L-2006-136, Emergency License Amendment Request No. 185 Icw Pump Allowed Outage Time One Time Change

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Emergency License Amendment Request No. 185 Icw Pump Allowed Outage Time One Time Change
ML061520362
Person / Time
Site: Turkey Point NextEra Energy icon.png
Issue date: 05/20/2006
From: Stall J
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2006-136
Download: ML061520362 (23)
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Text

0 FPL 10 CFR 50.90 10 CFR 50.91 L-2006-136 May 20, 2006 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Re: Turkey Point Unit 3 Docket No. 50-250 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change Pursuant to 10 CFR 50.90 and 10 CFR 50.91(a)(5), Florida Power and Light Company (FPL) requests approval of a change to Turkey Point Unit 3 Facility Operating License DPR-3 1. The change concerns the allowed outage time for one inoperable intake cooling water (ICW) pump. The proposed amendment would revise Technical Specification (TS) 3.7.3, Action a, to revise the allowed outage time (AOT) of seven (7) days to fourteen (14) days, on a one-time basis. A description of the proposed change is included in Attachment 1 to this letter.

The Turkey Point Plant Nuclear Safety Review Committee and the FPL Company Nuclear Review Board have reviewed and approved the proposed amendment.

FPL requests approval of the proposed amendment by 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> on May 22, 2006, based on the expiration of the current Technical Specification AOT at that time to prevent an unnecessary shutdown of Turkey Point Unit 3. The reason for the one-time request for extension of the AOT is to complete repairs to the 3B ICW pump discharge flange. As described in Attachment 1, public safety is not compromised by extending the TS AOT. There is an inherent safety benefit of repairing the 3B ICW pump discharge flange without shutting the plant down when compared to shutting the plant down without the 3B ICW pump available.

Therefore, in accordance with 10 CFR 50.91 "Notice for public comment; State consultation,"

paragraph (a)(5), FPL is requesting NRC approval of the proposed amendment on an emergency basis. Sufficient time is not available to support 30 days for prior public comment on a schedule to prevent an unnecessary plant shutdown upon the expiration of the current AOT. An explanation of the emergency and why it could not be avoided is included in Attachment 1. Once approved, this amendment will be implemented prior to the expiration of the current AOT.

The proposed change has been evaluated in accordance with 10CFR50.91(a)(1), using the criteria in 10CFR50.92(c). FPL has determined that the proposed change involves no significant hazards considerations.

400 an FPL Group company

Turkey Point Unit 3 1-2006-136 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change Page 2 of In accordance with 10 CFR 50.91(b)(1), a copy of the proposed amendment is being forwarded to the State Designee for the State of Florida.

Please contact Mr. Walter Parker, Licensing Manager, at (305) 246-6632, if there are any questions regarding this submittal.

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

Very truly yours, May 20, 2006

/"Jý00ý-:Lýý 5/2qVO( /535 Executed on Senior Vice President - Nuclear and Chief Nuclear Officer Attachments: 1) Proposed License Amendment

2) Marked Up Technical Specification Page
3) Camera Ready Technical Specification Page cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Mr. W. A. Passetti, Florida Department of Health

ATTACHMENT 1 Turkey Point Unit 3 Docket No. 50-250 License No. DPR-31 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change Description of Proposed Change, Technical Analysis, and No Significant Hazards Consideration

Turkey Point Unit 3 Attachment 1 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 1 of 16 ATTACHMENT 1 CONTENTS 1.0 Introduction 2.0 Description of Proposed Change

3.0 Background

4.0 Regulatory Requirements & Guidance 5.0 Technical Analysis 6.0 Regulatory Analysis 7.0 No Significant Hazards Consideration 8.0 Environmental Consideration

Turkey Point Unit 3 Attachment 1 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 2 of 16

1.0 INTRODUCTION

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Florida Light and Power Company (FPL) is proposing that the Turkey Point Unit 3 Facility Operating License be amended to revise the Technical Specifications (TS) associated with the intake cooling water (ICW) system pumps. The proposed change to TS 3.7.3, Intake Cooling Water System, Action a would increase the TS allowed outage time (AOT) for one inoperable ICW pump from seven (7) days to fourteen (14) days, on a one-time basis, to support emergent maintenance and repair on the 3B ICW pump discharge flange. This extended AOT will be effective from 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, May 22, 2006 until 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, May 29, 2006. FPL requests approval of the proposed amendment by 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, May 22, 2006, to prevent an unnecessary Turkey Point Unit 3 shutdown as a result of the expiration of the AOT of TS 3.7.3, Action a.

