ML14213A078
| ML14213A078 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/18/2014 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14213A077 | List: |
| References | |
| L-2014-197 | |
| Download: ML14213A078 (20) | |
Text
FPL.July 18, 2014L-2014-19710 CFR 2.39010 CFR 50.90U.S. Nuclear Regulatory CommissionDocument Control DeskWashington, D.C. 20555-0001Re: Turkey Point Nuclear Generating Station Units 3 and 4Docket Nos. 50-250 and 50-251Response to Request for Additional Information Regarding License AmendmentRequest No. 216 -Transition to 10 CFR 50.48(c) -NFPA 805 Performance-BasedStandard for Fire Protection for Light Water Reactor Electric Generating Plants (2001Edition)By Florida Power and Light Company (FPL) letter L-2012-092 dated June 28, 2012, inaccordance with the provisions of 10 CFR 50.90, "Application of License or ConstructionPermit," FPL requested an amendment to the Renewed Facility Operating License (RFOL) forTurkey Point Nuclear Generating Station Units 3 and 4. The License Amendment Request(LAR) will enable FPL to adopt a new fire protection licensing basis which complies with therequirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide(RG) 1.205.On July 14, 2014, the NRC Staff requested additional information regarding the LAR.Attachment 1 to this letter provides the response to the requests for additional information(RAIs) that involve clarifications of the Turkey Point Probabilistic Risk Assessment (PRA)methodology with the exception of RAI PRA 07.01c.01. As discussed with the NRC Staff,response to RAI PRA 07.01c.01 will be provided by July 31, 2014. The additional informationdoes not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration"previously provided in FPL letter L-2012-092.This letter revises the new Table S-3 Implementation Item proposed by FPL letter L-2014-071dated April 4, 2014. This letter does not add any new commitments.Enclosure 1, "PRA Model for Flowserve 3 Stage N-Seals with Abeyance Seal," Revision 0, datedDecember 20, 2013, contains proprietary information to Flowserve Corporation. Enclosure 1 isreferenced in the Attachment to this letter in the response to PRA RAI 29.b.1. Enclosure 2provides the supporting affidavit signed by Flowserve Corporation, the owner of the information.The affidavit sets forth the basis for which the information may be withheld from public disclosureby the Commission and addresses with specificity the considerations listed in 10 CFR Section2.390 paragraph (b)(4). Accordingly, it is requested that the information which is proprietary toFlowserve Corporation be withheld from public disclosure.If you should have any questions regarding this application, please contact Robert Tomonto,Licensing Manager, at 305-246-7327.Florida Power & Light Company9760 SW 344 St Homestead, FL 33035 L-2014-197Page 2 of 2I declare under penalty of perjury that the foregoing is true and correct.Executed on July 18, 2014.Michael KileyVice PresidentTurkey Point Nuclear Generating StationAttachment and Enclosurescc: Regional Administrator, Region II, USNRCSenior Resident Inspector, USNRC, Turkey PointUSNRC Project Manager for Turkey PointMs. Cindy Becker, Florida Department of Health Attachment to L-2014-197Page 1 of 12L-2014-197 AttachmentResponse to Request for Additional Information RegardingLicense Amendment Request No. 216Florida Power and Light CompanyTurkey Point Nuclear Generating Station Units 3 and 4Transition to 10 CFR 50.48(c) -NFPA 805Performance-Based Standard for Fire Protection forLight Water Reactor Electric Generating Plants, 2001 Edition Attachment to L-2014-197Page 2 of 12PTN RAI PRA 01.j.01.01The response to PRA 01 .j.01 identified several fire-specific parameters for which Monte Carlouncertainty has been performed to generate mean values that include state-of-knowledge-correlations (SOKCs). The response reported that the mean values are no more than onepercent higher than the point estimates. A one percent difference of a total core damagefrequency (CDF) of about 5 x 105/year is a negligible value compared to the CDF guideline of1 x 10-5/year for transition. The entry for PRA RAI 01 .j in the Table on page 94 of 101 under"Post Transition PRA Disposition" in the response dated April 4, [1]2014, states that the "Pointvalue will continue to be used based on the point value being consistent with the mean value."A one percent difference of a total CDF of about 5 x 10-5/year is about 5 x 1007/year, which is fivetimes greater than the self-approval CDF guideline after transition. If mean values will not begenerated post-transition, clarify in the "Post Transition PRA Disposition" how the results of thepost-transition fire risk evaluations will be verified to be close enough to the mean that they candistinguish between lying above or below the self-approval mean value guidelines.RESPONSE:The Monte Carlo calculations are performed to assess the impact of the SOKC. Normally, themean CDF obtained is very close to the point estimate. If they are sufficiently close, like the 1%difference for the total fire CDF, then using the point estimate is justified. There is no need toperform Monte Carlo calculations to assess the impact of the SOKC for any future delta riskcalculations as 1) the difference for the base case is minimal, and 2) the difference for the deltarisk calculation will be similar and will subtract out.As part of any PRA model update, these same SOKC calculations are updated and the variancebetween the mean and the point value are assessed to ensure a small variation between thetwo values.The PRA RAI 29 disposition has been revised in the associated entry for the PRA RAI 29 tableprovided below. The table below reflects the change made from that provided in the originalPRA RAI 29 response on April 4, 2014.Issue Final Composite Post Transition PRAAnalysis Disposition DispositionPRA RAI 01.j.01 regarding Confirmation of Given the SOKCthe state-of-knowledge uncertainty analysis mean calculations show minimalcorrelation (SOKC) value consistent with the difference between thetreatment in post-transition point value used. mean and point values, thefire risk evaluations point values will be used tojudge whether the changemeets the self-approvalguidelines.SOKC calculations will beperformed following eachmodel update to verifyminimal variance betweenthe mean and point values.
Attachment to L-2014-197Page 3 of 12PTN PRA RAI 01.k.01In the April 4, 2014, RAI response to PRA RAI 29a, the entry for PRA RAI 01 .k in the Table onpage 92 of 101, under "Post Transition PRA Disposition," states that "[c]redit for joint HEPs[human error probabilities] below 1 OE-051 will be retained with adequate justification per thePRA Standard." NUREG-1921 indicates, and NUREG-1792 (Table 2-1) states that joint HEPvalues should not be below 10-5. Electric Power Research Institute (EPRI) Table 4-3 provides alower limiting value of 10-6 for sequences with a very low level of dependence. Alternatively, theNRC staff has accepted general use of a 10-5 floor value for fire specific joint HEPs and 10-6floor value for joint HEPs from the internal events that are credited in the fire PRA withoutadditional justification for individual HEPs.i. Confirm that each HEP value used to support the LAR below 10-5 includes its ownjustification that demonstrates the inapplicability of the NUREG-1 792 lower valueguideline. Provide an estimate of the number of joint HEPs between 10-5 and 10-6 and atleast two different examples of the justification.ii. Confirm that each HEP value below 10-6 further includes its own justification thatdemonstrates that all the individual actions are independent. Provide an estimate of thenumber of HEPs less than 10-6 and at least two different examples of the justification.iii. Clarify in the "Post Transition PRA Disposition" how joint HEPs will be retained.1 -1 OE-05 in the RAI text was clearly intended to be 1.OE-05.RESPONSE:The final fire PRA quantification (to be provided with final responses to the current group ofRAIs) which will constitute the Post Transition PRA model, will be performed in the followingmanner with respect to joint HEP dependency floor values:1. Quantify the fire CDF and LERF using a recovery rule file with a dependency floor of1E-5.2. Identify the Human Failure Event (HFE) combinations with a probability of 1 E-5 due toimposition of the dependency floor that have a significant impact on the fire CDF andLERF results.3. Individually analyze these HFE combinations to see if a lower combination eventprobability can be justified.4. Document the justification for the lower probabilities for these HFE combinations, anduse the adjusted probabilities in the fire CDF and LERF quantifications.PTN PRA RAI O1.r.02.c.01The April 4, 2014, response to RAI PRA 01.r.02.c states that "scenarios have been created forthe back panels in which adjacent panels are assumed to be impacted from fire propagation."Briefly summarize how the method to consider propagation of fire beyond the ignition sourcecabinets in the back panels of the main control room aligns with the approach recommended inAppendix S of NUREG/CR-6850. If the approach differs, provide justification for its use.
