post-EPU (e.g., 148 integral fuel burnable absorber (IFBA) at 1.25X) input is bounding of Pre-EPU operation with WABA. However, no justification is provided to support this assumption.

The NRC staff understands that no Post-EPU operation fuel contains WABA and future fuel will be Criticality Fuel Design 3, but until such time as Pre-EPU operation fuel containing WABA is removed from the spent fuel pool (SFP) for long term storage, a combination of Pre-EPU WABA and Post-EPU fuels will exist in the SFP. 10 CFR 50.68(b)(4) requires licensees demonstrate, when taking credit for soluble boron, the effective neutron multiplication factor (k-effective) of the SFP storage racks loaded with fuel of the maximum fuel assembly reactivity does not exceed 0.95 ifflooded with borated water and remains below 1.0 when flooded with unborated water. Therefore, analyses should give consideration to the residual reactivity of Pre-EPU operation fuel containing WABA and to Post-EPU operation fuel to ensure the SFP k-effective remains below the specified requirements.

Provide justification (e.g., sensitivity analyses, explicit reactivity comparisons, etc.) that Post-EPU operation fuel is bounding of Pre-EPU operation fuel with WABA. Conversely, please provide updated Criticality Fuel Design analyses that consider Pre-EPU operation fuel with WABA.

FPL Response:

As discussed in the related NRC audit, depletion conditions for fuel cycles containing assemblies operated with WABA (both blanketed and unblanketed designs were surveyed) during Pre-EPU operation were categorized. Analysis was performed to ensure assemblies with WABA, operated in Pre-EPU conditions, are bounded by Criticality Fuel Design 2 (CFD2) isotopics as detailed in Reference 1.

Ja,c Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page2of10

[Non-Proprietary Information]

T bl 1 1 D I a e - ep1e 10n on 110n ompanson T bl f C dT C a e

Nominal Case Case 1 Case 2 Case 3 Case 4* Case 5** a,c

-~ -

f-

~

Note that the following depletion conditions are unchanged across all depletions (including nominal) and are from the CFD2 depletion conditions, for which many are conservative to pre-EPU operation.

  • Core Loading
  • Core Power
  • Blanket Type
  • Pump Flow
  • Relative Power
  • Temperature Profile
  • Blanket Length

. Ja,c

While the depletions performed for [ J a,c have reduced overall conservatism when compared to actual operation for assemblies being evaluated, very significant conservatisms still exist within these models. Some of these conservatisms are as follows:

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 3 of 10

[Non-Proprietary Information]

Therefore, all cycles containing WABA operated under Pre-EPU conditions were found to be acceptably bounded by CFD2 isotopics, confirming the statement in question.

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 4 of 10

[Non-Proprietary Information]

Table 1-2: kett Differences (Nominal minus Case) for 2 wt% Assemblies Burnup Case 1 Case 2 Case 3 Case4 Case 5 (GWd/MTU) a,c

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 5 of 10

[Non-Proprietary Information]

Table 1-3: kett Differences (Nominal minus Case) for 5 wt% Assemblies Burnup Case 1 Case 2 Case 3 Case 5 (GWd/MTU) Case4 a,c

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 6 of 10

[Non-Proprietary Information]

RAl-1

References:

1. WCAP-18830-P, "Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles," September 2023
2. WCAP-17094-P, Revision 3, "Revision 3 ** Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis," February 2011

Section 5.7.2 of WCAP-18830-P for the Turkey Point Nuclear Generating Units 3 and 4 fuel storage criticality analysis for 24 months discusses the usage of soluble boron for accident conditions. Section 5.7.2 states that the multiple misload accident (I )) bounds all other justification is provided to support this accidents listed in Section 4.2.9 of WCAP-18830-P. However, no statement. 10 CFR 50.68(b)(4) requires licensees demonstrate the effective neutron multiplication factor (k-effective) of the SFP storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0. 95 if flooded with borated water.

Provide justification showing that [ )) is bounding of all other accidents listed in Section 4.2.9. Conversely, please provide the results of the criticality calculations for all other accidents listed in Section 4.2.9.

FPL Response:

The following responses justify that the [ ]a,c is bounding of all other accidents listed in Section 4.2.9 of WCAP-18830-P (Reference 1) for Region II. The keff value of the [ ]a,c is significantly higher than the keff values obtained from modeling the other accident scenarios at the same or even more conservative soluble boron concentration used in the [ ]a,c case. While a different total bias and uncertainty term may be applied dependent on the accident condition, none of the biases and uncertainties would result in a more limiting accident. This summary is presented in Table 2-1. [

]a,c

Table 2-1: kett Values for Anal zed Accident Conditions keff + 2a Accident Condition keff CI ___ a,c

Misloaded fresh fuel assembly or assemblies in a storage rack

The single assembly misload is bounded by the multiple assembly misload.

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 7 of 10

[Non-Proprietary Information]

Inadvertent Removal of an Absorber Insert

During the fuel rearrangement operations, the inadvertent removal of an absorber is possible. [

J a.c [

J a,c

Spent Fuel Pool Temperature Greater Than Normal Operating Range

The spent fuel pool can heat up to a temperature that is greater than the normal operating range due to a loss of cooling. Due to the large volume of water in the spent fuel pool, boiling off the pool water before remediation is not credible; therefore, the lowest possible water density is that at boiling at pool depth. A density of 0.958 g/cm 3 is utilized from atmospheric boiling conditions combined with a temperature of 256°F typical at fuel depth (Reference 2). [

. J a,c

Table 2-2: kett for Various Coolant Density at 256 °F for Selected Storage Arrays Density, Region 11-E g/cm 3 Region 1-A Region 1-8 Region II-A Region 11-B Region 11-C a,c

