ML15233A417

Turkey Point, Units 3 and 4 - Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-

ML15233A417
Person / Time
Site:	Turkey Point
Issue date:	08/11/2015
From:	Summers T Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, L-2015-193, TAC MF0982, TAC MF0983
Download: ML15233A417 (17)

Text

~August 11, 2015L-2015-193I=PLoU. S. Nuclear Regulatory CommissionAttn.: Document Control DeskWashington, D.C. 20555-0001Re: Turkey Point Unit 3 and Unit 4Docket Nos. 50-250 and 50-251Florida Power and Light Company's. Turkey Point Units 3 and 4, Fifth Six-Month Status Reportin Response to March 12. 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA- 12-049)References:1. U.S. Nuclear Regulatory Commission, Order Number EA-12-049, Order toModify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events, dated March 12, 2012, ADAMS Accession No. ML12056A045.2. FPL Letter, L-20 13-06 1, Florida Power and Light Company's Overall Integrated Plan inResponse to March 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA-12-049), dated February 26, 2013, ADAMS Accession No. ML13072A038.3. FPL Letter, L-20 13-249, Florida Power and Light Company's, Turkey Point Units 3 and 4, FirstSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated August 21, 2013, ADAMS Accession No. ML13248A31 1.4. NRC Letter, Turkey Point Units 3 and 4 -Interim Staff Evaluation Relating to Overall IntegratedPlan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0982 and M1F0983),dated February 6, 2014, ADAMS Accession No. M1L14002A151.5. FPL Letter, L-2014-041, Florida Power and Light Company's, Turkey Point Units 3 and 4,Second Six-Month Status Report in Response to March 12, 2012 Commission Order ModifyingLicenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (Order Number EA-12-049), dated February 26, 2014, ADAMS Accession No.ML 14073A454.6. FPL Letter, L-2014-243, Florida Power and Light Company's, Turkey Point Units 3 and 4, ThirdSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated August 27, 2014, ADAMS Accession No. M1L14253A162.7. FPL Letter; L-2015-017, Florida Power and Light Company' s, Turkey Point Units 3 and 4,Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order ModifyingLicenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-BasisExternal Events (Order Number EA-12-049), dated February 26, 2015, ADAMS Accession No.ML 15076A 195.Florida Power &~ Light Company9760 S.W. 344"h Street Homestead, FL 33035

'(" Turkey Point Units 3 and 4 L-20 15-193Docket Nos. 50-250 and 50-251 Page 2 of 2On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1, an immediatelyeffective Order to all licensees including Florida Power and Light Company's (FPL) Turkey Point Units 3and 4. In Reference 2, FPL submitted an Overall Integrated Plan for the implementation of this Order.The Order required Licensee' s to provide periodic status reports for the Overall Integrated Plan.FPL submitted the first six-month update to the Overall Integrated Plan on August 21, 2013 (Reference3). On February 6, 2014, the NRC Staff provided the interim staff evaluation and audit report includingopen and confirmatory items (Reference 4). On February 26, 2014, FPL submitted the second six-monthupdate to the Overall Integrated Plan (Reference 5). On August 27, 2014, FPL submitted the third six-month (Reference 6), and on February 26, 2015 the fourth six-month update (Reference 7) to the OverallIntegrated Plan.The purpose of this letter is to provide the fifth six-month status report pursuant to Section IV, ConditionC.2, of Reference 1, Which delineates progress made in implementing the requirements of Reference 1.The enclosure to this letter provides an update since the fourth six-month status report of milestoneaccomplishments, confirmatory items and open items, including any changes to the compliance method,schedule, or need for relief and the basis, if any.Should you have any questions regarding this submittal, please contact Mr. Mitch Guth, Turkey PointLicensing Manager, at 305-246-6698.I declare under penalty of perjury that the foregoing is true and correct.Executed on August 11, 2015.This letter contains no new regulatory commitments and no revisions to existing regulatory commitments.Sincerely,Thomas SummersSite Vice PresidentTurkey Point Nuclear PlantEnclosure*cc: USNRC Regional Administrator, Region IIUSNRC Project Manager, TurkeyPoint Nuclear PlantUSNRC Senior Resident Inspector, Turkey Point Nuclear Plant L-2015-193EnclosureFlorida Power and Light Company'sTurkey Point Units 3 and 4Fifth Six-Month Status Report for the Implementation of Order EA-12-049Order Modifying Licenses with Regard to Requirements for MitigationStrategies for Beyond-Design-Basis External EventsPage 1 of 15 L-2015-193Enclosure1 IntroductionFlorida Power and Light Company's (FPL) Turkey Point developed an Overall Integrated Plan (OIP)(Reference 2), documenting the diverse and flexible strategies (FLEX), in response to Reference 1. Thisenclosure provides an update of milestone accomplishments since the fourth six-month status reportincluding any changes to the compliance method, schedule, or need for relief/relaxation and the basis, ifany.2 Milestone AccomplishmentsSince the last six-month update, the analyses supporting FLEX