Attachment to L-2014-197Page 4 of 12RESPONSE:The Turkey Point Main Control Room includes two types of panels in the "back panel area".The first type is the main control board vertical boards (3C03, 3C04, 3C05, 3C06, 4C03, 4C04,4C05, 4C06), located behind the main control board. These panels are open back panels whichform an "L" shape with two panels on each side of the "L" with the closed side of the panel andthe opening of the "L" facing the unit's main control board console and the opposite unit. Thesecond type of panel in the "back panel area" is a stand-alone panel configuration which facesthe open side of the open vertical board. These panels are separated from each other bydouble wall and air gaps. Figure 1 is a markup of Turkey Point drawing 561 0-E-1 28 whichhighlights the following:* Main control board (orange),* Main control board open back panels (pink) and" Stand-alone panels (blue/green, no significance in the two colors used).The analysis of the open back panels assumes a fire in each panel will spread to one adjacentpanel. Scenarios are evaluated for the following panel combinations:3C04/3C033C03/3C053C05/3C064C03/4C044C04/4C054C05/4C06The analysis of the stand-alone back panels is based on no fire spread between these backpanels where double wall and air gap configuration exists (most of these panels have doublewall air gap between them; in cases where they do not, the fire is assumed to impact bothadjacent panels). Transient fires are postulated between the open back panel and the stand-alone panels which face the open back panels. Each transient fire scenario is assumed toimpact the adjacent open back panel section and two adjacent stand-alone panels. Suchscenarios are postulated for each combination of two stand-alone panels and the open backpanel which faces them. For transient fires at the centerline between the adjacent open backpanels both of these panels are assumed to be impacted.This methodology is consistent with that specified in NUREG/CR-6850, Appendix S. Asummary of the guidance in Appendix S and how the guidance is addressed in the evaluation ofthe back panel area is provided below:1. Fire Propagation to Adjacent Cabinet:a. "Assume no fire spread if... Cabinets are separated by a double wall withan air gap... "(p. S-1, item 1 at the bottom of the page)b. This assumption is applied for the stand-alone panels (as describedabove).2. Fire Damage to Adjacent Cabinet:a. "Assume loss of function in an adjacent cabinet if there is not a doublewall with an air gap." (p. S-3, 1s" bullet)b. This assumption is applied for the open back panels in the back panelarea.
Attachment to L-2014-197Page 5 of 123. Fire Damage to Second Adjacent Cabinet:a. "Assume no damage in the second adjacent cabinet occurs until after thefire propagates to the adjacent cabinet." (p. S-3, 2nd bullet)b. Not applicable to the stand-alone panels since there is no fire propagationbetween panels with double walls and an air gap. Due to the large sizeand open configuration of the vertical boards (open back panels) and theirlocation within the continuously manned control room, fire spread to asecond adjacent panel is not expected or postulated. A fire impacting twoadjacent vertical boards would need to travel a horizontal distance of atleast 8 feet in two opposite directions (each of the vertical board openback panels is sixteen feet wide) and would need to traverse the 90degree corner between two adjacent panels. With the open panelconfiguration this type of fire spread is not expected prior toextinguishment activities which would limit further spread of the fire (notnecessarily completely extinguishing the fire). Horizontal fire spread viathe non-qualified cables over a distance of 8 feet would requireapproximately 45 minutes (based on the horizontal spread rate specifiedin NUREG/CR-6850, Appendix R, Section R.4.1.2 for non-qualified (PVC)cables).4. Damage to Sensitive Electronics:a. "Assume damage to sensitive electronics occurs at 10 minutes if there isa double wall with an air gap.Assume damage to sensitive electronics can be prevented before 10minutes if the fire is extinguished and the cabinet is cooled, e.g., by CO2extinguishers." (p. S-3, 4th bullet and paragraph following the bullet).b. Given the location in the continuously manned control room, action tosuppress the fire is expected to be initiated within 10 minutes and, even ifthe fire is not extinguished, it is expected that the fire would be controlledand its impact on sensitive electronics in an adjacent panel separated bydouble wall and air gap would be precluded. The spread of a fire in theopen back panels that could spread to an adjacent panel will not impactsensitive electronics beyond the adjacent panel given the openconfiguration of the panels which will more readily dissipate the heat withrespect to impact on a third panel (see discussion in item 3 aboveregarding time required for fire spread to a third panel). Therefore, thecontinuously manned control room will ensure that fire extinguishment willbe initiated and the fire will be cooled, if not controlled, in a short timeafter initiation thus precluding damage to sensitive electronics.Based on the discussion above, the analysis of control room panels in the main control room isconsistent with the guidance of NUREG/CR-6850, Appendix S.