FPL is requesting NRC approval of the proposed change on an emergency basis, as sufficient time is not available to allow 30 days for prior public comment on a schedule to prevent an unnecessary plant shutdown at the expiration of the existing AOT. As described in Section 5.0 below, extending the TS 3.7.3, Action a AOT and avoiding the risk incurred by a plant shutdown, will not compromise public safety.

The Turkey Point 3B ICW pump is presently inoperable due to a planned maintenance outage.

During the pump and motor replacement activities, a through-wall crack was discovered on the threaded pipe flange connecting the 3B pump discharge elbow to the pipe flange penetrating the concrete intake deck. A temporary repair of the flange was implemented in parallel with expediting a replacement flange. The temporary repair utilized a gasket sealant and a metal replacement compound. During post-maintenance testing of the 3B pump breaker, which involved starting and stopping the pump, the flange repair failed resulting in leakage of approximately 5 gpm.

Basis for Emergency The need to request an emergency TS change arose from an unexpected condition discovered during planned maintenance performed on the 3B ICW pump beginning May 15, 2006.

During the pump and motor replacement activities, a through-wall crack was discovered on the threaded pipe flange connecting the 3B pump discharge elbow to the pipe flange penetrating the concrete intake deck. A temporary repair of the flange was implemented in parallel with expediting a replacement flange. The temporary repair utilized a gasket sealant and a metal replacement compound. During post-maintenance testing of the 3B pump breaker, which involved starting and stopping the pump, the flange repair failed resulting in leakage of approximately 5 gpm. A replacement pump discharge flange was received on May 19, 2006.

Due to the complexity of fitting up the new flange, thread sealant cure time and restoration of the 3B ICW pump to operable status, additional time beyond the current TS AOT is anticipated to

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 3 of 16 complete a permanent repair. This issue has been entered into the site Corrective Action Program for resolution and determination of causes and corrective actions.

FPL could not have foreseen the need for this TS change prior to identification of the cracked flange and the inability to repair it. The flange joint did not exhibit signs of cracking or operational degradation prior to the planned maintenance outage. Therefore, FPL requests that this proposed TS change be considered under emergency circumstances as described in 10 CFR 50.91(a)(5).

2.0 DESCRIPTION

OF PROPOSED CHANGE FPL proposes to revise TS 3.7.3, "Intake Cooling Water System," as follows:

"The 7-day allowed outage time of Technical Specification 3.7.3, Action a, which was entered on May 15, 2006 at 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, may be extended one time by an additional 7 days to complete repair and testing of the Unit 3 3B ICW pump (3P9B)."

The proposed change will permit completing required corrective maintenance and repair on the 3B ICW pump discharge flange, perform post-maintenance and surveillance testing, and return the pump to an operable status. The extension of the existing 7-day AOT to 14 days will prevent exposure to the inherent risks associated with an unnecessary plant shutdown.

3.0 BACKGROUND

Description of Events Completion of repairs, post-maintenance testing, and surveillance testing to establish operability may not be completed prior to expiration of the 7-day AOT. At the conclusion of the 7-day AOT, TS 3.7.3, Action a would require the unit to be in Hot Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Cold Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of the AOT expiration time of 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> on May 22, 2006.

The purpose of this amendment request is to provide additional time in order to satisfactorily complete repairs, post-maintenance testing, and surveillance testing of the 3B ICW pump. FPL has determined that the risk of a one time extension of the 7-day AOT by an additional 7 days does not warrant the inherent risks associated with an unnecessary plant shutdown. Accordingly, FPL is requesting that the 7-day AOT specified by TS 3.7.3, Action a, be extended one time by an additional 7 days to allow completion of repairs and testing of 3B ICW pump. This requested extension would be limited to the current period of 3B ICW pump inoperability.

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 4 of 16 Basis for Current Requirements The ICW System provides cooling water to the safety related Component Cooling Water (CCW)

Heat Exchangers and to the Turbine Plant Cooling Water (TPCW) Heat Exchangers, and supplies water to the Lube Water System. A separate ICW System is provided for each nuclear unit. The TPCW and Lube Water Systems are intended to serve non-safety related functions only. The ICW pumps are not credited for fire water sources. The normal fire water system utilizes the raw water tanks (which store fresh city water) as suction for the electric and backup diesel driven fire pumps. The screen wash pumps can provide a backup source of fire protection water from the intake canal.