strategies have been completed.Specifically, the Reactor Coolant System (RCS) thermal hydraulic response (RETRAN-3D) during anextended loss of alternating current power (ELAP) and loss of normal access to the ultimate heat sink(LUllS) has been issued and the results support the core cooling mitigation and RCS inventory controlstrategies.For Unit 3, detailed design of the mechanical and electrical tie-in modifications is complete. The designmodification for the Unit 3 RCP seal replacement has been issued. Implementation of the on-line Unit 3modifications has been completed. The remaining outage related Unit 3 modifications are on track forimplementation during the upcoming Unit 3 2015 fall refueling outage. Installation of the Unit 3Flowserve low leakage reactor coolant pump (RCP) seal packages, with abeyance seal is included in the2015 fall refueling outage.For Unit 4, all of the design modification packages are complete. The implementation of the Unit 4electrical tie-in modifications are complete as well as the implementation of the on-line mechanical tie-insare complete. Installation of the Flowserve low leakage seal packages with abeyance seal are included inthe 2016 spring refueling outage.The construction of the FLEX storage building was delayed from our original forecast but is nowcomplete, and the majority of the FLEX equipment has been loaded into the building.Additionally, the following activities have started, and some have advanced with substantial progress:Development of the phase 2 staffing analysis, FLEX procedures, training plans and FLEX strategiesvalidation and verification activities.3 Milestone Schedule StatusThe following Table provides an update to Attachment 3 of the OIP. It provides the activity status ofeach item, and whether the expected completion date has changed. The dates are planning dates subjectto change as design and implementation details are developed. Accordingly, the target completion dateshave been adjusted to address procedure development and validation, scheduler completion of the FLEXbuilding, related milestones regarding training plans and ordering equipment. These revised milestonetarget completion dates do not impact Turkey Point's ability to meet the final compliance date for NRCOrder EA-12-049 implementation and are expected to support the NRC audit cilrrently scheduled forAugust 17, 2015.New Milestones:* There are no new milestones.Page 2 of 15 L-2015-193EnclosureRevised Milestones:* The milestone for the phase 2 staffing study was revised to September 2015* The completion of maintenance procedures is revised to November 2015* The completion of operator training on procedures is revised to January 2016* Delivery of phase 3 equipment is revised to September 2015Milestone Target Activity Revised TargetCompletion Date Status Completion DateSubmit 60 Day Status Report Oct 2012 Complete N/ASubmit Overall Integrated Plan Feb 2013 Complete N/ASubmit 6 Month Updates:Update 1 Aug 2013 Complete N/AUpdate 2 Feb 2014 Complete N/AUpdate 3 Aug 2014 Complete N/AUpdate 4 Feb 2015 Complete N/AUpdate 5 Aug 2015 Complete N/AUpdate 6 Feb 2016 Not Started N/AUpdate 7 Aug 2016 Not Started N/AWalk-through or Demonstrations:Complete Analyses Supporting FLEX Strategies Apr-20 15 Complete N/AComplete Final Time Constraint Validations May-20 15 Complete N/AComplete Staffing Analysis (Phase 2) Jun-20 15 Started Sept 2015Complete Final Walkthrough Validation August-20 15 Started N/AModifications:Issue Modification Packages for Unit 3 Mar-20 15 Complete N/AUnit 3 Implementation Complete Nov-20 15 Started N/AIssue Modification Packages for Unit 4 Jun-20 15 Complete N/AUnit 4 Implementation Complete May-20 16 Started N/AStorage:FLEX Storage Building Completed May-20 15 [Complete N/AFLEX Equipment:Order Equipment (procurement phase 1)

• Jun-2014 Complete N/AReceive Equipment (procurement phase l)* Feb-20 15 Complete N/APage 3 ofi15 L-2015-193EnclosureMilestone Target Activity Revised TargetCompletion Date Status Completion DateOrder Equipment (procurement phases 2/3)* Mar-20 15 Complete N/AReceive Equipment (procurement phase 2)* June-2015 Complete N/AReceive Equipment (procurement phase 3)* July-20 15 Started Sept-20 15Develop Strategies (Site Response Plan) with the Jul-20 15 Complete N/ANational Safer Response Center (NSRC) throughoutProcedures:Issue Operations Procedure Changes including FSGs Nov-20 15 Started N/ACreate Maintenance Procedures Jun-20 15 Started Nov- 2015Training:Operations Procedure Changes Training Material May-20 15 Started January 2016CompleteDevelop Training Plan Apr-20 15 Complete N/ATraining Complete Oct-20 15 Started January 2016* Note phase refers to the procurement sequence of equipment to be ordered, not the FLEX Phases as described inNET 12-06.4 Changes to Compliance Method4.1 Changes to ModificationsModification No. 13, FLEX Portable Diesel Generator to Renower Vital 120 VAC Panelsto Reduce Loading on Station Batteries.This modification is being implemented to conserve battery capacity in severe hurricane events,where environmental conditions could potentially delay installation of 480 VAC temporarygenerators and their connection to the vital AC load centers.The modification will install new receptacles on the secondary windings