Text

Proposed License Amendments Accident Monitoring Instrumentation Technical Specification 3.3.3.3
	ML041250367
Person / Time
Site:	Turkey Point
Issue date:	04/23/2004
From:	Jones T; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML041250367 (27)
	v • d • e

A:.

APR 2 3 2004 FPL L-2004-067 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Accident Monitoring Instrumentation Technical Specification 3.3.3.3 Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) requests to amend Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4. The proposed amendments revise several of the allowed outage times of Technical Specification (TS) 3.3.3.3 Accident Monitoring Instrumentation, to be consistent with the Completion Times in Specification 3.3.3 of NUREG-143 1, Revision 2, "Standard Technical Specifications Westinghouse Plants (the Improved Standard Technical Specifications, or ISTS)."

Enclosure I provides the proposed License Amendments description and justification. Enclosure 2 is the No Significant Hazards Considerations and Enclosure 3 provides the Environmental Consideration. Enclosure 4 provides the marked-up copies of the proposed Technical Specification changes and an information copy of the proposed changes to the TS Bases. Enclosure 5 is a copy of the retyped TS and TS Bases pages. FPL has determined that the proposed License Amendments do not involve a significant hazards consideration pursuant to 10 CFR 50.92.

Approval of the requested license amendments will allow Turkey Point to optimize the on-line installation of an upgrade to the Qualified Safety Parameter Display System (QSPDS). This approval will also provide FPL adequate allowed outage times to implement on-line repairs to accident monitoring instrumentation, if required. The proposed allowed outage times for the subject instrumentation are consistent with the Improved Standard Technical Specifications (NUREG-1431, Revision 2).

The proposed license amendments are similar in nature to other NRC approved industry license amendments associated with accident monitoring instrumentation allowed outage times, in particular the Vermont Yankee plant License Amendment No. 207, approved May 10, 2002.

an FPL Group company

L-2004-067 Page 2 of 4 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Accident Monitoring Instrumentation Technical Specification 3.3.3.3 The Turkey Point Plant Nuclear Safety Committee and the Florida Power & Light CompanyNuclear Review Board have reviewed the proposed amendments. In accordance with 10 CFR 50.91 (b)(1), a copy of the proposed amendments are being forwarded to the State Designee for the State of Florida.

FPL requests that the proposed License Amendments be approved by December 30, 2004. Please issue the amendments to be effective on the date of issuance and to be implemented within 60 days of receipt by FPL.

Please contact Mr. Walter J. Parker, Licensing Manager, at 305-246-6632 if there are any questions about this submittal.

Very truly yours, Terry 0. Jones Vice President Turkey Point Nuclear Plant Enclosures cc:

Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Department of Health Bureau of Radiation Control

L-2004-067 Page 3 of 4 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Accident Monitoring Instrumentation Technical Specification 3.3.3.3 STATE OF FLORIDA

)

ss.

COUNTY OF MIAMI-DADE

)

Terry 0. Jones being first duly sworn, deposes and says:

That he is Vice President, Turkey Point Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

[T NV0.

JONES]

Sworn to and subscribed before me this

-3 day of 4veL.

, 2004

, WOMMISSION # C926970

~~

EXPIRES: Juzie 18,2004 i_

Bonrdd Thru Notay Pubic Undewthrs Name of Nftary Public (Type or-Print)

Terry 0. Jones is personally known to me.

L-2004-067 Page 4 of 4 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Accident Monitoring Instrumentation Technical Specification 3.3.3.3

ENCLOSURE I

ENCLOSURE 2

ENCLOSURE 3 ENCLOSURE 4

ENCLOSURE 5 TABLE OF CONTENTS Enclosures Proposed License Amendments Description and Justification No Significant Hazards Considerations Environmental Consideration Proposed Mark-Up of Affected Technical Specifications and Bases Pages Retyped Technical Specification Pages and Bases Pages (for information only)

Enclosure I to L-2004-067 Page 1 of 6 ENCLOSURE ]

PROPOSED LICENSE AMENDMENTS DESCRIPTION AND JUSTIFICATION

Enclosure ] to L-2004-067 Page 2 of 6 Introduction The proposed changes revise several of the allowed outage times of Unit 3 and Unit 4 Technical Specification (TS) 3.3.3.3 Accident Monitoring Instrumentation, to be similar to the Completion Times in TS 3.3.3 ofNUREG-1431, Revision 2, "Standard Technical Specifications Westinghouse Plants" (the Improved Standard Technical Specifications, or ISTS).

