L-2016-172, Response to Request for Additional Information Regarding License Amendment Request 242, Changes to Snubber Surveillance Requirements, Snubber Testing Program Plan - Fifth Inspection Interval

Response to Request for Additional Information Regarding License Amendment Request 242, Changes to Snubber Surveillance Requirements, Snubber Testing Program Plan - Fifth Inspection Interval

ML16260A399
Person / Time
Site:	Turkey Point
Issue date:	09/01/2016
From:	Summers T Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2016-172
Download: ML16260A399 (13)

Text

September 1, 2016 L-2016-172 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Additional Information Regarding License Amendment Request 242, Changes to Snubber Surveillance Requirements, Snubber Testing Program Plan -

Fifth Inspection Interval

References:

1. Florida Power & Light Company letter L-2016-055, "License Amendment Request 242, Changes to Snubber Surveillance Requirements, Snubber Testing Program Plan - Fifth Inspection Interval," April 4, 2016 (ML16110A266)

2. NRC E-mail "Request for Additional Information - Turkey Point 3 & 4 - LAR-242 (CACs MF7557 & MF7558)," August 11, 2016 (ML16228A004)

In Reference 1, Florida Power & Light Company (FPL) submitted license amendment request (LAR) 242 for Turkey Point Units 3 and 4. The proposed amendment would revise Technical Specification (TS) 3/4.7.6, Snubbers, to conform with the Snubber Testing Program. The Snubber Testing Program implements Subsection ISTD, "Preservice and Inservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants," of the ASME OM Code, 2004 Edition with 2005 and 2006 Addenda.

In Reference 2, the NRC staff requested additional information to complete its review of LAR 242. The enclosure to this letter provides the FPL response to the NRC staffs request. to the enclosure provides markups of the TS showing revisions to the proposed changes. These markups supersede the corresponding markups provided in Reference 1. provides proposed changes to the Bases for TS 3/4.7.6 and are provided for information only.

This response does not alter the conclusion in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the changes.

No new or revised commitments are included in this letter.

Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035

Florida Power & Light Company L-2016-172 Page 2 of2 Should you have any questions regarding this submission, please contact Mr. Mitch Guth, Licensing Manager, at 305-246-6698.

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

Executed on September I, 2016 Sincerely, Thomas Summers Site Vice President Turkey Point Nuclear Plant Enclosure cc: NRC Regional Administrator, Region II NRC Senior Resident Inspector NRC Project Manager Ms. Cindy Becker, Florida Department of Health

Florida Power & Light Company L-2016-172 Enclosure Page 1of5 ENCLOSURE Response to Request for Additional Information Regarding License Amendment Request 242 Changes to Snubber Surveillance Requirements Snubber Testing Program Plan - Fifth Inspection Interval

Florida Power & Light Company L-2016-172 Enclosure Page 2of5

RAI 1

Section 4.1 of the LAR Enclosure, "Evaluation of Proposed Change," page 3 of7, second paragraph, states, "Currently, snubber testing and examination are performed in accordance with specific requirements of TS 3/4.7.6 and ASME OM Code Subsection ISTA and ISTD, 1998 Edition with addenda through 2000." For Turkey Point 3 and 4, the fifth IO-year inservice inspection inteI"Vals started on February 22, 2015, and April 15, 2015, respectively. Historically, the licensee used TS 3/4.7.6 at Turkey Point 3 and 4 for snubber examination and testing. The staff requests the licensee to provide the date(s) when it started using ASME OM Code Subsection ISTA and ISTD, 1998 Edition with addenda through 2000, for Turkey Point Units 3 and4.

• FPL Response The statement quoted above is incorrect. It should have stated: Currently, snubber testing and examinations are performed in accordance with specific requirements of TS 3/4.7.6, ASME OM Code ISTA and ISTD 2004 Edition with Addenda through 2006, and ASME Section XI, 2007 Edition with 2008 Addenda (attachments).