The ICW System includes three ICW pumps, tie headers, two independent supply headers, piping, valves, basket strainers, and those components required to take ICW from the plant cooling canals via the intake structure and supply the CCW, TPCW, and Lube Water Systems and return the ICW to the plant cooling canal system.

The ICW System safety function is to remove the heat load from the CCW System during accident conditions to support both reactor heat removal and containment heat removal requirements.

The ICW quality related functions are to remove the heat load from the CCW System to support spent fuel cooling requirements, remove the heat load from the CCW System to achieve and maintain safe (cold) shutdown during plant fires that require control room evacuation, with or without concurrent loss of offsite power, to remove the heat load from the CCW System to achieve and maintain safe (hot) standby during plant fires not requiring control room evacuation with or without concurrent loss of offsite power, and to remove the heat load from the CCW System during refueling operation (Mode 6) to support the core decay heat removal requirements.

The non-nuclear safety functions of the ICW System are to remove the turbine plant heat load from the TPCW System to support turbine plant operation during normal, shutdown and refueling operations, to supply water to the non-safety related Lube Water System to meet the lube water supply requirements of the pumps in the intake area, and to remove the CCW System heat loads during normal and shutdown conditions to support normal containment heat removal and reactor power operation, including radwaste system operation.

The ICW System design basis heat load is 120 million BTUs per hour during a LOCA. The ICW flow rate required to remove this heat load at an intake canal design temperature of 100°F and corresponding CCW heat exchanger design parameters is 16,000 gpm. This flow rate can be provided by one ICW pump.

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 5 of 16 The CCW heat load on the ICW system can vary significantly and is dependent on numerous factors including the postulated event and time frame of interest, the cooling system operating alignment and assumed single failure, and the cooling system flows. Heat exchanger performance monitoring confirms the ability of the CCW and ICW systems to remove design basis heat loads based on the ultimate heat sink temperatures that are being experienced. This monitoring determines system operability and establishes when CCW heat exchangers must be cleaned to maintain design basis heat removal capability with a single ICW pump.

The ICW system is required to be capable of performing its safety functions assuming a single failure. To accommodate single active failures, the ICW supply headers to the CCW heat exchangers are cross-connected in an "open-system" configuration during normal plant operation. This requirement is necessary because at least one pump, one header, and two CCW heat exchangers are required for 100% post-accident heat removal capability. The ICW headers may be cross-connected via either, or both, of the cross-connects located between the pump discharge and the CCW heat exchangers.

The Emergency AC Power system provides power from independent, redundant, safety-related buses to the ICW System components.

The ICW to TPCW isolation valves are required to automatically isolate ICW flow to the TPCW system following an accident to ensure adequate ICW flow is diverted to the CCW system heat exchangers for post-accident heat removal in the event of a single failure that results in only one ICW pump being available. The ICW to TPCW isolation valves do not automatically isolate upon loss of offsite power (LOOP). Should a LOOP event occur which is accompanied by a coincident single failure affecting the availability of one intake cooling water pump, a condition could exist where flow from one intake cooling water pump may not be sufficient to accommodate intake cooling water system flow requirements. To mitigate this potential condition, controls are provided locally and in the control room to initiate manual closure of the power operated valve (POV) and isolate the TPCW heat exchangers. In addition, these valves (one for each unit) are provided with the capability to remain open for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following a loss of instrument air to avoid potential damage to turbine plant equipment.

If the single active failure is assumed to be a POV, two ICW pumps can be assumed to be operable. The two operable ICW pumps can provide sufficient flow to accommodate the flow diverted through the TPCW system. Flow calculations have been performed for this configuration and indicate that the flows through the CCW heat exchangers are within the limits required to remove accident heat loads.

The 1CW system design basis is that one ICW pump will provide the cooling water required to two CCW heat exchangers for heat removal during a design basis accident, i.e., a loss-of-coolant

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 6 of 16 accident. The analyses of record assume that the cooling water supplied by the ICW pumps to the inlet of the CCW heat exchangers does not exceed 100°F.

The A and B pumps are powered by 4160 volt buses which can be powered by each train's associated emergency diesel generator. The C pump is powered by a swing 4160 volt safety related bus which can be powered, through aligning the bus manually, by either the train A or train B emergency diesel generator associated with the same unit. This pump is interlocked, such that, it is started on a LOOP or safety injection signal, if the supply breaker for the A or B ICW pump (associated with the A or B 4KV Bus to which it is aligned) is open and racked out.

