ML15132A821

2014/07/29 Turkey Point 3 & 4 La - Turkey Point UHS Ftp Site Is Updated

ML15132A821
Person / Time
Site:	Turkey Point
Issue date:	07/29/2014
From:	- No Known Affiliation
To:	Division of Operating Reactor Licensing
References
15-935-02-LA-BD01
Download: ML15132A821 (13)

Text

1 TurkeyPointLANPEm Resource From: Czaya, Paul [Paul.Czaya@fpl.com]

Sent: Tuesday, July 29, 2014 8:01 AM To: Klett, Audrey

Subject:

Turkey Point UHS FTP Site is Updated Attachments:

L-2014-253, Response to BOP &

SCVB RAIs from 7282014 Final.pdf Audrey: The RAI response (attached) Bob sent to you last night is also available now on the FTP site.

It's a better copy as well.

Paul Czaya Turkey Point Nuclear Plant Licensing

305-246-7150

Hearing Identifier: TurkeyPoint_LA_NonPublic Email Number: 337 Mail Envelope Properties (D54425CBA899B24E9A1BB07269D2DC7343244532)

Subject:

Turkey Point UHS FTP Site is Updated Sent Date: 7/29/2014 8:00:52 AM Received Date: 7/29/2014 8:00:57 AM From: Czaya, Paul Created By: Paul.Czaya@fpl.com Recipients: "Klett, Audrey" <Audrey.Klett@nrc.gov>

Tracking Status: None

Post Office: GOXSA1809.fplu.fpl.com Files Size Date & Time MESSAGE 216 7/29/2014 8:00:57 AM L-2014-253, Response to BOP & SCVB RAIs from 7282014 Final.pdf 157242 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

Florida Power & Light Company9760 SW 344 thSt., Florida City, FL3303510 CFR 50.90L-2014-253 July 28, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control Desk Washington, DC 20555-0001Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251 Renewed Facility Operating LicenseNos. DPR-31 and DPR-41

Subject:

Response to Request for Additional Information Regarding License Amendment Request No. 231, Applicati on to Revise Ultimate Heat Sink Temperature Limit

References:

1.Florida Power & Light Company Letter L-2014-216, "LicenseAmendment Request No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit," July 10, 2014.2.Florida Power & Light CompanyLetter L-2014-226, "License Amendment Request No.

231, Application to Revise Ultimate Heat SinkTemperature Limit -Request for Emergency Approval," July 17, 2014.3.Florida Power & Light Company Letter L-2014-235, "License Amendment Request No. 231,Application to Revise Ultimate Heat Sink Temperature Limit -Supplement 1, and Response to Request for Additional Information" July 22, 2014.4.Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information -LAR 231 (TACs MF4392 and MF4393)," July 28, 2014 (SCVB RAI-4,BOPRAI-7,8).In Reference 1, Florida Power & Light Company (FPL) requested an amendment to the Technical Specifications (TS) for the Turkey Point Nuclear Plant (Turkey Point), Units 3 and 4. The proposed amendment would revise the u ltimate heat sink (UHS) water temperature limit from100ºF to 104ºF. In Reference 2, FPL requestedthe U.S. Nuclear Regulatory Commission (NRC) to review and approve the applicationon an emergency basis.FPL supplemented the Reference 1 application and provided responses toarelated requestfor additional information (RAI)in Reference 3.

Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 1of 7Response to Request for Additional Information(RAI)Balance of Plant RAIs 7 and 8Turkey Point Units 3 and 4License Amendment Request No.231Application to Revise Ultimate Heat Sink Temperature LimitEnclosure1 Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 2of 7 BackgroundBy letter dated July 10, 2014, as supplemented by lettersdated July 17,July 22, July 24, and July 26,2014, Florida Power & Light Company (FPL) submitted a license amendment request for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to the Turkey Point Technical Specifications (TSs), Sec tion 3/4.7.4, Ultimate Heat Sink."The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the informationprovidedand determined that it needs additional information to complete the review. The NRC staff's request for additional information (RAI) is contained in Reference 1. TheFPL responseto Balance of Plant (BOP) RAIs 7 and 8follows.BOP RAI-7The licensee's response to BOP RAI-1 states that the input to HX3/HX4 is TICW in, TICW out , TCCW in, TCCW out, and intake cooling water (ICW) Flow Rate.The licensee's response also states that "The HX3/HX4 program equates the heat gain by the ICW system, the heat loss from CCW [component cooling water] and then determines the overall heat transfer coefficient, 'U', based on the surveillance heat transfer rate and logarithmic mean temperature difference. The HX3/HX4 program determines the TR