Background

The allowed outage times in the current Turkey Point Unit 3 and Unit 4 Technical Specification 3.3.3.3, Accident Monitoring Instrumentation, are similar to those in NUREG-0452, "Westinghouse Standard Technical Specifications."

NUREG-0452 allows 7 days to restore an inoperable accident monitoring instrument channel to operable status. If the instrument channel cannot be restored to operable status within the time allowed, the plant is required to shut down. If no instrument channels are available to monitor a particular parameter, 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to restore the inoperable channel(s) to operable status. If the channel(s) cannot be restored to operable status within the time allowed, the plant is required to shut down.

During the development of the ISTS, it was determined that the 7 day and 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Times were overly restrictive. NUREG-1431 Revision 2 extended the Completion Time for one instrument channel inoperable from 7 days to 30 days. If the instrument channel is not restored to operable status at the end of the 30 day Completion Time, a Special Report must be submitted to the NRC within the next 14 days. This Special Report discusses the cause of the inoperability, the preplanned alternate method of monitoring, and identifies proposed actions to restore the inoperable channel.

Additionally, NUREG-1431, Revision 2, also extended the Completion Time for restoring an inoperable instrument channel to operable status from 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to 7 days, when all instrument channels monitoring a required parameter are inoperable. If one of the instrument channels is not restored to operable status at the end of the 7 day Completion Time, a plant shutdown is required unless there is a preplanned alternative means to monitor the parameter. In that case, a Special Report is required to be submitted to the NRC in lieu of a plant shutdown.

NUREG-1431, Revision 2 also contains a clarifying Action Note that states that separate Condition entry is allowed for each Function.

Description of the Proposed Changes The proposed changes to the Unit 3 and Unit 4 Technical Specification 3.3.3.3 make several of the accident monitoring instrumentation allowed outage times similar to the Completion Time guidance in NUREG-1431, Revision 2, TS 3.3.3. The proposed changes are as follows:

0

Enclosure I to L-2004-067 Page 3 of 6

A new Action c is being added to Specification 3.3.3.3 which states that separate Action entry is allowed for each Instrument.

Table 3.3-5, Action 31, which applies when the number of operable channels is less than the total number of channels, requires the inoperable channel(s) to be restored to operable status within 7 days. This requirement is being revised to require the inoperable channel(s) to be restored within 30 days.

Table 3.3-5, Action 31, also requires the plant 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 at least Hot Shutdown within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the channel(s) are not restored to operable status within the allowed outage time. This requirement is being revised to require a Special Report be submitted to the NRC pursuant to Specification 6.9.2 within the next 14 days after the allowed outage time. The proposed Special Report content is specified consistent with the content required by the Unit 3 and Unit 4 TS Actions 34, 37, and 38.

Table 3.3-5, Action 32, which applies when the number of operable channels is less than the minimum number of channels, requires the inoperable channel(s) to be restored to operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This requirement is being revised to allow 7 days to restore the inoperable channel to operable status.

Table 3.3-5, Action 34, which applies when the number of operable channels is less than the minimum number of channels, requires initiation of a preplanned alternate method of monitoring within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and either restore the inoperable channel(s) to operable status within 7 days, or submit a Special Report within 14 days following the event. The Special Report requirement is being revised to require submission of a Special Report to the NRC within the next 14 days after the allowed outage time.

Table 3.3-5, Action 37, which applies when the number of operable channels is one less than the total number of channels, requires the system to be restored to operable status within 7 days. This requirement is being revised to require the system to be restored to operable status within 30 days.