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- 44 ... 5 ýWW'I I Attachment to L-2014-197Page 7 of 12PTN PRA RAI 01.t01.01In the April 4, 2014 response to PRA RAI 29, the entry for RAI 01.t.01 in the Table on page 95of 101 under "Final Composite Analysis Disposition" states that the Fire PRA "[e]liminated panelfactors and incorporated use of NUREG/CR-6850, Appendix H." However, this disposition doesnot fully characterize the modeling changes addressed by the response to PRA RAI 01 .t.01(e.g., those associated with the damage accrual function and its treatment of the preheating oftargets, treatment of dependencies between manual non-suppression probabilities, the reliabilityand unavailability of credited automatic detection and suppression systems, etc.). Clarify in the"Final Composite Analysis Disposition" that the fire PRA used to support the final compositeanalysis and post-transition will be updated to incorporate the analysis and modeling changesdescribed in the response to PRA RAI 01 .t.01.RESPONSE:The PRA RAI 29 disposition has been revised in the associated entry for the PRA RAI 29 tableprovided below. The table below reflects the change made from that provided in the originalPRA RAI 29 response on April 4, 2014. The analysis incorporating the PRA RAI 01 .t.01 will beprovided in conjunction with the final RAI responses associated with this set of RAIs.Issue Final Composite Post Transition PRAAnalysis Disposition DispositionPRA RAI 01 .t-01 regarding Eliminated panel factors The post transition fire PRAreplacement of panel and incorporated use of model will be the finalfactors with a new fire NUREG/CR-6850, composite analysis modelscenario development Appendix H. which has been updated tomethodology instead of incorporate the analysisacceptable methods and modeling changesdescribed in the responseto PRA RAI 01t01.PTN PRA RAI 11.01.c.01The April 4, 2014, response to RAI PRA 11.01 .c did not provide the requested frequencies forthe fire-induced main control room (MCR) abandonment scenarios. The results of the delta-riskevaluation for MCR abandonment documented in the license amendment request andexperience from other NFPA-805 reviews indicate that the assumption about the probability offailing to successfully shutdown after MCR abandonment is a key assumption that can directlyimpact the regulatory decision. To support resolution of this key assumption, provide therequested MCR abandonment frequency for the compliant case, and for each of the threevariant case bins developed from the final composite analysis.RESPONSE:The control room abandonment analysis is not yet finalized. The control room abandonmentfrequency will be provided in conjunction with the final RAI responses associated with this set ofRAIs. The format of that input will be:
Attachment to L-2014-197Page 8 of 12Calculated CCDP CCDP Bin (CCDP TotalRange Value Used in AbandonmentEstablishing Total Frequency ofVariant Risk) AssociatedScenarios (peryear) -applicableto the variant caseas well as thecorrespondingcompliant case< 1E-03 0.1 X< 0.1, 0.2 Y> 1 E-03> 0.1 1.0 ZPTN PRA RAI 13.01 .c.01The April 4, 2014, response to PRA RAI 13.01.c states that the methods used for evaluatingACDF and ALERF provide a conservative bounding analysis of the delta risk." An overestimateof the compliant plant risk, unless offset with a similar overestimate in the variant plant risk,results in a non-conservative analysis of the delta risk. The method applied to the cablespreading room described in the response to RAI 13.01 .a and summarized below appliesdifferent assumptions to the variant and the compliant plant risk estimates with an indeterminatebut most likely non-conservative impact on the change in risk estimate.The March 18, 2013, response to PRA RAI 13 states that "[tihere are no outside control roomfires which result in the loss of sufficient control room control capabilities to warrant control roomabandonment. For a control room fire, control room abandonment results from habitability(temperature and visual impact of the fire)." The response to PRA RAI 13 discusses cablespreading room fires and states that following fires in this area, the plant will be shut down usingthe MCR and assisted by primary control station (PCS) actions as needed. Nevertheless, PRARAI 13.01 states that cable-spreading room fire "scenarios with variant-case CCDP [conditionalcore damage probability] >0.056 (...) used 0.056 as the