The intake cooling water system provides sufficient redundancy so that at least one intake cooling water pump will continue to operate to handle heat loads from design basis accidents following a postulated single active failure.

Based on the identified ICW system design basis and the electrical independence of the ICW pumps, there is no credible single failure event that could reduce the number of available ICW pumps below the design basis minimum of one operating pump.

Reason for Requesting Emergency Amendment 10 CFR 50.91(a)(5) states that where the Nuclear Regulatory Commission (NRC) finds that an emergency situation exists, in that failure to act in a timely manner would result in derating or shutdown of a nuclear power plant, or in prevention of either resumption of operation or of increase in power output up to the plant's licensed power level, it may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment. The regulation also states that the NRC will decline to dispense with notice and comment on the determination of no significant hazards if it determines that the licensee has abused the emergency provision by failing to make timely application for the amendment and thus itself creating the emergency. The regulation requires that a licensee requesting an emergency amendment explain why the emergency situation occurred and why the licensee could not avoid the situation. As explained below, an emergency amendment is needed to preclude an unnecessary plant shutdown. FPL could not have reasonably avoided the situation nor could it have made any more timely application for an amendment.

Reason Emergency Situation Has Occurred The emergency situation resulted from an unforeseen problem that occurred during this ICW maintenance outage that was originally scheduled to be completed within the TS 7-day AOT.

The problem associated with a cracked discharge piping flange discovered during the maintenance, as well as the time required to complete repairs and perform post-maintenance and surveillance testing, is the cause for the current emergency situation for which a license amendment is being requested.

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 7 of 16 FPL has determined that the risk of extending the 7-day AOT by an additional 7 days does not warrant the inherent risks associated with an unnecessary plant shutdown. Neither a routine nor an exigent amendment could be processed within the available time remaining under the current AOT. Therefore, an emergency amendment is needed to preclude an unnecessary shutdown.

Reason the Situation Could Not Have Been Avoided On May 15, 2006, at 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, the Unit 3 3B ICW pump was declared inoperable for a planned maintenance outage, entering the 7-day Action a of TS 3.7.3. During the outage, maintenance personnel discovered a through-wall crack on the threaded pipe flange connecting the 3B pump discharge elbow to the pipe flange penetrating the concrete intake deck. A temporary repair of the flange was implemented in parallel with expediting a replacement flange.

The temporary repair utilized a gasket sealant and a metal replacement compound. During post-maintenance testing of the 3B pump breaker, which involved starting and stopping the pump, the flange repair failed resulting in leakage of approximately 5 gpm. A new flange was received that requires a complex fit up process, with subsequent pump post-maintenance and surveillance testing.

FPL could not have reasonably foreseen exceeding the 7-day AOT of TS 3.7.3, Action a. The original pump maintenance outage schedule was extended only after the repaired flange failed and developed a leak. The additional repair activities are beyond the planned scope of the maintenance outage. The time required to receive, install and fit up the flange, cure the thread sealant, and test the pump and flange extended the completion time of the outage and is projected to exceed the current 7-day AOT. As such, FPL is requesting a one-time extension of this 7-day AOT by an additional 7 days to assure adequate time is available for completion of all activities necessary to restore the 3B ICW pump to operable status. This requested extension would be limited to the current period of 3B ICW pump inoperability.

FPL therefore considers that the situation could not have been avoided and there is justification for requesting the proposed license amendment on an emergency basis.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE 10 CFR 50.36, "Technical specifications," provides the regulatory requirements for the content required in a licensee's TS. Criterion 3 of 10 CFR 50.36(c)(2)(ii) requires a limiting condition for operation to be established for a structure, system or component that is part of a primary success path and which functions or actuates to mitigate a design basis accident or transient: that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The ICW pumps satisfy these criteria.

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 8 of 16 FPL has determined that the proposed change does not require any exemption or relief from regulatory requirements, other than the TSs, and does not affect conformance to any General Design Criteria differently than described in the Updated Final Safety Analysis Report.

5.0 TECHNICAL ANALYSIS

The integrity of the reactor coolant system, fuel and other components of the primary system of a nuclear plant can be adversely affected by the number of thermal or power transients that they are subjected to during their lifetime. As each additional thermal transient can affect this integrity, it is prudent to avoid such transients provided the health and safety of the public is preserved. Additionally, the cycling of the unit through a thermal transient cycles the secondary plant systems, as well as increases challenges to the operators. Placing the unit in hot shutdown requires additional routine surveys and inspections within the reactor containment building that increase personnel exposure.