RAI2 , "Technical Specification Mark-up," of the LAR, page 3/4 7-22, provides a marked-up version of TS 3.7.6 ACTION as follows, with proposed additions in bold italicized text and deletions in stricken text:

With one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and determine the impact perform an engineering evaluation per Specification 4.7.6.f on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

With the deletion of the reference to SR 4.7.6.f, which essentially explains how to determine the impact of an inoperable snubber, it is not clear to the staff the criteria the licensee would use to determine the impact of an inoperable snubber. Therefore, the staff requests the licensee to explain how it would determine the impact of an inoperable snubber per the proposed ACTION statement given that it doesn't reference the Snubber Testing Program (i.e., TS 4.7.6, which refers to TS 6.8.4.m).

FPL Response FPL's intent is to perform the evaluation in accordance with the Snubber Testing Program. To provide clarity the proposed change to the ACTION is revised as follows:

Florida Power & Light Company L-2016-172 Enclosure Page 3of5 With one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and determine the impact perform an engineering evaluation per Specification 4.7.6.f on the attached component by evaluation in accordance with Specification 4. 7.6, or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

The revision to the proposed change is shown on the TS mark-up in Attachment 1 for page 3/4 7-22.

RAI3 of the LAR, page 3/4 7-22, shows the licensee's proposal to revise SR 4.7.6 by adding a reference to the newly added TS 6.8.4.m, "Snubber Testing Program," as follows, with proposed additions in bold italicized text and deletions in stricken text:

Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection Snubber Testing Program in Specification 6.8.4.m in addition to the requirements of Specification 4.0.5.

The stfilfrequests the licensee to clarify the use of TS 4.0.5 along with newly added TS 6.8.4.m. Please confirm whether these TSs are duplicative and/or if TS 6.8.4.m encompasses all requirements of TS 4.0.5.

FPL Response TS 6.8.4.m and TS 4.0.5 are duplicative with respect to snubbers. FPL has proposed to delete reference to TS 4.0.5 in TS 4.7.6 via a separate license amendment application (Reference 1) consistent with Technical Specifications Task Force traveller TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing."

RAI4 of the LAR, page 6-14, shows the proposed TS 6.8.4.m, item 2, which states:

The program shall meet the requirements for ISI of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(b) subject to limitations and modifications listed in 10 CFR 50.55a(b) and subject to Commission approval [emphasis added].

The staff notes that 10 CFR 50.55a was revised such that 10 CFR 50.55a(a) rather than

,.,Florida Power & Light Company L-2016-172 Enclosure Page 4of5 10 CFR 50.55a(b) provides the documents approved for incorporation by reference and that the "limitations and modifications" of 10 CFR 50.55a(b) are now referred to as "conditions." The staff requests the licensee to either reflect these changes in its proposal or justify the currently proposed phrasing.

FPL Response FPL hereby revises the proposed wording in TS 6.8.4.m, Item 2, to reflect the appropriate 10 CFR 50.55a(a) section for incorporated references and the revised wording of 10 CFR 50.55a(b) as follows:

The program shall meet the requirements for ISi of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR 50.55a(a) subject to the use and conditions on the use of standards listed in 10 CFR 50.55a(b) and subject to Commission approval. '

A revision to the origin.al mark-up reflecting the changes above is contained in Attachment 1.

RAIS Attachment 3, "Snubber Testing Program Plan," of the LAR, page 1 of 6 (i.e., the cover page) shows that the program is applicable for the Turkey Point 3 and 4 fifth 10-year intervals. The staff requests the licensee to clarify whether it is proposing that the Snubber Testing Program is applicable only for the fifth 10-year inservice testing (IST) intervals at Turkey Point 3 and 4.

FPL Response The proposed Snubber Testing Program is only applicable for the fifth 10-year intervals for Turkey Point Units 3 and 4. Note that the fifth 10-year interval end dates for Turkey Point should be in 2025 not 2024, i.e. February 21, 2025 for Unit 3 and April 14, 2025 for Unit 4. The fifth 10-year intervals for the Inservice Testing Program were established in FPL letter L-2016-139 dated July 6, 2016 (Reference 2). The Snubber Testing Program Plan will be revised to reflect the correct end dates.

RAI6 Attachment 3 of the LAR, Section 7.2 states, "Controlled listings of the snubbers which are included in this program are maintained and controlled within the O-OSP-105.1 and O-OSP-105.2."