compliant case CCDP." The 0.056value was developed to characterize the failure to shut down using only a single, least reliabletrain and after MCR abandonment. This approach sets the variance from deterministicrequirements (VFDR) delta risk to zero for all scenarios having a variant-case CCDP less than0.056. Hence, this approach, and any similar approach that essentially sets to zero the deltarisk for scenarios impacting VFDRs (e.g., assuming such impact only for hot gas layer (HGL)scenarios), is non-conservative for the delta risk. There appears to be no reason to use worstcase MCR abandonment CCDP for every fire in the cable spreading room that doesn't alwaysfail all equipment but the least reliable train, and that doesn't require the operator to abandonthe MCR. In general, compliant case CCDPs for the cable room fires should be smaller thanthe worst-case MCR abandonment CCDP. Apparently the variant case CCDP has beenestimated (to know whether it is greater than 0.056), and the accepted method of removingvariations from deterministic requirement failures from the variant case models to represent thecompliant plant could be applied. An alternative is to not credit MCR abandonment due to lossof control and resolve VFDRs in the compliant case (e.g., set associated recovery actions in the Attachment to L-2014-197Page 9 of 12variant case to successful). Provide a change in risk estimate that is not indeterminately nonconservative.RESPONSE:Further review of the cable spreading room compliant case configuration is being pursued. Thecompliant case CCDP will be re-calculated based on credit for equipment available at thealternate shutdown panel (ASP) with equipment failures only applied to these components (toconservatively assume a human error probability, HEP, of zero). Components required tosupport the operation of the components at the ASP, which are not currently available at theASP, will also be credited based on equipment failures only and an assumed HEP of zero. Thisapproach provides a compliant case risk for the control room abandonment assuming allrequired actions can be performed at the primary control station (i.e., the ASP), consistent withguidance of RG 1.205, Rev. 1.Since the control room abandonment procedures credit offsite power, if available, restoration ofoffsite power at the ASP will also be assumed based on equipment failures only and an HEP ofzero. Although the ASP design is not intended to ensure the availability of offsite power, thisapproach is included to provide a more realistic estimate of the compliant case CCDP andreduce potential non-conservative delta risk estimates.Variant case fire scenarios where the CCDP is less than this compliant case CCDP areconsidered to be sufficiently low to not require control room abandonment, and will therefore notcontribute to the delta risk. The variant case for these scenarios will be included in the total riskbased on shutdown from the control room.The final risk results incorporating the above methodology will be provided in conjunction withthe responses to the remaining RAIs.PTN RAI PRA 18.01.01The April 4, 2014, response to PRA RAI 18.01 states that a review of transient controls duringthe period between November 2009 and April 2012 revealed violations "primarily related tooutage activities," which implies that at least some violations were identified during poweroperations or low-power operations, such as plant start-up. In accordance with thememorandum dated June 21, 2012 (ADAMS Accession No. ML12171A583), from Joseph Guitterto Biff Bradley, titled, "Recent Fire PRA Methods Review Panel Decisions and EPRI 1022993,'Evaluation of Peak Heat Release Rates in Electrical Cabinets Fires,"' characterize theseviolations, considering whether (1) they impact the transient fire HRR determination and(2) whether they reflect isolated incidents or a more general pattern of violations.RESPONSE:Previously, as discussed in the response to PTN RAI PRA 18.01, a review of transientcontrols during the period for November 2009 to April 2012 was performed. The reviewconcluded that the violations of transient controls during this time period were found tobe primarily related to outage activities, many of which were related to significant scopeExtended Power Uprate (EPU) outages during this time period. Also, a review ofdocumentation to determine if any transient fires had been experienced was performedwith no fires identified.