The proposed amendment to allow a one time extension of the AOT for the 3B ICW pump (3P9B), is based on the following considerations.

Risk from Proposed Allowed Outage Time Extension The evaluation was performed using the Turkey Point Equipment Out of Service (EOOS) model.

The EOOS model is based on the probabilistic safety assessment (PSA) model of record and includes both core damage frequency (CDF) and large early release fraction (LERF). The LERF model is based on the CDF model with simplified PDS (plant damage states) and level 2 containment event trees. The baseline PSA model PDS and containment end states are contained in the LERF fault trees. Thus, the LERF model is solved for each configuration change in the CDF model. The evaluation used the "zero maintenance" PRA model to generate the baseline CDF and LERF numbers, which were compared to the results with 3P9B out-of-service. The values calculated for Incremental Conditional Core Damage Probability (ICCDF) and Incremental Conditional Large Early Release Probability (ICLERP) were determined based on the additional 7-day 3P9B AOT. The analysis is shown below:

ICCDP = (CDF 3PgB - CDFbasc)* At where:

ICCDP = Incremental Conditional Core Damage Probability (per RG 1.177)

CDF3 p9 B = Core Damage Frequency with 3P9B out of service

= 6.07E-6 /yr CDFbase = Core Damage Frequency for the baseline quantification

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 9 of 16

= 5.97E-6 /yr At = Change in duration for the proposed one-time AOT extension

= 7 days.

ICCDP = (6.07E-6 /yr - 5.97E-6 /yr) * (7 days / (365 days/yr)) = 1.9 E-9 and ICLERP = (LERF3P9 B - LERFbase)* At ICLERP = Incremental Large Early Release Probability (per RG 1.177)

LERF3p9 B = Large Early Release Frequency with 3P9B out-of-service

= 3.49E-7 /yr LERFbase = Large Early Release Frequency for the baseline quantification

= 3.49E-7 /yr ICLERP = (3.49E-7 /yr - 3.49E-7 /yr) * (7 days / (365 days/yr)) = 0 (negligible)

The above calculated values are well below the thresholds specified in NRC Regulatory Guide (RG) 1.177 (ICCDP of 5.OE-7 and ICLERP of 5.0E-8) for a permanent TS change.

The main reason of the low risk impact of one ICW pump failure is that the Turkey Point ICW system is cross-tied and consists of three 100% pumps and two cross-tied headers. Losing one pump does not lose either train of ICW header. The normal power feed to the C ICW pump is 4KV bus D. 4 KV bus D is a swing bus and can be aligned to either 4.16 KV A bus (if the A ICW pump fails) or 4.16 KV B bus (if B ICW or 13 CCW pump fails). Since B ICW pump was out of service, the D bus (C ICW pump) has been aligned to B bus. Aligning the D bus to B bus, effectively maintains a two-train ICW system configuration. In addition, the auxiliary feedwater system (AFW) and the emergency diesel generators (EDGs) do not depend on ICW for cooling.

The fire protection system (FPS) water source is a separate raw water tank. Thus, loss of ICW does not have as much impact as those plants that have a stronger dependency on ICW as a source of cooling water or as the water source. Loss of ICW has negligible impact on steam generator tube rupture or containment bypass scenarios. In addition, the Turkey Point containment is a large dry containment and has significant margin for core damage sequences; thus, the impact of losing one ICW pump on LERF is not noticeable.

The analysis was completed with the following assumptions:

1. All Turkey Point CDF calculations were performed using the current approved EOOS model based on the Revision 5b version of the Turkey Point PRA model run at the truncation of 1.OE-10. This model represents plant operation at full power and includes failure terms for

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 10 of 16 all systems, as well as nominal initiating event frequencies and zero maintenance unavailability.