of vital AC ConstantVoltage Transformers (CVTs) that can be used to locally power the vital AC panels. Thesereceptacles will be the connection point for small diesel driven portable generators. TheEmergency Operating Procedures (EOP) and FLEX Supporting Guidelines (FSG) proceduresprovide the procedural controls for the connection of the portable generators to the receptaclesmounted in the CVT cabinets.4.2 Changes to Strategies4.2.1 Current Strategy for Time Critical Actions (OIP Section Page 5 of 101)OLP Section: Provide a sequence of events and identify any time constraint required forsuccess including the technical basis for the time constraint.Page 4 of 15 L-2015-193EnclosureTime Critical Actions:T+I (hour) -Operating Crew Completes Deep Load Shedding (page 6 of 101)"The operating crew completes deep load shedding once the ELAP is declared and before 1hour has elapsed after the event. By completing the deep load shedding in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, run time onthe batteries of 15.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> will be available providing sufficient time to install portable dieselgenerators (Ref 29). Procedural guidance will be provided on the time critical nature of thisactivity and the loads to be shed."Change to the Strategy_ for Deep Load SheddingThere are two scenarios that affect the response to an ELAP event at Turkey Point. The first isan ELAP event that occurs while the units are operating at power. The second scenario is theresponse to a category 4 or higher hurricane.In both cases there will be a deep load shed activity that will commence within approximately30 minutes of the initiation of an ELAP event, and be completed within 90 minutes of theELAP initiation. In the first event, an alternate means of powering the vital 120 VAC panelswill not be initiated as the installation of temporary diesel generators to power the 480 VACvital load centers will be completed in T+8 hours. In the second case, for severe hurricanes(category 4 or 5), there will be advance notice prior to the onset of a hurricane. Pre-staging oftemporary diesel generators in sheltered locations to provide 120 VAC power to vital ACpanels will be completed. This pre-staging does not include connection of temporary diesels,only placing of diesels and cables in needed locations. If an ELAP condition occurs thetemporary cables will be connected and the temporary diesels will be started to carry the vitalAC panel load that has been reduced through the deep load shed activity at approximatelyT+/-1 .5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The repowering of the vital AC panels will also be completed in the same T+l .5hours. These generators (1 per unit) will be used to power the vital 120 VAC panels as anintermediate coping strategy for recovery from the hurricane event timeline. Use of this powersource is only required until the 480 VAC portable diesel generators (PDGs) are available fordeployment following the extended wind condition. Use of the temporary diesel generators isan interim activity that is considered to be an enhancement to the existing coping strategies forrepowering of the vital DC loads during a hurricane event.4.3 Clarification to Strategies4.3.10ILP Section: Safety Functions Support, Portable Equipment Phase 2, Identify Modifications(page: 62 of 101)The following represents clarifications to Turkey Point's FLEX coping strategy for MaintainCore Cooling and Heat Removal Phase 2 (OIP pages 2 1-22) and Portable Equipment Phase 2(OIP pages 61 -62). The Phase 2 coping strategy following an ELAP and LUllS eventcontinues to rely on the use of 480 VAC PDGs to power select electrical loads; includingstation battery chargers. Part of this strategy includes installation of receptacles (viaModification 13) for repowering the vital 120 VAC panels. As discussed in the Enclosure toReference 1, the coping strategy for maintaining core cooling and heat removal variesdepending upon whether or not the precipitating event is a hurricane. During a hurricane eventPage 5 ofi15 L-2015-193Enclosurea high wind condition may exist for an extended period of time and prevent deployment of 480VAC PDGs within the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> assumed in the base (non-hurricane scenario) timeline. Tofacilitate coping with severe hurricane conditions (Category 4 or higher) [consistent with NEI12-06 paragraph 3.2.1.7] separate, temporary diesel generators and cabling will be pre-staged ina location protected from the hurricane specific external conditions.The coping strategy for a hurricane induced ELAP and LUTHS event (as discussed in theEnclosure to Reference 1 and plant procedures) is:1. shutdown the reactor and cooldown to Modes 3, 4 or 5 (specific Mode depends on theprojected strength of the hurricane) at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the onset of projectedhurricane force winds on site. Remain in this condition until it is safe to return topower and reliable off-site power to the site has been restored2. fill both condensate storage tanks (CSTs) to maximum level (prior to the onset ofprojected hurricane force winds on site)3. lock in the steam supply for the auxiliary feedwater (AFW) flow control valves (FCVs)(prior to the onset of projected hurricane force winds on site)4. Stage small PDGs and cabling for powering the 120 VAC power panels for severehurricane storms, with the intention to connect and operate, if an ELAP condition wereto occur.After landfall and high winds have subsided sufficiently to allow full plant access:1. manually operate the AFW FCVs as necessary2. establish CST makeup from the well3. establish a secondary steam generator (SG) injection path4. power the 480 V load centers with the PDG (this action was not previously noted in theReference 1 Enclosure)5. remove vital AC panel loads from the small diesel generators and restore the vital ACportion of the vital DC system to normal alignmentAs noted above, the RCS will be cooled down to Modes 3, 4 or 5 (depending on the projectedhurricane strength) a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to hurricane force winds reaching the plant site.Under this condition the inventory of a single CST will be sufficient to cope with anELAP/LUHIS event for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, by which time AC power, CST makeup,secondary SG makeup, RCS makeup and spent fuel pool (SFP) makeup will have beenestablished. The hurricane specific timetable has also been supported by the results of the RCSthermal hydraulic response (RETRAN-3D) developed specifically for Turkey Point.4.3.2 Current Strategy for RCS makeup and Subcriticality using AccumulatorsOIP Section: Safety Function: Maintain RCS Inventory Control PWR Portable EquipmentPhase 2, Modes 1 through 5 with Steam Generators Available page 33 of 101.In the second six-month update it was stated that the primary method for accomplishing RCSmakeup in phase 2 is the use of the accumulators to make up for losses from the RCP lowleakage seals and for contraction of the primary due to cooldown. Alternate strategies involvethe use of Boric Acid Storage Tank (BAST) or refueling water storage tank (RWST)inventories through the installed charging and boric acid transfer pumps or onsite portable RCSFLEX pump.Page 6 of 15 L-20 15-193EnclosureThis strategy is changed as a result of additional analysis. The revised analysis shows that apressure bubble is created in the reactor head which prevents the accumulators fromdischarging their inventory until a cooldown is commenced. A delay is experienced in the RCSpressure reduction as a result of this bubble. The size of the bubble does not impact hot or coldleg flowpaths. Repowering the charging pump and boric acid transfer pumps will occur within12 hours and they are the primary method to make up to the RCS since there is no accumulatorinventory contribution until the steam generator pressure drops to 220 psig. When steamgenerator pressure drops to 170 psig, accumulators will be isolated. Calculations show that theaccumulator inventory contribution is between 13 and 15%.5 Need for Relief/Relaxation and Basis for the Relief/RelaxationFPL has received an order relaxation for compliance on Unit 3 to coincide with the compliance date forUnit 4. Physical modifications will still be completed as previously planned. This relaxation forcompliance with Order EA- 12-049 requirements had been requested due to the significant unitinterdependency of shared plant systems and the fact that low leakage RCP seals have not yet beeninstalled on unit 4. During the interim period, reactor coolant pump seals will not have been replaced onunit 4, which would complicate the cooldown requirements and event mitigation philosophy on bothunits. There is no impact on meeting the final compliance date for both units.6 Pending Actions from Overall Integrated Plan and NRC Interim StaffEvaluation Open ItemsThe following tables provide a summary of the open items documented in the OIP or the draft SafetyEvaluation (SE) and the status of each item. Resolution of these items will not affect the schedule forcompleting implementation of the Order' s requirements.Page 7 of 15 L-2015-193EnclosureNo. Overall Integrated Plan Open Item (Pending Actions) Target StatusCompletion Date1 Perform a revised analysis of the containment structure once the Being tracked asdetailed performance parameters for the shutdown seals are obtained NRCand using more realistic heat input parameters. April 2015 ConfirnatoryItem 3.2.1.6.AComplete2 A hydraulic analysis will be perfonned to determine the minimum Being tracked asrequirements of the portable FLEX pumps and connection point sizes. NRCThe outputs of this analysis will include a minimum flow and April 2015 Confirmatorydischarge pressure for each pump. Item 3.2.1.9.BComplete3 A hydraulic analysis will be performed to support the ability to heatup from Mode 5 to a condition where the AFW pumps are removing April 2015 Starteddecay heat via the SGs.4 Heat loads will be removed via the SFP Cooling heat exchangers,residual heat removal (RHR) heat exchangers, and ContainmentCoolers. Analysis will be required to determine the minimum January 2015 Completerequirements for ultimate heat sink (UHS) National SAFER ResponseCenter (NSRC) pump.5 Analysis will be required to determine fuel requirements of FLEX Being tracked asequipment. This analysis will determine requirements and capabilities NRCof onsite FLEX portable