Attachment to L-2014-197Page 10 of 12As part of this response, a second review of the transient controls during the time periodof November 2009 to April 2012 was performed. This review was concentrated on thenon-outage time frame. The quantity of issues related to transient controls decreasessignificantly when the issues related to outage activities are disregarded. From thequantity of issues related to transient controls during non-outage time frame, only twoissues were identified related to the fire zones/areas crediting the reduced transientheat release rate. These fire zones/areas are:* Fire Zone 058 / Fire Area F -Unit 3 and Unit 4 Auxiliary Building 18' ElevationHallway* Fire Zone 079A / Fire Area CC -Unit 3 and Unit 4 Auxiliary Building North-SouthBreezeway* Fire Zone 098 / Fire Area HH -Unit 3 and Unit 4 Cable Spreading RoomAR 1703279 identified transient combustible materials in the Auxiliary BuildingBreezeway (Fire Zone 079A) on 11/04/2011. Per the screening notes, the transientcombustible material was 100 feet of fiber optic cable whose fire rating allows it to beinstalled per modification EC 247024. The total weight of the material was around 30lbs.AR 1723579 identified transient combustible materials with no permit in the Auxiliary-Building Hallway (Fire Zone 058) on 1/12/2012. The transient combustible materialswere tools, fall protection harnesses, batteries, flashlight, etc. The AR originatorgathered all the equipment and returned them to the hot tool room.Two issues were identified related to the fire zones/areas crediting the reduced transientheat release rate. The first one, AR 1703279 at Fire Zone 079A, is related to materialsapproved to the permanently installed in the zone. The other issue, AR 1723579 at FireZone 058, is related to combustible material, but it was low risk material (e.g., noflammable liquids). In this case, as soon as the material was identified by the ARoriginator, it was removed from the zone and returned to the hot tool room, which is agood housekeeping practice.Based on the information presented above, only two issues related to transient controlsin fire zones/areas crediting the reduced transient heat release rate had been identifiedin a 30 month time period. This is equivalent to less than one issue per year.Therefore, it is concluded that these issues are isolated incidents that do notdemonstrate a general pattern of transient control violation in fire zones/areas creditingthe reduced transient heat release rate. The increased controls proposed for theseareas will serve to further limit such violations in the future.PRA RAI 29.b.01The April 4, 2014, response to RAI PRA 29.b indicates that a FlowServe reactor coolant pump(RCP) seal PRA model (logic structure and basic event values) has been developed for theFlowServe RCP seal package that will be installed. The response states that an implementation Attachment to L-2014-197Page 11 of 12item will be added to LAR Attachment S, Table S-2, "that will include confirmation of the abovelogic against the NRC approved FlowServe Topical Report."i. Confirm whether the referenced "NRC approved" report is, "Model for Failure of RCPSeals Given Loss of Seal Cooling in CE NSSS [Combustion Engineering Nuclear SteamSupply System] Plants," WCAP-16175-P-A, Rev 0, March 2007 (ADAMS Accession No.ML071130391). If this is not the report that is used, please clarify.ii. Provide technical design and testing evaluations that support the Turkey Point PRAmodel.iii. Summarize the differences and similarities between the FlowServe RCP PRA model inthe Turkey Point PRA and the PRA models in WCAP-16175-P-A. Separately discussthe logic model and the basic events values if possible.iv. Summarize whether any testing will be required to confirm the projected reliability of theseals and how such testing is reflected in the FlowServe RCP PRA model.v. Provide an additional Table S-3 implementation item that will specifically identify when aconfirmatory evaluation of the achieved NFPA-805 transition change in risk that includesthe installed and tested seals will be completed, what change in risk guidance will beused to determine any required action, and what that action will be required to replace orcompliment the new implementation item 18 on page 100 of 101 in the RAI response.RESPONSE:i. The referenced report is not WCAP-16175-P-A. It is the Flowserve report, PRA Modelfor Flowserve 3 Stage N-Seals with Abeyance Seal, Revision 0, 12/20/13 (Enclosure 1).ii. The technical design and testing evaluations that support the Turkey Point PRA modelare documented in the Flowserve report, PRA Model for Flowserve 3 Stage N-Seals withAbeyance Seal, Revision 0, 12/20/13.iii. The major difference from the N-9000 seal is the fact that the N-Seals with abeyanceextend the time the seal package successfully prevents an RCP seal LOCA when theRCPs are running and seal cooling and injection have failed. In this scenario, the sealswill remain intact for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, although the Turkey Point PRA model conservativelycredits only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. For those cases where the RCPs are stopped early in the transient,e.g., a loss of offsite power, the N -Seal package with the Abeyance seal virtuallyguarantees that no RCP seal LOCA will occur. The N-9000 seal performance, asanalyzed in WCAP-1 6175-P-A, under these conditions is very similar. See the tablebelow.
