Text

License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5 -Request for Supplemental Information Response
	ML22019A067
Person / Time
Site:	Turkey Point
Issue date:	01/19/2022
From:	Maher W; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2022-010, NUREG-1431 R5
	Download: ML22019A067 (58)
	v • d • e

January 19, 2022 L-2022-010 10 CFR 50.90 10 CFR 50.91(b)(1)

U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11545 Rockville Pike One White Flint North Rockville, MD 20852-2746 Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 LICENSE AMENDMENT REQUEST FOR THE TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1431 REVISION 5 - REQUEST FOR SUPPLEMENTAL INFORMATION (RSI) RESPONSE

References:

1. Florida Power & Light Company (FPL) Letter L-2021-158 dated September 22, 2021, License Amendment Request for the Technical Specifications Conversion to NUREG-1431 Revision 5 (ADAMS Accession No. ML21265A371)

2. NRC November 5, 2021, Notice of Forthcoming Meeting with NextEra/Florida Power and Light (FPL) Regarding the Conversion of Turkey Point Nuclear Generating Station, Units 3 and 4, and St.

Lucie Plant, Units 1 and 2 to Improved Technical Specifications (ADAMS Accession No. ML21312A082)

3. NRC November 17, 2021 Public Meeting, Turkey Point and St. Lucie Improved Technical Specifications Conversions, Issues Identified to Date - Draft (ADAMS Accession No. ML21320A261)

4. NRC letter dated December 21, 2021, Turkey Point Nuclear Plant, Units 3 And 4 - Supplemental Information Needed for Acceptance of Requested License Amendment Request Concerning Technical Specification Conversion to NUREG-1431, Revision 5 (EPID L-2021-LLI-0002)

(ADAMS Accession Nos. ML21342A293)

FPL, licensee for Turkey Point (PTN) Units 3 and 4, has submitted Improved Technical Specifications (ITS) conversion License Amendment Requests (LARs) for the Facility Operating Licenses for PTN Units 3 and 4 (Reference 1). On November 17, 2021, the NRC held a public meeting (Reference 2) with FPL to discuss review topics of interest (Reference 3) for the ITS conversion LAR submittals. Based on this meeting, the NRC subsequently issued to FPL its RSI for the PTN ITS conversion LAR (Reference 4). The attachments to this letter provide FPLs response to the NRC RSI for PTN.

Florida Power & Light Company 15430 Endeavor Drive, Jupiter, FL 33478

Document Control Desk L-2022-010 Page 2 of 4 For ease of reference, the index of attached information is provided on page 3 of this letter. The changes to the ITS conversion LAR identified in this RSI Response will be submitted to the NRC in a future ITS conversion LAR revision.

Should you have any questions regarding this submittal, please contact me at (561) 304-6256 or William.Maher@fpl.com.

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

Executed on the 19th day of January 2022.

Sincerely, William Digitally signed by William Maher DN: cn=William Maher, o=Nuclear, ou=Nuclear Licensing Projects, Maher email=william.maher@fpl.com, c=US Date: 2022.01.19 09:07:29 -05'00' William D. Maher Licensing Director - Nuclear Licensing Projects Cc: Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Nuclear Generating Units Senior Resident Inspector, USNRC, Turkey Point Nuclear Generating Units Chief, Bureau of Radiation Control, Florida Department of Health

Document Control Desk L-2022-010 Page 3 of 4 Attachments Index Attachment RSI No. Subject No.

1 3.1-1 Volume 6 - Section 3.1 (ADAMS Accession No. ML21265A377) Question 1 2 3.3-1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 1 3 3.3-2 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 2 4 3.3-3 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 3 5 3.3-4 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 4 6 3.3-5 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 5 7 3.3-6 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 6 8 3.3-7 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 7 9 3.3-8 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 8 10 3.4-1 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 1 11 3.4-2 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 2 12 3.4-3 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 3 13 3.4-4 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 4 14 3.5-1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 1 15 3.5-2 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 2 16 3.5-3 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 3 17 3.5-4 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 4 18 3.5-5 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 5 19 3.5-6 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 6 20 3.6-1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 1 21 3.6-2 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 2 22 3.6-3 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 3 23 3.6-4 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 4 24 3.6-5 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 5 25 3.6-6 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 6 26 3.6-7 Volume 11 - Section 3.3 (ADAMS Accession No. ML21265A382) Question 7 27 3.8-1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 1 28 3.8-2 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 2 29 3.8-3 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 3 30 3.8-4 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 4 31 3.8-5 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 5 32 3.8-6 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 6 33 3.8-7 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 7 34 3.8-8 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 8 35 3.8-9 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 9 36 3.8-10 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 10 37 3.8-11 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 11 38 3.8-12 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 12 39 3.8-13 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 13 40 3.8-14 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 14 41 3.8-15 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 15 42 3.8-16 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 16 43 3.8-17 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 17 44 3.8-18 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 18 45 3.8-19 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 19

Document Control Desk L-2022-010 Page 4 of 4 Attachments Index Attachment RSI No. Subject No.

46 3.8-20 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 20 47 3.8-21 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 21 48 3.9-1 Volume 14 - Section 3.9 (ADAMS Accession No. ML21265A385) Question 1 49 5.5-1 Volume 16 - Section 5.5 (ADAMS Accession No. ML21265A387) Question 1

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.1-1 L-2022-010 Attachment 1 Page 1 of 1 Volume 6 - Section 3.1 (ADAMS Accession No. ML21265A377) Question 1 ITS 3.1.1 - page 18 - The markup of the STS Bases for ITS Subsection B 3.1.1 does not include an ASA section passage about reactivity excursion transients resulting from reactor coolant pump (RCP) start. The markup of the ASA section of the Bases for STS Subsection 3.1.1, indicates that justification for deviations (JFDs) 1 and 5 apply to this omission. Provide an explanation of whether this transient is included as an analyzed transient in the Updated Final Safety Analyses Report (UFSAR), and if the passage is valid for Turkey Point.

FPL Response:

Turkey Point plant technical specifications preclude plant operation with one or more reactor coolant loops inactive. The startup of an inactive reactor loop event was originally included in the Updated FSAR when the potential for operation with a loop out of service was allowed under plant technical specifications. Based on the plant technical specifications which prohibit plant startup and power operation (Modes 1 and 2) with one or more loops out of service, this event was removed from the Turkey Point licensing basis as part of the plant thermal uprate evaluation.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-1 L-2022-010 Attachment 2 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 1 On page 168/499, provide an explanation for why the L01 discussion does not address why the qualifier and [de-activated] is not incorporated into note g. Without an acceptable justification, this change may be considered a beyond scope item (BSI) because NUREG-1431 assumes the valves are closed and rendered incapable of being open, which is denoted by the [de-activated]

to allow for a plant specific term. The "and" is not in brackets.

FPL Response:

DOC L01 will be changed to add the qualifier "and de-activated," to "closed" when referring to the MSIVs. It will now state, "closed and de-activated." In addition, "and de-activated" will be added to Note g at the end of "Except when the MSIVs are closed" in the CTS Markup of Table 3.3-2, Table Notation, on page 3/4.3.21. It will now state, "Except when the MSIVs are closed and de-activated." Also "and de-activated" will be undeleted in Note g of ITS 3.3.2 markup, Table 3.3.2-1, on pages 3.3.2-14 through 3.3.2-17. It will now state, "Except when the MSIVs are closed and de-activated." The Bases will be revised as necessary to include "and de-activated."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-2 L-2022-010 Attachment 3 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 2 On page 169/499, provide an explanation for why the L02 discussion does not address why the qualifier and [de-activated] is not incorporated into note h. Without an acceptable justification, this change may be considered a BSI because NUREG-1431 assumes the valves are closed and rendered incapable of being open, which is denoted by the [de-activated] to allow for a plant specific term. The and is not in brackets.

FPL Response:

DOC L02 will be changed to add the qualifier "and de-activated," to "closed" when referring to the MFIVs, MFRVs, and associated bypass valves. It will now state, "closed and de-activated."

In addition, "and de-activated" will be added to Note h at the end of "Except when the MFIVs, MFRVs, and associated bypass valves are closed" in the CTS Markup of Table 3.3-2, Table Notation, on page 3/4.3.21. It will now state, "Except when the MSIVs are closed and de-activated." Also "and de-activated" will be undeleted in Note h of ITS 3.3.2 markup, Table 3.3.2-1, on page 3.3.2-18. The Bases will be revised as necessary to include "and de-activated."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-3 L-2022-010 Attachment 4 Page 1 of 2 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 3 On page 172/499, Discussion of Changes (DOC) L06 appears to propose a Condition where the limiting condition for operation (LCO) is not met that does not currently exist in NUREG-1431.

Provide an explanation in DOC L06 on whether or not this condition currently exists in NUREG-1431 as well as what the CTS for restoration of the inoperable train is in NUREG-1431.

FPL Response:

The CTS does not provide any restoration time while NUREG-1431 provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one train of actuation logic is inoperable for steam line isolation, auxiliary feedwater, or feedwater isolation. FPL is proposing a 6-hour completion time for Turkey Point based on WCAP-10271.

ITS 3.3.2 DOC L06 will be revised to add additional justification for this change as specified below.

L06 (Category 4 - Relaxation of Required Action) CTS Table 3.3-2 Actions 20 and 22 do not provide any time to restore the inoperable train. CTS Table 3.3-2 Action 20 applies when Functional Unit 4.b (Steam Line Isolation Automatic Actuation Logic and Actuation Relays) or 6.a (Auxiliary Feedwater Automatic Actuation Logic and Actuation Relays) train is inoperable. CTS Table 3.3-2 Action 22 applies when Functional Unit 5.a (Feedwater Isolation Automatic Actuation Logic and Actuation Relays) train is inoperable. ITS 3.3.2 Required Action D.1 will allow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore an inoperable Function 4.b, 5.a or 6.a train to OPERABLE status prior to requiring a unit shutdown.

This changes the CTS by allowing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to restore the affected train to OPERABLE status prior to starting a shutdown.

The purpose of the ITS 3.3.2 ACTION D is to provide a short period of time to restore the inoperable train.

NUREG 1431, Revision 5 provides similar Conditions for an inoperable automatic actuation logic or actuation relay associated with Feedwater Isolation, Steam Line Isolation, and Auxiliary Feedwater Actuation train as LCO 3.3.2, "ESFAS Instrumentation," Conditions G or H, one train inoperable. ISTS Conditions G and H require restoration of the inoperable channel within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months versus the proposed 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The reason there are two ISTS Conditions (G and H) is the endstate required when the Required Action and associated Completion Time is not met. Not meeting Condition G results in a plant shutdown to MODE 4, while not meeting the Required Action and associated Completion Time of Condition H results in a plant shutdown to MODE 3.