pumps and diesel generators for Phase 2. April 2015 ConfinnatoryItem 3.2.4.9.AComplete6 A determination of the "drop off' location from the NSRC is pending. Being tracked asOnce selected, the path to the site will be reviewed. NRCMay 2015 ConfirmatoryItem 3.1.1.4.AComplete7 An analysis will be performed to establish the timeline for safety My/05Cmltinjection (SI) or RWST injection for Modes 5 & 68 Complete a final assessment of haul paths and staging areas toconfirm access including review for soil liquefactionApi205Cmlt9Generic WCAP guidance recommends that a site-specific evaluationbe performed once the seal design is completed to validate that thecooldown and depressurization time is supported.Being tracked asNRCConfirmatoryItem 3.2.1.B3April 2015CompletePage 8 of 15 L-2015-193EnclosureNRC Interim Staff Evaluation Open Item Status3.2. 1.8.A- Core Sub-Criticality -Confirm that Turkey Point Closed per the status provided in the 2nd six-monthwill apply the generic resolution for boron mixing under update (Reference 8).natural circulation conditions potentially involving two-phase The status provided confirms Turkey Point willflow, in accordance with the PWROG position paper, dated apply PWROG position paper on boron mixing,August 15, 2013, and subject to the conditions provided in the including the NRC additional considerations.NRC endorsement letter dated January 8, 2014. Alternatively,justify the boric acid mixing assumptions that will ensure Therefore the alternative approach of justifying theadequate shutdown margin exists through all 3 phases of an boric acid mixing assumptions is no longerELAP event. applicable.3.2.1.9. A- The Turkey Point RCS inventory coping strategy Based on NRC comments received regardinginvolves an approach that relies on repowering one of three Attachment 6 of the 2nd six-month update, Turkeyinstalled charging pumps in each unit from multiple power Point has verified and documented compliance in aconnection points using one of the two 100% capacity, portable white paper titled "Turkey Point FLEX Open Item480 VAC FLEX diesel generators. Verify that these installed Paper" that is available through the NRCpumps will be capable of performing their mitigating strategies streamlined process of the audit review.function following an undefined ELAP event, in contrast tousing a portable FLEX pump.3 .2.4.7.A- The licensee relies on separation and redundancy of Based on NRC comments received regardingthe RWSTs to show that at least one will survive a high wind Attachment 7 of the 2nd six-month update, Turkeyevent with wind-driven missiles. Verify that the RWSTs are Point has documented compliance in a white papersufficiently robust and that sufficient separation exists between titled "Turkey Point FLEX Open Item Paper" that isthe tanks to support the determination that at least one tank will available through the NRC streamlined process ofbe available as a water source following a high wind event, as the audit review.credited in the Turkey Point mitigating strategies.7 Potential Draft Safety Evaluation ImpactsSee FPL response to open items in Section 8.8 Interim Staff Evaluation Confirmatory ItemsConfirmatory¢ Item 3.1.1.3.A:Confirm that the large internal flooding sources that are not seismically robust will not impact theimplementation of the mitigating strategies during an ELAP event.Response:Complete -The components required to implement the mitigating strategies during an ELAP eventhave been identified. The component locations and the travel paths associated with the mitigatingstrategies have also been identified. A detailed analysis has been performed to determine that thereare no adverse effects from an internal flooding event. There are no non-seismic tanks or piping inthe auxiliary building upper elevations (where equipment relied upon for the strategies are located).Flooding from any failures of tanks or piping on the secondary side of the power block or yard areaswould not occur based on the open design of the structures and adjacent terrain. There is no impacton the flex strategy for external flooding events given the flat open terrain surrounding the Plant andthe short duration of the flooding that would be present for such events.NRC question 5 indicated that Turkey Point did not consider considerations 2 and 3 of NEI 12-06section 5.3.3. FPL's response to question 5 provided the response that mitigation of large non-seismically robust hazards does not require AC power, and mitigation of ground water does notPage 9 of 15 L-2015-193Enclosurerequire AC power. Portable diesel driven pumps would be prestaged in advance of a hurricane forcases where water would be retained within the flood barrier system from heavy precipitation.Confirmatory Item 3.1.1.4.A:Off-Site Resources -Confirm the location of the local staging-area for the NSRC equipment, and thataccess routes to the site, the method of transportation, and the drop off area have been properlyevaluated for all applicable hazards.Response:Multiple meetings with the NSRC team have been held. A final NSRC report has been issued whichapproved the staging areas, transportation methods and properly evaluated routes for all expectedhazards.Confirmatory Item 3.2.1.A:Confirm recalculation of the boration