ML043480388

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Issuance of License Amendments 227 and 223 Regarding Accident Monitoring Instrumentation Outage Times
ML043480388
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 01/06/2005
From: Ellen Brown
NRC/NRR/DLPM/LPD2
To: Stall J
Florida Power & Light Co
Brown Eva, NRR/DLPM, 415-2315
References
TAC MC2884, TAC MC2885
Download: ML043480388 (17)
v • d • e


Text

January 6, 2005 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING ACCIDENT MONITORING INSTRUMENTATION OUTAGE TIMES (TAC NOS. MC2884 AND MC2885)

Dear Mr. Stall:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 227 to Renewed Facility Operating License No. DPR-31 and Amendment No. 223 to Renewed Facility Operating License No. DPR-41 for the Turkey Point Plant, Units Nos. 3 and 4, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated April 23, 2004.

The amendments revise several TS Allowed Outage Times for TS 3.3.3, Accident Monitoring Instrumentation, to be consistent with the Completion Times in the related Specification in NUREG-1431, Revision 2, Standard Technical Specifications Westinghouse Plants (the Improved Standard TSs, or ISTSs).

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Eva A. Brown, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 227 to DPR-31
2. Amendment No. 223 to DPR-41
3. Safety Evaluation cc w/enclosures: See next page Mr. J. A. Stall

Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420

SUBJECT:

TURKEY POINT UNITS 3 AND 4 - ISSUANCE OF AMENDMENTS REGARDING ACCIDENT MONITORING INSTRUMENTATION OUTAGE TIMES (TAC NOS. MC2884 AND MC2885)

Dear Mr. Stall:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 227 to Renewed Facility Operating License No. DPR-31 and Amendment No. 223 to Renewed Facility Operating License No. DPR-41 for the Turkey Point Plant, Units Nos. 3 and 4, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated April 23, 2004.

The amendments revise several TS Allowed Outage Times for TS 3.3.3, Accident Monitoring Instrumentation, to be consistent with the Completion Times in the related Specification in NUREG-1431, Revision 2, Standard Technical Specifications Westinghouse Plants (the Improved Standard TSs, or ISTSs).

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Eva A. Brown, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 227 to DPR-31
2. Amendment No. 223 to DPR-41
3. Safety Evaluation cc w/enclosures: See next page Distribution:

PUBLIC PDII-2 R/F EBrown MMarshall BClayton (Hard Copy)

OGC ACRS BMarcus EMarinos JMunday, RII GHill (4 copies) EHackett TBoyce DLPM DPR Package No. ML050120372 Enclosure No. ML050120134 ADAMS ACCESSION NO. ML043480388 *NLO [no legal objections] w/noted corrections OFFICE PDII-2/PM PDII-2/LA EEIB/SC IROB/SC OGC PDII-2/SC NAME EMarinos by EBrown BClayton letter dated TBoyce MZobler

  • MMarshall DATE 1/6/05 1/6/05 12/17/04 1/14/05 12/17/04 1/6/05 OFFICIAL RECORD COPY

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT PLANT UNIT NO. 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 227 Renewed License No. DPR-31

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power and Light Company (the licensee) dated April 23, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Renewed Facility Operating License No. DPR-31 is hereby amended to read as follows:

(B) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 227, are hereby incorporated in the license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into the license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days within issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA Margaret Chernoff for/

Michael L. Marshall, Jr., Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: January 6, 2005

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT PLANT UNIT NO. 4 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 223 Renewed License No. DPR-41

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Florida Power and Light Company (the licensee) dated April 23, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 3.B of Renewed Facility Operating License No. DPR-41 is hereby amended to read as follows:

(B) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223, are hereby incorporated in the license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into the license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(C) This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA Margaret Chernoff for/

Michael L. Marshall, Jr., Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: January 6, 2005