The difference in the Condition's Completion Time is due to the adoption of three WCAPs associated with RPS and ESFAS Surveillance Test Interval, Completion Time, and Bypass Time changes (WCAPs 10271, 14333, and 15376) and the assumed adoption of NUREG 1431 Revision 5. NUREG 1431, Revision 5, (ISTS) is written assuming all three WCAPs have been or are being adopted. Two of these WCAPs changed the Completion Time for an inoperable logic cabinet. WCAP 10271 changed the Completion Time for an inoperable logic cabinet from 0 (zero) hours to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

WCAP 14333 changed the Completion Time for an inoperable logic cabinet train from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the current Completion Time listed in NUREG 1431, Revision 5, for

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-3 L-2022-010 Attachment 4 Page 2 of 2 an inoperable SLI, FWI, or AFW Actuation Automatic Actuation Logic and Actuation Relays Function.

In November of 1995 the NRC approved PTN License Amendment Numbers 179 and 173 for PTN Unit 3 and Unit 4 respectively (ADAMS Accession No. ML013390084).

This amendment approved adoption of WCAP 10271 at PTN. The NRC stated that, for PTN, the responses provided were acceptable for the SER Conditions (3.2.1(1) -

3.2.1(6), 3.2.2(1), and 3.2.2(2)). Therefore, instead of the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months stated in NUREG-1431, Revision 5, for ISTS 3.3.2 Condition G or H, FPL is requesting 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for ITS 3.3.2, Condition D as approved in WCAP 10271.

The proposed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.3.2 ACTION D is acceptable considering that there is another train OPERABLE and the low probability of an event occurring during this interval. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-4 L-2022-010 Attachment 5 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 4 On page 288/499, LA03 justifies deletion of the footnote at the bottom of CTS TABLE 4.3-4 by stating, in part: Also, this change is acceptable because these types of procedural Bases. However, the proposed bases for ITS 3.3.3 do not mention where criteria for calibration of the Containment Area Radiation (High Range) monitor is located. The final policy statement on TS Improvements for Nuclear Power Reactors states that licensees should identify the location of and controls for the relocated technical and administrative requirements. Provide the location of the details proposed for removal.

FPL Response The location of the acceptable criteria for the calibration of the Containment Area Radiation (High Range) will be added to ITS 3.3.3 Bases, SR 3.3.3.2 Section on page B 3.3.3-14.

Specifically, the following statement will be added at the end of the current Bases writeup:

"Acceptable criteria for Containment Area Radiation (High Range) calibration are provided in Table II.F.1-3 of NUREG-0737."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-5 L-2022-010 Attachment 6 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 5 On page 450/499, the Final Policy Statement on TS Improvements for Nuclear Power Reactors states When licensees submit amendment requests based on this Policy Statement, they should identify the location of and controls for the technical and administrative requirements of the relocated requirements. The DOCs for CTS 3.3.3.2 R01 FPL do not state where requirements for the movable instrument drive system (MIDS) will be relocated or change controls that would apply. Provide information on where the relocated requirements will be located and the change controls that will apply.

FPL Response:

The following statement will be added to the end of the second paragraph of Discussion of change R01 for the Relocated CTS 3.3.3.2.

"Therefore CTS 3.3.3.2 will be relocated to the PTN TRM. Changes to the PTN TRM will be controlled in accordance with 10 CFR 50.59."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-6 L-2022-010 Attachment 7 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 6 On page 335/499, the Note (Separate Condition entry is allowed for each Function) above the ITS 3.3.4 Actions Table is not referenced to CTS and there is no DOC for it. Provide an explanation for this change.

FPL Response:

The Note, "Separate Condition entry is allowed for each Function," will be added to the ACTIONS section of CTS 3.3.2 for ITS 3.3.4. DOC A04 will be added to the right-hand margin adjacent to the added Note and the following DOC will be added.

A04 CTS 3.3.2 ACTION and CTS Table 3.3-1 provide the compensatory actions to take when Reactor Trip System (RTS) instrumentation is inoperable. ITS 3.3.1 ACTIONS similarly provide the compensatory actions for inoperable RTS Instrumentation. ITS 3.3.1 ACTIONS are modified by a Note that allows separate Condition entry for each Function. In addition, due to the manner in which the Required Channel's description modifies ITS Functions, separate Condition entry is allowed within a Function. This changes the CTS by providing a specific allowance to enter the ACTION for each inoperable RTS instrumentation Function and for certain Functions on a loop, steam generator (SG), bus, or breaker, etc.

This change is acceptable because it clearly states the current requirement. The CTS considers each RTS instrumentation Function to be separate and independent from the others. In addition, the channels associated with some Functions are allowed separate Condition entry on the specified basis (i.e., per loop, SG, bus, or breaker). This separate condition entry is allowed because the channels associated with each component, as applicable, will provide the associated Engineered Safety Feature Actuation System (ESFAS) actuation based on the logic associated with the channels on the specified basis. This change is designated as administrative because it does not result in technical changes to the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-7 L-2022-010 Attachment 8 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 7 On page 336/499, ITS 3.3.4 Required Action B.2 has a proposed 7-day CT modified from the ITS immediately CT. The referenced CTS Table 3.3-2 Action 24B.1 (page 326/499) has an immediately CT. Provide justification for this beyond scope item that is not in CTS or Improved Standard Technical Specifications (ISTS).

FPL Response:

This is not a beyond scope item (BSI); ITS 3.3.4 ACTION B is revised to match CTS 3.3.2, Table 3.3-2 Action 24B. Both the PTN ITS and CTS allow 7 days to place the Control Room Emergency Ventilation System (CREVS) in the recirculation mode with both Control Room emergency recirculation fans operating. Below is CTS Action 24B "1. Immediately place the Control Room Emergency Ventilation System in the recirculation mode with BOTH Control Room emergency recirculation fans operating, OR

2. a. Immediately place the Control Room Emergency Ventilation System in the recirculation mode with ONE Control Room emergency recirculating fan operating, AND

b. Restore at least one inoperable channel to OPERABLE status within 7 days, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . If this ACTION applies to both Units simultaneously, then be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " Based on CTS Action 24B above, PTN Operators can perform Action 1 or Actions 2a and 2b. If Action 2 is performed and at day 7 the Condition is not met, the Operators have the option of shutting down per Action 2 or complying with Action 1; thus, essentially PTN has 7 days to complete Action 1. Because there is an OR statement between Action 1 and Actions 2a and 2b, the Operators always have the option within the 7days to perform Action 1 or Actions 2a and 2b.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.3-8 L-2022-010 Attachment 9 Page 1 of 1 Volume 8 - Section 3.3 (ADAMS Accession No. ML21265A379) Question 8 On page 425/499, ITS Table 3.3.6-1 Function 2 has N/A for its Surveillance Requirements (SRs),

consistent with CTS. Provide a discussion on how LCO 3.3.6 will be met without demonstrating operability via SRs.

FPL Response:

This change to the ITS is consistent with current licensing basis. CTS Table 4.3-2, Channel Functional Unit 3.c.2, Automatic Actuation Logic and Actuation Relays, contains "NA" for all surveillances. These relays are shared and tested with Safety Injection, Manual Phase A and B, and Radioactivity-High.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.4-1 L-2022-010 Attachment 10 Page 1 of 1 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 1 On page 7, per LA01, CTS SR 4.2.5.3 is proposed to be relocated to the Technical Requirements Manual (TRM). Provide a justification to why the subject SR is not required to be performed to verify LCO 3.4.1 is met.

FPL Response:

CTS SR 4.2.5.3 is a calibration of the reactor coolant system flow instruments. These are the same instrument for which a CHANNEL CALIBRATION is required by CTS Table 4.3-1, Functional Unit 10, Reactor Coolant Flow-Low. ITS Table 3.3.1-1 Function 10, Reactor Coolant Flow-Low requires a CHANNEL CALIBRATION of these instruments. Therefore, SR 4.2.5.3 is a duplicate requirement and unnecessary. However, LA01 will be changed to A04 and LA02 will be changed to LA01. Since the SR is being performed in ITS Section 3.3, it does not need to be relocated to the TRM and instead consistent with ITS, not included in the RCS Pressure, Temperature, and Flow DNB Limits TS SRs CTS DOC LA01 will be deleted, DOC LA02 will be changed to LA01 and DOC A04, as specified below, will be added.

A04 CTS 4.2.5.3 requires that the indicators which are used to determine RCS flow rate be subjected to a CHANNEL CALIBRATION at least once per 18 months. ITS 3.4.1 does not include this surveillance requirement. This changes the CTS by deleting CTS SR 4.2.5.3.

The removal of requirements for indication-only instrumentation and alarms from the CTS 3.4 Section is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The RCS flow rate indicators are currently calibrated in CTS Section 3.3. These are the same instruments for which a CHANNEL CALIBRATION is required by CTS Table 4.3-1, Functional Unit 10, Reactor Coolant Flow-Low. ITS Table 3.3.1-1 Function 10, Reactor Coolant Flow-Low requires a CHANNEL CALIBRATION of these instruments. Therefore, SR 4.2.5.3 is a duplicate requirement and unnecessary. This change is designated as administrative because no technical change is being made to the Technical Specifications.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.4-2 L-2022-010 Attachment 11 Page 1 of 1 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 2 On page 8/456, L01 states: CTS 3.2.5 ACTION requires THERMAL POWER to be reduced to less than 5% of RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if the DNB parameters are not restored to within limit in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ." ITS 3.4.1 ACTION B requires the power reduction to less than or equal to 5% RTP (MODE 2) within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the DNB parameters are not restored to within limit in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . L01 further states, This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

Since there is no change in the design and operation of the Turkey Point units, provide plant specific technical justification for extending the time from current 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

FPL Response:

PTN CTS was developed in the late 1980s and approved in 1990 using the current version of NUREG-0452 as a template (ML20059C455). The reason for the 4-hour shutdown time was based strictly on conformance with the NRC approved NUREG 0452 Competition Time. During the early 1990s the NRC and the Industry embarked on a project to create a new standard technical specification template based on human factor insights. This project culminated in the development of improved standard technical specification (ISTS) that the NRC published in September of 1992 as NUREG 1431 (ML13196A330). The CTS 4-hour completion time is based on NUREG-0452. The ITS 6-hour completion time is based on NUREG 1431. NUREG 1431 Bases states that the Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable to reach the required plant conditions in an orderly manner. The Completion Time change from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in NUREG-0452 to the 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in NUREG-1431 is a reasonable time to reach the required plant conditions as determined by the industry and the NRC.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.4-3 L-2022-010 Attachment 12 Page 1 of 1 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 3 On page 49/456, CTS SR 4.4.9.1.1 (ITS SR 3.4.3.1), provide justification for the deletion of specified in the PTLR.