requirements for the Phase 2 RCS cooldown to provideadditional margin and flexibility for the boration activity.Response:Complete -Calculations have been completed to determine that additional boration is required at 13hours to achieve a Keff below 0.00 at 396°F (RCS temperature resulting from SG pressure at 220psig). Injection of accumulators will start but the calculation does not credit boron injection fromthe accumulators. RETRAN-3D best estimate ELAP analysis has concluded that Turkey Pointremains in natural circulation beyond 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Therefore the RCS will be in natural circulation at13 hours when boration will commence with charging pump operation. Separately, calculationsshow that boration is not required to remain subcritical until cool down below 400°F at T+/- 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.Confirmatory Item 3.2.1.B:Confirm the analysis used to validate the RCS cooldown and depressurization timeline once the RCPlow-leakage seal design is completed.Response:Completed -The capability to initiate an early cooldown depends on the status of the CSTs andrestoring Steam Dump to Atmosphere (SDTA) valve capability. Providing a CST makeup watersource and enabling SDTA capability is expected to take 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Starting a cooldown after 12hours is acceptable based on limited RCS losses of the low leakage RCP seals and an RCStemperature that would stabilize at 556°F, which is the saturation temperature for Main Steam Safetyvalve with the lowest pressure setpoint.The engineering modification package for the RCP low leakage seal and a RETRAN analysis werecompleted which enveloped the effects of a delay of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for initiation of the RCS cooldown.Until the cooldown commences, there is some predicted degradation of the RCP seal 0-rings.Procedurally the RCP seal leak off flowpath will be isolated within 30 minutes by closure of thecombined bleed off valve (CBO). The CBO valve will remain closed by virtue of an accumulatorthat would store sufficient air volume to keep the valve closed for at least 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, in the case of anat power trip which assumes a cooldown starts at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.Without cooling down from an RCS temperature of 556°F, leakage through the postulated failed seal0-ring would be on the order of 1.65 gpm per RCP and would be expected to start at about 7.8hours. RETRAN-3D was used to identify the onset of reflux cooling. The RETRAN analysis uses amuch higher leak rate of 5.25 gpm per RCP and shows that the onset of reflux cooling would notoccur until T+ 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.Page 10 of 15 L-2015-193EnclosureConfirmatory Item 3.2.1.1.A:Reliance on the NOTRUMP code for the ELAP analysis of Westinghouse plants is limited to theflow conditions before reflux condensation initiates. This includes specifying an acceptabledefinition for reflux condensation cooling. Confirmn that Turkey Point has properly applied theseconditions for the ELAP analysis.Response:In Progress- RETRAN has been selected as the code and methodology for performing the RCScooldown analysis during reflux conditions. The RETRAN methodology is already under NRCreview for applicability to STP. The Turkey Point analysis will be consistent with the NRCacceptance of the STP methodology for the RCS cooldown analysis.Confirmatory Item 3.2.1.1.B:Confirm recalculation of the SG pressure setpoint to prevent injection of nitrogen from theaccumulators using the guidance in the PWROG position paper.Response:Completed- This calculation has been finalized and the lowest SG pressure value (220 psig) toisolate accumulators has been incorporated into the applicable EOP and FSG procedures.Confirmatory Item 3.2.1.1.C:Confirm site-specific evaluation for controlling containment pressure using MAALP to determinewhen containment venting must be initiated.Response:Completed- Our Modular Accident Analysis Program (MAAP) analyses looked at two conditions,the first is for Mode 1 through 5 with steam generators available for heat removal. The secondanalysis reviewed Modes 5 and 6 with steam generators not available. In the first case, with steamgenerators available, containment pressure will reach a maximum increase of 4.3 psi within theevaluated 120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> timeframe. This is within the design pressure rating of containment. The methodto cool and vent containment will rely on phase 3 equipment that will enable the use of theemergency containment coolers to reduce containment temperature, use of the RIIR system toreduce RCS temperature and bleed off containment pressure through the instrument air bleed path,when instrument air becomes available. For times when steam generators are not available, theoutage risk procedure will direct opening both doors of a personnel hatch or the equipment hatch toprevent a pressure increase.Confirmatory Item 3.2.1.2.A:Confirm that the RCP seal leakage rate of one gpmlseal for the Flows erve safe shutdown/lowleakage seals used in the ELAP analysis is adequately justified, including