ATTACHMENT TO LICENSE AMENDMENT AMENDMENT NO. 227 RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 223 RENEWED FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove pages Insert pages 3/4 3-41 3/4 3-41 3/4 3-44 3/4 3-44 3/4 3-45 3/4 3-45 B48 B48

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 227 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 223 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER AND LIGHT COMPANY TURKEY POINT UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251

1.0 INTRODUCTION

By application dated April 23, 2004, the Florida Power and Light Company (the licensee) proposed an amendment to the Technical Specifications (TSs) for Turkey Point Plant (TP),

Units 3 and 4. The requested changes would revise several allowed outage times (AOTs) and associated action requirements for certain accident monitoring instrumentation in TS 3.3.3.3, "Accident Monitoring Instrumentation," to be consistent with the Completion Times suggested in NUREG-1431, Revision 2, "Standard Technical Specifications Westinghouse Plants."

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The Commissions regulatory requirements related to the content of the TSs are contained in Title 10 to the Code of Federal Regulations (10 CFR) Section 50.36. Section 50.36(c)(2)(ii)(C) of 10 CFR requires that TS limiting conditions for operation (LCOs) of a nuclear reactor be established for 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. Section 50.36(c)(2)(ii)(D) of 10 CFR requires that TS LCOs of a nuclear reactor be established for a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

NUREG-1431, Revision 2, contains the improved Standard TSs (ISTS) for Westinghouse plants and documents the positions of the U.S. Nuclear Regulatory Commission (NRC) based on the Westinghouse Owners Groups proposed standard TSs. The ISTSs are used as the basis for developing improved plant-specific TSs and support the review of requests made in accordance with this regulatory guidance.

The licensee cited other industry submittals as precedents, specifically the Vermont Yankee amendment, which was approved on May 10, 2002.

3.0 EVALUATION 3.1 Action C The current LCO for TS 3.3.3.3 does not discuss how individual and multiple AOTs of inoperable instrument channels of the same Instrument are tracked. The licensee proposed adding Action C to the LCO for TS 3.3.3.3 to allow separate action entry for each instrument and would read:

Separate Action entry is allowed for each instrument.

This addition would allow the action statements of TS 3.3.3.3 to be entered independently for each instrument. The AOT of each inoperable channel of an instrument would be tracked separately, starting from the time the action was entered for that channel. In ISTSs, the instruments are identified as FUNCTIONS. The proposed Action C is consistent with the ISTS 3.3.3 LCO Action Note, which states that:

Separate Condition entry is allowed for each Function.

Based on the proposed addition providing clarification of the Action entry conditions and being consistent with the application of the current ISTSs, the NRC staff finds this change acceptable.

3.2 Action Statement 31 for Instruments 1, 3, 4, 5, 6, 7, 8, 13, 14, 17, 20, and 21 The current Action 31 requires a shutdown of the plant if the number of operable channels is less than the total number of channels specified in TS Table 3.3-5 and the inoperable channel cannot be restored to operable status within 7 days. The licensee proposed revising Action Statement 31 for the following Instruments:

- Instrument 1, Containment Pressure (Wide Range);

- Instrument 3, Reactor Coolant Outlet Temperature THOT (Wide Range);

- Instrument 4, Reactor Coolant Inlet Temperature TCOLD (Wide Range);

- Instrument 5, Reactor Coolant Pressure - Wide Range;

- Instrument 6, Pressurizer Water Level;

- Instrument 7, Auxiliary Feedwater Flow Rate;

- Instrument 8, Reactor Coolant System Subcooling Margin Monitor;

- Instrument 13, Containment Water Level (Wide Range);

- Instrument 14, In Core Thermocouples (Core Exit Thermocouples);

- Instrument 17, Neutron Flux, Backup Nuclear Instrumentation System (NIS) (Wide Range);

- Instrument 20, RWST Water Level; and

- Instrument 21, Steam Generator Water Level (Narrow Range).

Currently Action 31 reads:

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 7 days, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The licensee has proposed revising Action 31 to read:

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.