Table 3.3-5, Action 37, also requires that a Special Report be submitted to the NRC within 30 days following the event if the system has not been restored to operable status within 7 days, and if repairs are not feasible without shutting down. This requirement is being revised to require a Special Report be submitted to the NRC within the next 14 days after the allowed outage time.

Table 3.3-5, Action 38, which applies when the number of operable channels is less than the minimum number of channels, requires the inoperable channel(s) to be restored to operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This requirement is being revised to require the inoperable channel(s) to be restored to operable status within 7 days.

Enclosure I to L-2004-067 Page 4 of 6

Table 3.3-5, Action 38 also requires that if the inoperable channel(s) cannot be restored to operable status within 48,hours, and if repairs are not feasible without shutting down, an alternate method of monitoring the reactor vessel inventory shall be initiated, a Special Report shall be submitted to the NRC within 30 days following the event. The Special Report requirement is being revised to require submission of a Special Report to the NRC within the next 14 days after the allowed outage time.

Table 3.3-5, Action 39, w'hich applies when the number of operable channels is less than the minimum number of channels, requires verification of the containment isolation valve position indication by alternate means within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and restoration of the inoperable channel(s) to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72-hour requirement is being revised to allow 7 days to restore the inoperable channel(s) to operable status.

Justification Per the Turkey Point Units 3 & 4 Technical Specification Bases, the operability of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, Revision 3, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," May 1983 and NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980.

The accident monitoring instrumentation requirements in the Turkey Point Unit 3 and Unit 4 Technical Specifications are similar to the requirements in NUREG-1431, Revision 2, Specification 3.3.3, "Post Accident Monitoring (PAM) Instrumentation" as delineated below:

The ISTS and Turkey Point TS Limiting Conditions for Operation (LCOs) require the instruments to be operable.

The ISTS Applicability is Modes 1, 2, and 3 for all instruments. The Turkey Point TS Applicability is Modes 1,2, and 3 except for the plant vent exhaust and the Unit 3 spent fuel pit exhaust, which are applicable in all Modes. This is the appropriate Applicability for these instruments.

The ISTS provide an exception to LCO 3.0.4. The Turkey Point TS provide an exception to the equivalent TS 3.0.4.

The ISTS and Turkey Point TS require a Channel Check of each channel at least once per 31 days and a Channel Calibration of each channel at least once per 18 months.

The current Unit 3 and Unit 4 TS 3.3.3.3 Actions are being modified to explicitly allow separate Action entry for each Instrument. This Action is provided for clarification, and is consistent with the application of the current TS. This Action has the same intent as the NUREG-1431, Revision 2 Action Note which states, "Separate Condition entry is allowed for each Function."

Enclosure I to L-2004-067 Page S of 6 The current Unit 3 and Unit 4 TS Actions 31 and 37 allow 7 days to restore the inoperable channel(s) or system to operable status when the number of operable channels is less than the required total number of channels. The proposed changes allow 30 days to restore the inoperable channel(s) or system to operable status. The 30 day allowed outage time is appropriate based on operating experience and takes into account the remaining operable channel, the passive nature of the instruments (no critical automatic action is assumed to occur from these instruments), and the low probability of an event requiring the accident monitoring instrumentation during this interval.

The current Unit 3 and Unit 4 TS Action 31 requires a plant shutdown if an inoperable channel is not restored to operable status within the allowed outage time. This Action is required if the number of operable channels is less than the required total number of channels, and the allowed outage time for restoring the inoperable channel(s) to operable status has been exceeded. The proposed change requires submission of a Special Report to the NRC within the next 14 days after the allowed outage time. A Special Report in lieu of a shutdown is appropriate because the instrument functional capability has not been lost, and given the likelihood of unit conditions that would require information provided by this instrumentation. The proposed Special Report content is specified consistent with the content required by the Unit 3 and Unit 4 TS Actions 34, 37, and 38.

