L-2012-056, Response to NRC Request for Additional Information Regarding Control Room Habitability TSTF-448, License Amendment Request No. 194

Response to NRC Request for Additional Information Regarding Control Room Habitability TSTF-448, License Amendment Request No. 194

ML12088A008
Person / Time
Site:	Turkey Point
Issue date:	03/13/2012
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2012-056, TAC ME0004, TAC ME0005
Download: ML12088A008 (9)

Text

FPL. L-2012-056 POWERING TODAY. 10 CFR 50.90 EMPOWERING TOMORROW.

U.S. Nuclear Regulatory Commission MAR 1 3 2012 Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to NRC Request for Additional Information Regarding Control Room Habitability TSTF-448 License Amendment Request No. 194 (TAC Nos. ME0004 and ME0005)

References:

1) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-004), "License Amendment Request (LAR 194) - Control Room Habitability TSTF-448," July 16, 2010, (NRC Accession No. ML10210386).

2) Email from J. Paige (NRC) to Bob Tomonto (FPL), "Requests for Additional Information,"

June 16, 2011 (NRC Accession No. ML11167A291).

3) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-264), "License Amendment Request (LAR 194) - Control Room Habitability TSTF-448 Requests for Additional Information, System (TAC Nos. ME0004 and ME0005)," July 18, 2011 (NRC Accession No. ML1 120A021).

4) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-276), "Supplemental Response Regarding LAR 194, Control Room Habitability TSTF-448, and Changes to Technical Specification 3.7.5, Control Room Emergency Ventilation System (TAC Nos.

ME0004 and ME0005)," August 1, 2011 (NRC Accession No. ML11215A013).

5) Email from J. Paige (NRC) to Bob Tomonto (FPL), "Acceptable Wording for TSTF-448, a.5," September 6, 2011.

6) Email from J. Paige (NRC) to Bob Tomonto (FPL), "Requests for Additional Information, Round 2," September 29, 2011 (NRC Accession No. ML11273A003).

7) J. Paige (NRC) to M. Nazar (FPL), "Turkey Point Units 3 and 4 - Issuance of Amendments Regarding Alternative Source Term (TAC Nos. ME1624 and ME1625,"

June 23, 2011 (NRC Accession No. ML110800666).

8) M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-380), "License Amendment Request (LAR 194) Control Room Habitability TSTF-448 Responses to NRC Questions and LAR 194 Changes (TAC Nos. ME004 and ME005)," October 27, 2011 (NRC Accession No. ML11304A184).

By letter L-2010-004 dated July 16, 2010 [Reference 1], Florida Power and Light (FPL)

Company requested an amendment to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 Technical Specifications. The proposed amendment would modify the Technical Specification (TS) requirements related to control room envelope A ,C. )a an FPL Group company 0 ý-Z

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Page.2 of 3 Responses to NRC Request for Additional Information Regarding Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND ME0005) habitability in accordance with Technical Specification Task Force (TSTF) Change Traveler TSTF-448 Revision 3, "Control Room Habitability."

On June 16, 2011, FPL received Requests for Additional Information (RAI) via email [Reference 2] from the U.S. Nuclear Regulatory Commission (NRC) Project Manager (PM) Mr. Jason Paige.

The RAI consisted of five questions pertaining to the License Amendment Request (LAR 194).

The responses to these five questions were provided in FPL letter L-2011-264 dated July 18, 2011

[Reference 3] and supplemented by FPL letter L-2011-276 dated August 1, 2011 [Reference 4].

References 5 and 6 were sent by the NRC to FPL providing additional direction concerning the information needed from FPL.

During the phone call held between NRC and FPL on September 2, 2011, the NRC requested that the proposed changes for adoption of TSTF-448 be based upon the changes to Technical Specification (TS) 3.7.5 that were approved and issued by the NRC under Amendments 244 and 240 on Alternative Source Term on June 23, 2011 [Reference 7]. Accordingly, the proposed changes for TSTF-448 to the TS and the TS Bases (provided for information only) are based upon the NRC issued amendment pages for AST. FPL provided its responses to the NRC's Round 2 Questions regarding TSTF-448 via letter L-2011-3 80 on October 27, 2011 [Reference 8].

On January 19, 2012, additional information regarding the TSTF-448 submittals was requested by the PM during a telephone call with licensing. FPL's response to this request for additional information is provided in the Attachment to this letter.

AST license conditions 3.H. 1 and 3.1.1 of Renewed Licenses DPR-31 and DPR-41, respectively

[Reference 7] include requirements that FPL will perform post-modification testing (including tracer gas testing) and a confirmatory assessment which demonstrates that the requirements of 10 CFR 50 Appendix A, GDC 19 will be met.

This letter contains no new commitments and no revisions to existing commitments but does contain one proposed license condition for each unit (3.L. 1 for Unit 3 and 3.M. 1 for Unit 4) regarding the first performance of required post-modification testing (including tracer gas testing) and confirmatory assessment for the Control Room Emergency Ventilation System (CREVS).