The licensee stated that during the development of the ISTSs it was determined that the 7-day completion time was overly restrictive. The ISTSs extended the completion time for one inoperable instrument channel from 7 days to 30 days. If this channel could not be restored to operable status by 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 should discuss the cause of the inoperability and the preplanned alternate method of monitoring and identify proposed actions to restore the inoperable channel.

The NRC staff reviewed the licensees proposed revision against the associated ISTS REQUIRED ACTIONS. The proposed 30-day restoration AOT takes into account the remaining operable channels, the passive nature of the instrument (i.e., the instrument does not initiate critical automatic actions), and the low probability of an event requiring the accident monitoring instrumentation during this interval. The proposed submission of a special report within the next 14 days, in lieu of a shutdown, ensures that there would be at least one functional instrument channel to provide information, and the special report would adequately address actions taken and the availability of diverse or alternate monitoring capability. Based on the above and the consistency with ISTSs, the NRC staff finds the proposed revision to Action Statement 31 acceptable.

3.3 Action Statement 32 for Instruments 1, 3, 4, 5, 6, 7, 8, 11, 13, 14, 17, 20, and 21 The current Action Statement 32 requires a shutdown of the plant if the number of operable channels is less than the minimum channels operable specified in TS Table 3.3-5 and at least one inoperable channel cannot be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Specifically, Action Statement 32 reads:

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 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY

within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The licensee proposed revising Action Statement 32 to read:

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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT SHUTDOWN within the following hours.

The licensee proposed revising Action Statement 32 for the following

- Instrument 1, Containment Pressure (Wide Range);

- Instrument 3, Reactor Coolant Outlet Temperature THOT (Wide Range);

- Instrument 4, Reactor Coolant Inlet Temperature TCOLD (Wide Range);

- Instrument 5, Reactor Coolant Pressure - Wide Range;

- Instrument 6, Pressurizer Water Level;

- Instrument 7, Auxiliary Feedwater Flow Rate;

- Instrument 8, Reactor Coolant System Subcooling Margin Monitor;

- Instrument 11, Safety Valve Position Indicator (Primary Detector);

- Instrument 13, Containment Water Level (Wide Range);

- Instrument 14, In Core Thermocouples (Core Exit Thermocouples);

- Instrument 17, Neutron Flux, Backup NIS (Wide Range);

- Instrument 20, RWST Water Level; and

- Instrument 21, Steam Generator Water Level (Narrow Range).

The licensees proposal extends the 48-hour AOT to restore an inoperable channel to 7 days.

The licensee stated that during the development of the ISTS it was determined that the 48-hour completion time was overly restrictive.

The NRC staff reviewed the licensees proposed revision against the ISTSs. The ISTSs extended the completion time from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 7 days when all instrument channels monitoring a required parameter are inoperable. If at least one of the inoperable channels could not be restored to operable status by the end of the 7-day completion time, a plant shutdown would be required. Based on the proposed revision allowing a reasonable time for repair, taking into consideration that the probability of an event requiring the accident monitoring instrumentation

during this interval is low, and ensuring an alternate means of obtaining the required information are available, the extension to Action Statement 32 is acceptable.

3.4 Action Statement 34 for Instruments 15 and 19 The current Action Statement 34 requires that the preplanned alternate method of monitoring the appropriate parameters be initiated within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and if at least one inoperable channel cannot be restored to operable status within 7 days a special report must be submitted within 14 days following the event. Specifically, Action 34 reads:

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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, 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 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.

In the submittal, the licensee indicated that the submittal of a special report within 14 days following the event is overly restrictive because an alternate monitoring method ensures that the monitoring function continues to be performed. The licensee proposed that the completion time to submit a special report be changed from within 14 days following the event to within the next 14 days after the expiration of the 7-day restoration AOT. The action statement would be revised to read:

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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, 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.

