L-2011-521, License Amendment Request No. 214, Response to Request for Additional Information Questions

License Amendment Request No. 214, Response to Request for Additional Information Questions

ML11350A234
Person / Time
Site:	Turkey Point
Issue date:	12/01/2011
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2011-521, LAR 214
Download: ML11350A234 (8)

Text

0 DEC 012011 L-2011-521 FPL.

POWERING TODAY.

EMPOWERING TOMORROW.0 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Docket Nos. 50-250 and 50-251 License Amendment Request No. 214 Response to Request for Additional Information Questions

References:

1) FPL letter L-2011-046 to the USNRC, dated August 17, 2011, License Amendment Request No. 214, Accident Monitoring Instrumentation Technical Specification Changes Regarding High Range-Noble Gas Effluent Monitors-Main Steam Lines Accident Monitoring Instrumentation

2) Email from J. Paige (NRC) to R. J. Tomonto (FPL), "Turkey Point Accident Monitoring Instrumentation TS Changes LAR (ME6891 and ME6892)," dated November 10, 2011 On August 17, 2011, Florida Power and Light Company (FPL) submitted in letter L-2011-046, the License Amendment Request No. 214 (Reference 1) to relocate the Turkey Point Accident Monitoring Technical Specification and Surveillance Requirements for the High Range Noble Gas Effluent Monitor for the Main Steam Lines (RAD-6426) from the Technical Specifications (TS) to the Updated Final Safety Analysis Report (UFSAR) and related procedures.

By electronic mail from the Nuclear Regulatory Commission (NRC) Project Manager (PM) dated November 10, 2011, the NRC requested Florida Power & Light Company (FPL) to respond to request for additional information questions within 30 days (Reference 2).

Attachment 1 contains the NRC RAI questions and the FPL responses. Enclosure 1 provides procedural references to RAD-6426 to facilitate the review of the response to RAI questions.

an FPL Group company

L-2011-521 Page 2 The information provided herein does not change the conclusions stated in Reference 1, and does not create any new commitments.

Should there be any questions, please contact Mr. Robert J. Tomonto, Licensing Manager at 305 246-7327.

Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant SM Attachment Enclosure cc: Regional Administrator, USNRC Region II USNRC Senior Resident Inspector - Turkey Point Plant

L-2011-521 Attachment I Page 1 of 2 RAI EICB-1:

Verify that the RAD6426 instrument is not solely credited in any emergency / abnormal operational procedures for an event that involves degradation of the primary coolant boundary (e.g., SG tube rupture). Provide the documentation that demonstrates that RAD6426 has been removed from such procedures.

FPL Response to EICB-1:

The Main Steam Line Monitor, RAD-6426, indication and/or alarms are used in the following off-normal (ONOP) and emergency operating procedures (EOP):

3/4-ONOP-067, "Radioactive Effluent Release" 3/4-ONOP-071.2, "Steam Generator Tube Leakage" 3/4-EOP-FR-H.3, "Response to Steam Generator High Level" 3/4-EOP-E-2, "Faulted Steam Generator Isolation" In each of these procedures, Steam Line Monitor RAD-6426 indication and/or alarms are used as one of several methods available to determine if secondary-side effluent radioactivity has increased, which could be an indication of steam generator tube leakage or tube rupture.

RAD-6426 indications and/or alarms are not used in these procedures as the sole indication of an increase in secondary side radioactivity. For example:

o In 3/4-ONOP-067, an increase in radioactivity (alarm) on either RAD-6426 or RAD-6417 (Condenser Air Ejector radiation monitor) directs the operator to 3/4-ONOP-067 (Steam Generator Tube Leakage).

o In 3/4-EOP-FR-H.3, a check for secondary-side increased radioactivity is made by sampling steam generators, checking RAD-6426 and taking radiation readings on the steam lines.

RAD-6426 indication/alarm is one of several methods available to determine if secondary system activity has increased. It is unlikely that RAD-6426 will detect low levels of radiation increase (due to its higher detection range), before other monitors (such as condenser air ejector and blowdown) detect such increase.

It is concluded that since RAD-6426 is considered as one of several methods available that may be used to determine if secondary activity has increased, it is appropriately included in the station's ONOPs and EOPs.

L-2011-521 Attachment I Page 2 of 2 RAD-6426 monitor is not credited in any of the accident analyses for the prevention or mitigation of any accident. RAD-6426 is not used in any procedure as a sole source of information for operator actions, or in determining if a barrier to fission product release has been breached.

RAD-6426 monitor is credited in the Steam Generator Tube Rupture Radiological Consequences analysis (UFSAR 14.2.4.1) as being available during the event to monitor releases from the Main Steam Safety Valves or Atmospheric Dump Valves.