The Turkey Point Plant Nuclear Safety Committee has reviewed the changes to the previously proposed TS changes and TS Bases pages for TSTF-448 approval. The proposed changes were evaluated in accordance with 10 CFR 50.91(a)(1), using the criteria in 10 CFR 50.92(c). FPL reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the Consolidated Line Item Improvement Process (CLIIP). FPL has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Turkey Point Units 3 and 4 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a). This submittal does not alter the NSHCD or environmental assessment.

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Page 3 of 3 Responses to NRC Request for Additional Information Regarding Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND ME0005)

In accordance with 10 CFR 50.91(b)(1), a copy of the proposed amendment changes was forwarded to the State Designee for the State 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 March 13 , 2012.

Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Generating Station Attachment (1) cc: Regional Administrator, Region II, USNRC USNRC Project Manager, Turkey Point Nuclear Plant Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Mr. W. A. Passetti, Florida Department of Health

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Attachment 1 Responses to NRC Request for Additional Information Regarding Page 1 of 6 Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND ME0005)

Turkey Point Units 3 and 4 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTROL ROOM HABITABILITY TSTF-448 ATTACHMENT

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Attachment 1 Responses to NRC Request for Additional Information Regarding Page 2 of 6 Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND MEOO05)

Response to Request for Additional Information The following information is provided by Florida Power and Light Company (FPL) in response to the U. S. Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI).

This information was requested to support License Amendment Request (LAR) 194, Control Room Habitability, for Turkey Point Nuclear Plant (PTN) Units 3 and 4 that was submitted to the NRC by FPL via letter (L-2010-004) dated July 16, 2010 [Reference 1].

NRC OUESTION #1:

By letter L-2010-004 [Reference 1], FPL proposed new license conditions for Turkey Point Units 3 and 4 Renewed Licenses DPR-31 and DPR-41 based on Technical Specification Task Force (TSTF) Change Traveler TSTF-448 Revision 3, "Control Room Habitability." By letter L-2011-276 [Reference 2], FPL proposed an additional surveillance requirement (SR 4.7.5.g) to perform Control Room Envelope (CRE) unfiltered air inleakage testing in accordance with the CRE Habitability Program. Therefore, the license conditions should be revised to reflect SR 4.7.5.g rather than SR 4.7.5.f

Response

FPL concurs that the proposed license conditions for DPR-31 and DPR-41 should cite SR 4.7.5.g instead of SR 4.7.5.f due to the proposed changes in the 4.7.5 surveillance requirements reflected in FPL letter L-2011-276 [Reference 2]. In addition, a new surveillance requirement was proposed for SR 4.7.5.d.2 in letter L-2011-380 [Reference 3] to reflect the Control Room Envelope (CRE) pressure measurement testing requirement. Thus, the reference in (a) of the license condition below to the CRE unfiltered air inleakage testing (tracer gas test) SR 4.7.5.f is revised to SR 4.7.5.g and reference to CRE pressure measurement testing SR 4.7.5.d.2 is added to (c) of the license condition.

Proposed License Condition 3.L.1 for DPR-31 (Unit 3)

1. Upon implementation of Amendment No. adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5.g, in accordance with Technical Specification (TS) 6.8.4.k.c.(i), the assessment of CRE habitability as required by TS 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by Specification 6.8.4.k.d, shall be considered met.

(a) The first performance of SR 4.7.5.g, in accordance with TS 6.8.4.k.c.(i), shall be within the specified Frequency of 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.**

(b) The first performance of the periodic assessment of CRE habitability, TS 6.8.4.k.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(c) The first performance of SR 4.7.5.d.2, in accordance with TS 6.8.4.k.d, shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Attachment 1 Responses to NRC Request for Additional Information Regarding Page 3 of 6 Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND ME0005)

Proposed License Condition 3.M.1 for DPR-41 (Unit 4)

1. Upon implementation of Amendment No. adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5.g, in accordance with Technical Specification (TS) 6.8.4.k.c.(i), the assessment of CRE habitability as required by TS 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by Specification 6.8.4.k.d, shall be considered met.

(a) The first performance of SR 4.7.5.g, in accordance with TS 6.8.4.k.c.(i), shall be within the specified Frequency of 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(b) The first performance of the periodic assessment of CRE habitability, TS 6.8.4.k.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(c) The first performance of SR 4.7.5.d.2, in accordance with TS 6.8.4.k.d, shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

Basis for the Changes:

The changes to the cited SR reference in the proposed license conditions originally proposed in FPL letter L-2011-004 [Reference 1] are consistent with changes proposed to the TS 4.7.5 surveillance requirements in FPL letters L-2011-276 [Reference 2] and L-2011-380 [Reference 3].

See attached DPR-31 (page 4) and DPR-41 (page 5) markups. Note that the markups reflect the DPRs with the EPU LAR license conditions which are currently pending final approval by the NRC.

NRC QUESTION #2:

The license condition references the same date for both the tracer gas test and the periodic assessment. This seems incorrect.