[tube resistance] based on the surveillance overall heat transfer coefficient 'U', first principle equations and appropriate film coefficients."When doing the surveillances, Q is unknown. Equations:1.Q ICW= (MICW) (CP ICW) (TICW out -TICW in)2.QCCW = (MCCW) (CP CCW) (TCCW in -TCCW out)3.Q = U 0(A) LMTD4.Q= QICW = Q CCWWhere:

Q ICW= Heat Gain to ICW from CCW CP ICW = ICW Specific Heat MICW =ICW Mass Flow Rate TICW out= ICW Outlet Temperature TICW in=ICW Inlet Temperature QCCW = Heat Loss from CCW to ICW MCCW = CCW Mass Flow Rate CP CCW= CCW Specific Heat Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 3of 7 TCCW in= CCW Inlet Temperature TCCW out= CCW Outlet Temperature U 0 = Overall Heat Transfer CoefficientA= Total Tube Exterior Surface AreaLMTD= log mean temperature differentialVariables that are underlined are known.

Q is needed to get U 0, which is neededto get TR (tube resistance), so that one can accurately enter Figure 3.5-1 of the licensee's letter dated July 10, 2014, or the graphs ofHX3/HX4.The unknowns are Q, CP ICW, MCCW, and U 0.Considering equations 1, 2, and 3, there are 3 equations and 4 unknowns.

A. How does the licensee know the value of U 0?B.When the licensee knows the value of U 0, how does it find TR knowing that the tube side film coefficient is affected by the algae

?C. How does the licensee know it has the correct TR when doing surveillances and thus is able to know that there is sufficient heat transfer capability for a design basis accident?

Response:The determination of the heat exchanger performance is based on the conservation of energy equations for heat transfer between the ICW and CCW systems and the performance equation for the heat exchanger. The heat gain (to the ICW System) is equal to the heatlost (from the CCW System) and is also equal to the heat transferred within the heat exchanger as described by the total surface area, A os, the heat exchanger heat transfer coefficient, U o, and the logarithmic mean temperature difference, LMTD.QG = HeatGain to the Tube Side from the Shell Side, BTU/hrQL = Heat Loss from the Shell Side to the Tube Side, BTU/hrQO = Total Overall Heat Transfer, BTU/hr Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 4of 7The logarithmic mean temperature difference is defined as:Therefore, there are six equations and six unknowns. If we add the tube side fouling resistance as an unknown and its associated equation for U o, we have seven equations and seven unknowns. These parameters are T o1 , T o2 , T i1 , T i2 , W o , W i, and r i. Therefore, there will be a unique solution to this system of equations for a given heat exchanger.The ICW specific heat coefficient (C pi) is found by using equations formulated from a study performed as part of the Extended Power Uprate efforts. These equations take actual salinity and bulk temperature as inputs to obtain a specific heat coefficient value by interpolation. Specific heats of freshwater (0% salinity), salt water with normal seawater salinity (3.44%), salt water with double normal salinity (6.88%), and salt water with triple normal salinity (10.32%) are used as interpolation points. Equations for the aforementioned specific heats are as follows:Fresh Water (0% salinity)

C pi= 1.362E-10*T i 4-6.797E-08*T i 3+ 1.272E-05*T i 2-1.023E-03*T i+ 1.028Salt water with normal salinity (3.44% salinity)