2. The 3B ICW pump (3P9B) will be returned to service within 14 days from the initial LCO entry. Thus, the assessment evaluates the 7 additional days of unavailability beyond the 7-day AOT in the TSs.
3. No adjustment is made to equipment failure probabilities even though some credit could be given due to restricting access to certain plant equipment required to guarantee the safe shutdown of the plant in the event of a transient.
4. No credit was taken for compensatory measures that may be taken to decrease operator or equipment failure rates.
5. There is some amount of non-negligible risk associated with the transition and shutdown periods with the ICW pump unavailable. This risk has not been quantified but as a conservative measure, no credit is given for offsetting the online risk with the transition and shutdown risk that would be incurred by shutting down the unit.
6. The impact of external events on the increase in risk associated with having 3P9B out of service was not calculated due to the lack of an up-to-date, realistic fire PRA model for Turkey Point. The fire protection system water source is a separate raw water tank. The failure of one ICW pump has minimal impact on the decay heat removal system (AFW or Standby Steam Generator Feed water Pumps), hence the impact on fire is expected to be minimal. As a bounding analysis, the external events' contribution was assumed to be equal to the internal events' contribution. This results in a total ICCDP of 3.8E-09 and a negligible ICLERP, values still well below the RG 1.177 thresholds of 5.OE-7 and 5.0E-8, respectively.
7. The Turkey Point PSA model underwent a peer review in January 2002. The "A" and "B" peer review findings have all been resolved with the exception of four "B" level findings.

Two of the "B" findings are documentation issues, one is a Level 2 issue, and the last is an internal flooding issue. Given the margin in ICLERP, and the assumption above used to account for the effect of external events, these are judged to not affect the conclusions of this analysis of the risk associated with the 7-day extension of the ICW pump TS AOT.

8. The error factor for the baseline CDF at a truncation of IE-10 is approximately 1.8 based on our baseline model.

A sensitivity study of the truncation at 1.0E-11 was performed to ensure that no significant cutsets were missed due to the use of the higher truncation at 1.OE-10. The results indicate that the risk impact due to additional cutsets is small (delta CDF changes from 1.0E-7/Yr for truncation at 1.OE-10 to 1.2E-7IYr for truncation at 1.0E-11). A review of the cutsets indicates that the dominant sequences due to the loss of one ICW pump are related to reactor coolant pump seal LOCA scenarios. It is noted that the loss of ICW is modeled in the PSA using a fault tree. Thus the risk impact of an ICW pump as an initiator and mitigating system is captured by

Turkey Point Unit 3 Attachment 1 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 11 of 16 the fault trees in the PSA model. The human actions were also reviewed for their potential impact on the CDF. The dominant human actions include actions to prevent or mitigate a seal LOCA. The failure probability of these human actions are not affected by the loss of one ICW pump. As a benchmark exercise, the Turkey Point SPAR model was reviewed. Based on the Bimbaum importance of the ICW pump (approximately 1.03), the CDF increase would be approximately 7.0E-8/Yr, comparable to the 1.OE-7/Yr estimated using the Turkey Point PSA model.

Common Cause Failure Assessment In addition to normal TS surveillance requirements, in order to provide additional assurance of the reliability of the redundant Unit 3 ICW pumps (3A and 3C), vibration analysis was conducted on those pumps after the 3B ICW pump was removed from service on May 15, 2006.

Pump motor temperatures were monitored, recent oil analyses were reviewed, available indicators were checked, and seal water flows were measured. These checks confirmed that the 3A and 3C ICW pumps and motors were operating within normal parameters. The Unit 4 ICW pumps and motors were also checked.

Plant operating experience discovered multiple ICW flanges with cracks of different orientations and locations starting circa 1988. One flange crack was attributed to a direct impact, most probably during handling of the pipe spool or during original assembly. The remaining cracks were attributed to a combination of assembly stresses (interference fit) and system hydraulic transients. The stress analysis performed at that time determined that once initiated, the stored stresses relaxed to a value low enough to arrest further crack propagation. Since these causes are time and service dependent, they would not likely affect the structural integrity of multiple flanges simultaneously. A walkdown of all accessible ICW flanges between the Unit 3 pumps and header identified no other observable cracks. As such, there is no common cause failure concern with the current risk analysis.

Operation and Maintenance Restriction Commitments The following identifies those actions committed to by FPL. Any other actions discussed represent intended or planned actions by FPL and are not regulatory commitments. The compensatory measures have been entered as regulatory commitments in the Turkey Point Licensing Action Item Tracking System, which complies with Nuclear Energy Institute 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes."

1. While in the extended 3P9B outage time period, overall plant risk will be managed by the existing Maintenance Rule (a)(4) program. This program utilizes the EOOS software to evaluate unique plant configurations. Turkey Point procedure 0-ADM-225 addresses the actions required to be taken at each risk level. Work control assesses and manages the risk of

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 12 of 16 work week activities in advance, while the control room assesses and manages the risk of emergent work.

2. Protected signs will be established on the following equipment:

" 3P9A - 3A ICW Pump

" 3P9C - 3C ICW Pump

" 3A4160Vbus

" 3D 4160V bus via the B 4160V bus

3. The following restrictions will be in effect until 3P9B is restored to operable status:

" Elective maintenance will not be performed on the 3P9A, 3P9C, or other ICW components.