The current Unit 3 and Unit 4 TS Actions 32 and 38 allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore the inoperable channel(s) to operable status when the number of operable channels is less than the required minimum number of channels. Action 39 allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore an inoperable containment isolation valve position indication channel to operable status. The proposed changes allow 7 days to restore the inoperable channel(s) to operable status. The additional time to restore the inoperable channel(s) to operable status is appropriate based on providing a reasonable time for repair; the low probability of an event requiring accident monitoring instrumentation operation during the restoration interval; and other means for some channels which may be available to obtain the required information.

The current Unit 3 and Unit 4 TS Action 37 requires a Special Report to be submitted to the NRC within 30 days following the event. This action is required if the number of operable channels is one less than the total number of channels, the allowed outage time for restoring the system to operable status has been exceeded, and it has been determined that repairs are not feasible without shutting down. The proposed change requires submission of a Special Report to the NRC within the next 14 days after the allowed outage time. Changing the submittal time for the report is consistent with the NUREG-1 431, Revision 2 Specification 5.6.7, which requires a Post Accident Monitoring Report to be submitted within 14 days if the Required Actions and Associated Completion Time of the restoration actions are not met. A Special Report in lieu of a shutdown is appropriate because the instrument functional capability has not been lost, and given the likelihood of unit conditions that would require the information provided by this accident monitoring instrumentation.

The current Unit 3 and Unit 4 TS Action 38 requires a Special Report to be submitted to the NRC within 30 days following the event. TS Action 34 specifies 14 days following the event. These Actions are required if the number of operable channels is less than the required minimum number of channels, and the allowed outage time for restoring the inoperable channel(s) to operable status has been exceeded. The proposed changes revise these Actions to require a Special Report to be

Enclosure I to L-2004-067 Page 6 of 6 submitted within the next 14 days after the allowed outage time. This is consistent with the actions in NUREG-1 43 1, Revision 2 Specification 5.6.7, which requires a Post Accident Monitoring Report to be submitted within the next.] 4 days if the Required Actions and Associated Completion Time of the restoration actions are not met. The 14 day submittal time is appropriate because the alternate monitoring method ensures that the monitoring function continues to be pcrformed by other instruments. The TS Actions 34 and 38 provide for alternate methods of monitoring containment area radiation, noble gas effluent, and reactor vessel level. If these alternate methods are used, the Action is not to shut down the unit, but rather to prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 outlining the action taken, the cause ofthe inoperability, and the plans and schedule for restoring the system to operable status.

to L-2004-067 Page 1 of3 I

ENCLOSURE 2 NO SIGNIFICANT HAZARDS CONSIDERATIONS to L-2004-067 Page 2 of 3 Introduction The proposed changes revise several of the allowed outage times of Unit 3 and Unit 4 Technical Specification (TS) 3.3.3.3 Accident Monit6ring Instrumentation, to be similar to the Completion Times in TS 3.3.3 ofNUREG-l1431,Revision 2, "Standard Technical Specifications Westinghouse Plants" (the Improved Standard Technical Specifications, or ISTS).

Determination of No Significant Hazards Consideration The standards used to arrive at a determination that a request for amendment involves a no significant hazards consideration are included in the Commission's regulation, 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. A discussion of the standards as they relate to this request for the License Amendments follows:

(1)

Operation of the facility in accordance 'with the proposed amendment wvould not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes revise the Actions and allowed outage times of the accident monitoring instrumentation. The accident monitoring instrumentation is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased by these proposed changes.

The Technical Specifications continue to require the accident monitoring instrumentation to be operable.

Therefore, the accident monitoring instrumentation will continue to provide sufficient information on selected plant parameters to monitor and assess these variables following an accident. The consequences of an accident during the extended allowed outage time are the same as the consequences during the current allowed outage time.

As a result, the consequences of any accident previously evaluated are not significantly increased by these proposed changes. Therefore, the proposed amendments do not involve a significant increase in the probability or consequences of any accident previously evaluated.