C pi=-2.352E-11*T i 4+ 7.445E-09*T i 3-7.772E-07*T i 2+ 7.993E-05*T i+ 9.522E-01Salt water with double normal salinity (6.88% salinity)

C pi=-5.654E-11*T i 4+ 2.160E-08*T i 3-3.393E-06*T i 2+ 3.636E-04*T i+ 9.015E-01Salt water with triple normal salinity (10.32% salinity)

C pi=-2.669E-11*T i 4+ 1.210E-08*T i 3-2.269E-06*T i 2+ 3.127E-04*T i+ 8.678E-01where, T iis the tube side ICW bulk temperature, °F.When five of the parameters are specified, the remaining two parameters can be determined by iteration. All other parameters which describe the physical aspects of the heat exchanger and the fouling on the shell side of the heat exchanger tubes are taken as specified constants.The five "known" parameters are the four temperatures (inletand outlet on both sides of the heat exchanger) and the ICW mass flow rate through the tubes (recorded as a volumetric flow rate): T o1 , T o2 , T i1 , T i2, and W i. They are surveillance data inputs for the CCW heat exchanger fouling evaluation. Given the five specified parameters, the computer code determines the CCW flow rate on the shell side (W o) from the heat balance, U ofrom the heat transfer equation and calculates the tube internal fouling (r i) based on the surveillance data inputs(See formulas Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 5of 7below). In order to determine r i, the terms r o and r ware constants and the other parameters are calculated using the equations below with the surveillance data.

r i= Tube side (ICW) fouling, (hr-ft2-°F)/BTU h o= Shell Side Film Coefficient, BTU/(hr-ft2-°F) h i= Tube Side Heat Transfer Coefficient, (BTU)/(hr-ft2-°F)Once r iis calculated, using the formula below the TR is calculated.TR= Tube resistance, (hr-ft2-°F)/BTUDuring the discovery of the algae, several samples of the cooling canals were performed to determine the effect on the water properties. The only parameter that was not bounded by the current analysis was the viscosity. The viscosity affects the tube side film coefficient calculation. To compensate for the effect of the viscosity, internal tube fouling "r i" will captured this effect based on the calculated overall heat transfer coefficient "U o".To assess the performance of the heat exchangers for a design condition, the design basis heat load, shell side (CCW) inlet/outlet temperatures, and the assured tube side (ICW) flow rate are assumed with the previously calculated internal tube fouling. The other parameters are Design Basis parameters consistent with and varying only slightly from the Heat Exchanger Specification Sheets for the Unit 3 and 4 heat exchangers. The tube side temperatures are Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 6of 7calculated, specifically the maximum allowable ICW inlet temperature. This process is illustrated in Figure 1 of RAI1-B.BOP-8:In its response to BOP RAI-6 by letter dated July 26, 2014, thelicens ee stated, "The RHR [residual heat removal] Pump mechanical seals are cooled by CCW [component cooling water] through mechanical seal coolers with process fluid on the tube side and CCW water on the shell side. Per Drawing 5610-M-450-96, Sheet 1, CCW is to be available at 145ºF [degrees Fahrenheit] initially, decreasing to 125ºF in 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />."The licensee also stated, "The CS [containment spray] Pump m echanical seal is cooled by CCW through a mechanical seal cooler. The maximum operating temperature for the Containment Spray Pump mechanical seal is 205ºF.Per the vendor data sheets for the mechanical seals on the Unit 4 CS pumps, 3 gpm [gallons per minute] of flow at 150ºF is needed for the CS pump seal coolers."However, the peak CCW supply temperature to the RHR and CS pumps during a loss-of-coolant accident, double-ended pump suction (LOCA-DEPS) break approaches 160°F and stays above 150°F for several hours after the accident, according to the licensee's letter dated July 24, 2014.The CCW supply temperature appears to be too high to meet the vendor-specified cooling requirements for these pumps. Discuss how the RHR and CS pumps will have adequate cooling to run continuously in order to perform their design basis function during a design basisaccident.