FPL Response:

The JFD 3 designation adjacent to SR 3.4.3.1 is being changed to JFD 4 and ITS 3.4.3 JFD 4 is being revised to replace the portion in front of the ":" as follows. The limits are specified in the LCO.

"Turkey Point does not currently have a Pressure Temperature Limits Report (PTLR) nor is it adopting a PTLR"

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.4-4 L-2022-010 Attachment 13 Page 1 of 1 Volume 9 - Section 3.4 (ADAMS Accession No. ML21265A380) Question 4 On page 89/456, provide an explanation for why the proposed changes to LCO 3.4.5, Conditions C and D and associated Required Actions do not follow the STS format.

FPL Response:

PTN ITS ACTION C will be changed to adopt NUREG-1431 Section 3.4.5 ACTION C as written.

PTN ITS ACTION D will be changed to adopt NUREG-1431 Section 3.4.5 ACTION D with the following exception. At the end of the second part of Condition D, "when the Rod Control System is not capable of rod withdrawal," will be added. If not added, when the Rod Control System is capable of rod withdrawal and the required RCS loops are not in operation, both Actions C and D will be required to be entered.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-1 L-2022-010 Attachment 14 Page 1 of 1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 1 ITS - 3.5.1 - pages 5, 9, 12, 21, and 25 - The proposal is to change the Completion Time for CTS 3.5.1 Action a. from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , consistent with STS 3.5.1 Action B and WCAP-15049-A.

Provide an explanation on the applicability of WCAP-15049-A to Turkey Point and intended implementation of any limitations and/or conditions for applying this topical report.

FPL Response:

Yes, the PTN SI Accumulators are bounded by WCAP-15049-A Rev. 1, (ADAMS Accession No. ML ML20196L106) and there are no limitations and/or conditions for applying this report.

WCAP-15049-A R1 is applicable to all Westinghouse Nuclear Steam Supply (NSS) plants.

The Safety Evaluation (SE) to WCAP-15049-A R1 states, By using the conservative approach, Westinghouse intended to encompass all of the various vintages of Westinghouse plants, and the staff agrees that this was accomplished.

WCAP-15049-A Rev. 1 concluded, the impact of the increase in the accumulator Completion Time on core damage frequency (CDF) for all the cases evaluated is within the acceptance limits set by the NRC. The acceptance limit is 1E-06/yr CDF increase providing the total plant CDF is less than 1E-03/yr. The CDFs for PTN-3 and PTN-4 are orders of magnitude below 1E-03 per year.

Per WCAP-15049-A Rev. 1, the incremental conditional core damage probabilities (ICCDP) calculated meet the criterion of 5E-07 set by the NRC for the increased Completion Time except for those that are based on the design basis success criterion; however, the design basis accumulator success criterion is not considered necessary to mitigate large loss of coolant accident (LOCA) events and is only included as a worst-case data point. In addition, the large LOCA and medium LOCA frequencies used in the WCAP to calculate the risk increase associated with the accumulator allowed outage time (AOT) extension are extremely conservative. If realistic values for these initiating event frequencies were used, even the design basis success criterion would result in an acceptable risk increase.

Therefore, WCAP-15049-A Rev 1 is applicable to PTN with no limitations or conditions.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-2 L-2022-010 Attachment 15 Page 1 of 1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 2 ITS - 3.5.2 - page 35 - CTS SR 4.5.2 g.1 requires the position stops for emergency core cooling system (ECCS) throttle valves be verified to be in the correct position within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following completion of each valve stroking operation or maintenance on the valve when the valve is required to be OPERABLE. The proposed ITS does not contain this requirement. This changes the CTS by eliminating the requirement from TS. Provide a justification for eliminating this requirement from TS.

FPL Response:

DOC L01, below provides justification for the deletion of CTS 4.5.2.g.1 consistent with NUREG-1431.

L01 (Category 7 - Relaxation of Surveillance Frequency Change - NON-24 MONTH TYPE CHANGE) CTS SR 4.5.2 g.1 requires the position stops for ECCS throttle valves be verified to be in the correct position within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following completion of each valve stroking operation or maintenance on the valve when the valve is required to be OPERABLE. The ITS does not contain this requirement. This changes the CTS by eliminating the requirement from Technical Specifications.

The purpose of CTS SR 4.5.2 g.1 is to ensure the position stops are realigned following stroking or maintenance. The ITS does not contain any other frequency for verifying valve alignment besides the routine interval in the SFCP. This change is acceptable because following maintenance or stroking the valves will be verified to be in position by other unit requirements. Following maintenance on any valve, the valve stops are required to be verified in position in order to be called OPERABLE. The plant controls (maintenance rule and plant procedures) ensure that an acceptable level of equipment reliability is provided. The post maintenance and post testing requirements will continue to be performed such that the verification of the position stops will not change. This change is designated as less restrictive because Surveillances will be performed less frequently per Technical Specifications under the ITS than under the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-3 L-2022-010 Attachment 16 Page 1 of 1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 3 ITS 3.5.2 - page 49 - for SR 3.5.2.8, the licensee is relocating information from their CTS that deviates from the STS into their Bases. However, the submittal does not indicate that information in the CTS SR is being moved to the ITS bases regarding SR 3.5.2.8. Provide a justification for the proposed change and relocation.

FPL Response:

It is our understanding that the NRC is referring to SR 3.5.2.9, as no text in the CTS that refers to SR 3.5.2.8 is being moved to the ITS Bases. The text associated with ITS SR 3.5.2.9 was intended to be equivalent to the text associated with CTS 4.5.2.e.3 with DOC A01 justifying any editorial difference in the text. To align the ITS Surveillance more closely with the CTS Surveillance, ITS SR 3.5.2.8 will be revised to state: Verify, by visual inspection, each ECCS containment sump suction inlet is not restricted by debris and the suction components show no evidence of structural distress or abnormal corrosion. The examples of the sump components (trash racks, screens, etc.) is being moved to the Bases. The justification is specified below, as excerpted from DOC LA07.

"The removal of these details (trash racks, screens, etc.) of examples of containment sump components from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to perform the inspection of the sump components. Also, this change is acceptable because these types of details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-4 L-2022-010 Attachment 17 Page 1 of 1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 4 ITS 3.5.2 - page 55 - In last paragraph of the background section of the Bases for ITS 3.5.2, the licensee refers to other LCOs. The licensee points to containment sump and provides a correction indicating LCO 3.6.19, Containment Sump of STS is LCO 3.6.8 for the plant-specific TS. However, the ITS Section 3.6 volume of Enclosure 2 of the application indicates that Turkey Point is not adopting the containment sump TS. Provide a justification for the proposed change and relocation and the deviation from NUREG-1431.

FPL Response:

The information referring to the containment sump Technical Specification in the Background Section of ITS 3.5.2 is an error. CTS 4.5.2.e.3 is being retained in the ITS (ITS SR 3.5.2.8) consistent with the PTN current licensing basis instead of adopting the ISTS 3.6.19, Containment Sump. The ITS 3.5.2 Bases will be updated to remove the reference to ISTS 3.6.19 (ITS 3.6.8).

FPL has chosen to maintain the applicable Surveillance Requirements associated with verifying the system containment sump suction inlets instead of adopting a separate Containment Sump Specification. Justification is currently provided in ITS 3.5.2 JFD 3, which states, Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description. In addition, Attachment 9 of Enclosure 2, Volume 11 provides additional discussion related to not adopting ISTS 3.6.19. ISTS 3.6.19 JFD 1 states, Improved Standard Technical Specification (ISTS) 3.6.19, "Containment Sump," is not being adopted because Turkey Point Nuclear Generating Station (PTN) does not include a separate Containment Sump specification.

Therefore, ISTS 3.6.19 is not included in the PTN Improved Technical Specifications."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-5 L-2022-010 Attachment 18 Page 1 of 1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 5 ITS 3.5.3 - page 76 - CTS 3.5.3 ACTION a. allows one hour to restore an ECCS flow path from the refueling water storage tank (RWST) and, if it cannot be restored, requires a cooldown to COLD SHUTDOWN. ITS 3.5.3 requires an immediate initiation of Action to restore the ECCS train. This changes CTS by eliminating a cooldown requirement if the flow path cannot be restored. While the be in cold shutdown portion being removed appears less restrictive, the completion time is more restrictive (immediate versus 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ). Provide a justification for why this is characterized as less restrictive instead of more restrictive.

FPL Response:

Below is second paragraph from DOC L02. As stated below, the change is less restrictive because after the one hour requirement to restore the ECCS flow path to the RWST expires, plant must be brought to Mode 5, whereas in the ITS, the requirement is to initiate Action to restore immediately with no completion time to complete restoration.

"The purpose of CTS 3.5.3 ACTION a is to restore an ECCS flow path if there is none OPERABLE and further requires a cooldown if it cannot be restored. ITS does not require a cooldown but requires immediate Action to commence to restore the ECCS train. This is the more prudent action when there is no cooling capability. Since the ECCS is the preferred cooldown method and it is not available, it is more prudent to stay in MODE 4 until a train of ECCS can be restored. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition.

This includes a reasonable time for repairs or replacement, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. With no ECCS flow paths available, it would be unwise to require the plant to go to MODE 5, where the only available heat removal system is the residual heat removal (RHR). Therefore, the appropriate action is to initiate measures to restore one ECCS RHR subsystem and to continue the actions until the subsystem is restored to OPERABLE status. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-6 L-2022-010 Attachment 19 Page 1 of 1 Volume 10 - Section 3.5 (ADAMS Accession No. ML21265A381) Question 6 ITS 3.5.4 - page 97 - The change to the CTS markup is to increase the COMPLETION TIME for restoration of an inoperable refueling water storage tank (RWST) due to boron concentration or temperature not within limits from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . In DOC L01, the licensee indicated that 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is not sufficient to address changes in boron concentration and/or temperature. Provide a justification that supports the completion time change (i.e., 8-hour).

FPL Response:

As stated in ITS 3.5.4 DOC L01, the primary function of the RWST is to provide large volumes of water to the Reactor Coolant System following a Loss of Coolant Accident. This large volume of water continues to be available while in ITS 3.5.4, Condition A. As a result, the most important safety function of the RWST can still be provided. Because of the volume of the RWST, changes to the boron concentration or temperature occur slowly, and thus, if one of these parameters was out of limit, more than one hour would likely be required to restore the parameter. The proposed change is acceptable because the Completion Time continues to consider a reasonable time to restore the out of limit condition and the low probability of a Design Basis Accident (DBA) occurring during the allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months limit specified in the ISTS to restore the RWST temperature or boron concentration to within limits was developed considering the time required to change either the boron concentration or temperature and the fact that the contents of the tank are still available for injection. This basis also applies to the PTN RWST. The proposed ITS ACTION of restoring the RWST boron concentration or temperature parameters to within limits within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is consistent with the ISTS and provides sufficient remedial action pursuant to 10 CFR 50.36(c)(2)(i).