(2)

Operation of the facility in accordance %vith the proposed amendments would not create the possibility of a new or different kind of accident from any previously evaluated.

The proposed changes do not alter the design, physical configuration, or mode of operation of the plant. The accident monitoring instrumentation is not an initiator of any accident previously evaluated. No changes are being made to the plant that would introduce any new accident causal mechanisms. The proposed changes do not affect any other plant equipment.

Therefore, operation of the facility in accordance with the proposed amendments does not create the possibility of a new or different kind of accident from any previously evaluated.

to L-2004-067 Page 3 of 3 (3)

Operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.

The proposed changes do not change the operation, function, or modes of the plant or equipment operation. The proposed changes do not change the level of assurance that the accident monitoring instrumentation will be available -o perform its function. The proposed changes provide a more appropriate time to restore the inoperable channel(s) to operable status, and only apply when one or more channels of a required instrument are inoperable.

The additional time to restore an inoperable channel to operable status is appropriate based on the low probability of an event requiring an accident monitoring instrument during the

,interval, providing a reasonable time for repair, and other means which may be available to obtain the required information. Therefore, operation of the facility in accordance with the proposed amendments would not involve A significant reduction in the margin of safety.

Based on the above, FPL has determined that the proposed amendments do not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.

to L-2004-067 Page l of2 ENCLOSURE 3 ENVIRONMENTAL CONSIDERATION to L-2004-067 Page 2 of 2 Environmental Consideration The proposed license amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The proposed amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released off-site, and no significant increase in individual or cumulative occupational radiation exposure. FPL has concluded that the proposed amendments involve no significant hazards consideration, and therefore, meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Hence, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendments.

to L-2004-067 Page I of 7 ENCLOSURE 4 PROPOSED MARK-UP OF AFFECTED TECHNICAL SPECIFICATIONS AND BASES PAGES Affected Technical Specification Pages 3/4 3-41 3/4 3-44 3/4 3-45 Affected Bases Page (for information only) 48 to L-2004-067 Page 2 of 7 INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.3 The accident monitoring instrumentation channels shown in Table 3.3-5 shall be OPERABLE.

APPLICABILITY:

As shown In Table 3.3-5.

ACTION:

a.

As shown In Table 3.3-5.

b.

The provisions of Spedcfication 3.0.4 are not applicable to ACTIONS in Table 3.3-5 that require a shutdown.

C.

5epeta:ec Ac-+4; er4g is 4Ilot.*J jO, eaJ Inm ey, SURVFIL LANCE REOUIREMENTS 4.3.3.3 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION at the frequencies shown in Table 4.3-4.

TURKEY POINT - UNITS 3 8 4 314 3-41 AMENDMENT NOS. 137 AND 132 to L-2004-067 Page 3 of 7 TABLE 3.3-5 (Continued)

ACTION STATEMENTS ACTION 31 With the number et OPERABLE accident monitoring Instrumentation channel(s) less than the Total Number of Chan either rest re the Ino rable cha I) to OPERABLE status With days n

6 hot a

uDOWNp ACTION 32 W~h the number of OPERABLE accident monitoring instrumentation channels less than the Mini Channels OPERABLE either restore the Inoperable channel(s) to OPERABLE status i

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 at least HOT

-~'HTSHTDW0N within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 33 Close the associated block valve and open Its circuit brdaker.

ACTION 34 With the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirements, initiate the preplanned alternate method ct monitoring the appropriate parameter(s), within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and:

1)

Either restore the inoperable channel(s) to OPERABLE status within 7 days of the event, or

_ 2)

Prepare and su It a Spcial Re rt to the Commission pursuant to Specification 6.9.2 (fol o4 daysi u

outlining the action taken, the cause of the noperabilityand the ans a schedule for restoring the system to OPERABLE status.