The NRC staff reviewed the licensees proposal against the ISTSs. The extension of the report submittal time to 14 days after the expiration of the 7-day restoration completion time for these instruments is acceptable because the proposal is consistent with ISTSs, the probability of an event requiring the accident monitoring instrumentation during this interval is low and an alternate means of obtaining the required information will be available.

3.5 Action Statement 37 for Instrument 16

The current Action Statement 37 requires that if the number of operable channels is less than the total number of channels specified in TS Table 3.3-5 and the inoperable channel cannot be restored to operable status within 7 days without shutting down, a special report must be submitted pursuant to Specification 6.9.2 within 30 days following the event. Specifically, Action Statement 37 reads:

With the number of OPERABLE channels one less than the Total Number of Channels, restore the system to OPERABLE status within 7 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 30 days following the event outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

In the submittal, the licensee indicated that the 7-day restoration completion time is overly restrictive. The licensee proposed that the 7-day AOT to restore an inoperable channel be extended to 30 days. The licensee also proposed that the completion time to submit a special report be changed from within 30 days following the event to within the next 14 days after the expiration of the 30-day restoration AOT. The licensee has proposed to revise Action Statement 37 to read:

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.

The NRC staff reviewed the proposed revision against the ISTSs. The ISTSs extended the completion time for one inoperable instrument channel from 7 days to 30 days. If this channel could not be restored to operable status by the end of the 30-day completion time, a special report must be submitted to the Commission within the next 14 days. This special report should discuss the cause of the inoperability and the preplanned alternate method of monitoring and identify proposed actions to restore the inoperable channel.

The proposed 30-day restoration AOT takes into account operating experience, the remaining operable channels, the passive nature of the instrument (i.e., the instrument does not initiate critical automatic actions), and the low probability of an event requiring the accident monitoring instrumentation during this interval. The proposed requirement to submit a report within 14 days of the expiration of the 30-day restoration AOT incorporates the fact that the probability of an event requiring the accident monitoring instrumentation during this interval is low, and alternate means of obtaining the required information are available. Based on the above and the consistency with ISTSs, the NRC staff finds the proposed revision to Action Statement 31 acceptable.

3.6 Action Statement 38 for Instrument 16 The current Action Statement 38 requires that if the number of operable channels is less than the minimum channels operable specified in TS Table 3.3-5 and at least one inoperable channel cannot be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> without shutting down, an alternate method of monitoring the reactor vessel inventory be initiated and a special report be submitted pursuant to TS 6.9.2 within 30 days following the event, and at least one channel be restored to operable status at the next scheduled refueling. Currently Action Statement 38 reads:

With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirements, restore the inoperable channel(s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If repairs are not feasible without shutting down:

1. Initiate an alternate method of monitoring the reactor vessel inventory;
2. Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event 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.

The licensee proposed that the 48-hour AOT to restore at least one inoperable channel be extended to 7 days, and the completion time to submit a special report be changed from within 30 days following the event to within the next 14 days after the expiration of the 7-day restoration AOT.

Specifically, the licensee proposed revising Action 38 to read:

With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirements, restore 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.

In the submittal, the licensee stated that during the development of the ISTS it was determined that the 48-hour restoration completion time was overly restrictive. The ISTSs extended the completion time from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 7 days when all instrument channels monitoring a required parameter are inoperable. The licensee also stated that the submittal of a special report within 14 days after the expiration of the 7-day completion time is consistent with the ISTSs.

The NRC staff reviewed the proposed revision against the ISTSs. The proposed 7-day restoration AOT provides a reasonable time for repair, the probability of an event requiring the accident monitoring instrumentation during this interval is low, and alternate means of obtaining the required information are available. Additionally, the proposed requirement to submit a report within 14 days after the expiration of the 7-day restoration AOT is appropriate because the probability of an event requiring the accident monitoring instrumentation during this interval is low and alternate means of obtaining the required information are available. Based on the above and the consistency with ISTSs, the NRC staff finds the proposed revision to Action Statement 38 acceptable.