This use of the monitor is consistent with the definition of a Regulatory Guide 1.97 Type E variable: "those variables to be monitored as required in determining the magnitude of the release of radioactive materials and for continuously assessing such releases".

RAI EICB-2:

RAD6417 was credited as performing the RG 1.97 Type C instrument function that RAD6426 was previously credited regarding detection of a steam generator tube rupture. Are the 19.c entries in Tables 3.3-5 and 4.3-4 of Technical Specification 3.3.3.3 intended to address operability and surveillance of this instrument? Alternately, if this instrument is not addressed in the Technical Specification, explain why.

FPL Response to EICB-2:

Yes, the instrument 19.c entries in Tables 3.3-5 and 4.3-4 of Technical Specification 3.3.3.3 address operability and surveillance requirements specifically for RAD-6417 (Condenser Air Ejector Monitor).

L-2011-521 Enclosure 1 Procedural References Relevant Pages

Procedure No.: Procedure

Title:

Page:

13 Approval Date:

3-ONOP-067 Radioactive Effluent Release 5/27/10 SE I ACTIONIEXPECTED RESPONSE RESPONSE NOT OBTAINED r- - - - - - - - - - - - - - - - - - - - - - - -

NOTE I Step 8 is NOT applicable to a channel failure of R-11, R-12, R-15, orR-19. I L. - - - - - - - - - - - - - - -

8 Check For PRMS Channel Failure Perform the following:

" Check Fail indicator - OFF a. IF R-14 fails low AND a gas decay tank release is in progress, THEN stop the

• Display and recorder reading - NOT release.

FAILED LOW

b. IF R-18 fails low AND a liquid release is in progress, THEN stop the release.

c. Notify the Shift Manager to refer to Tech Specs AND take all required actions for the failed channel(s).

d. Notify I&C of the PRMS failure.

9 Check R11/12 RM-80 Green Monitor Light - Identify and correct the cause of failure ON using applicable Steps 18 through 28.

10 Check If Effluent Radiation Monitors ALARMS - OFF

a. Check the following radiation monitor a. Go to 3-ONOP-071.2, STEAM alarms - OFF GENERATOR TUBE LEAKAGE.

• RAD-3-6417 (SJAE SPING)

• RAD-3-6426 (DAM-1 Monitor)

b. Check RAD-6304 (Plant Vent SPING) b. Perform the following as applicable:

alarm - OFF

1) 4-ONOP-033.1, SFP COOLING SYSTEM MALFUNCTION

2) IF Steps 42 through 45 NOT previously performed, THEN go to Step 42.

c. Check RAD-6418 (SFP Vent SPING) alarm c. Perform 3-ONOP-033.3, ACCIDENT

- OFF INVOLVING NEW OR SPENT FUEL.

WV97Inw/mr/cla

1.0 PURPOSE 1.1 This procedure provides instructions to be followed in the event of a secondary radiation monitor alarm or malfunction that could result in a radiation hazard or inadvertent release of radioactivity to the environment.

2.0 SYMPTOMS OR ENTRY CONDITIONS 2.1 Alarms on the followina PRMS Channels 2.1.1 Condenser Air Ejector Gas Monitor R-4-15 2.1.2 Steam Generator Liquid Sample Monitor R-4-19 2.2 Hiah Radiation alarms on the following Radiation Monitors 2.2.1 Steam Jet Air Ejector SPING, RAD 6417 2.2.2 DAM-1 Monitor, RAD-6426 2.3 Contr ol Room Annunciators 2.3.1 H 1/4, PRMS HI RADIATION 2.3.2 H 1/6, PRMS CHANNEL FAILURE 2.4 Increasing Count Rate on the following Radiation Monitors 2.4.1 Condenser Air Ejector Gas Monitor R-4-15 2.4.2 Steam Generator Liquid Sample Monitor R-4-19 2.4.3 Steam Jet Air Ejector SPING, RAD 6417 2.4.4 DAM-1 Monitor, RAD-6426 2.5 HP reports high activity on Steam Generator Steam or Blowdown line(s) 2.6 Chemistry reports increasing secondary activity 97*/JEC/ds/ds/cls

STE ACIONEXPECTED RESPONSE RESPONSE NOT OBTAINED 8 Check Affected SIG(s) Radiation - NEAR Perform one of the following:

ROUTINE OPERATION VALUE

• IF an E-3 or ECA-3 series procedure is

" Direct Nuclear Chemistry to take activity in effect, THEN return to procedure AND sample of affected S/G step in effect.

" Direct Nuclear Chemistry to check DAM 1 " IF an E-3 or ECA-3 series procedure is monitor reading NOT in effect, THEN go to 4-EOP-E-3, STEAM GENERATOR TUBE

" Direct Radiation Protection to take radiation RUPTURE, Step 1.

readings on main steam line W97:JCIcls