Loss of Water Gap Between Region I and Region II due to Seismic Event

For the accident due to a seismic event, the water gap between Region I and Region II can be reduced to zero such that each storage module makes contact. [

. J a,c

Dropped Fresh Fuel Assembly

It is possible to drop a fresh fuel assembly on top of the spent fuel pool storage racks. The dropped assembly could land horizontally on top of the other fuel assemblies in the rack. In this case, there is

2 MetamicTM is a trademark ofMetamic, LLC. Other names may be trademarks of their respective owners.

Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 8 of 10

[Non-Proprietary Information]

significant separation between the dropped fuel assembly and the rest of the fuel assemblies due to the top nozzle, fuel rod plenum, fuel rod end plug, and the separation between the fuel rod and the top nozzle. This separation is at least 12 inches meeting the requirements outlined in Reference 2. The separation between the fallen fuel assembly and the stored fuel will be further increased by the outer structure of the fallen assembly.

In this case, the physical separation between the fuel assemblies in the spent fuel pool storage racks and the assembly lying on top of the racks is sufficient to neutronically decouple the accident per the guidance given in Reference 2, Section 6.3.2. In other words, dropping the fresh fuel assembly on top of the storage racks may only produce a very small positive reactivity change. Any very small positive reactivity increase will not be limiting.

Misplaced Fuel Assembly

It is possible to misplace a fuel assembly in a location not intended for fuel. Any assembly placed outside of the racks is surrounded by water on at least two sides. The additional neutron leakage of the two sides not facing fuel ensures that this condition is bounded by the misload event.

Misplacement of Cask Area Rack

Two potential accident scenarios in the cask area rack were considered. The first evaluated condition is such that the cask area rack has a corner where there is no storage cell box. It is possible, though very unlikely, that a fresh fuel assembly could be placed in this corner such that there is only one absorber panel separating this misplaced fresh fuel assembly from the fuel assemblies in the cask area rack. [

. J a,c The second condition is concerned with the fact that one side of the cask area rack does not contain any absorber because it is designed to face the pool wall. While it is considered extremely unlikely that the cask rack could be mis-positioned, if the entire rack is rotated 180 degrees, then the side with no absorber panel will be facing fuel assemblies in Region II. [

. J a,c Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure 4 Page 9 of 10

[Non-Proprietary Information]

. ] a,c

RAl-2

References:

1. WCAP-18830-P, "Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles," September 2023
2. NEI 12-16 Revision 4, "Guidance for Performing Criticality Analyses of Fuel Storage at Light Water Reactor Power Plants"

Appendix A of WCAP-18830-P for the Turkey Point Nuclear Generating Units 3 and 4 fuel storage criticality analysis for 24 months discusses the validation of SCALE 6.2.4, and Table A-21 details the validation area of applicability for the criticality analysis. NRC staff noted the selected critical experiments do not consider [I

))

The guidance provided in Section A.1.1 of NEI 12-16 for the range of parameters to be validated for criticality codes states, with regard to isotopic content, "Experiments should cover materials representative of the rack structure... and others if... used in the criticality analysis." As indicated in Section 4.2.1 of WCAP-18830-P, the [I )) is necessary to maintain multiple fresh and SFP storage arrays subcritical in unborated conditions. Section 4.2.3 of WCAP-18830-p indicates [I )) are conservatively modeled, but it is not clear from the submittal what the approximate magnitude is of the introduced conservatism. Consistent with NEI 12-16, the influence [

)) have on neutronic behavior should be appropriately captured and considered with respect to quantified biases and uncertainties.

Provide the approximate magnitude (e.g., via sensitivity analyses, explicit reactivity comparisons, etc.) of the reactivity conservatism that is introduced by the modeling approach chosen for [I )).

FPL Response:

As discussed in Reference 1 and the related NRC audit, the [ ]a,c used in the Spent Fuel Pool Region I and Region II analyses were modeled conservatively per section 4.2.3 of Reference 1 by [

] a,c Thus, associated neutron cross sectional data must be significantly in error to result in reactivity which is not conservative as modeled. [

. ]a,c Turkey Point Nuclear Plant L-2024-151 Docket Nos. 50-250 and 50-251 Enclosure4 Page 10 of 10

[Non-Proprietary Information]

The cases analyzed contain [

  • ] a,c

Configurations 11-8 and 11-E were evaluated for Region II. [

. ]

a,c The keff differences are presented in Table 3-1, showing the approximate magnitude of the conservatism.

For fuel assembly categories containing burnup, at a minimum, the models used to determine the final burnup limits across enrichments for CFD3 of Reference 1 were evaluated in terms of reactivity differences. Some additional cases were compared in addition to these models. [

] a,c This indicates that a very significant validation gap must exist to exhibit a large impact. For other cases with a larger impact, a significant margin exists.

In addition to this, the approach used to determine the methodology bias and bias uncertainty for both fresh and fresh and burned assemblies with [ ] a,c, was a non-parametric method. The resulting bias is greater than an order of magnitude larger than the appropriately which was determined methodology bias and bias uncertainty for fuel [ ] a,c determined without non-parametric analysis. The non-parametric method applied is very conservative.

[

] a,c

Table 3-1: keff Differences (Nominal Minus Conservative)

Config Min Max a,c

RAl-3

Reference:

1. WCAP-18830-P, Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles," September 2023

General

References:

1. Florida Power & Light Company letter L-2023-077, License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis, October 11, 2023 (ADAMS Accession No. ML23285A035)
2. US Nuclear Regulatory Commission electronic memorandum dated August 20, 2024, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - SFP LAR (L-2023-LLA-0142) (ADAMS Accession No. ML24234A014)
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