Response:The Turkey Point Containment Spray Pump (CSP) mechanical seal is cooled by a seal cooler which in turn is cooled by Component Cooling Water (CCW). Per WCAP 12263, Section 4.1.2, an evaluation was performed by the seal manufacturertemperature and no seal cooling. The tests resulted in insignificant wear to the seals and demonstrated that the seals could perform their required post-seal cavity temperature. Itwas determined that the Containment Spray Pump post-accident conditions would have negligible effect on the Containment Spray Pump mechanical Seal Life. The peak containment sump temperatures to the RHR heat exchangers, which is CSP process fluid, was cacooling from these exchangers and is therefore conservative. For the Residual Heat Removal (RHR) Seal coolers, the OEM vendor (Flowserve ) provided analysis in Evaluation SR-1300 for post-accident recirculation operation of the RHR seal. The Florida Power & Light CompanyL-2014-253Response to BOP Request for Additional InformationEnclosure1Page 7of 7CCW temperature 165 F. The evaluation result showed a maximum RHR seal chamber temperature of 189.8 F, which is noted as below the operating limit (200F, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) and at post 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> CCW flow at 135F, the mechanical seal will not experience problems. Note that per operating procedures 3/4-NOP-030, the minimum CCW flow to the RHR seal coolers is 8.5 gpm.References1.Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3 and 4 Request for Additional Information -LAR 231 (TACs MF4392 and MF4393)," July 28, 2014 (SCVB RAI-4,BOP-7and 8).

Florida Power & Light CompanyL-2014-253Response to SCVB Request for Additional InformationEnclosure2Page 1of 2Response to Request for Additional Information(RAI)Containment and Ventilation Branch RAI-4Turkey Point Units 3 and 4License Amendment Request No. 231Application to Revise Ultimate Heat Sink Temperature LimitEnclosure2 Florida Power & Light CompanyL-2014-253Response to SCVB Request for Additional InformationEnclosure2Page 2of 2 BackgroundBy letter dated July 10, 2014, as supplemented by letters dated July 17, July 22, July 24, and July 26, 2014, Florida Power & Light Company (FPL) submitted a license amendment request for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). FPL requested revisions to the Turkey Point Technical Specifications (TSs), Sec tion 3/4.7.4, Ultimate Heat Sink."The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information providedand determined thatit needs additional information to complete the review. The NRC staff's request for additional information (RAI) is contained in Reference 1. The FPL response to Containment and Ventilation Branch (SCVB) RAI-4follows.SCVB RAI-4Please describe the changes that will be included in the UFSAR related to the license amendment request (e.g., regarding maintaining the component cooling water heat exchangers so that they are ready and capable of functioning as intended during normal and accident conditions)

.ResponseA note will be added to UFSAR Table 14.3.4.3-1, "Containments Analysis Parameters" to clarify the continued applicability of the containment integrity accident analysis for ICW temperatures higher than 100 F. The following note is proposed to be added to UFSAR Table 14.3.4.3-1."Note: The ICW temperature of 100 F assumed in the containment integrity accident analysis can be exceeded up to the Technical Specification limit of 104 F if heat exchanger performance monitoring demonstrates the ability to remove postulated post-accident heat loads at the elevated ICW temperature. Maintaining the same heat removal capability with a higher ICW temperature assures that the containment integrity accident analysis described in the UFSAR remains valid."UFSAR Sections 9.3 and 9.6 discuss maintaining the heat removal capability of the CCW system during normal and accident conditions. Furthermore, the surveillance requirements of Technical Specification 4.7.2 assure that the heat removal capability of the CCW system is maintained such that it remains ready and capable of functioning as intended to remove the design basis heat loads during normal and accident conditions

.

Reference:

1.Email from A. Klett (NRC) to R. Tomonto, et al. (FPL), "Turkey Point 3and 4 Request for Additional Information -LAR 231 (TACs MF4392 and MF4393)," July 28, 2014 (SCVB RAI-4and BOP RAI-7 and 8).