Attachment to L-2014-197Page 12 of 12Feature N-Seals (Flowserve) N-9000 Sealswith Abeyance Seal (WCAP-1 6175)Time to trip RCPs to avoid seal 2 hour* 20 minutesLOCA given loss of seal coolingand injectionLeakage (gpm/pump) for a loss of 480 gpm/pump** 480 gpm/pump*seal cooling and injection withRCPs not tripped in timeProbability and leakage < 1 E-04 probability of < 1 E-03 probability(gpm/pump) for a loss of seal leakage (assume 480 of leakage (assumecooling and injection with RCPs gpm/pump*) 480 gpm/pump*)tripped in time I ITurkey Point PRA model conservatively credits only 1 hour** 480 gpm/pump is the maximum leakage possible.iv. No further testing to confirm the projected reliability of the seals is planned. In addition tothe testing performed by Flowserve, the N-seals are currently being used at a few sitesthat provide additional assurance for the projected reliability.v. Table S-3 Implementation ItemNew Item proposed in FPL letter L-2014-071dated April 4, 2014, Page 101 of 101:Confirm consistency between the PRA model logic used for modeling theFlowserve seals with NRC-approved Topical Report for these seals when theTopical Report is approved.New Revised Table S-3 Implementation Item:Upon NRC approval of the Flowserve topical report for the Reactor CoolantPump (RCP) seals and related PRA model, the Turkey Point PRA model shall bereviewed using the final version of the topical report as well as anyexceptions/clarifications included in the NRC approval to determine if the internalevents and Fire PRA require a revision. The Turkey Point internal events andFire PRA will be updated, if applicable, with the latest RCP seal information. Ifthe updates results in a risk increase greater than the self-approval limits (1 E-07for CDF and 1 E-08 for LERF), FPL will take action to reduce the risk results towithin the self-approval limits. Compensatory measures established prior to theRCP seal replacement shall remain in place until the calculated risk increase iswithin the self-approval limits. to L-2014-197FLOWSERVE APPLICATION FORWITHHOLDING PROPRIETARY INFORMATION FROM PUBLICDISCLOSURE(5 Pages)
FLOWSERVEFlowserve CorporationEngineered Products DivisionNuclear Products Operations2300 E. Vernon Ave.Vernon, CA 90058U.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Date: 05/28/2014Document: AW05-2014AFLOWSERVE APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE
Subject:
PRA Model for Flowserve 3 Stage N-Seals with Abeyance SealRevision 0, Dated December 20, 2013 (Proprietary)The Application for Withholding Proprietary Information from Public Disclosure is submitted by FlowserveCorporation, pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the U.S. Nuclear RegulatoryCommission's regulations. It contains commercial strategic information proprietary to Flowserve andcustomarily held in confidence.The proprietary material for which withholding is being requested is identified in the proprietary version of thesubject report. In conformance with 10 CFR Section 2.390, Affidavit AW05-2014B accompanies thisapplication for withholding, setting forth the basis on which the identified proprietary information may bewithheld from public disclosure. The Document is considered proprietary in its entirety.Correspondence with respect to the proprietary aspects of the Application for Withholding (AW05-2014A)or the accompanying Affidavit (AW05-2014B) should reference the applicable document and addressed asfollows:Main ContactMr. James M. CookFlowserve Director Nuclear SalesPhone (Office): 845-548-9275E-Mail: icook(aflowserve.comRegulatory Compliance Proprietary ReviewerMr. Greg HighfillDirector EngineeringPhone: 323-584-1838E-Mail: ghiighfill(,flowserve.comAddress: Flowserve CorporationNuclear Products Operations2300 E. Vernon Ave.Vernon, CA 90058Proprietary Reviewer Document: AW05-2014BAFFIDAVITSTATE OF CALIFORNIA:COUNTY OF LOS ANGELES:Before me, the undersigned authority, personally appeared Greg Highfill, who, being by me dulysworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofFlowserve Corporation, and that the averments of fact set forth in this Affidavit are true and correct to the bestof his knowledge, information, and belief:Compliance Proprietary ReviewerSworn to and subscribed before met day of May 2014ulNotary PublicCommission # 19866043Notary Public -CaliforniaLos Angules CountyI Document: AW05-2014B(1) I am Manager, Regulatory Compliance for Nuclear Products Operations, FlowserveCorporation, and as such, I have been specifically delegated the function of reviewing theproprietary information sought to be withheld from public disclosure in connection withnuclear power plant licensing and rule making proceedings, and am authorized to apply for itswithholding on behalf of Flowserve.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Flowserve Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) 1 have personal knowledge of the criteria and procedures utilized by Flowserve in designatinginformation as a trade secret, privileged or as confidential commercial or financial infornmation.