L-2025-102, Notification of Commitment Change for RTD Response Time Testing
| ML25139A459 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/19/2025 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-2025-102 | |
| Download: ML25139A459 (1) | |
Text
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U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE:
Turkey Point Nuclear Plant, Unit 3 Docket No. 50-250 May 19, 2025 Subsequent Renewed Facility Operating License DPR-31 Notification of Commitment Change for RTD Response Time Testing
Reference:
- 1.
Florida Power & Light Company Letter L-90-442 NRC, Turkey Point Units 3 and 4, Docket Nos.
50-250 and 50-251, "Resistance Temperature Detector Bypass Elimination Project," December 13, 1990
- 2.
NRC Letter to Florida Power & Light Company (FPL), "Turkey Point Units 3 and 4 - Issuance of Amendments RE: Removal of RTD Bypass Manifold (TAC Nos. 7763 and 77634," dated April 23, 1991 Florida Power & Light Company (FPL) notified the NRC staff, in Reference 1, that Resistance Temperature Detector (RTD) response time testing would be performed to meet the following criteria:
The on-site response time testing of RTDs will be performed using the Loop Current Step Response method; and The above testing will be performed for the three channels every three refueling cycles on a staggered test basis, with a separate channel being tested during each refueling cycle (18 months).
In Reference 2, the NRC issued License Amendments 140 and 135 to Turkey Point Units 3 and 4, respectively, which provided, in part, for the replacement of the resistance thermal detector (RTD) bypass manifold system with fast-response thermowell-mounted RTDs. The NRC staff stated in the Safety Evaluation that the RTD response time has been addressed in an acceptable manner.
Turkey Point Unit 3 intends to revise the commitment, moving the Loop A response time test to the next Unit 3 refueling outage. The Attachment to this letter provides the commitment change evaluation summary for extending the Loop A response time test and for 24-month fuel cycles.
Should you have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.
This letter contains no new regulatory commitments.
Sincerely, K~~
Director, Licensing and Regulatory Affairs Florida Power & Light Company Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035
cc:
USNRC Regional Administrator, Region II Project Manager, USNRC, Turkey Point Nuclear Plant Resident Inspector, USNRC, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health
Attachment:
Turkey Point Unit 3 Commitment Change Evaluation Summary L-2025-102 Page 2 of 2
ATTACHMENT TURKEY POINT UNIT 3 COMMITMENT CHANGE EVALUATION
SUMMARY
(1 page follows)
TURKEY POINT UNIT 3 COMMITMENT CHANGE EVALUATION
SUMMARY
EXISTING COMMITMENT DESCRIPTION L-2025-102 Attachment Page 1 of 1 "The on-site response time testing of the RTDs will be performed using the loop current step response method.
The above testing will be performed for the three channels once every three refueling cycles on a staggered test basis, with a separate channel being tested during each refueling cycle (18 months)."
This commitment was made in response to an NRC request for additional information during the review process of License Amendments 140 (U3) and 135 (U4). The commitment was not the basis for approval of the corresponding Safety Evaluation.
REVISED COMMITMENT DESCRIPTION "In-situ response time testing of the RTDs will be performed using the loop current step response method.
The above testing will currently remain as is to perform three channels once every three refueling cycles however, future changes to the testing frequency will be controlled by the licensee under the preventative maintenance process."
EVALUATION The Unit 3 Tavg Loop A time response test was initially planned to be performed during the 2024 Unit 3 refueling outage (RFO). The test was not completed because of an early, unplanned manual reactor shutdown. The revised commitment moves the Loop A response time test to the next Unit 3 RFO.
Since the Loop B response time test will also be performed during the next Unit 3 RFO, the three tests will no longer be on a staggered test basis. Additionally, Turkey Point is transitioning to 24-month fuel cycles, and as such, the 18-month frequency noted in the original commitment is revised to 'every three fuel cycles.'
The change does not negatively impact the ability of a system, structure or component to perform its safety function. The original commitment did not restore an obligation, therefore the revised commitment does not introduce a non-conformance with a rule, a regulation, an order or license condition. A review of the last three performances (2020, 2015, 2010) of the Loop A response time test show satisfactory results with no drift identified. Therefore, there is little risk to the extension granted by the revised commitment.