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-1 L-2022-010 Attachment 20 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 1 ITS 3.6.2 - page 34 - CTS markup of SR 4.6.1.3.a (related to containment air locks) points to ITS SR 3.6.2.1 as the ITS SR that meets CTS SR 4.6.1.3.a requirements. However, ITS SR 3.6.2.1 does not appear to fully meet the requirements of CTS SR 4.6.1.3.a (i.e., it is missing: Following each closing, ... by verifying that the seals have not been damaged ... by vacuum testing...) and there is no DOC associated with CTS SR 4.6.1.3.a that addresses ITS omission of this requirement. Provide justification for the missing requirement to verify no seal damage by vacuum testing.

FPL Response:

The CTS markup for SR 4.6.1.3.a will be modified to delete specific reference to a vacuum test of the airlock door seals and refer only to the Containment Leakage Rate Testing Program of ITS 5.5.13. DOC L03 will be created since this change would permit a vacuum test of the door seals or a pressure test of the airlock, either of which would be permitted under the Containment Leakage Rate Testing Program. A draft of the DOC is as follows:

L03 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria) CTS SR 4.6.1.3.a states, in part, that a vacuum test between the door seals of an airlock door shall be performed upon closing of the door at a frequency specified in the Containment Leakage Rate Testing Program. ITS 3.6.2 does not refer to a vacuum test between the door seals. The specific reference to a vacuum test is CTS SR 4.6.1.3.a is removed and replaced with generic reference to the Containment Leakage Rate Testing Program. This changes the CTS by allowing a vacuum test of the door seals or a pressure test of the airlock, either of which would be permitted under the Containment Leakage Rate Testing Program.

The airlock testing requirements verify that the airlock leakage does not exceed the allowed fraction of the overall containment leakage rate. The PTN ITS Containment Leakage Rate Testing Program is based on Nuclear Energy Institute (NEI) 94-01, Revision 3-A, which requires pressure testing of airlocks and other containment integrity related components to ensure leakage rates are maintained within acceptable limits.

PTN ITS 5.5.13 is modified to also include the option of performing a vacuum test between the door seals within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following opening of an airlock door (see ITS 5.5, DOC A09). This test frequency is more restrictive than the pressurization test frequency provided in NEI 94-01 which states:

When containment integrity is required, airlock door seals should be tested within 7 days after each containment access. For periods of multiple containment entries where the airlock doors are routinely used for access more frequently than once every 7 days (e.g., shift or daily inspection tours of the containment), door seals may be tested once per 30 days during this time period.

Regardless of the test method employed, the intent of the program is maintained by ensuring that airlock door, and subsequently, overall containment leakage is maintained within limits. Therefore, pressure or vacuum testing of the airlock doors will provide the intended margin to safety associated with the containment design basis. This change is designated as less restrictive because less stringent SR acceptance methods are being applied in the ITS than were applied in the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-2 L-2022-010 Attachment 21 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 2 ITS 3.6.3 - page 65 - The CTS markup DOC A07 description refers to containment air locks while the DOC A07 subject (CTS SR 4.6.1.7.2) appears to be limited to containment purge and exhaust valves. Provide a discussion for the proposed change to the containment air locks.

FPL Response:

DOC A07 will be modified to remove reference to air locks. A draft of a revised version of DOC A07 is as follows:

AO7 CTS 4.6.1.7.2 requires the containment purge and exhaust valve leakage rate to be less than or equal to 0.05 La when pressurized to Pa. CTS 6.8.4.h provides the requirements for the Containment Leakage Rate Testing Program, and states that the peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is defined here as the containment design pressure of 55 psig. ITS SR 3.6.3.5 requires performance of the containment purge and exhaust valve leakage test but does not include requirement for testing when pressurized to Pa. This changes the CTS by removing duplicate information associated with the containment purge and exhaust leakage rate testing.

The removal of these details from CTS 4.6.1.7.2 is acceptable because this information is not necessary to be included in ITS SR 3.6.3.5 to provide adequate protection of public health and safety. The ITS still retains the requirement to verify that the containment purge and exhaust valves leakage is within the associated containment leakage rate limits. ITS SR 3.6.3.5 requires performance of the containment purge and exhaust valve leakage test. ITS 5.5.13, "Containment Leakage Rate Testing Program," requires, in part, that a program establish the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B. 10 CFR 50, Appendix J, Option B requires that leakage rate tests be conducted under conditions representing design basis loss-of-coolant accident containment peak pressure (Pa). Thus, although not specifically stated in ITS 3.6.3.5, the requirement to perform containment leakage rate testing at Pa is retained in ITS 5.5.13. This change is designated as an administrative change because it does not result in technical changes to the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-3 L-2022-010 Attachment 22 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 3 ITS 3.6.3 - page 82 - The ISTS 3.6.3 markup references DOC L02 in the left margin near Condition C (insert 2). It is not clear that DOC L02 applies because it appears that DOC L02 is limited to penetration flow paths with two containment isolation valves (Condition A), whereas Condition C is applicable to penetration flow paths with only one containment isolation valve and a closed system. Provide a justification for the applicability of DOC L02 to Condition C (insert 2).

FPL Response:

This is a typographical error. The DOC reference aligned with Condition C will be corrected to refer to DOC L01.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-4 L-2022-010 Attachment 23 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 4 ITS 3.6.6 - pages 160, 163 - DOCs L01 and L05 (containment spray and containment cooling, respectively) discuss changes to the CTS that would permit a Required Action end state of HOT SHUTDOWN (MODE 4) rather that an end state of COLD SHUTDOWN (MODE 5). For specific TS conditions, TSTF-432 and Westinghouse Topical Report WCAP-16294-A R1 (ADAMS Accession No. ML103430249) justifies MODE 4 as an acceptable alternate end state to MODE 5. The WCAP states that the containment spray and containment cooling systems are designed for accident conditions initiated at power. One train of each system satisfies the assumptions in the safety analyses and one train of containment spray is required to satisfy assumptions regarding iodine removal. If one train of either containment spray or containment cooling is inoperable the other train is available to mitigate the accident along with both trains of the other system. If both trains of containment cooling are inoperable, containment spray can serve as the cooling system and it also serves to remove iodine. Therefore, sufficient defense-in-depth is maintained when the end state is changed from MODE 5 to MODE 4.

ITS 3.6.6 JFD 4 explains that the redundancy in cooling capability is no longer available due to power uprate and one containment spray train and two emergency containment cooling units are required to provide post-accident cooling. Turkey Point Units 3 and 4 design for containment spray and containment cooling differs from the STS design assumed in the TSTF-432 and WCAP-16294-A.

Given that the containment spray and containment cooling design differ from the systems, structures, or component (SSC) design assumed in the STS (TSTF-432 and WCAP- 16294),

provide an explanation for how TSTF-432 and WCAP-16294 justify these less restrictive changes for ITS 3.6.6, as described in DOCs L01 and L05.

FPL Response:

ITS 3.6.6 DOCs L01 and L05 will be modified to include further discussion of containment cooling capability considering an end state of MODE 4. In conjunction with the WCAP, the PTN analyses crediting containment spray and containment cooling units assumes an accident initiates at full power conditions where the maximum mass and heat inputs to the containment structure would be realized. While a specific analysis has not been performed for like accidents initiating while operating in MODE 4, the RCS and steam generator pressures and temperatures are significantly reduced when compared with full power pressures and temperatures. MODE 4 conditions represent RCS temperatures of < 350 °F (given normal margins to saturation, RCS pressures would normally be < 200 psia). This is far below the assumed RCS pressure of 2250 psia at the beginning on an accident initiating at full power (average RCS temperature of approximately 580

°F). Therefore, it is reasonable to conclude that one containment spray train or two containment cooling units would be sufficient to provide containment cooling needs should an accident be initiated during operation in MODE 4. In this respect, the intent of the WCAP is met in that the remaining redundant spray or cooling units are sufficient to justify continued operation in MODE 4 without challenging the containment building design basis limits.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-5 L-2022-010 Attachment 24 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 5 ITS Bases 3.6.5 - page 145 - ITS Bases B 3.6.5 ASA section STS markup inserts temperature values without justification. Provide the UFSAR reference (e.g., section, table, figure, page number, etc.) which supports confirmation of the associated temperature information.

FPL Response:

The referenced temperatures are associated with bracketed [ ] information specifically intended for incorporation of plant specific values. NEI 96-06, Attachment 1, NRC Recommended Conversion Application Guidelines," regarding ISTS and ISTS Bases markups states, Bracketed numbers or requirements need not be addressed by a difference discussion provided that the existing requirement is being retained. NEI 96-06 is provided as a reference in NRR Office Instruction LIC-601, Improved Technical Specification Conversion Amendment Review Procedures.

UFSAR Section 5.1.1 confirms the peak design basis containment temperature. The ITS 3.6.5 Bases already includes reference to UFSAR Section 14.3, which contains the initial containment temperature and the peak containment temperature (post steam line break). UFSAR Section 14.3.4.2.2 and Table 14.3.4.3-1 confirms the initial containment temperature assumption of 130°F. UFSAR Table 14.3.4.3-6 confirms the maximum containment structural temperature of 279.4 °F for the associated accident being analyzed, which is below the containment design temperature of 283°F as stated in UFSAR Sections 5.1.1, 6.3.2, and 6.4.1.

ITS Bases will be revised to match the UFSAR temperature values.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-6 L-2022-010 Attachment 25 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 6 ITS Bases 3.6.6 - page 179 - ITS Bases 3.6.6 ASA markup changes containment High-3 pressure setpoint to containment High-2 pressure setpoint. Provide the UFSAR reference that supports the selection for the High-2 pressure setpoint.

FPL Response:

Consistent with CTS, PTN uses the High and High-High nomenclature for containment pressure instrumentation in ITS 3.3.2, Engineered Safety Feature Actuation System (ESFAS)

Instrumentation, instead of the ISTS nomenclature High-1 or High-2. In addition, PTN design does not contain an equivalent ISTS High-3 setpoint. The Applicable Safety Analyses Section of ITS Bases 3.6.6 will be revised to reflect the PTN nomenclature for containment pressure ESFAS instrumentation; High-2 will be revised to "High-High."