  • Elective maintenance will not be performed on the Component Cooling Water (CCW) system.

" Elective maintenance will not be performed on the Chemical Volume and Control System (CVCS) components supporting RCP seal injection.

" Elective maintenance will not be performed on the 3A, 3B and 3D 4160V buses.

" Elective maintenance will not be performed on the 3A and 3B EDGs.

Conclusion As discussed above, there is no significant increase in risk associated with extending the AOT for 7 days to accomplish the repair and subsequent testing of 3P9B. Additionally, there is an inherent safety benefit of repairing 3P9B without shutting the plant down as compared to shutting the plant down with 3P9B unavailable. Therefore, requiring this repair to be performed during shutdown would result in additional plant equipment and personnel challenges without any significant benefit to the safety of the plant or the health and safety of the public. In addition to the risk insights discussed above, redundant equipment exists to ensure that the ICW cooling function is performed. The redundant equipment (3P9A and 3P9C) will be maintained in an operable condition in accordance with TSs. Work on 3P9B is prioritized such that work is performed around the clock in accordance with site administrative procedures. In addition, to ensure that the work proceeds in an orderly, yet expeditious manner, the Outage Command Center is activated to ensure that appropriate focus is placed on scheduling, prioritization, contingencies, and relief turnover. Senior Corporate and Site Management personnel will continue to closely monitor the work activities to assure prompt completion.

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 13 of 16

6.0 REGULATORY ANALYSIS

Existing TS Actions would require a plant shutdown if 3B ICW pump is not returned to an operable status within the 7-day AOT. The PRA analysis has shown that the increase in risk from extending the AOT from 7 to 14 days is less than the stringent threshold criteria specified in RG 1.177 for a permanent TS change. The restriction of other safety-related or risk -

significant components being considered as protected equipment during the extended 3B ICW pump AOT will assure that redundant systems and equipment are available in the unlikely event of an accident that would require these components to function properly.

In conclusion, based on the considerations above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Description of amendment request:

The proposed license amendment to Facility Operating License DPR-31 for Turkey Point Unit 3 will revise the TSs to allow a one-time extension of the current AOT for the inoperable ICW pump 3B from 7 days to 14 days to support emergent maintenance and repair on ICW pump 3P9B.

Pursuant to 10 CFR 50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each consideration is discussed below.

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change affects the AOT for TS 3.7.3, Action a. The proposed change allows a one-time extension of the current AOT for the inoperable 3B ICW pump (3P9B) from seven (7) days to fourteen (14) days. The proposed change does not affect the

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 14 of 16 design of the ICW System, the operational characteristics or function of the ICW System, the interfaces between the ICW System and other plant systems, or significantly affect the reliability of the ICW System. Limiting conditions for operation and their associated allowed outage times are not considered initiating conditions for any accident previously evaluated, nor is the ICW System considered an initiator for any accident previously evaluated. The ICW System provides the cooling water to the safety related Component Cooling Water (CCW) Heat Exchangers. The ICW System also provides cooling water to the Turbine Plant Cooling Water (TPCW) Heat Exchangers and supplies water to the Lube Water System. During accident conditions, the ICW System performs the accident mitigation function of removing the heat load from the CCW System to support both reactor heat removal and containment heat removal requirements. The consequences of accidents previously evaluated are not affected by the proposed change in AOT. To fully evaluate the effect of the proposed ICW AOT extension, Probabilistic Risk Assessment (PRA) methods and a deterministic analysis were utilized. The results of the analysis show no significant increase in Core Damage Frequency or Large Early Release Frequency based upon the guidance provided in Regulatory Guide 1.174 "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and 1.177, "An Approach for Plant-Specific, Risk-Informed Decision Making: Technical Specifications".

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the probability of a new or different accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a change in the design, configuration, or method of operation of the plant. The proposed change will not alter the manner in which equipment operation is initiated, nor will the functional demands on credited equipment be changed. The proposed change allows operation of the unit to continue while pump 3B is repaired and retested. The proposed extension does not affect the interaction of pump 3B with any system whose failure or malfunction can initiate an accident. As such, no new failure modes are being introduced.