(4) Pursuant to the provisions of paragraph (b)( 4) of Section 2.390 of the Commission'sregulations, the following is for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.1. The information sought to be withheld from public disclosure is owned and has beenheld in confidence by Flowserve.II. The information is of a type customarily held in confidence by Flowserve and notcustomarily disclosed to the public. Flowserve has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of infonnation inconfidence. The application of that system and the substance of that system constituteFlowserve policy and provide the rational basis required.Under that system, i is held in confidence if it falls in one or more of several, typds. the release 6r
- result in the loss of an existing or potentialcomppeititve adyan Le, 11ws:a. The information reveals the distinguishing aspects of a process (orcomponent, structure, tool, method, etc.) where prevention of its use by anyof Flowserve's competitors without license from Flowserve constitutes acompetitive 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 datasecures a competitive economic advantage, e.g., by optimization orimproved marketability.c. Its use by a competitor would reduce his expenditure of resources orimprove his competitive position in the design, manufacture, shipment,installation, assurance of quality, or licensing a similar product.2 Document: AW05-2014Bd. It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Flowserve, its customers or suppliers.e. It reveals aspects of past, present, or future Flowserve or customer fundeddevelopment plans and programs of potential commercial value toFlowserve.f. It contains patentable ideas, for which patent protection may be desirable.There are sound policy reasons behind the Flowserve system which include the following:a. The use of such information by Flowserve gives Flowserve a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Flowserve competitive position.b; It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Flowserve ability tosell products and services involving the use of the information.c. Use by our competitor would put Flowserve at a competitive disadvantageby reducing his expenditure of resources at our expense.d. Each component of proprietary information pertinent to a particularcompetitive advantage is potentially as valuable as the total competitiveadvantage. If competitors acquire components of proprietary information,anyone component may be the key to the entire puzzle, thereby deprivingFlowserve of a competitive advantage.e. Unrestricted disclosure would jeopardize the position of prominence ofFlowserve in the world market, and thereby give a market advantage to thecompetition of those countries.f. The Flowserve capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.3 Document: AW05-2014Biii. The information is being transmitted to the Commission in confidence and, under theProvisions of 10 CFR Section 2.390, it is to be received in confidence by theCommission.iv. The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or methodto the best of our knowledge and belief.v. The proprietary information sought to be withheld in this submittal/Affidavit is thatwhich is appropriately marked in the "PRA Model for Flowserve 3 Stage N-Seals withAbeyance Seal" Revision 0, Dated December 20, 2013 (Proprietary) being transmittedalong with the Application for Withholding Proprietary Information from PublicDisclosure (Document #AW05-2014A). The proprietary information as submitted byFlowserve is expected to be applicable for review only, and may be used only for thatpurpose.Public disclosure of this proprietary information is likely to cause substantial harm to the competitiveposition of Flowserve because it would enhance the ability of competitors to provide similar product,calculational models and licensing defense services for commercial power reactors withoutcommensurate expenses. Also, public disclosure of the information would enable others to use theinfornation to address NRC requirements for licensing documentation without purchasing the right touse the information.The development of the technology described in part by the information is the result of applying theresults of many years of experience in an intensive Flowserve effort and the expenditure of aconsiderable sum of money.In order for competitors of Flowserve to duplicate this information, similar technical programs wouldhave to be performed and a significant manpower effort, having the requisite talent and experience,would have to be expended.Further the deponent sayeth not.PROPRIETARY INFORMATION NOTICETransmitted herewith is the proprietary version of a document furnished to the NRC in connection withrequests for informational use only. The document is to be considered proprietary in its entirety.4