PTN current technical specifications use the High and High-High nomenclature instead of the High-1 or High-2 and has no High-3 setpoint. Setpoint identification will be changed from High-2 to "High-High". The sentence for the ITS Bases 3.6.6 states, "The modeled Containment Spray System actuation from the containment analysis is based on a response time associated with exceeding the containment High-3 pressure setpoint to achieving full flow through the containment spray nozzles." The PTN ITS conversion submittal changed this to the containment High-2 pressure setpoint, as listed several places in the PTN UFSAR (e.g., UFSAR Table 14.3.4.3-6, Containment Pressure Hi-2). However, PTN CTS uses containment pressure High-High identification as also listed in UFSAR Table 7.2-1. Although the containment spray actuation signal is Containment Pressure - High-High coincident with Containment Pressure -

High the containment pressure High-2 (High-High) was listed because this is when the timing to full flow would start.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.6-7 L-2022-010 Attachment 26 Page 1 of 1 Volume 11 - Section 3.6 (ADAMS Accession No. ML21265A382) Question 7 ITS Bases 3.6.6 - page 180 - ITS Bases B 3.6.6 discussion of Required Action A.1 refers to ...

the redundant heat removal capability afforded by the Containment Spray System, ...However, based on ITS 3.6.6 JFD 4 (page 171), it appears that redundancy in heat removal is afforded by combinations of containment spray and emergency containment cooling units. Provide an explanation that addresses which system(s) afford heat removal capability in this context.

FPL Response:

No changes are proposed to the referenced Bases excerpt. ITS 3.6.6 governs OPERABILITY of the Containment Spray and Cooling Systems. Required Action A.1 is associated with one inoperable containment spray train and is not intended to address overall heat removal capability which may require a combination of spray and cooling units. PTN did not propose changes to the STS Bases for Required Action A.1. The preceding sentence to the excerpt presented in Item 7 above states (emphasis added):

In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions.

The excerpt is not intended to imply that cooling trains may not be required to provide overall heat removal requirements, but only to address why a 72-hour Completion Time is reasonable for restoring an inoperable containment spray train. Because no changes are proposed to the NRC-approved STS wording, FPL concludes that the wording is acceptable as presented.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-1 L-2022-010 Attachment 27 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 1 ITS 3.8.1 - page 19/419 - On ITS 3.8.1 discussion of change (DOC) page 3 of 17, DOC M01 describes Actions in Mode 1. There is also a less restrictive change which is missing a discussion of the change. In Modes 2, 3, and 4, CTS action a.5 requires restoration of the inoperable startup transformer within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is less than the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed in ITS. Provide a DOC for this less restrictive change.

FPL Response:

There is no missing Less Restrictive change; CTS Action a.5 is equivalent to ITS ACTION C. As described in ITS 1.3, Completion Times, "if situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time." ITS LCO 3.8.1, ACTION C is applicable when one required associated offsite circuit is inoperable. Condition C is modified by a Note stating that it is only applicable when the associated unit is in MODES 2, 3, or 4, similar to CTS Action a.5 which states, "If the inoperable startup transformer is the associated startup transformer and became inoperable while the unit was in MODE 2, 3, or 4 . . ." As in CTS Action a.5, ITS ACTION C allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the inoperable Startup Transformer.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-2 L-2022-010 Attachment 28 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 2 ITS 3.8.1 - page 23 - On discussion of changes (DOC) page 7 of 17 of ITS 3.8.1, DOC LA05 states that the removal of CTS 4.8.1.1.2.a.6, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the TS to provide adequate protection of public health and safety. DOC LA05 also states that an OPERABLE Emergency Diesel Generator (EDG) must be capable of providing power to the associated emergency bus as indicated in the Bases. ITS 3.8.1 LCO b is the requirement for EDGs to be capable of supplying the onsite Class 1E power distribution subsystem therefore the details of CTS 4.8.1.1.2.a.6 are not being removed from TS. Provide a revised discussion of change for CTS 4.8.1.1.2.a.6.

FPL Response:

It is agreed that a DOC is required; however, an Administrative DOC will be provided because the surveillance requirement is being deleted but the definition of OPERABLE/OPERABILITY and the LCO retain the details of surveillance. CTS 4.8.1.1.2.a.6 is a surveillance requirement to specifically verify the diesel generator is aligned to provide standby power to the associated emergency buses. For the diesel generator to provide its safety function, as required by the definition of OPERABLE, it must be aligned to provide standby power. The change will be categorized as an Administrative Change with a revised discussion of change as follows.

A09 CTS 4.8.1.1.2.a.6 requires the verification that each EDG is aligned to provide standby power to the associated emergency buses. ITS 3.8.1 does not contain this surveillance requirement. This changes the CTS by deleting the surveillance requirement as the detail that each EDG is aligned to provide standby power to the associated emergency buses is included in the ITS LCO.

The removal of CTS 4.8.1.1.2.a.6, which is related to system design, from the Technical Specifications is acceptable because this type of information is not necessary to be included as a specific surveillance requirement to provide adequate protection of public health and safety. ITS LCO 3.81 requires the EDGs to be OPERABLE. For the emergency diesel generator to provide its safety function, as required by the definition of OPERABLE, it must be aligned to provide standby power, capable of providing power to the associated emergency bus as described in the Bases. This change is designated as administrative because it does not result in a technical change to the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-3 L-2022-010 Attachment 29 Page 1 of 2 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 3 ITS 3.8.1 - page 25 - On ITS 3.8.1 discussion of change (DOC) page 9 of 17, DOC L01 states, CTS ACTIONs a.3.b. a.4, a.5, b.3, d.1, e.2, and f, in part, require that if the associated Action and Completion time are not met to be ... in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ... However, the action to be in HOT Standby within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months does not seem to apply to any of the listed CTS Actions. Provide an explanation to why this action is listed in DOC L01 or revise DOC L01.

FPL Response:

The statement, "in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ," does not apply to any of the listed CTS Actions. The statement, "in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ," is associated with CTS ACTION d.2. CTS ACTION d.2 was not included in this DOC. The DOC will be revised to delete this statement as follows.

L01 (Category 4 - Relaxation of Required Action) CTS ACTIONs a.3.b, a.4, a.5, b.3, d.1, e.2, and f, in part, require that if the associated Action and Completion Time are not met to be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; or in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ITS ACTION J requires that with the Required Action and associated Completion Time of Condition A, B, C, D, E, F, G, or H not met to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by requiring a less restrictive end state in the required actions, MODE 4 (HOT SHUTDOWN) instead of MODE 5 (COLD SHUTDOWN).

The purpose of the CTS 3.8.1.1 ACTIONS is to limit the time the unit can remain operating with different combinations of inoperable offsite circuits and EDGs. Once these limits to operation are exceeded, ACTION J is entered to provide a reasonable time to place the unit is a safe condition. End states are usually defined based on placing the unit into a MODE or condition in which the Technical Specification Limiting Condition for Operation (LCO) is not applicable. MODE 5 is the current end state for LCOs that are applicable in MODES 1 through 4. This change is acceptable because the risk of the transition from MODE 1 to MODES 4 or 5 depends on the availability of alternating current (AC) sources and the ability to remove decay heat such that remaining in MODE 4 may be safer. During the realignment from MODE 4 to MODE 5, there is an increased potential for loss of shutdown cooling and loss of inventory events.

Decay heat removal following a loss-of-offsite power event in MODE 5 is dependent on AC power for shutdown cooling whereas, in MODE 4, the turbine driven auxiliary feedwater (AFW) pump will be available. Therefore, transitioning to MODE 5 is not always the appropriate end state from a risk perspective. Thus, for specific TS conditions, Westinghouse Topical Report WCAP-16294-A R1 (ADAMS Accession No. ML103430249) justifies MODE 4 as an acceptable alternate end state to Mode 5. The proposed change to the Technical Specifications will allow time to perform short-duration repairs, which currently necessitate exiting the original mode of applicability. The MODE 4 TS end state is applied, and risk is assessed and managed in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.65, "Requirements for

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-3 L-2022-010 Attachment 29 Page 2 of 2 monitoring the effectiveness of maintenance at nuclear power plants." Modified end states are limited to conditions where: (1) entry into the shutdown mode is for a short interval, (2) entry is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable TS, and (3) the primary purpose is to correct the initiating condition and return to power operation as soon as is practical. This proposed change is consistent with NRC approved TSTF-432-A Revision 1 (ADAMS Accession No. ML103360003), noticed for availability by the NRC in the Federal Register (77 FR 27814) on May 11, 2012. The NRC's approval of WCAP-16294-A included four limitations and conditions on its use as identified in Section 4.0 of the NRC Safety Evaluation associated with WCAP-16294-A. Implementation of these stipulations were addressed in the Bases of TSTF-432-A. Florida Power & Light implemented these limitations and conditions at PTN in the adoption of the associated TSTF-432-A Bases. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-4 L-2022-010 Attachment 30 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 4 ITS 3.8.1 - page 25 - On ITS 3.8.1 discussion of change (DOC) page 9 of 17, DOC L01 states, CTS ACTIONs a.3.b. a.4, a.5, b.3, d.1, e.2, and f, in part, require that if the associated Action and Completion time are not met to be ... in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ... However, the action to be in HOT Standby within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months does not seem to apply to any of the listed CTS Actions. Provide an explanation to why this action is listed in DOC L01 or revise DOC L01.

FPL Response:

Insert 3 has been inadvertently inserted inconsistent with the ISTS format. The insert should be inserted after the "AND" logic connector following Required Action E.1. A revision will be provided showing INSERT 3 following the "AND" logic connector following Required Action E.1.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-5 L-2022-010 Attachment 31 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 5 ITS 3.8.1 - page 40 - On ITS 3.8.1 page 3.8.1-3, the completion time for Required Action F.2 states, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months [OR In accordance with Risk Informed Completion Time Program], and the proposed change deletes the brackets. However, license amendment numbers 284 and 278 did not approve a risk informed completion time (RICT) for CTS 3.8.1.1 Action e. Therefore, remove or in accordance with the Risk Informed Completion Time Program from the Completion Time for ITS 3.8.1 Required Action F.2, as it is not consistent with license amendment numbers 284 and 278.

FPL Response:

"[OR In accordance with Risk Informed Completion Time Program]," will be removed from Required Action F.2. In PTN's submittal to adopt the RICT program the NRC staff had a concern associated with "loss of function". One of the industry-proposed options to address the staff's concern was to exclude the use of the loss of function provisions provided in TSTF-505 and, based on PTNs definition of OPERABLE/OPERABILITY, this included two inoperable offsite circuits as a loss of function condition. With the adoption of the ISTS definition of OPERABLE/OPERABILITY two inoperable offsite circuits is no longer a loss of function condition. However, because PTNs adoption of the RICT program did not include the ISTS option, it will be deleted.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-6 L-2022-010 Attachment 32 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 6 ITS 3.8.1 - page 42 - On ITS 3.8.1 page 3.8.1-4, ITS 3.8.1 Condition I is entered when one automatic load sequencer is inoperable and Required action I.1 has a required completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time. CTS 3.8.1.1 does not have a specific Action for an inoperable automatic load sequencer and therefore, was not evaluated under license amendment numbers 284 and 278 for Units 3 and 4, respectively. For ITS 3.8.1 required action I.1 provide the following information: (1) the success criteria parameters used to determine PRA functional determination are the same as the design-basis success criteria parameters or, if different, plant-specific analyses used to support the PRA are justified; (2) identify how the load sequencers are implicitly or explicitly modeled in the PRA; (3) CCFs and/or surrogate identification; and (4) the Configuration Risk Management Program (CRMP) provides the capability to select the load sequencers as out-of-service in order to calculate a RICT.

