L-2014-249, Request for Revision of Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink

Request for Revision of Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink

ML14210A005
Person / Time
Site:	Turkey Point
Issue date:	07/25/2014
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-249
Download: ML14210A005 (2)

Text

PPl.

L-2014-249 July 25, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating License Nos. DPR-31 and DPR-41

Subject:

Request for Revision of Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink

Reference:

1) Florida Power & Light Company (FPL ) Letter L-2014-231. "Request for Enforcement Discretion Regarding Technical Specification 3/4.7.4, Ultimate Heat Sink," dated July 21, 2014.

2) NRC Letter, "Notice of Enforcement Discretion (NOED) for Florida Power and Light Company Regarding Turkey Point Nuclear Generating Station Units 3 and 4

[NOED No. 14-2-001], dated July 23, 2014.

3) Florida Power & Light Company (FPL) Letter L-2014-216, "License Amendment Request No. 231, Application to Revise Technical Specification to Revise Ultimate Heat Sink Temperature Limit, dated July 10, 2014.

4) Florida Power & Light Company (FPL) Letter L-2014-226, "License Amendment Request No. 231, Application to Revise Ultimate Heat Sink Temperature Limit -

Request for Emergency Approval," dated July 17, 2014.

By letter dated July 21, 2014 (Reference 1), FPL requested that the NRC exercise discretion from enforcing compliance with TS 3.7.4 "Ultimate Heat Sink." By letter dated July 23, 2014 (Reference 2), NRC issued the Notice of Enforcement Discretion (NOED) consistent with the NRC Enforcement Policy and NRC staff guidance concluding that the request had no adverse impact on public health and safety or the environment. Florida Power & Light Company (FPL) requests that the NRC grant a revision to that discretion from enforcing the shutdown requirements of Turkey Point Units 3 and 4 Technical Specification (TS) 3/4.7.4, Ultimate Heat Sink.

On July 20, 2014, Turkey Point Units 3 and 4 entered TS 3.7.4, Required Action for ultimate heat sink (UHS) average supply water temperature exceeding 100°F, and if not restored, FPL would be required to place the units in Mode 3 (Hot Standby) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and in Mode 5 (Hot Shutdown)

Florida Power & Light Company Page 2 of 2 Request to Revise Notice of Enforcement Discretion within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. As discussed in the NOED request and in a telephone conference with the NRC on July 20, 2014, this condition would result in an unnecessary shutdown of Turkey Point Units 3 and 4 without a corresponding health and safety benefit during a period of high system load demand when the operation of the units is essential for grid voltage stability.

The purpose of this letter is to request the NRC revise one of the conditions associated with the NOED. The original length of time requested in the NOED was 10 days. The UHS peak temperatures have continued to cycle near the Technical Specification limit of I 00°F and are anticipated to exceed the limit during the duration of the NOED. FPL requests that the 10 day condition be changed to "upon approval or disapproval of the emergency License Amendment Request" that would permanently revise the UHS temperature limit (References 3 and 4). All other statements and conditions of the NOED remain valid.

FPL remains in a period of high system load demand such that this request for revision concerns an avoidance of a dual unit shutdown of Turkey Point Units 3 and 4.

This NOED revision request was reviewed and approved by the Turkey Point Plant Nuclear Safety Committee on July 25, 2014.

If you have any questions or require additional information, please contact Mr. Robert Tomonto at 305-246-7327.

Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant