L-2024-105, License Amendment Request 300, Modify Containment Average Air Temperature Requirements

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License Amendment Request 300, Modify Containment Average Air Temperature Requirements
ML24178A265
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 06/26/2024
From: Rasmus P
Point Beach
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2024-105
Download: ML24178A265 (1)


Text

NEXTera ENERGY.

~

BEACH U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE:

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Renewed Facility Operating Licenses DPR-24 and DPR-27 L-2024-105 10 CFR 50.90 June 26, 2024 License Amendment Request 300, Modify Containment Average Air Temperature Requirements Pursuant to 1 O CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby requests amendments to Renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach), respectively. The proposed amendments modify Point Beach Technical Specifications (TS) 3.6.5, Containment Air Temperature, by relocating to licensee control, limits on the containment average air temperature measurement which account for instrument uncertainty, and conforming changes to the TS Bases.

The enclosure to this letter provides NextEra's evaluation of the proposed change. Attachment 1 to the enclosure provides the TS pages marked up to show the proposed change. Attachment 2 provides the TS Bases pages marked up to show the proposed change. The TS Bases changes are provided for information only and will be implemented upon issuance of the requested license amendments in accordance with the Point Beach TS Bases Control Program.

NextEra has determined that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and that there are no significant environmental impacts associated with the change. The Point Beach Onsite Review Group (ORG) has reviewed the enclosed amendment request.

In accordance with 10 CFR 50.91 (b)(1 ), a copy of this license amendment request is being forwarded to the designee for the State of Wisconsin.

NextEra requests approval of the proposed license amendments within one year of satisfactory acceptance, with the license amendments being implemented within 90 days of approval.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Kenneth Mack, Licensing and Regulatory Compliance Senior Manager, at 561-904-3635.

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

Executed on the 25th day of June 2024.

Sincerely,

/(A1~

Paul Rasmus General Manager, Regulatory Affairs NextEra Energy Point Beach, LLC 661 O Nuclear Road, Two Rivers, WI 54241

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 cc:

USNRC Regional Administrator, Region Ill Project Manager, USNRC, Point Beach Nuclear Plant Resident Inspector, USNRC, Point Beach Nuclear Plant Public Service Commission of Wisconsin Attachments (2)

1.

Proposed Technical Specification pages (mark-up)

2.

Proposed Technical Specification Bases pages (mark-up)

L-2024-105 Page 2 of 2

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Point Beach Units 1 and 2 License Amendment Request 300 Modify Containment Average Air Temperature Requirements Evaluation of the Proposed Changes L-2024-105 Enclosure Page 1 of 9

1.0 DESCRIPTION

................................................................................................................................. 2 2.0 DETAILED DESCRIPTION............................................................................................................. 2 2.1 System Design and Operation............................................................................................. 2 2.2 Current Requirements / Description of the Proposed Change............................................ 2 2.3 Reason for the Proposed Change....................................................................................... 3

3.0 TECHNICAL EVALUATION

............................................................................................................ 3

4.0 REGULATORY EVALUATION

....................................................................................................... 6 4.1 Applicable Regulatory Requirements Criteria...................................................................... 6 4.2 No Significant Hazards Consideration................................................................................. 7 4.3 Conclusion........................................................................................................................... 8

5.0 ENVIRONMENTAL CONSIDERATION

.......................................................................................... 8

6.0 REFERENCES

............................................................................................................................... 8, Proposed Technical Specification Changes (mark-up)............................................ 10, Proposed Technical Specification Bases Changes (mark-up)................................. 12

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301

1.0 DESCRIPTION

L-2024-105 Enclosure Page 2 of 9 NextEra Energy Point Beach, LLC (NextEra) requests amendments to Renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach), respectively.

The proposed amendments modify Point Beach Technical Specifications (TS) 3.6.5, Containment Air Temperature, by relocating to licensee control, limits on the containment average air temperature measurement which account for instrument uncertainty, and conforming changes to the TS Bases.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Point Beach Unit 1 and 2 containments are horizontally and vertically pre-stressed, post-tensioned concrete cylinders positioned on reinforced concrete slabs and covered by pre-stressed, post-tensioned shallow concrete domes. Their structural members have sufficient capacity to accept a combination of normal operating loads, functional loads due to a loss of coolant accident (LOCA), and the loadings imposed by the safe shutdown earthquake (SSE) without exceeding specified stress limits. The design pressure and temperature of the containments are in excess of the peak pressure and temperature occurring as the result of the complete blowdown of the reactor coolant through any rupture of the reactor coolant system up to and including the hypothetical severance of a reactor coolant pipe. The pressure and temperature loadings obtained by analyzing various LOCAs, when combined with operating loads and maximum wind or seismic forces, do not exceed the load carrying capacity of the structures.

The containment air temperature monitoring system presently consists of three independent instrument channels which can be monitored from the control room. The maximum allowable containment average air temperature of 120°F represents the initial containment temperature assumed in accident analyses that demonstrate a calculated transient containment air temperature acceptable for withstanding the design basis LOCA. The allowable containment average air temperature expressed in TS 3.6.5 is presented by three temperature limits which are based on the number of available containment air temperature channels.

The three limits ensure that the containment average temperature is maintained below the value assumed in the accident analyses while providing operational flexibility when one or more containment temperature channels are unavailable. Because the number of available channels used to determine the containment average air temperature impacts the magnitude of measurement uncertainty, the TS was revised in Reference 6.1 to establish the three limits based on the availability of the three instrument channels. By adding in the conservative direction, the calculated uncertainty for a given number of available channels to the maximum allowable containment average air temperature limit of 120°F, the containment average air temperature assumed as an initial condition in plant safety analyses is preserved.

2.2 Current Requirements/ Description of the Proposed Change TS 3.6.5 specifies the Limiting Condition for Operation (LCO), required ACTIONS, applicable MODES and surveillance requirements (SRs) for the containment average air temperature. LCO 3.6.5a, b, and c, specify limits for the containment average air temperature based on the available number of instrument channels.

The proposed change modifies LCO 3.6.5 by specifying a single containment average air temperature limit of~ 120°F, by relocating the discussion of uncertainty adjusted temperature requirements to the TS Bases, and by deleting LCO 3.6.5a, LCO 3.6.5b and LCO 3.6.5c, as follows:

LCO 3.6.5 Containment average air temperature shall be;*-~ < 120°F. :

I I

a.
S: 11fi.3°F basefil en #Jr,ee averagefii temf)e1atu.~ ehanneJs,

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301

b.

S: 115.7°F base/ @fl tv.'6 aw3,:agei tempeJCatu~ ehaflfle,.'s, er

e.

S: 112.5°F base/ @fl a siflgle tempe.ratu,.,:e ehaflflel.

2.3 Reason for the Proposed Change L-2024-105 Enclosure Page 3 of 9 The proposed change aligns TS 3.6.5, Containment Air Temperature, with NUREG-1431, Standard Technical Specifications, Westinghouse Plants (Reference 6.2), which presents a single value for the containment average air temperature and relocates to licensee control the procedural details associated with an accounting for instrument uncertainty based on the available number of measurement channels.

3.0 TECHNICAL EVALUATION

In Reference 6. 1, TS 3.6.5 was modified to impose voluntarily limits on the containment average air temperature measurement which account for the magnitude of instrument uncertainty based on the available number of measurement channels. NextEra has since found the added elements of TS 3.6.5 to be overly restrictive and unnecessary for TS inclusion. Specifically, TS 3.6.5 does not allow for additional temperature instruments which serve to provide a more comprehensive representation of the average temperature in containment. In addition, TS 3.6.5 allows for the determination of the containment average air temperature using a single temperature instrument, which is inconsistent with the TS Bases requirement to obtain an arithmetic average using measurements from selected locations providing a representative sample of the overall containment atmosphere.

Finally, the instrumentation limits were added as an enhancement to further assure TS 3.6.5 compliance, but otherwise do not meet the requirements of 10 CFR 50.36(c)(2)(ii) for TS inclusion, as inferred in the Reference 6. 1 technical evaluation. The proposed change remedies these concerns by providing for a single containment average air temperature TS limit, by relocating the current containment temperature instrumentation related requirements to the TS Bases, and by eliminating the authorization to obtain the containment average air temperature using a single temperature instrument. In addition to the conforming TS Bases changes, TS Bases changes are proposed which further emphasize the arithmetic average and instrument uncertainty measurement requirements and which delineate acceptable methodologies for calculating the magnitude for instrument uncertainty.

3. 1 Proposed TS Bases Changes The current TS 3.6.5 limits were determined by applying the calculated instrument uncertainty in the conservative direction to the containment average air temperature assumed in plant safety analyses (120°F) and by rounding in the conservative direction for readability of the containment temperature instrument indicator. As previously described in Reference 6.1, the instrument uncertainty was calculated to combine the random effects that influence instruments such as accuracy, drift, calibration tolerance, and environmental effects such as ambient temperature. The calculations were performed in accordance with Point Beach Design and Installation Guidelines Manual DG-101, "Instrument Setpoint Methodology" (Reference 6.3), which establishes a consistent approach for the analysis of instrument loop uncertainties and their effect on safety-related setpoints and process indications. The determination of loop indication errors is required to provide plant operators with the necessary information to make timely and correct manual actions in response to plant transients and abnormal operating conditions. The methodologies described in DG-101 are based on the industry guidance of American Nuclear Standards Institute (ANSI)

International Society of Automation (ISA) Standard ISA-S67.04-2000, Part I, "Setpoints for Nuclear Safety-Related Instrumentation" (Reference 6.4) and ISA RP67.04, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation," Part II (Reference 6.5). The design guide also reflects regulatory guidance presented to the Nuclear Energy Institute (NEI) setpoint methods task force on September 7, 2005 (Reference 6.6). These accepted industry standards provide the basis for identifying, quantifying and characterizing the error effects that must be considered in the development of an instrument

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2024-105 Enclosure Page 4 of 9 uncertainty setpoint calculation. The methodologies both define and determine how each error type is characterized and combined, e.g., square-root-sum-of-squares (SRSS) method, straight-sum-algebraic (SSA), etc.

The method of combining errors effects, including effects characterized as independen(

dependent, random, or non-random, are described as accepted by the NRC in Reference 6.1.

The calculated channel uncertainty is applied to the TS specified limit and adding the uncertainty in a conservative direction to adjust the analysis value to an indicated value. Additional margin is then applied by rounding in a conservative direction to reflect limitations in instrument readability.

Point Beach application of these methodologies, including the uncertainty calculations and incorporation of the calculation results into acceptance criteria, are available for NRC review upon request.

Point Beach DG-101 further provides for averaging identical indication loops such that the average uncertainty is less than the individual loop uncertainty, as described in NUREG/CR-3659, Mathematical Model for Assessing the Uncertainties of Instrumentation Measurements for Power and Flow of PWR Reactors (Reference 6.7). As summarized in Reference 6.1, a reduction in the average uncertainty can be obtained by dividing the random portion of the individual uncertainty by the square root of the number of available channels to obtain an average such that if all three temperature channels are averaged, the random portion is reduced to 0.995%. When combined with the bias term, the average uncertainty for three channels (rounded up conservatively) is 3.7°F. For two channels, the random portion is 1.219%, which results in an average uncertainty of 4.3°F. For additional temperature channels, the average uncertainty would be calculated similarly.

Accordingly, the proposed change retains in the TS Bases the requirement to account for instrument uncertainty in the containment average air temperature measurement and adds that the instrument uncertainty shall be calculated in accordance with Point Beach DG-101. This change is in addition to the provision for a single temperature instrument measurement being eliminated as described below. The proposed TS Bases change also reinforces the requirement for containment average air temperature measurements to be based on the arithmetic average of the available containment temperature instrument channels by repeating this requirement in the LCO and Surveillance Requirements (SR) sections of the TS Bases. By specifying that the containment average air temperature measurement must be based on the arithmetic average of representative locations within containment and account for measurement uncertainty calculated in accordance with DG-101, these TS Bases changes ensure that the measured containment average air temperature will not exceed the value assumed in plant safety analyses.

3.2 Elimination of Single Containment Average Air Temperature Measurement The proposed change eliminates the current TS 3.6.5.c authorization to determine the containment average air temperature employing a single temperature measurement instrument. Specifically, TS 3.6.5.c currently allows the LCO to be satisfied when the measured containment average air temperature is less than or equal to 112.5°F whenever two of the three presently employed containment temperature measurement channels are unavailable. The TS 3.6.5.c authorization is inconsistent with the TS Bases requirement for the measured containment average air temperature to be determined using the arithmetic average of the available temperature instruments since an average cannot be obtained from a single temperature measurement. Accordingly, the proposed change does not relocate to the TS Bases the current TS 3.6.5.c authorization to satisfy the LCO using a single temperature measurement instrument. The determination of the containment average air temperature shall be based on an arithmetic average of two or more containment temperature instruments from selected representative locations within containment. The proposed change is acceptable since it provides for a measured containment average air temperature more representative of the overall containment atmosphere while continuing to account for instrument measurement uncertainty.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 3.3 1 O CFR 50.36(c)(2)(ii) Evaluation L-2024-105 Enclosure Page 5 of 9 The proposed change replaces the current containment average air temperature requirements with a single containment average air temperature limit of.::: 120°F by relocating the containment average air temperature provisions for temperature measurement instrument uncertainty to the TS Bases and applicable plant procedures whereby future changes will be subject to the provisions of 1 O CFR 50.59 and by eliminating the provision for a single temperature measurement instrument. The proposed change is acceptable since the current containment average air temperature limits are procedural details associated with an accounting for the magnitude of instrument uncertainty and thereby do not meet the four Criterion of 1 O CFR 50.36(c)(2)(ii) for TS inclusion as an LCO. Specifically, the instrument measurement uncertainties are not installed instrumentation used to detect, and indicate in the Control Room, a significant abnormal degradation of the reactor coolant pressure boundary, and thereby do not satisfy Criterion 1. Though the containment average air temperature limit of.::: 120°F does satisfy Criterion 2, the instrument measurement uncertainties are not process variables, design features, or operating restrictions that are an initial condition of a design basis accident or transient analysis that assumes the failure of or presents a challenge to the integrity of a fission product barrier, and thereby do not satisfy Criterion 2. The instrument measurement uncertainties are not SSCs that are part of the primary success path and which function or actuate to mitigate a design basis accident or transient that assumes the failure of or presents a challenge to the integrity of a fission product barrier and thereby do not satisfy Criterion 3. The instrument measurement uncertainties do not include systems, structures and components (SSCs) which operating experience or probabilistic risk assessment have shown to be significant to public health and safety.

Hence, the instrument measurement uncertainties do not meet the 1 O CFR 50.36(c)(2)(ii) criteria for TS inclusion as a LCO and is appropriate for relocation to licensee controlled documents with no adverse impact on safety.

This determination is consistent with the NRC's Final Policy Statement on TS Improvements for Nuclear Power Reactors (Reference 6.8), which states in reference to the 10 CFR 50.36(c)(2)(ii) criteria:

"The purpose of Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval."

The Final Policy Statement further states:

"If a licensee elects to apply these [10 CFR 50.36(c)(2)] criteria, the requirements of the removed specifications will be relocated to the FSAR or other licensee-controlled documents. Licensees are to operate their facilities in conformance with the descriptions of their facilities and procedures in their FSAR. Changes to the facility or to procedures described in the FSAR are to be made in accordance with 10 CFR 50. 59."

The determination that the temperature instrument measurement uncertainties do not meet the four Criterion of 1 O CFR 50.36(c)(2)(ii) for TS inclusion as an LCO is consistent with the Reference 6.1 description of the TS changes as "administrative and an enhancement to the current TS presentation". The proposed change neither changes the containment average air temperature assumed in plant safety analyses nor modifies the manner in which the containment average air temperature limit is measured and maintained with the sole exception that the authorization to employ a single temperature instrument is removed. All other aspects of the containment average air temperature requirements are maintained, including the applicable MODES, ACTIONS and SRs. With the exception of the provision to allow a single measurement instrument, the instrument measurement requirements will be relocated to the TS Bases and applicable plant procedures. As such, the existing defense in depth and diversity described in the TS Bases with regard to the containment average air temperature measurement will not be diminished.

The containment temperature limit of.::: 120°F assumed in plant safety analyses will continue to meet Criterion 2 of 10 CFR 50.36(c)(2)(ii) and proposed revisions to the TS Bases or applicable plant procedures will be subject to the regulatory change provisions of 1 O CFR 50.59. Accordingly, replacement of the current TS

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2024-105 Enclosure Page 6 of 9 3.6.5 requirements for the containment average air temperature with a single containment average air temperature limit of.::: 120°F by relocating the containment average air temperature provisions for measurement instrument uncertainties to the TS Bases and applicable plant procedures and by eliminating the provision for a single temperature measurement instrument is reasonable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements Criteria NextEra has determined that the proposed TS changes do not require any exemptions or relief from regulatory requirements and do not affect conformance with any general design criteria (GDC) differently than described in the Point Beach Final Safety Analysis Report (FSAR).

10 CFR 50.36, Technical Specifications, sets forth in 10 CFR 50,36(c)(2)(ii), four criteria to be used in determining whether a limiting condition of operation (LCO) is required to be included in the licensee TS. These criteria are:

Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

[Note: Point Beach was licensed prior to the general design criteria (GDC) of 1 O CFR 50 Appendix A The Point Beach Final Safety Analysis Report (FSAR) lists plant-specific GDCs to which Point Beach was licensed, which are similar in content to the 1967 proposed GDCs published for public comment.]

Point Beach GDC 1, Reactor Containment, states, in part, that systems and components of reactor facilities which are essential to the prevention, or the mitigation of the consequences, of nuclear accidents which could cause undue risk to the health and safety of the public shall be designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed... Where adherence to such codes or standards does not suffice to assure a quality product in keeping with the safety function, they shall be supplemented or modified as necessary.

Point Beach GDC 10, Reactor Containment, states that the containment structure shall be designed (a) to sustain, without undue risk to the health and safety of the public, the initial effects of gross equipment failures, such as a large reactor coolant pipe break, without loss of required integrity, and (b) together with other engineered safety features as may be necessary, to retain for as long as the situation requires, the functional capability of the containment to the extent necessary to avoid undue risk to the health and safety of the public.

Point Beach GDC 12, Instrumentation and Control Systems, states that instrumentation and controls shall be provided as required to monitor and maintain within prescribed operating ranges essential reactor facility operating variables.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2024-105 Enclosure Page 7 of 9 Regulatory Guide (RG) 1.105, "Setpoints for Safety-Related Instrumentation," Revision 3, December 1999, (ADAMS Accession No. ML993560062), describes a method that the NRC staff considers acceptable for complying with the agency's regulations for ensuring that setpoints for safety-related instrumentation are initially within, and remain within, the TS limits.

The proposed change complies with the requirements of 10 CFR 50.36(c)(2)(ii) and does not alter the manner in which the facility is operated and maintained, consistent with Point Beach GDCs 1, 10 and 12, as applicable. All regulatory requirements will continue to be satisfied as a result of the proposed change.

4.2 No Significant Hazards Consideration NextEra requests amendments to Renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach), respectively. The proposed amendments modify Point Beach Technical Specifications (TS) 3.6.5, Containment Air Temperature, by relocating to licensee control, limits on the containment average air temperature measurement which account for instrument uncertainty and conforming changes to the TS Bases. As required by 1 O CFR 50.91 (a), NextEra evaluated the proposed changes using the criteria in 10 CFR 50.92 and determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

1)

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change relocates to licensee control, procedural details associated with measurement uncertainty of the containment air temperature instrumentation while preserving the Technical Specification requirement to maintain the containment average air temperature below that assumed in plant safety analyses. The proposed change neither alters plant equipment nor the manner in which plant equipment is operated and maintained, and thereby cannot increase the probability of an accident. The proposed change does not affect the type or quantity of radioactive effluent that may be released off-site or increase individual or cumulative occupational exposures resulting from any accident, and thereby cannot increase the consequences a previously evaluated accident.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2)

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change relocates to licensee control, procedural details associated with measurement uncertainty of the containment air temperature. Preserving the existing containment temperature limit while accounting for instrument uncertainty cannot adversely affect plant operation as currently licensed or the capability to respond to design basis accidents consistent with safety analysis assumptions. The proposed change neither installs new equipment nor introduce new equipment failure modes and thereby cannot introduce and thereby cannot create a new or different type of malfunction or accident. The proposed change does not create or revise any safety analysis inputs or projections and thereby cannot create new accident initiators or precursors. The proposed change aligns with applicable regulations and safety analyses.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2024-105 Enclosure Page 8 of 9 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3)

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change relocates to licensee control, the procedural details associated with measurement uncertainty of the containment air temperature instrumentation. The proposed change does not alter the approach to any safety limits, limiting safety system settings, or safety analysis assumptions or inputs, and thereby cannot affect plant operating margins. The proposed change does not modify the design and capability of equipment credited in safety analyses, or introduce new energy sources, and thereby cannot affect the integrity of any radiological barrier.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based upon the above, NextEra concludes that the proposed presents no significant hazards consideration under the standards set forth in 1 O CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

NextEra evaluated the proposed amendments for environmental considerations. The review determined that the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 US NRC letter to NextEra Energy Point Beach, LLC Point Beach Nuclear Plant, Units 1 and 2 -

Issuance of Amendment to Revise Technical Specification Operating Limits to Include Measurement Uncertainty (TAC Nos. ME5906 and ME5907), January 30, 2012 (ADAMS Accession No. ML113540147) 6.2 NUREG 1431, Revision 5, Improved Standard Technical Specifications, Westinghouse Plants (ADAMS Accession No. ML21259A155).

6.3 Point Beach Design Guideline DG-101, Instrument Setpoint Methodology, Revision 8.

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 L-2024-105 Enclosure Page 9 of 9 6.4 American Nuclear Standards Institute (ANSI)/ International Society of Automation (ISA) Standard -

67.04.01-2000, "Setpoints for Nuclear Safety-Related Instrumentation." Reaffirmed February 29, 2000.

6.5 International Society of Automation (ISA) Recommended Practice ISA-RP67.04-1994, Part II, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation".

6.6 US NRC letter to Nuclear Energy Institute, dated September 7, 2005, Technical Specification for Addressing Issues Related to Setpoint Allowable Values (ADAMS Accession No. ML052500004) 6.7 NUREG/CR-3659, Feb

1985, "Mathematical Model for Assessing the Uncertainties of Instrumentation Measurements for Power and Flow of PWR (Pressurized Water Reactors) Reactors,"

Battelle Pacific Northwest Labs., Richland, WA 6.8 NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132)

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 ATTACHMENT 1 Point Beach Technical Specifications Page Markups (1 page follows)

L-2024-105 Enclosure

Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature

~ 120°F.

LCO 3.6.5 Containment average air temperature shall b Y

a.

.s 116.3°F based on three a*,eraged temperature ehannels,

b.

E 115. 7°F based oA two averaged ter:nperaturo channels, or

c.

6 112.5°r based on a single temperature chaAnel.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A.

Containment average air A.1 Restore containment temperature not within average air temperature limit.

to within limit.

B.

Required Action and 8.1 Be in MODE 3.

associated Completion Time not met.

AND 8.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.6.5.1 Verify containment average air temperature is within limit.

COMPLETION TIME 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 6 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> FREQUENCY In accordance with the Surveillance Frequency Control Program I Point Beach 3.6.5-1 Unit 1 - Amendment No. ~

Unit 2 - Amendment No. ~

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 ATTACHMENT 2 Point Beach Technical Specifications Bases Page Markups (3 pages follow)

L-2024-105 Enclosure

BASES APPLICABLE SAFETY ANALYSES

( continued)

LCO Containment Air Temperature B 3.6.5 and Containment Cooling System being rendered inoperable. The postulated OBA SLB was similarly analyzed, except that both trains of the Containment Spray System and the Containment Cooling System are assumed operable. This is acceptable since the OBA SLB analysis assumed a single failure of the feedwater isolation valve as the worst case single failure for the containment integrity analysis.

The limiting OBA for the maximum peak containment air temperature is a SLB. The initial containment average air temperature assumed in the design basis analyses (Ref. 1) is 120°F. This resulted in a maximum containment air temperature of 284.4°F. The design temperature of the containment structure is 286°F.

The temperature limit is used to establish the environmental qualification operating envelope for containment. The basis of the containment design temperature is to ensure the performance of safety related equipment inside containment (Ref. 2). It is concluded that the calculated transient containment air temperature is acceptable for the OBA LOCA.

The initial containment air temperature also has an impact on the containment pressure transient. This is primarily due to the OBA assumption that all the containment structures are initially at the same temperature as the containment air. The limiting OBA for establishing the maximum peak containment internal pressure is a SLB. The temperature limit is used in this analysis to ensure that in the event of an accident the maximum containment internal pressure will not be exceeded.

Containment average air temperature satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

During a OBA, with an initial containment average air temperature less than or equal to the LCO temperature limit, the resultant peak accident


temperature is maintained below the containment design temperature.

  • *
  • measurement is based As a result, the ability of containment to perform its design function is on an arithmetic average ensured.

of representative locations 1---------------.

within containment and accounts for...

an arithmetic average of representative indicated containment temperatures is ~ 120°F, to include the impact of instrument uncertainty. The instrument uncertainty is calculated in accordance with Point Beach DG 101, Instrument Setpoint Methodology (Refs. 3 and 4)

Point Beach B 3.6.5-2 Unit 1 - Amendment No. ~ 6 I Unit 2 - Amendment No. 2~

BASES APPLICABILITY ACTIONS SURVEILLANCE REQUIREMENTS

... measurement is based on an arithmetic average of representative locations within containment and Containment Air Temperature B 3.6.5 In MODES 1, 2, 3, and 4, a OBA could cause a release of radioactive material to containment. In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations of these MODES. Therefore, maintaining containment average air temperature within the limit is not required in MODE 5 or 6.

When containment average air temperature is not within the limit of the LCO, it must be restored to within limit within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This Required Action is necessary to return operation to within the bounds of the containment analysis. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is acceptable considering the sensitivity of the analysis to variations in this parameter and provides sufficient time to correct minor problems.

B.1 and 8.2 If the containment average air temperature cannot be restored to within its limit within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.6.5.1 Verifying that containment average air temperature is within the LCO limits ensures that containment operation remains within the limit assumed for the containment analyses. In order to determine the containment average air temperature, an arithmetic average is calculated using measurements taken at locations within the containment selected to provide a representative sample of the overall containment atmosphere. The containment average air temperature liffiits inolude instrument uncertainty. The Surveillance Requirement is met when*

0 accounts for...

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

... an arithmetic average of representative indicated containment temperatures is~ 120°F, to include the impact of instrument uncertainty. The instrument uncertainty is calculated in accordance with Point Beach DG 101, Instrument Setpoint Methodology (Refs. 3 and 4)

Point Beach B 3.6.5-3 Unit 1 - Amendment No. ~ 53 Unit 2 - Amendment No. 25:(

BASES REFERENCES Point Beach

1. FSAR, Section 14.
2. 10 CFR 50.49.

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Containment Air Temperature B 3.6.5

\\_ 3. Point Beach Calculation (Doc) No: 2006-0035, Parametric Values

4. Point Beach DG 101, Instrument Setpoint Methodology B 3.6.5-4