3.7 Action Statement 39 for Instrument 22 The current Action 39 requires that if number of operable channels is less than the minimum channels operable specified in TS Table 3.3-5 the position of the valve is to be determined by alternate means within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and the inoperable channel be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the provisions of TS 3.6.4 for an inoperable containment isolation valve should be instituted. Specifically, Action Statement 39 reads:

With the number 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and restore the inoperable channel(s) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or comply with the provisions of Specification 3.6.4 for an inoperable containment isolation valve.

The licensee stated that the 72-hour completion time is overly restrictive. The licensee proposed that the 72-hour AOT to restore an inoperable channel be extended 7 days.

Specifically, the licensee proposed revising Action Statement 39 to read:

With the number 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 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.

The NRC staff reviewed the licensees proposal against the ISTSs. The ISTSs extended the restoration completion time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days, when all instrumentation channels monitoring a required parameter are inoperable. The proposed 7-day restoration provides a reasonable time for repair, the probability of an event requiring the accident monitoring instrumentation during this interval is low, and alternate means of obtaining the required information are available. Additionally, the accident monitoring instrumentation requirements in TP TS 3.3.3.3 are similar to the recommendations in ISTS TS 3.3.3:

- The ISTSs and TP TS LCOs require the instruments to be operable.

- The ISTSs applicability is Modes 1, 2, and 3 for all instruments. The TP TSs applicability is Modes 1, 2, and 3 except for Instrument 19a, "Plant Vent Exhaust," and Instrument

19b, "Unit 3 - Spent Fuel Pit Exhaust," which are applicable in all modes. This is the appropriate applicability for these instruments.

- The ISTSs provide an exception to LCO 3.0.4. The TP TSs provide an exception to the equivalent TS 3.0.4.

- The ISTSs and TP TSs 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.

Based on the above and the consistency with ISTS, the NRC staff finds the proposed revision to Action Statement 39 acceptable.

3.0 STATE CONSULTATION

Based upon a letter dated May 2, 2003, from Michael N. Stephens of the Florida Department of Health, Bureau of Radiation Control, to Brenda L. Mozafari, Senior Project Manager, U.S. Nuclear Regulatory Commission, the State of Florida does not desire notification of issuance of license amendments.

4.0 ENVIRONMENTAL CONSIDERATION

These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (69 FR 29767). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Barry S. Marcus Date: January 6, 2005

Mr. J. A. Stall TURKEY POINT PLANT Florida Power and Light Company cc:

M. S. Ross, Managing Attorney Attorney General Florida Power & Light Company Department of Legal Affairs P.O. Box 14000 The Capitol Juno Beach, FL 33408-0420 Tallahassee, Florida 32304 Marjan Mashhadi, Senior Attorney Michael O. Pearce Florida Power & Light Company Plant General Manager 801 Pennsylvania Avenue, NW. Turkey Point Nuclear Plant Suite 220 Florida Power and Light Company Washington, DC 20004 9760 SW. 344th Street Florida City, FL 33035 T. O. Jones, Site Vice President Turkey Point Nuclear Plant Walter Parker Florida Power and Light Company Licensing Manager 9760 SW. 344th Street Turkey Point Nuclear Plant Florida City, FL 33035 9760 SW 344th Street Florida City, FL 33035 County Manager Miami-Dade County David Moore, Vice President 111 Northwest 1 Street, 29th Floor Nuclear Operations Support Miami, Florida 33128 Florida Power and Light Company P.O. Box 14000 Senior Resident Inspector Juno Beach, FL 33408-0420 Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission Mr. Rajiv S. Kundalkar 9762 SW. 344th Street Vice President - Nuclear Engineering Florida City, Florida 33035 Florida Power & Light Company P.O. Box 14000 Mr. William A. Passetti, Chief Juno Beach, FL 33408-0420 Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100

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