FPL Response:

FPL provides the following response for RSI No, 3.8-6.

(1) There is no success criterion for the emergency load sequencers. The emergency load sequencers sequence the loading of front-line and support system components on the diesel generators when there is a loss of offsite power. There are success criteria for these components for different scenarios; therefore, the sequencers affect whether these success criteria are met given a loss of offsite power.

(2) The load sequencers are modeled under the front-line and support system fault tree logic as necessary for their operation given a loss of offsite power.

(3) Common cause failures are not modeled for the sequencers.

(4) The load sequencers may be selected as out of service in the CRMP risk monitor and their selection will result in the option to enter a RICT.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-7 L-2022-010 Attachment 33 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 7 ITS 3.8.1 - page 42 - On ITS 3.8.1 insert page 3.8.1-4, Condition J Note states, Condition J only applies [emphasis added] to one Unit during a dual Unit shutdown. Condition Note K.1 states, Condition K only applies when a dual Unit shutdown is required. Condition Note K.2 states, Only one Unit can enter Condition K. The above Condition Notes are written such that they do not allow for a single Unit that doesn't meet the Required Action Completion Times for shutdown, they drive a single unit to LCO 3.0.3.

FPL Response:

FPL will revise the Condition J Note to state, "During a dual unit shutdown, Condition J only applies to one Unit."

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-8 L-2022-010 Attachment 34 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 8 ITS 3.8.1 - page 48, 103 - On ITS 3.8.1 Insert page B 3.8.1-18, Insert 18 states, ...SR [3.8.1.6]

is modified by a Note to indicate that all EDG starts for this Surveillance may be preceded by an engine pre-lube period and followed by a warmup period prior to loading. However, the SR Note is missing from ITS SR 3.8.1.6. Add the Note to ITS SR 3.8.1.6 or change the ITS Bases to be consistent with SR 3.8.1.6.

FPL Response:

The ITS Bases will be revised to remove the statement associated with a warmup period. The Note is included with ITS SR 3.8.1.6 that this Surveillance may be preceded by an engine pre-lube period however because this test is a rapid start of the EDG a warmup period is not applicable and will be removed from the ITS Bases.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-9 L-2022-010 Attachment 35 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 9 ITS 3.8.1 - page 63 - On ITS 3.8.1 page 3.8.1-15, Note 1 in SR 3.8.1.14 that states, Momentary transients outside of load range do not invalidate this test. The proposed change to Note 1 replaces test with pre-test requirement. The proposed change no longer allows momentary transients outside the load range for SR 3.8.1.14 and now applies to the pre-test requirement in Note 1. JFD 5 provides the basis for adding the momentary transients outside the load range to the pre-test requirement but does not provide the basis for removing the momentary transients outside the load range for SR 3.8.1.14. Provide an explanation for the basis for removing the momentary transient Note from SR 3.8.1.14, instead of adding the pre-test requirement to the already written STS SR 3.8.1.14 Note 1, therefore applying it to both.

FPL Response:

No change is needed. ITS SR 3.8.1.14 is a rapid start test of the EDG with no loading requirement. Without a loading requirement an allowance for momentary transient outside the load range is unnecessary. Only the Note 1 pre-test requirement of the EDG being loaded for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months requires an allowance for momentary transients outside the load range.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-10 L-2022-010 Attachment 36 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 10 ITS 3.8.1 - page 72 - On ITS 3.8.1 Bases page B 3.8.1-1, it states, Offsite power is supplied to the unit switchyard(s) from the transmission network by 10 transmission lines. However, Turkey Points UFSAR Section 8.2.1 states, The switchyard is connected to Florida Power and Light Company's transmission network through nine 240 kV circuits as shown on Figure 8.2-2.

Provide an explanation for the discrepancy on the number of transmission lines and/or circuits.

FPL Response:

There are 10 lines connecting the Turkey Point switchyard and FPL electrical grid. A design change constructed Bay 11 (total 12 bays), which included the 10th connecting line. Turkey Point Units 3 and 4, UFSAR Rev 431, Section 8.2.1, correctly describes the recent modification of the switchyard to include 12 bays (numbered 0-11) and 10 connecting lines and was provided to the NRC in the May 12, 2021 UFSAR Update. Below is the revised paragraph.

The switchyard is connected to Florida Power and Light Company's transmission network through ten 240 kV circuits as shown in Figure 8.2-2. The total capacity of the ten lines at the Turkey Point Switchyard is approximately 5800 MVA (between 478 and 759 MVA each).

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-11 L-2022-010 Attachment 37 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 11 ITS 3.8.1 - page 80 - On ITS 3.8.1 Bases page B 3.8.1-5, JFD 1 is applied to the proposed addition of a qualified to the offsite source. ITS 3.8.1 Bases JFD 1 state that changes are made to the improved standard technical specifications Bases that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

Provide an explanation on how ITS 3.8.1 Bases JFD 1 applies to this change.

FPL Response:

Reference to "a qualified" will be deleted from the Bases.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-12 L-2022-010 Attachment 38 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 12 ITS 3.8.1 - page 87 - On ITS 3.8.1 Bases Insert Page B 3.8.1-8b, insert 11 for Required Action E.5 states, The Required Actions have been modified by a Note. The Note states that Required Actions E.2 and E.3 are not applicable for Unit 4 when the required Unit 3 EDG is declared inoperable by LCO 3.8.3 Condition F. ITS 3.8.1 Required Actions E.2 and E.3 are not modified by a Note stating that they are not applicable for Unit 4 when the required Unit 3 EDG is declared inoperable by LCO 3.8.3, Condition F. Remove the discussion of the Note from insert 11 or provide the proposed Note and its JFD in ITS 3.8.1 Required Actions E.2 and E.3 as discussed in Bases insert 11.

FPL Response:

The Note is not associated with Required Action E.5 and will be removed from Required Action E.5 Bases. A Note will be added to Required Action E.2 and E.3 stating that these Required Actions are not applicable for Unit 4 when the required Unit 3 EDG is declared inoperable by LCO 3.8.3, Condition F and a discussion will be added to Required Actions E.2 and E.3 Bases.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-13 L-2022-010 Attachment 39 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 13 ITS 3.8.1 - page 121 - On ITS 3.8.1 Bases page B 3.8.1-29 it discusses that SR 3.8.1.13 is modified by three Notes, a portion of this discussion related to Note 2 is deleted, and the justification for the proposed deletion is Bases JFD 5. Bases JFD 5 discusses SR 3.8.1.2 and SR 3.8.1.7. Provide an explanation of how JFD 5 applies to this change.

FPL Response:

The inadvertent insertion of JFD 5 is a typographical error. This JFD is referenced to a section in the ITS Bases that is not being changed. The deletion of the ISTS Note 2 bases is being deleted and that deletion is covered by JFD 1 as PTN CTS does not include the restriction associated with this Note. JFD 1 will be added to discuss the deletion of ISTS Note 2 and JFD 5 will be deleted.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-14 L-2022-010 Attachment 40 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 14 ITS 3.8.1 - page 140 - On CTS page 3/4 8-11, it is proposed that operations involving CORE ALTERATIONS be deleted from the CTS 3.8.1.2 Action statement. However, the proposed change does not have a discussion of change associated with it. In STS this Required Action was deleted under TSTF-471. In order to delete CORE ALTERATIONS from CTS, provide a description of the limitations and controls that would prevent movement of any unirradiated fuel assembly, source, reactivity control component, or other component affecting reactivity within the reactor vessel capable of damaging an irradiated fuel assembly prior to the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months decay time assumed in the Fuel Handling Accident (FHA) analysis or information demonstrating that the dropping of any unirradiated fuel assembly, sources, reactivity control component, or other component affecting reactivity within the reactor vessel onto irradiated fuel assemblies prior to the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months decay time assumed in the FHA will not result in a radioactive release from the irradiated fuel.

FPL Response:

A DOC associated with the deletion of Core Alterations was inadvertently omitted. FPL will add the following DOC associated with this deletion.

L05 (Category 4 - Relaxation of Required Action) The CTS 3.8.1.2 ACTION specifies the compensatory action for an inoperable required AC Source while in MODES 5 and 6.

One of the compensatory actions is the suspension of CORE ALTERATIONS. Under similar conditions, ITS 3.8.2 does not require suspension of CORE ALTERATIONS.

This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when a required AC source is inoperable.

The purpose of the CTS 3.8.1.2 ACTION to suspend CORE ALTERATIONS is to minimize the possibility of an event that may need the AC source to mitigate the consequences of the event. CORE ALTERATION is defined in CTS 1.9, in part, as "the movement of any fuel, sources, reactivity control components, or other components affecting reactivity, within the reactor vessel with the head removed and fuel in the vessel." CORE ALTERATIONS only occur when the reactor vessel head is removed - it only applies in MODE 6. There is only one accident considered during MODE 6 that involves a CORE ALTERATION: a fuel handling accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the containment or in the fuel building. Suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident. ITS 3.8.2 retains the requirement to suspend movement of irradiated fuel assemblies in ITS 3.8.2 Required Action A.2.1 (for an inoperable required offsite circuit) and Required Action B.1 (for one or more inoperable required EDG(s)). Therefore, because the only CORE ALTERATION analyzed in the safety analysis and potentially affected by a loss of an AC source is covered by the ITS Required Actions, deletion of the term "CORE ALTERATIONS" is acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-15 L-2022-010 Attachment 41 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 15 ITS 3.8.1 - page 140 - On CTS page 3/4 8-11, the CTS markup states that the Applicability of CTS 3.8.1.2 is Modes 5* and 6* and deletes footnote

which states, Caution - If the opposite unit is in MODES 1, 2, 3, or 4 see Specification 3.8.1.1. The markup of CTS 3.8.1.2 shows LA01 pointing to footnote *. However, on ITS 3.8.2 discussion of change page 2 of 5, it states that there are no removed detail changes. Provide the discussion of change for deleting footnote *.

FPL Response:

A DOC justifying the change that deleted footnote

was inadvertently omitted. FPL will add the following DOC associated with this deletion.

LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.8.1.2, Applicability Footnote

states "CAUTION - If the opposite unit is in MODES 1, 2, 3, or 4 see Specification 3.8.1.1." ITS 3.8.2, Applicability does not include this Footnote. This changes the CTS by removing the procedural details cautioning the operator to refer to CTS Specification 3.8.1.1 (ITS 3.8.1) for the opposite unit if the opposite unit is in MODES 1, 2, 3, or 4.

The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements for AC Sources - Operating (ITS 3.8.1) that continues to assure protection of public health and safety. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases.

Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-16 L-2022-010 Attachment 42 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 16 ITS 3.8.1 - page 143 - On ITS 3.8.2 DOC page 2 of 5, DOC L01 discusses CTS 3.8.1.2 Action requirement to depressurize and vent the reactor coolant system (RCS) through a greater than or equal to 2.2 square inch vent within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , when less than the minimum required alternating current (AC) electrical power sources are operable. Proposed ITS 3.4.12 provides overpressure mitigation systems, which aligns with a portion of the CTS 3.8.1.2 Action. CTS 3.8.1.2 Action also addresses water inventory in the RCS if less than the minimum required AC electrical sources are operable and requires increasing RCS inventory as soon as possible if in Mode 5 with the reactor coolant loops not filled, or in Mode 6 with water level less than 23 feet above the reactor vessel flange. This portion of CTS 3.8.1.2 Action appears to be deleted from Turkey Points technical specifications. Provide the technical basis addressing deletion of the RCS water inventory for the specified conditions in Mode 5 and 6.

FPL Response:

FPL agrees, DOC L01 does not discuss this change. FPL will add a more restrictive DOC to discuss this change as follows.

M02 The CTS 3.8.1.2 Action requires, in part, that with less than the minimum required A.C.

electrical power sources OPERABLE that when in MODE 5 with the reactor coolant loops not filled, or in MODE 6 with the water level less than 23 feet above the reactor vessel flange to increase RCS inventory as soon as possible. ITS 3.8.2 Required Actions A.2.3 and B.3 require the immediate initiation of action to restore the required AC Sources to OPERABLE status. This changes the CTS by expanding the Action requirement to restore the inoperable AC Sources to OPERABLE status regardless of fill status of the reactor coolant loops or the water level above the top of reactor vessel flange.

The purpose of ITS 3.8.2 Required Actions A.2.3 and B.3 is to promptly initiate action to restore the LCO requirements. When a required offsite circuit or one required EDG is inoperable, the actions imposed by the CTS 3.8.1.2 ACTION do not necessarily place the unit in a MODE or other specified condition in which CTS 3.8.1.2 is not applicable.

Therefore, proposed ITS 3.8.2 Required Actions A.2.3 and B.3 are being expanded to apply in all plant configurations in MODES 5 and 6. When in MODE 5 with the reactor coolant loops filled and MODE 6 with water level 23 ft above the reactor vessel flange, at least one shutdown cooling loop is required to be OPERABLE and in operation and two trains of the Control Room Emergency Ventilation System are required to be OPERABLE during movement of irradiated fuel assemblies. Therefore, AC Sources are, at a minimum, required to be OPERABLE to support these required systems to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite emergency diesel generator (EDG) power. These additional restrictions will ensure action is immediately taken to restore compliance with the LCO requirements. In addition, ITS 3.4.8, "RCS Loops - MODE 5, Loops not Frilled," and ITS 3.9.5, "RHR and Coolant Circulation - Low Water Level," provide appropriate Required Actions when their associated LCO is not met due to a loss of an AC source causing a loss of an RHR pump. This change is designated as more restrictive because the CTS Required Actions are expanded to apply to all plant configurations in MODES 5 and 6 and during movement of irradiated fuel assemblies.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-17 L-2022-010 Attachment 43 Page 1 of 2 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 17 ITS 3.8.1 - page 175 - On ITS 3.8.3 discussion of change (DOC) page 3 of 6, DOC M02 states, ITS SR 3.8.3.4 requires verification that the required starting air receiver pressure is > 210 psig

[pounds per square inch gauge] for each EDG. The proposed ITS SR 3.8.3.4 value, 212 psig for Unit 3 and 195 psig for Unit 4, will ensure the five-diesel air start requirement is met. However, proposed ITS SR 3.8.3.4 requires verifying each EDG air start receiver pressure is greater than or equal to 195 psig for Unit 3 and 185 psig for Unit 4. Provide an explanation of the difference in values in M02 and ITS SR 3.8.3.4.

FPL Response:

The difference in the values is associated with an option PTN has of either using 4 air flasks and 4 associated air start motors (2 sets) or 2 air flasks and 2 associated start motors (1 set).

For Unit 3, with starting air receiver pressure 212 psig (1 air start set available) or 195 psig (2 air start sets available) sufficient capacity for five successive EDG start attempts exists. For Unit 4 with starting air receiver pressure 195 psig (1 air start set available) or 185 psig (2 air start sets available) sufficient capacity for five successive EDG start attempts exists.

Discussion of change M02 will be revised to explain this difference and SR 3.8.4.4 will be revised similar to Condition E with the required pressure for 5 successive start attempts in the Bases, similar to SR 3.8.4.1 and SR 3.8.4.2.

M02 The CTS does not provide any starting air receiver pressure requirements. ITS LCO 3.8.3, in part, requires the required starting air receiver pressure to be within limits for each required EDG. The Applicability for this requirement is when the associated EDG is required to be OPERABLE. ITS SR 3.8.3.4 requires verification that the required starting air receiver pressure is the 5 start air pressure for each EDG. ITS 3.8.3 ACTION E provides an ACTION if the limit of ITS SR 3.8.3.4 is not met. This changes the CTS by adding a starting air receiver pressure requirement, with an appropriate ACTION and SR.

The purpose of the starting air receiver pressure requirement in ITS LCO 3.8.3 and SR 3.8.3.4 is to ensure sufficient starting air for five successive air start attempts for each EDG without recharging the air start receivers. The proposed ITS SR 3.8.3.4 value, is the 5 start air pressure will ensure the five-diesel air start requirement is met. The EDG air start system design includes four air start receivers and four air start motors arranged in two sets. Each set includes two air start receivers and two air start motors. Each EDG can be aligned such that one or two sets of air starting sets can be aligned to start the EDG. With two sets of air start receivers/motors aligned to the EDG, 195 psig (Unit 3 EDGs) or 185 psig (Unit 4 EDGs) receiver air pressure is required for 5 successive air start attempts. With one set of air start receivers/motors aligned to the EDG, 212 psig (Unit 3 EDGs) or 195 psig (Unit 4 EDGs) receiver air pressure is required for 5 successive air start attempts. In addition, ITS 3.8.3 ACTION E will allow the five-diesel air start requirement to not be met for each EDG for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , provided the required starting air receiver pressure is sufficient for one EDG start ( 160 psig).

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-17 L-2022-010 Attachment 43 Page 2 of 2 If the required starting air receiver pressure is not restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , or if the required starting air receiver pressure is not sufficient for one start, then the associated EDG is required to be declared inoperable immediately. Furthermore, as stated in the ITS 3.8.3 ACTIONS Note, ITS 3.8.3 ACTION E can be separately entered for each EDG.

Therefore, this change is acceptable because it provides additional assurance that the EDGs will be capable of performing their function. This change is considered more restrictive because it adds a new requirement to maintain a starting air receiver pressure for each EDG.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-18 L-2022-010 Attachment 44 Page 1 of 2 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 18 ITS 3.8.1 - page 181 - On ITS 3.8.3 Insert Page 3.8.3-1, insert 1, states, ...If the diesel fuel oil system is not returned to service within 10 days, LCO 3.8.1 Required Actions E.1, E.4, and E.5 apply to Unit 4 and LCO 3.8.2 ACTIONS apply to Unit 3. This proposed Note seems to limit which LCO 3.8.1 required actions should be entered for Unit 4. If the diesel fuel oil system is not returned to service within 10 days, provide an explanation for why LCO 3.8.1 Required Actions E.2 and E.3 are left out of this Note (i.e., why the Note does not point to entering LCO 3.8.1 Condition E for Unit 4) or to entering LCO 3.8.3 Condition F.

FPL Response:

The proposed change was crafted in this manner to convert the ITS to match the CTS requirements.

The fuel supply specified for the Unit 3 EDGs (Diesel Oil Storage Tank or temporary storage system) will ensure sufficient fuel for either EDG associated with Unit 3 for at least a week. The fuel supply specified for the Unit 4 EDGs ensures sufficient fuel for each EDG associated with Unit 4 for at least a week. This change was approved under Amendment No 197 and 191 (ADAMS Accession No ML013390410). The NRC SE states, "If 10 days of operation are exceeded using the temporary fuel oil storage system, the appropriate action statements for an inoperable but required Unit 3 EDG will be entered." The PTN CTS Note states that, "If the diesel fuel oil storage tank is not returned to service within 10 days, Technical Specification 3.8.1.1 Action b and 3.8.1.2 Action apply to Unit 4 and Unit 3 respectively." CTS 3.8.1.1, Action b has three Actions:

1. Demonstrate the OPERABILITY of the above required startup transformers and their associated circuits by performing Surveillance Requirement 4.8.1.1.1.a within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

2. If the diesel generator became inoperable due to any cause other than an inoperable support system, an independently testable component, or preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining required diesel generators by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unless the absence of any potential common mode failure for the remaining diesel generators is determined. If testing of remaining required diesel generators is required, this testing must be performed regardless of when the inoperable diesel generator is restored to OPERABILITY.

3. Restore the inoperable diesel generator to OPERABLE status within 14 days** or in accordance with the Risk Informed Completion Time Program, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

- 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if inoperability is associated with Action Statement 3.8.1.1.c.

These three Actions in CTS are equivalent to ITS 3.8.1 Required Actions E.1, E.4, and E.5.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-18 L-2022-010 Attachment 44 Page 2 of 2 ITS 3.8.1 Required Action E.2 requires two or more safety injection pumps to be OPERABLE and capable of being powered from their associated OPERABLE EDGs. ITS 3.8.1 Required Action E.3 requires the required feature(s) supported by the inoperable EDG to be declared inoperable when its required redundant feature(s) is inoperable. These Required Actions are associated with CTS Action d and were not considered necessary as the EDG still retains the required amount of fuel oil; the time needed to clean the fuel oil storage tank is only longer than expected.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-19 L-2022-010 Attachment 45 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 19 ITS 3.8.1 - page 182 - On ITS 3.8.3 page 3.8.3-2, ITS 3.8.3 Condition E is modified to state, One or more EDGs with required starting air receiver pressure < 5 start air pressure and > 160 psig. On ITS 3.8.3 Bases page B 3.8.3-4, ITS Condition E.1 states, With starting air receiver pressure < 212 psig (1 air start set available) or < 195 psig (2 air start sets available) for Unit 3 and < 195 psig (1 air start set available) or < 185 psig (2 air start sets available) for Unit 4, sufficient capacity for five successive EDG start attempts does not exist. On ITS 3.8.3 page 3.8.3-3, ITS SR 3.8.3.4 states, Verify each EDG air start receiver pressure is > 195 psig for Unit 3 and > 185 psig for Unit 4. In ISTS the bracketed air pressure in SR 3.8.3.4 is that which represents the 5 air start pressure, and it matches the less than bracket air pressure stated in ISTS 3.8.3 Condition E. The five start air pressure is consistent between the ISTS SR and Condition E, therefore it is clear when Condition E must be entered. As proposed ITS 3.8.3.4 and ITS 3.8.3 Condition E are not consistent and therefore it is not clear to the NRC staff when Condition E would be entered. In addition, ITS 3.8.3 JFD 1 and JFD 2 does not explain what is required nor does it explain why 5 start air pressure was added instead of inserting the air pressure for 5 starts for Units 3 and Unit 4. Provide a revision to ITS 3.8.3 such that ITS SR 3.8.3.4 matches ITS 3.8.3 Condition E, and the numerical values are contained in ITS SR 3.8.3.4. In addition, provide a JFD that explains the corresponding changes.