Response

The license condition specifies the dates for the first performance of the tracer gas test and the first performance of the periodic assessment of CRE habitability. Since the last tracer gas test that was performed on July 31, 2009 was unsuccessful and consistent with Regulatory Guide 1.197, Revision 0 and NEI 99-03, Revision 1, the tracer gas test is required to be performed within 3 years from the July 31, 2009 test date. The CRE habitability assessment is also required to be performed within 3 years from the tracer gas test date. Therefore, the tracer gas test and the CRE habitability assessment will be performed within 3 years (plus grace period) from the last tracer gas test performance date of July 31, 2009.

As part of the Alternative Source Term (AST) Amendments 244 and 240, a compensatory air filtration unit is being added to the Control Room Ventilation System, and post-modification testing will be required. In accordance with license conditions 3.H. 1 and 4.H. 1 of DPR-31 and DPR-4 1, FPL is performing the tracer gas test and the CRE habitability assessment prior to restart of Unit 3 from the current cycle 26 refueling outage.

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Attachment 1 Responses to NRC Request for Additional Information Regarding Page 4 of 6 Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND MEOO5)

DPR-31 Changes 7

L. Control Room Habitability Testing

1. Upon implementation of Amendment No. adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5.g. in accordance with Technical Specification (TS) 6.8.4.k.c.(i), the assessment of CRE habitability as required by TS 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by Specification 6_8.4.k.d. shall be considered met.

(a) The first performance of SR 4.7-5-g, in accordance with TS 6.8.4.k.c.(i),

shall be within the specified Frequency of 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test (b) The first performance of the periodic assessment of CRE habitability, TS 6.8.4.kc.(ii), shall be within 3 years. plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(c) The first performance of SR 4.7-5-d.2, in accordance with TS 6.8.4.k.d, shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight July 19, 2032.

FOR THE NUCLEAR REGULATORY COMMISSION Signed by Eric J. Leeds, Director Office of Nudear Reactor Regulation Attachments:

Appendix A - Technical Specifications for Unit 3 Appendix B - Environmental Protection Plan Date of Issuance:

Renewed License No. DPR-31

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Attachment 1 Responses to NRC Request for Additional Information Regarding Page 5 of 6 Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND MEOO5)

DPR-41 Change 7

K. PAD TCD Safety Analyses

1. PAD 4.0 TCD has been specifically approved for use for the Turkey Point licensing basis analyses. Upon NRC's approval of a revised generic version of PAD that accounts for Thermal Conductivity Degradation (1-CD), FPL will within six months:

a. Demonstrate that PAD 4.0 TCD remains conservatively bounding in licensing basis analyses when compared to the new generically approved version of PAD w/TCD, or

b. Provide a schedule for the re-analysis using the new generically approved version of PAD w/TCD for any of the affected licensing basis analyses.

L Burnable Absorbers in Spent Fuel Pool

1. With respect to Technical Specification 5.5.1.3, FPL shall not credit any burnable absorber other than Integral Fuel Burnable Absorber (IFBA) rods for the storage of fuel assemblies in the Region I spent fuel racks.

M. Control Room Habitability Testing

1. Upon implementation of Amendment No. adopting TSTF-448 Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by Surveillance Requirement (SR) 4.7.5.g, in accordance with Technical Specification (TS) 6.8-4.k.c.(i), the assessment of CRE habitability as required by TS 6.8.4.k.c.(ii), and the measurement of CRE pressure as required by Specification 6.B.4.k.d, shall be considered met.

(a) The first performance of SR 4.7.5.g, in accordance with TS 6.8.4.k.c_(i),

shall be within the specified Frequency of 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31,2009. the date of the most recent tracer gas test (b) The first performance of the periodic assessment of CRE habitability, TS 6.8.4.k.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from July 31, 2009, the date of the most recent tracer gas test.

(c) The first performance of SR 4.7.5.d.2, in accordance with TS 6.8.4.k.d.

shall be within 36 months on a STAGGERED TEST BASIS, plus the 138 days allowed by SR 4.0.2, as measured from the date of the most recent successful pressure measurement test, or within 138 days of license amendment implementation if not performed previously.

4. This renewed license is effective as of the date of issuance, and shall expire at midnight April 10, 2033.

Renewed License No. DPR-41

Turkey Point Units 3 and 4 L-2012-056 Docket Nos. 50-250 and 50-251 Attachment 1 Responses to NRC Request for Additional Information Regarding Page 6 of 6 Control Room Habitability TSTF-448 License Amendment Request (LAR 194)

(TAC NOS. ME0004 AND ME0005)

References

1. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2010-004), "License Amendment Request (LAR 194) - Control Room Habitability TSTF-448," Accession No. ML10210386, July 16, 2010.

2. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-276), "Supplemental Response Regarding LAR 194, Control Room Habitability TSTF-448, and Changes to Technical Specification 3.7.5, Control Room Emergency Ventilation System (TAC Nos.

ME0004 and ME0005)," Accession No. MLI 1215A013, August 1, 2011.

3. M. Kiley (FPL) to U.S. Nuclear Regulatory Commission (L-2011-380), "License Amendment Request (LAR 194) Control Room Habitability TSTF-448 Responses to NRC Questions and LAR 194 Changes (TAC Nos. ME004 and ME005)," Accession No. ML11304A184, October 27, 2011.