Florida Power & Light Company L-2016-172 Enclosure Page 5of5 (a) The staff requests the licensee to explain any differences between the controlled snubber listings in O-OSP-105.1 and O-OSP-105.2.

(b) The staff requests the licensee to explain whether it has used the criteria of ASME Section XI, IWF-1230 to exempt snubbers while developing the controlled listings of snubbers in O-OSP-105.1 and O-OSP-105.2.

FPL Response -

(a) The snubber lists in procedures O-OSP-105.1, Visual Inspection, Removal and Reinstallation of Snubbers, and O-OSP-105.2, Functional Testing for Snubbers, are complete with the required snubbers but the lists differ based on the activity governed by the procedure. In procedure O-OSP-105 .1 the snubbers are listed as either accessible or inaccessible during power operation. In procedure O-OSP-105.2 the snubbers are listed as either safety-related or non-safety-related.

(b) FPL has not used the criteria of ASME Section Xl,JWF-1230 to exempt snubbers while developing the controlled listings of snubbers in procedures O-OSP-105.1 and O-OSP-105.2.

References

1. NextEra Energy/Florida Power & Light Company letter L-2016-137: "Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," and to Request an Alternative to the ASME Code," July 28, 2016 (ML16214A276)

2. Florida Power & Light Company letter L-2016-139: "Fifth 10-Year Interval, Inservice Testing (IST) Program Plan," July 6, 2016 (ML16202A067)

Attachments

1. Revised Markup of the Technical Specifications

2. Proposed Technical Specification Bases Changes (Information Only)

Florida Power & Light Company L-2016-172 Attachment 1 ATTACHMENT 1 Revised Markup of the Technical Specifications (2 pages follow)

PLANT SYSTEMS 3/4.7.6 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.6 All snubbers shall be OPERABLE. The only snubbers excluded from the requirements are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system.

APPLICABILITY: MODES 1, 2, 3, and 4. MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.

ACTION: determine the impact With one or more snubbers inoperabl n any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and * * * * * . . . on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system. by evaluation in accordance with Specification 4.7.6, Snubber Testing SURVEI LANCE RE UIREMENTS

4. 7.6 Each snubber shall be demonstrated OPERABLE by performance of the followin9 au9nmnted inservioe

. in.s13e;uon-,;rogram in~dition to the requ!reme_nts of Specific~tion 4.0.5.

!capitalizer' a,. lnspeot1on . Tvpes !Spec1ficat1on 6.8.4.m i........;_ _ _ _ _ _ _ ____.

ml As used in this s13eoifieation, ty13e of snueeer shall rnean snueeers of the sarne desi9n and rnanufaoturer, irres13ective of oa13aoity.

&.- Visual Inspections Snueeers are oate9orized as inaecessiele or aeoessiele durin9 roaster 013eration. E:aoh of these oate9ories (inaoeessiele and aooessiele) rnay ee ins13eoted inde13endently aooordin9 to the sohedule deterrnined ey Taele 4.7 2. The visual ins13eetion interval for each ty13e of snueeer shall ee deterrnined eased u13on the oriteria 13rovided in Taele 4 .7 2 and the first ins13eotion interval deterrnined usin9 this criteria shall ee eased u13on the 13revious ins13eotion interval as estaelished ey the requirernents in effuot eefore Arnendrnent 191 and 149.

&:- Visual lnspeotion Acoeptance Criteria Visual ins13ections shall verify that (1) the snueeer has no visiele indioations of darna9e or iri:i13aired OPE:R/\BILITY, (2) attaehFl'lents to the foundation or su1313ortin9 structure are secure, and (a) fasteners for attaehFl'lent of the snueeer to the 00Fl'113onent and to the snueeer anehora9e are seoure. Snueeers which a1313ear ino13eraele as a result of visual TURKEY POINT - UNITS 3 & 4 3/4 7-22 AMENDMENT NOS. :2eG AND 2ae I

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

I. Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operations are met:

a. The Surveillance Frequency Control Program shall contain a list of frequencies of those Surveillance Requirements for which the frequency is controlled by the program.

b. Changes to the frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10," Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the frequencies established in the Surveillance Frequency Control Program.

