L-2013-002

10 CFR 50.90JAN 1 1 2013FPL.

U. S. Nuclear Regulatory CommissionAttn.: Document Control DeskWashington, D.C. 20555-0001

Re: Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251Response to NRC Request for Additional Information RegardingLicense Amendment Request No. 224 on Technical Specification 3/4.6.2.3 -Recirculation pH Control System and NaTB Basket Minimum Loading Requirement

References:

(1) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-314), "LicenseAmendment Request No. 224 Regarding Technical Specification 3/4.6.2.3 - RecirculationpH Control System and NaTB Basket Minimum Loading Requirement," Accession No.ML12251A249, September 6, 2012.

(2) Email from Tracy Orf (NRC) to Olga Hanek (FPL), "Draft RAIs re: Sump pH LAR,"November 30, 2012.

By letter L-2012-314 dated September 6, 2012 [Reference 1], Florida Power & Light Company(FPL) requested to amend Renewed Facility Operating Licenses DPR-31 and DPR-41 and revisethe Turkey Point Units 3 and 4 Technical Specifications (TS). The proposed amendment willdecrease the minimum required mass of sodium tetraborate decahydrate (NaTB) specified in TSSurveillance Requirement 4.6.2.3 from 11,061 lbms to 7,500 lbms in order to lessen the long termsump pH profile, recover design margin, and facilitate NaTB basket loading and maintenance.

TS 3.6.2.3 addresses the requirements for the Recirculation pH Control System which is a passivesafeguard consisting of ten stainless steel wire mesh baskets located in the containment basementand containing a total of at least 11,061 Ibm of NaTB. This passive system assures that there issufficient NaTB available in the containment to ensure a sump pH greater than 7.0 at the onset ofthe recirculation phase of a postulated loss-of-coolant accident (LOCA).

By email from the U.S. Nuclear Regulatory Commission (NRC) Project Manager (PM) datedNovember 30, 2012 [Reference 2], additional information regarding the effects of the proposedreduction in basket loading was requested by the staff in NRC's Steam Generator Tube Integrityand Chemical Engineering Branch (ESGB) to support review of the NaTB License AmendmentRequest (LAR). The RAI consisted of two (2) questions regarding the projected post-LOCAminimum sump pH profile for 7,500 lbms and the impact of this reduced NaTB loading on post-LOCA chemical precipitate generation. On December 11, 2012, a meeting was held betweenFPL and NRC representatives to discuss these questions. Based on this discussion, the two RAIquestions and the applicable FPL responses are provided in the Attachment to this letter.

This submittal does not alter the significant hazards consideration or environmental assessmentpreviously submitted by FPL letter L-2012-3 14 [Reference 1].

This submittal contains no new commitments and no revisions to existing commitments.

Florida Power & Light Company

9760 SW 344 St., Florida City, FL 33035

Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251

L-2013-002Page 2 of 2

In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the StateDesignee of Florida.

Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto,Licensing Manager, at (305) 246-7327.

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

Executed on January //, 2013.

Very truly yours,

Michael KileySite Vice PresidentTurkey Point Nuclear Plant

Attachment

cc: USNRC Regional Administrator, Region IIUSNRC Project Manager, Turkey Point Nuclear PlantUSNRC Senior Resident Inspector, Turkey Point Nuclear PlantMs. Cindy Becker, Florida Department of Health

Florida Power & Light Company

9760 SW 344 St., Florida City, FL 33035

Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251

L-2013-002AttachmentPage 1 of 3

Turkey Point Units 3 and 4

Response to NRC Request for Additional Information RegardingLicense Amendment Request No. 224 on Technical Specification 3/4.6.2.3 -

Recirculation pH Control System and NaTB Basket Minimum Loading Requirement

ATTACHMENT

Turkey Point Units 3 and 4 L-2013-002Docket Nos. 50-250 and 50-251 Attachment

Page 2 of 3

Response to Request for Additional Information

The following information is provided by Florida Power & Light Company (FPL) in response tothe U. S. Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI). Thisinformation was requested to support License Amendment Request (LAR) No. 224, TS 3/4.6.2.3 -Recirculation pH Control System and NaTB Basket Minimum Loading Requirement, for TurkeyPoint Nuclear Plant (PTN) Units 3 and 4 that was submitted to the NRC by FPL letter L-2012-314on September 6, 2012 [Reference 1].