ACTION 35 DELETED ACTION 36 With the number of OPERABLE accident monitoring Instrumentation channels less than the Minimum Channel OPERABLE, either restore the inoperable channel to OPERABLE status within 30 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 at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 37 Wth the number c OPERABLE channel less than theTotal Number of Channels restore the system to OPERABLE status within days. I repairs are not feasible without shutting down.

prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within

-o daysfollfno hih-entbutlining the action taken, the cause of the inoperability and the plans )

and schedule for restoring the system to OPERABLE status.

TURKEY POINT - UNITS 3 & 4 3/4 3-44 AMENDMENT NOS. 217 AND 211 to L-2004-067 Page 4 of 7 INSERT I to TS 3/4.3.3.3.3 or submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 14 days outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.

to L-2004-067 Page 5 of 7 TABLE 3.3-5 (Continuedl ACTION STATEMENTS ACTION 35 With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirements, restore the inoperable channel(s) to OPERABLE status within If repairs are not feasible without shutting down:

1.

Initiate an alternate method of monitoring the reactor vessel inventory and g4 e n Y@

t.

Peob e land smi a SWecial Re ort to the Commission pursuant to Specification 6.9.2

ii% daysfo ute-evenuoutlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status; and

3.

Restore at least one channel to OPERABLE status at the next scheduled refueling.

ACTION 39 With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirement, verity position by an alternate means (e.g. administrative controls, ERDADS.

alternate position Indication, or visual observation) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and restore the Inoperable channel(s) within or comply with the provisions of Specification 3.6.4 for an Inoperable containment isolation va TURKEY POINT - UNITS 3 & 4 3/4 3-45 AMENDMENT NOS. 137 AND 132 to L-2004-067 Page 6 of 7 (FOR INFORMATION ONLY)

Procdurc No-,

Procedure rkiPc:

rst 48 0-ADM-536 Technical Speciflcation Bases Control rogram 511103 ATTACHMENT I (Page 38 of 102)

TECHNICAL SPECIFICATION BASES 314.3 INSTRUMENTATION (Continued) 3/4.3.3.3 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring. instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, Revision 3, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," May 1983 and NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980.

TS Table 3.3-5, Accident Monitoring Instrumientation, instrument item 3, Reactor Coolant Outlet Temperature, T-hot and instrument item 4 Reactor Coolant Inlet Temperature, T-cold, utilize the terms

'detector" and "channel". The term channel ( in the context of the specification) refers to one of the two channels of QSPDS. Each channel has three detectors as inputs, one from each loop. For example, Resistance Temperature Detectors TE-3-413A, TE-3-423A, and TE-3-433A are the three detectors which feed QSPDS Channel A for Unit 3. The TOTAL NUMBER OF CHANNELS is two (with two of the three detectors required). The MINIMUM CHANNELS OPERABLE is one (with two of the three detectors.)

To call a channel operable, it must have at least two of its three detectors operable.

Although the minimum channels operable is one (of two), having hannel inoperable ijof Action Statement 31 (restore in pdays or

)

=

n c t

The QSPDS is configured into two channels, but it is often referred to as having two 'trains". In general, the term "train" applies only to Reactor Protection System (RPS) / Engineering Safety Feature Actuation System (ESFAS) actuation signals, i.e., there are two trains of reactor protection; each train will trip one reactor trip breaker.

"Train" is not appropriate to QSPDS, since QSPDS serves no automatic protection function.

Technical Specification Table 3.3-5, Item 14,Incore Thermocouples (Core Exit Thermocouples), utilizes the term channel. There are no "channels" of Incore Thermocouples as stated previously, the term Channel refers to one of the two QSPDS channels. NUREG 0737, Section lI.F.2, Attachment I, Item (3) describes what is required from instrumentation standpoint: 'A...display...should be provided with the capability for selective reading of a minimum of 16 operable thermocouples, 4 from each core quadrant..'."

This description is the basis for our Technical Specification, and clarifies the requirement for Incore Thermocouples. If we have fewer than 4 thermocouples per core quadrant, Action 31 applies. If we have fewer than 2 thermocouples per quadrant, Action 32 applies. There is no regulatory requirement that these 2 or 4 thermocouples per core quadrant be assigned to or divided between the two channels of QSPDS.