~ ~<~~~~~~~~~~~~~~~

6.8.5 DELETED Snubber Testing Program This program conforms to the examination, testing and service life monitoring for dynamic restraints (snubbers) in accordance with 10 CFR 50;55a inservice inspection (ISi) requirements for supports. The program shall be in accordance with the following:

1. This program shall meet 10 CFR 50.55a(g) ISi requirements for supports.

2. The program shall meet the requirements for ISi of supports set forth in subsequent editions of the Code of Record and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) that are incorporated by reference in 10 CFR50.55a(a) subject to the use and conditions on the use of standards listed in 10 CFR 50.55a(b) and subject to Commission approval.

3. The program shall, as required by 10 CFR 50.55a(b)(3)(v), meet Subsection !STA, "General Requirements" and Subsection !STD, "Preservice and lnservice Examination and Testing of Dynamic Restraints (Snubbers) in Light-Water Reactor Nuclear Power Plants".

4. The 120-month program updates shall be made in accordance with 10 CFR 50.55a(g)(4), 10 CFR 50.55a(g)(3)(v) and 10 CFR 50.55a(b) (including 10 CFR 50.55a(b)(3)(v)) subject to the conditions listed therein.

TURKEY POINT - UNITS 3 & 4 6-14 AMENDMENT NOS. 2:ed AND ~I

Florida Power & Light Company L-2016-172 Attachment 2 ATTACHMENT2 Proposed Bases Changes (Information Only)

(2 pages follow)

REVISION NO.: PROCEDURE TITLE: PAGE:

18 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 175 of 211 PROCEDURE NO.:

O-ADM-536 TURKEY POINT PLA.NT ATTACHMENT 2 Technical Specification Bases (Page 158 of 194) 3/4.7.6 Snubbers All snubbers are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems is maintained durin and followin a seismic or other event initiating dynamic loads. Snubbers are demonstrated OPERABLE by performance of the Snubber Testing Program.

level of sn1::1bber protestioA to eash safety related system duriAg aA earthquake or se\*ere traAsieAt Therefore, the required iAspestioA iAterval varies iAversely with the observed sAubber failures aAd is determiAed by the Aumber of iAoperable sAubbers fouAd duriAg aA iAspestioA. IAspestitms performed betore that iAterval has elapsed may be used as a Rew refereAse poiAt to determiAe the Aext inspestioA. ~owever, t~e results of sush early iAspestioAs performed before the origiAal required time iAterval has elapsed (AomiAal time less 25%). may NOT be used to leAgtheA the required iAspestioA iAterval. AAy iAspestioA \'Jhose results require a shorter iAspestioA iAterval will override the previous sshedule.

WheA the sause of the rejestioA of a sAubber is visual iAspestioA is slearly established aAd remedied for the sAubber arid for aAy other snubbers that may be geAerisally susseptible, aAd verified operable by iAservise fuAstioAal testiAg, that sAubber may be exempted from beiAg souAted as iAoperable for the purposes of establishiAg the Aext visual iAspestioA iAterval. GeAerisally susseptible sAubbers are those whish are of a spesifie make or model aAd have the same desigA features direstly related to rejestioA of the sAubber by visual iAspestioA, or are similarly losated or exposed to the same eAviroAmeAtal soAditioAs sush as temperature, radiatioA, aAd vibratioA.

e When a snuboer is nd inoperable, an evaluation is performed,..iA-additioA to :tRe-deter iAatioA of the SA~bber mode of failure.,..., ~eelF-Ee 1-R.

determiAe if any Safety Related System or component has b en adverse!~ ffected by the inoperability of the snubber. The valuation shall det rmine whether or NOT the snubber mode of fail re has imparte a significant effect or degradation on the supp iied ent or system.

in accordance with the Snubber Testing Program

REVISION NO.: PROCEDURE TITLE: PAGE:

18 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 176 of 211 PROCEDURE NO.:

O-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical S~ecification Bases (Page 159 of 194) 3/4.7.6 (Continued)

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