the computercode/methodology and assumptions used, and the supporting test data applied, when the site specificevaluation is performed.Response:In Progress-FLOWSERVE submitted a white paper on this item .to the NRC which has beenaccepted by the NRC. Flowserve is preparing a formal submittal to the NRC on the outstandingPage 11 of 15 L-20 15-193Enclosureissues and an endorsement from the NRC is expected shortiy thereafter. Turkey Point will providean update to this in the next six-month update report after the endorsement is received.Confirmatory Item 3.2.1.5.A:Confirm that the instrumentation used to measure the listed parameters and the associated setpoints,credited in the ELAP analysis for automatic actuations and indications required for the operator totake appropriate actions, is reliable and accurate in the containment harsh conditions resulting froman ELAP event.Response:Completed -As noted in the third six- month update, (Reference 9), containment wide rangepressure transmitters do not have full environmental qualification (EQ) requirements and do notrequire EQ qualification. These transmitters are located outside of containment in a mildenvironment and will read containment pressures up to 180 psig. Our calculations determined thatcontainment pressure will not exceed 19 psia. The location of the transmitters will not exceed 105degrees F.Clarification Note: In Attachment 6, Figure 1 of the OIP, it was stated that the Safety InjectionAccumulators have wide range level transmitters. However, it is determined that the leveltransmitters are scaled for a narrow range for providing a more precise monitoring for TechnicalSpecification compliance. These transmitters are not EQ qualified and are not used in any of themitigation strategies. MAAP analysis was used to determine containment environmental conditionsduring an ELAP event. The MAAP analysis concluded that containment environmental conditionscreated by an ELAP event are enveloped by our EQ analysis.Confirmatory Item 3.2.1.6.A:Confirm that the revised Modular Accident Analysis Program containment analysis supports therevised strategy for maintaining containment (reliance on containment venting instead ofcontainment spray), and also confirm that the Sequence of Events timeline is properly revised andany impacts of the changes are appropriately addressed.Response:In Modes 1 through 4 and Mode 5 with steam generators available, MAAP concluded thatcontainment pressure will reach a maximum of 19 psia and a temperature of 1 920F. These valuesare well within the containment design pressure of 69.7 psia and a design temperature of 2830F.In Modes 5 and 6 with steam generators not available, core decay heat is released to containmentduring feed and bleed actions. The MAAP analysis concluded that containment pressure will notincrease if both doors of a containment air lock or the equipment hatch is opened or remain open,prior to RCS boiling. Control of the containment penetration airlocks will be controlled by plantprocedures.There is no impact on our sequence of events timeline. No additional action is required for eventsthat would occur when steam generators are available and during outage conditions, when steamgenerators are not available, there are additional personnel on site to properly secure the personnelhatch doors or the equipment hatch in the open position.Page 12 of 15 L-20 15-193EnclosureConfirmatory Item 3.2.1.9.B:Confirn completion of the licensee's final engineering designs and supporting analyses for portableequipment that directly performs a FLEX mitigation strategy.Response:Design engineering packages have been completed for portable equipment that directly performs aFLEX mitigation strategy. These engineering packages included calculations that specifyi theminimum flow values, minimum and maximum hose lengths and discharge pressures for the pumps.Confirmatory Item 3.2.3.A:Confirm that FLEX MAAP containment analyses will be revised and results included in the 6 monthupdate report.Response:MiAAP containment analyses have been revised and the results show that containment pressure forconditions when steam generators are available for RCS heat removal in Modes 1 through 5 willreach a maximum of 19 psia within the evaluated 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. Containment temperature will reach190°F in this same period.For conditions where steam generators are not available in Modes 5 and 6, containment pressuredoes not exceed atmospheric pressure by opening both inner and outer doors of a personnel hatch orthe equipment hatch prior to RCS boiling. For refueling outage conditions, these hatches are openedupon reaching Mode 5 and before the RCS is depressurized. Before exiting Mode 5 on a unitstartup, steam generators are available prior to closing the hatches.Confirmatory Item 3.2.4.1.A:Confirm that the charging pumps have adequate cooling following an ELAP event (i.e., throughintermittent operation, or by providing cooling to the fluid drive heat exchanger).Response:Charging pump cooling has been determined to be sufficient by providing deep well water to thefluid drive heat exchanger. This activity has been completed.Confirmatory Item 3.2.4.4.A:The NRC staff has reviewed the licensee communications