FPL Response:

The SR will be revised to be consistent with Condition E and the Bases will be corrected as appropriate. Additional detail explaining the corresponding changes is provided in the DOC M02 revision provided in FPLs response to RSI 3.8-17 (Attachment 43).

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-20 L-2022-010 Attachment 46 Page 1 of 2 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 20 ITS 3.8.1 - page 183 - On ITS 3.8.3 page 3.8.3-3, ITS SR 3.8.3.4 verifies each EDG air start receiver pressure is greater than or equal to 195 psig for Unit 3 and 185 psig for Unit 4 and has a required surveillance frequency of 31 days or in accordance with the Surveillance Frequency Control Program. CTS 3.8.1.1 and CTS 3.8.12 does not have a specific SR for air start receiver pressure and therefore, was not evaluated under license amendment numbers 263 and 258 for Units 3 and 4, respectively. For ITS SR 3.8.3.4, provide the following information: (1) The new SR base surveillance frequency interval for inclusion into the surveillance frequency control program; (2) Discussion of whether the new surveillance test interval can be modeled in the plant specific PRA; (3) A discussion of the request to include the new SR into the previously approved surveillance frequency control program (ADAMS Accession No. ML15166A320); and, (4) An implementation schedule (e.g., the first performance is due at the end of the first surveillance interval, which begins on the date of implementation of this amendment) for the new SR interval.

Provide a technical evaluation that discusses the above information and provide the implementation schedule for the new SR interval and why it is appropriate.

FPL Response:

FPL provides the following information in response to the NRC's request.

1) ISTS SR 3.8.3.4 verifying EDG air start receiver pressure includes the Frequency of [31 days or in accordance with the Surveillance Frequency Control Program.] FPL is proposing to adopt the Frequency for SR 3.8.3.4 of "In accordance with the Surveillance Frequency Control Program," for PTN. The new SR base surveillance frequency interval for inclusion into the surveillance frequency control program will be 31 days on implementation.

2) The EDG air start receiver is included in the emergency Diesel Generator (EDG) PRA component boundary. An out-of-service air-start receiver would be represented as an out-of-service EDG.

3) In July of 2015 the NRC approved a license amendment request (LAR) for changes to PTN's Technical Specifications (TS) that were consistent with NRC-approved Technical Specification Task Force (TSTF) Standard Technical Specifications change TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specifications Task Force (RITSTF) Initiative 5b," Revision 3 (ADAMS Accession No. ML15166A320). TSTF-425 included template TS changes including changes for LCO 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air," SR 3.8.3.4, verify each DG air start receiver pressure. The TSTF-425 SR 3.8.3.4 change is as is currently in NUREG-1431, Revision 5.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-20 L-2022-010 Attachment 46 Page 2 of 2 In the NRC's Safety Evaluation for the PTN relocation of surveillance frequencies to the SFCP the NRC stated that:

"When implemented, TSTF-425 relocates most periodic frequencies of TS surveillances to the SFCP and provides requirements for the new program in the Administrative Controls sections of the TSs. All surveillance frequencies can be relocated except the following:

Frequencies that reference other approved programs for the specific interval, such as the In-Service Testing Program or the Primary Containment Leakage Rate Testing Program;

Frequencies that are purely event-driven (e.g., "each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching ~ 95%

RTP"); and

Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of an SR (e.g., "drywell to suppression chamber differential pressure decrease").

The licensee proposed to add the SFCP to TSs Section 6.0, "Administrative Controls," Subsection 6.8, "Procedures and Programs."

The SFCP describes the requirements for controlling changes to the relocated surveillance frequencies."

Because the Frequency associated with ITS SR 3.8.3.4 does not meet one of the exceptions for relocation, as confirmed by NUREG 1431, and FPL has a SFCP that describes the requirements for controlling changers, controlling the Frequency of SR 3.8.3.4 in the SFCP is acceptable.

4) FPL proposes that the first performance of SR 3.8.3.4 will be completed prior to implementation of the approved license amendment and the new SR interval will start from the completion of the performance.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.8-21 L-2022-010 Attachment 47 Page 1 of 1 Volume 13 - Section 3.8 (ADAMS Accession No. ML21265A384) Question 21 ITS 3.8.1 - page 193 - CTS 6.8.4.e, Diesel Fuel Oil Testing Program, establishes the total particulate concentration of the fuel oil is less than or equal to 10 mg/liter when tested every 31 days in accordance with either American Society for Testing and Materials (ASTM) D-2276 or ASTM D-5452. Proposed ITS 5.5.10, Diesel Fuel Oil Testing Program, establishes total particulate concentration of the fuel oil is less than or equal to 10 mg/l when tested in accordance with the Surveillance Frequency Control Program in accordance with either ASTM D-2276 or ASTM D-5452. On ITS 3.8.3 Bases page B 3.8.3- 7, a paragraph describing particulate concentrations is proposed to be deleted. In addition, on ITS 3.8.3 Bases page B 3.8.3-9, reference to ASTM D5452 is deleted and ASTM.

FPL Response:

These standards were inadvertently deleted. They will be restored.

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.9-1 L-2022-010 Attachment 48 Page 1 of 1 Volume 14 - Section 3.9 (ADAMS Accession No. ML21265A385) Question 1 ITS 3.9.3 - page 127-132 - Provide a justification for relocating CTS LCO 3.9.3 for decay time to the TRM including an evaluation under 10 CFR 50.36(c)(2)(ii)(B).

FPL Response:

The current DOC LA01 supporting the relocation of decay time to the TRM will be revised to include additional justification for the change. Removing irradiated fuel from the reactor vessel within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from entering MODE 3 (i.e., keff < 0.99) is not realistic because of the physical time required to perform plant shutdown, cooldown, depressurize the Reactor Coolant System (RCS), and the additional operations required prior to moving recently irradiated fuel in the reactor vessel (e.g., containment entry, removal of vessel head, removal of vessel internals, etc.). Therefore, movement of irradiated fuel prior to the 72-hour decay period is precluded. Thus, it is unnecessary to retain the decay time requirement in Technical Specifications. ITS retains Specifications to mitigate a fuel handling accident associated with the movement of recently irradiated fuel, which encompasses the unlikely movement of fuel prior to a decay period of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Specifically, Specifications associated with the following systems ensure these systems are OPERABLE during movement of recently irradiated fuel:

ITS 3.7.10, Control Room Emergency Ventilation System (CREVS), and associated instrumentation actuation functions

ITS 3.8.10, Electrical systems needed to support required systems

ITS 3.9.2, Refueling Cavity Water Level

ITS 3.9.4, Containment Penetrations The administrative requirement to determine that the reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months by verification of the date and time of subcriticality prior to movement of irradiated fuel in the reactor vessel will be relocated to the TRM, along with the action requirement to immediately suspend irradiated fuel movement in the unlikely event that irradiated fuel movement did occur <

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from subcriticality. Any change to the decay time input assumption in the fuel handling accident analysis will be evaluated pursuant to the criteria of 10 CFR 50.59(c)(2). This change is acceptable because the removed information will be adequately controlled in the TRM. Changes to the TRM are controlled by the provisions of 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a requirement is being removed from the Technical Specifications

Turkey Point Units 3 and 4 Dockets 50-250 and 50-251 FPL Response to NRC RSI No. 3.5-1 L-2022-010 Attachment 49 Page 1 of 1 Volume 16 - Section 5.5 (ADAMS Accession No. ML21265A387) Question 1 ITS 5.5.9 - pages 67 and 94 - STS 5.5.9.c addresses provisions for gas decay tank explosive gas and radioactivity monitoring program. However, this item is missing from ITS no justification has been provided. Provide an appropriate justification for not including the item.

FPL Response:

The Justification for Deviation (JFD) is provided by JFD 2, which states: Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. STS 5.5.9.c is not consistent with CTS 6.8.4.o and is marked for deletion to reflect the plant-specific licensing basis consistent with the guidance provided in NEI 96-06, Improved Technical Specifications Conversion Guidance, dated August 1996 (ADAMS Accession No. 070810523). As stated in Section 2.7.3 of NEI 96-06, regarding deviations from the applicable ISTS, to the extent possible, deviations should be grouped.

NEI 96-06 is provided as a reference in NRR Office Instruction LIC-601, Improved Technical Specification Conversion Amendment Review Procedures..

To provide additional clarification for not including STS 5.5.9.c in the PTN ITS, an additional JFD will be added STS 5.5.11.c governs outdoor radioactive liquid storage tanks that, in general, are not surrounded by liners, dikes, or walls that are capable of holding the tank contents. The PTN site does not contain outdoor liquid radioactive storage tanks. This information was provided in FPL letter dated August 23, 2017 (ADAMS Accession No. ML17265B008), where PTN proposed to adopt STS 5.5.9, "Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program." The following is an excerpt from the subject letter:

However, the Program does not adopt the NUREG-1431, Section 5.5.12, guidance for outdoor liquid radwaste tanks since Turkey Point does not have outdoor liquid storage tanks that contain radwaste. Accordingly, the provisions of NUREG-1431, Section 5.5.12, relating to the limiting the contents of liquid radwaste storage tanks and determining the liquid radwaste quantities in accordance with SRP Section 15.7.3, Postulated Radioactive Release Due to Tank Failures, are not incorporated into the Turkey Point Gas Decay Tank Explosive Gas and Radioactivity Monitoring Program.

The NRC approved the amendment request by letter dated September 11, 2018 (ADAMS Accession No. ML18214A125).

v t e Letter Sequence Supplement
EPID:L-2021-LLI-0002, TSTF-500, TSTF-425, TSTF-360, TSTF-500, TSTF-505, TSTF-360, TSTF-422, TSTF-500, TSTF-360, TSTF-529, TSTF-372, TSTF-427, TSTF-422, TSTF-554, TSTF-425, TSTF-422 (Open)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance Supplement Administration Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting Questions 7 November 2022 Answers Results Approval Other: ML22229A525
MONTHYEAR2022-05-17 [Table View]

L-2022-010, License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5 -Request for Supplemental Information Response

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