The column heading "TOTAL NO. OF CHANNELS," is also misleading for the Incore Thermocouples.

There are more than 4 thermocouples in every core quadrant It takes 4 thermocouples per core quadrant to satisfy the Technical Specifications and unrestricted operation with fewer than the "TOTAL" but at least e "MINIMUM" is not allowed. For example, if there are only 3 om ble thermocouples in a guadrant, in ysone must be fixed ors v

peo4I t

)IeA is W97-DFS/rns/teYve to L-2004-067 Page 7 of 7 (FOR INFORMATION ONLY)

INSERT 2 to TS Bases 3/4.3.3.3.3. ACCIDENT MONITORING INSTRUMENTATION Action c states that separate Action entry is allowed for each Instrument. This Action has been added for clarification. The Actions of this Specification may be entered independently for each Instrument listed on Table 3.3-5. Allowable outage time(s) of the inoperable channel(s) of an Instrument will be tracked separately for each Instrument starting from the time the Action was entered for that Instrument.

to L-2004-067 Page 1 of5 ENCLOSURE 5 I

RE-TYPED TECHNICAL SPECIFICATION PAGES and BASES PAGE (for information only) to L-2004-067 Page 2 of 5 INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.3 The accident monitoring Instrumentation channels shown in Table 3.3-5 shall be OPERABLE.

APPLICABILITY:

As shown in Table 3.3-5.

ACTION:

a.

As shown in Table 3.3-5.

b.

The provisions of Specification 3.0.4 are not applicable to ACTIONS In Table 3.3-5 that require a shutdown.

c.

Separate Action entry Is allowed for each Instrument.

UllRVEILLACE RFQUJ1REMENTS 4.3.3.3 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION at the frequencies shown in Table 4.3-4.

TURKEY POINT - UNITS 3 & 4 314 341 AMENDMENT NOS.

AND to L-2004-067 Page 3 of 5 TABLE 3.3-5 (Continued)

ACTION STATEMENTS ACTION 31 With the number of OPERABLE accident monitoring Instrumentation channel(s) less than the Total Number of Channels either restore the inoperable channel(s) to OPERABLE status within 30 days. or submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 14 days outlining the action taken, the cause of the Inoperability. and the plans and schedule for restoring the system to OPERABLE status.

ACTION 32 With the number of OPERABLE accident monitoring Instrumentation channels less than the Minimum Channels OPERABLE, either restore the inoperable channel(s) 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 at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 33 Close the associated block valve and open Its circuit breaker.

ACTION 34 With the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirements, Initiate the preplanned alternate method of monitoring the appropriate parameter(s), within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and:

1)

Either restore the Inoperable channel(s) to OPERABLE status within 7 days of the event, or

2)

Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 14 days outlining the action taken, the cause of the inoperability. and the plans and schedule for restoring the system to OPERABLE status.

ACTION 35 DELETED ACTION 36 With the number of OPERABLE accident monitoring instrumentation channels less than the Minimum Channel OPERABLE, either restore the inoperable channel to OPERABLE status within 30 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 at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION 37 With the number of OPERABLE channels one less than the Total Number of Channels, restore the system to OPERABLE status within 30 days. If repairs are not feasible without shutting down, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next 14 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

TURKEY POINT - UNITS 3 & 4 3/4 3-44 AMENDMENT NOS.

AND to L-2004-067 Page 4 of 5 TABLE 3.3-5 (Continued)

ACTION STATEMENTS ACTION 38 With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirements. restdre the Inoperable channel(s) to OPERABLE status within 7 days. If repairs are not feasible without shutting down:

1.

Initiate an alternate method of monitoring the reactor vessel inventory; and

2.

Prepare and submit a Special Report to the Commission pursuant to SpecIfication 6.9.2 within the next 14 days outlining the action taken. the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status; and

3.