assessment (ADAMS Accession Nos. NIL123 00A425 and ML 13064A359) and has determined that the assessment is reasonable (ADAMSAccession No. ML13 149A3 82). Confirm that upgrades to the site's communications systems havebeen completed.Response:All design changes to provide upgrades to the communications system have been implemented. Thecompletion commitment date for full implementation of June 1, 2015 was satisfied.Page 13 of 15 L-2015-193EnclosureConfirmatory Item 3.2.4.9.A:Confirm completion of the refueling plan for portable FLEX equipment and sizing of the refuelingtrailer.Response:The refueling plan for the phase 1 and 2 strategies has been completed. The plan's strategy calls forthe use of an onsite diesel fuel oil refueling trailer to transfer fuel from the Unit 4 Diesel Oil StorageTank to those components that require diesel fuel oil to operate. There is sufficient refueling trailercapacity (1000 gallons) and the interval to load the refueling trailer and refuel all FLEX devices iswithin the fuel consumption rates for the specific equipment. There are multiple tow vehiclesavailable to transport the refueling trailer around to the diesel driven FLEX equipment and stillsupport other activities that require a tow vehicle. For phase 3 equipment, contracts are in place toprovide diesel fuel to the station on a priority basis during an emergency.Confirmatory Item 3.4.A:Confirm that NEI 12-06, Section 12.2 guidelines 2 through 10 regarding offsite resources have beenadequately addressed.Response:FPL has conducted an onsite meeting with the NSRC representatives in December 2014. Evaluationof the proposed drop site and the submittal of the Site Response Plan has been coordinated andcompleted with the SAFER team. The plan includes the maintenance testing, calibration, storageand control of phase 3 equipment. The surveillance testing and maintenance of the offsite equipmentfollows the NEI guidance for out of service time and contingency actions will align with stationrequirements for out of service equipment.Connection points for the phase 3 equipment have been incorporated into the design of thepermanent plant connection points, and the phase 2 equipment connection points and methods arethe same as what would be delivered by the NSRC for phase 3. The connection of the 4 kV portablediesel generators for phase 3 will require some disassembly at one of the plant 4kV bus cubicles.This is covered by the FLEX support guidelines.Contractual arrangements have been made for the maintenance and testing of the offsite phase 3equipment. Station configuration and design control procedures have been revised to reserve andmaintain the phase 3 connection points and spatial clearances.9 References1. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012, ADAMSAccession No. M1L12056A045.2. FPL Letter, L-2013-061, Florida Power and Light Company's Overall Integrated Plan in Responseto March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements forPage 14 of 15 L-2015-193EnclosureMitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"dated February 26, 2013, ADAMS Accession No. ML13072A038.3. FPL Letter, L-20 13-249, Florida Power and Light Company's, Turkey Point Units 3 and 4, FirstSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated August 21, 2013, ADAMS Accession No.M1L13248A3 11.4. Westinghouse Letter, LTR-FSE-13-46, Rev. 0, Westinghouse Response to NRC Generic Requestfor Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water ReactorOwners Group (PWROG), Dated August 15, 2013, Proprietary ADAMS Accession NoM!L13235A135.5. NRC Letter from Jack Davis, Director, Mitigating Strategies Directorate Office of Nuclear ReactorRegulation to Mr. Jack Stringfellow, Pressurized Water Reactors Owners Group, dated January 8,2014, ADAMS Accession No. ML13276A1 83.6. NRC Letter, Turkey Point, Units 3 And 4 -Interim Staff Evaluation Relating To Overall IntegratedPlan In Response To Order Ea-12-049 (Mitigation Strategies) (TAC NOS. MVF0982 ANDMF0983), dated February 6. 2014, ADAMS Accession No. ML14002A160.7. FPL Letter, L-2013-087, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)Regarding the Flood Hazard Reevaluation of Recommendation 2.1, dated March 11, 2013,ADAMS Accession No. ML13 095A 196.8. FPL Letter, L-2014-041, Florida Power and Light Company's, Turkey Point Units 3 and 4, SecondSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated February 26, 2014, ADAMS Accession No. ML14073A454.9. FPL Letter, L-2014-243, Florida Power and Light Company's, Turkey Point Units 3 and 4, ThirdSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated August 27, 2014, ADAMS Accession No. ML14253A162.10. FPL Letter L-2015-010, Florida Power and Light Company' s Turkey Point Units 3 and 4,Supplemental Information Regarding L-2014-199 "Response to NRC 10 CFR 50.54(f) Request forInformation Regarding Near-Term Task Force Recommendation 9.3, Emergency Preparedness"Commitment Revisions.11. FPL Letter, L-2015-017, Florida Power and Light Company' s, Turkey Point Units 3 and 4, FourthSix-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenseswith Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049), dated February 26, 2015, ADAMS Accession No. ML15076A195.10 AttachmentsNone.Page 15 ofl15