Therefore, the proposed action does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Turkey Point Unit 3 Attachment I Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Tirhý One Time Change L-2006-136 Page 15 of 16

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change does not alter the plant design, nor does it affect the assumptions contained in the safety analyses. Specifically, there are no changes being made to the ICW design, including instrument setpoints. The proposed change has been evaluated both deterministically, and using risk-informed methods. Based upon these evaluations, margins of safety ascribed to ICW availability and to plant risk have been determined to not be significantly reduced. The evaluation has concluded the following with respect to the proposed change:

Applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, sufficient safety margins will be maintained, and any increases in CDF and LERF are small and consistent with the NRC Safety Goal Policy Statement (Federal Register, Vol.5.1, P. 30028 (51 FR 30028), August 4, 1986) as interpreted by NRC Regulatory Guides 1.174 and 1.177. Furthermore, increases in risk posed by potential combinations of equipment out of service during the proposed extended ICW pump 3B AOT will be managed under a configuration risk management program consistent with 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," paragraph (a)(4).

The availability of the other ICW pumps (3P9A and 3P9C) and the use of on-line risk assessment tools, as well as planned compensatory measures, provide adequate compensation for the potential small incremental increase in plant risk associated with the extended ICW pump 3B AOT.

Therefore, the proposed change does not involve a significant reduction in margin of safety.

Based on the above, FPL concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

8.0 ENVIRONMENTAL CONSIDERATION

The proposed license amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The proposed amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. FPL concluded that the proposed amendment

Turkey Point Unit 3 Attachment 1 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change L-2006-136 Page 16 of 16 involves no significant hazards consideration and meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.

ATTACHMENT 2 Turkey Point Unit 3 Docket No. 50-250 License No. DPR-31 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change Marked Up Technical Specification Page Page 3/4 7-14

PLANT SYSTEMS 314.7.3 INTAKE COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 The Intake Cooling Water System (ICW) shall be OPERABLE with:

a. Three ICW pumps, and
b. Two ICW headers.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

a. With only two ICW pumps with Independ power pplies OPERABLE, restore the inoperable ICW pump to OPERABLE status within 7 be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the follo 3 rs. The provisions of Specification 3.0.4 are not applicable.
b. With only one ICW pump OPERABLE or with two ICW pumps OPERABLE but not from independent power supplies, restore two pumps from independent power supplies to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c. With only one ICW header OPERABLE, restore two headers to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.3 The Intake Cooling Water System (ICW) shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct position; and
b. At least once per 18 months during shutdown, by verifying that:
1) Each automatic valve servicing safety-related equipment actuates to its correct position on a SI test signal, and
2) Each Intake Cooling Water System pump starts automatically on a SI test signal.
3) Interlocks required for system operability are OPERABLE.

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TK+ 3Y 3BUNITS3 C (S43. 7 AN TURKEY POINT - UNITS 3 &4 3/4 7-14 AMENDMENT NOS. 137 AND 132

ATTACHMENT 3 Turkey Point Unit 3 Docket No. 50-250 License No. DPR-31 Emergency License Amendment Request No. 185 ICW Pump Allowed Outage Time One Time Change Camera Ready Technical Specification Page Page 314 7-14

PLANT SYSTEMS 3/4.7.3 INTAKE COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.3 The Intake Cooling Water System (ICW) shall be OPERABLE with:

a. Three ICW pumps, and
b. Two ICW headers.

APPLICABILITY: MODES 1, 2,3, and 4.

ACTION:

a. With only two ICW pumps with independent power supplies OPERABLE, restore the Inoperable ICW pump to OPERABLE status within 7 days* or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The provisions of Specification 3.0.4 are not applicable.
b. With only one ICW pump OPERABLE or with two ICW pumps OPERABLE but not from independent power supplies, restore two pumps from Independent power supplies to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c. With only one ICW header OPERABLE, restore two headers to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

$URVEILLANCE REQUIREMENTS 4.7.3 The Intake Cooling Water System (ICW) shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) servicing safety-related equipment that Is not locked, sealed, or otherwise secured in position is in its correct position; and
b. At least once per 18 months during shutdown, by verifying that:
1) Each automatic valve servicing safety-related equipment actuates to its correct position on a SI test signal, and
2) Each Intake Cooling Water System pump starts automatically on a SI test signal.
3) Interlocks required for system operability are OPERABLE.

The 7-day allowed outage time of Technical Specification 3.7.3, Action a, which was entered on May 15, 2006 at 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br />, may be extended one time by an additional 7 days to complete repair and testing of the Unit 3 3B ICW pump (3P9B).

TURKEY POINT - UNITS 3 & 4 3/4 7-14 AMENDMENT NOS. AND

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