Restore at least one channel to OPERABLE status at the next scheduled refueling.

ACTION 39 With the nurnber of OPERABLE channels less than the Minimum Channels OPERABLE requirement, verify position by an alternate means (e.g. administrative controls. ERDADS.

alternate position indication, or visual observation) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and restore the Inoperable channel(s) within 7 days. or comply with the provisions of Specification 3.6.4 for an Inoperable containment isolation valve.

TURKEY POINT-UNITS 3 & 4 3/4 3-45 AMENDMENT NOS.

AND to L-2004-067 Page 5 of 5 FOR INFORMATION ONLY Procedure No.:

d Titk:Page:

48 0-ADNI-536 Tcchnical Specification Bases Control Program XXXXX ATTACHIMENT I (Page 38 of 102)

TECHNICAL SPECIFICATION BASES 3/4.3 INSTRUMENTATION (Continued) 3/4.3.3.3 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these yariables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, Revision 3, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," May 1983 and NUREG-0737, "Clarification of TMI Action Plan Requirements," November 1980.

Action c states that separate Action entry is allowed for each Instrument. This Action has been added for clarification. The Actions of this Specification may be entered independently for each Instrument listed on Table 3.3-5. Allowable outage time(s) of the inoperable channel(s) of an Instrument will be tracked separately for each Instrument starting from the time the Action was entered for that Instrument.

TS Table 3.3-5, Accident Monitoring Instrumentation, instrument item 3, Reactor Coolant Outlet Temperature, T-hot and instrument item 4 Reactor Coolant Inlet Temperature, T-cold, utilize the terms "detector" and "channel". The term channel ( in the context of the specification) refers to one of the two channels of QSPDS. Each channel has three detectors as inputs, one from each loop. For example, Resistance Temperature Detectors TE-3-413A, TE-3-423A, and TE-3433A are the three detectors which feed QSPDS Channel A for Unit 3. The TOTAL NUMBER OF CHANNELS is two (with two of the three detectors required). The MINIMUM CHANNELS OPERABLE is one (with two of the three detectors.)

To call a channel operable, it must have at least two of its three detectors operable.

Although the minimum channels operable is one (of two), having one channel inoperable invokes Action Statement 31 (restore in 30 days or submit a Special Report in the next 14 days).

The QSPDS is configured into two channels, but it is often referred to as having two "trains". In general, the term "train" applies only to Reactor Protection System (RPS) / Engineering Safety Feature Actuation System (ESFAS) actuation signals, i.e., there are two trains of reactor protection; each train will trip one reactor trip breaker.

"Train" is not appropriate to QSPDS, since QSPDS serves no automatic protection function.

Technical Specification Table 3.3-5, Item 14, Incore Thermocouples (Core Exit Thermocouples), utilizes the term channel. There are no "channels" of Incore Thermocouples as stated previously, the term Channel refers to one of the two QSPDS channels. NUREG 0737,Section II.F.2, Attachment 1, Item (3) describes what is required from instrumentation standpoint: "A...display...should be provided with the capability for selective reading of a minimum of 16 operable thermocouples, 4 from each core quadrant...." This description is the basis for our Technical Specification, and clarifies the requirement for Incore Thernocouples. If we have fewer than 4 thermocouples per core quadrant, Action 31 applies. If we have fewer than 2 thermocouples per quadrant, Action 32 applies. There is no regulatory requirement that these 2 or 4 thermocouples per core quadrant be assigned to or divided between the two channels of QSPDS.

The column heading "TOTAL NO. OF CHANNELS," is also misleading for the Incore Thermocouples.

There are more than 4 thermocouples in every core quadrant. It takes 4 thermocouples per core quadrant to satisfy the Technical Specifications and unrestricted operation with fewer than the "TOTAL" but at least the "MINIMUM4" is not allowed. For example, if there are only 3 operable thermocouples in a quadrant, in 30 days one must be fixed or a Special Report submitted within the next 14 days.

W97:DPSfts/mrm'ev

ML041250367

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