In an email dated November 30, 2012 [Reference 2], the NRC staff requested additional informationregarding FPL's request to implement the proposed reduction in NaTB basket loading under LAR224. The RAI consisted of two (2) questions from the NRC's Steam Generator Tube Integrity andChemical Engineering Branch (ESGB) regarding the projected post-LOCA minimum sump pHprofile at 7,500 lbms and impact of this reduced NaTB loading on post-LOCA chemical precipitategeneration. On December 11, 2012, a telephone call was held between FPL and NRC representativesto discuss these questions. Based on the discussion, the two RAI questions and the applicable FPLresponses are documented below.

ESGB-1 License amendment request (LAR) 224 dated September 6, 2012 (ADAMS AccessionNo. ML12251A249) indicates that a minimum 7500 Ibm sodium tetraboratedecahydrate (STB) basket loading will ensure sump pH remains above 7.0 throughoutthe recirculation phase of a loss of coolant accident. Please provide a plot of sump pHprofile as a function of time assuming 75001bm STB and plant conditions that wouldresult in a minimum p11 profile. In addition, either confirm that the methodology usedto calculate pH was the same as provided to the NRC in letter dated April 28, 2010(Accession No. ML101200063) or describe the differences.

9.0 Sump pH for Case 8

8.5

8.0

7.5

7.0- / 2725 seo,7,045 pH

6.5

6.0

5.5

5.0

4.5

4 .0 -.. .. ..

10 100 1000 10000 100000 1000000 10000000

Time (sec)

Figure 1: Minimum Sump pH curve with 75001bs NaTB in sump baskets.

Turkey Point Units 3 and 4 L-2013-002Docket Nos. 50-250 and 50-251 Attachment

Page 3 of 3

The methodology, i.e., Palmer Method, used to calculate the minimum sump pHprofile above is the same as that provided to the NRC in FPL letter L-2010-082 datedApril 28, 2010 [Reference 3].

ESGB-2 The LAR also indicates that by reducing the STB quantity and therefore peakpH, the post-accident chemical precipitate generation is reduced. Please discussthe quantity of precipitate reduction associated with reducing the peak pHvalues. For example, providing a quantity of precipitates calculated by theWCAP-16530-NP-A method for a peak pH of 8.01 as compared to a pH of 7.68would be one way to respond to this question.

As indicated in FPL letter L-2012-3 14 [Reference 1], the proposed reduction in thetotal TS required mass of NaTB in the baskets from 11,061 lbms to 7,500 lbms willdecrease the peak sump pH to approximately 7.680. Preliminary analyses of the post-LOCA chemical precipitate generation using the above WCAP methodology for thesetwo cases will reduce the quantity of chemical precipitate generated by approximately6.5% for Unit 3 and approximately 5.2% for Unit 4.

References

1. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2012-314), "LicenseAmendment Request No. 224 Regarding Technical Specification 3/4.6.2.3 - RecirculationpH Control System and NaTB Basket Minimum Loading Requirement," Accession No.ML 12251 A249, September 6, 2012.

2. Email from Tracy Orf (NRC) to Olga Hanek (FPL), "Draft RAIs re: Sump pH LAR,"November 30, 2012.

3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-082), "Supplement toLicense Amendment Request 196 (ADAMS Accession No. ML092050112) - RevisedSummary of Turkey Point Sump pH Calculation Inputs, Assumptions, Methodology, andResults," Accession No. ML10 1200063, April 28, 2010.