ML052570650
| ML052570650 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/08/2005 |
| From: | Jones T Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2005-171 | |
| Download: ML052570650 (7) | |
Text
SEP 0 8 2005 FPL L-2005-171
§ 10 CFR 2.390 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 Response to Request for Supplemental Information Regarding the Proposed License Amendments for Reactor Trip System Technical Specifications Changes By letter dated March 22, 2005, Florida Power & Light Company (FPL) requested to amend Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4. The proposed amendments would revise the Turkey Point Units 3 and 4 Technical Specifications for several Reactor Trip System functional units as described below.
The Steam/Feedwater flow mismatch coincident with steam generator water level - low reactor trip is being deleted.
The reactor trip on turbine trip interlock is being changed from P-7 to P-8.
..The value of the P-8 interlock setpoint is being changed from 45% rated.
thermal power (RTP) to 40% RTP. The value of the P-8 interlock allowable value is being changed from 48% RTP to 43% RTP.
By email dated June 21, 2005 followed by a letter dated August 19, 2005 (MC6460 and MC6461), the NRC issued a request for supplemental information regarding FPL's Operating License amendment requests. The requested information is provided as Attachment 1 to this letter. Attachment 2 contains Westinghouse authorization letter, CAW-05-2031, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. A, WNA-LI-00049-FPL-P, Florida Power and Light, Turkey Point Units 3 and 4, Supplemental Licensing Input for Deletion of Steam / Feedwater Flow Mismatch Reactor Trip, contains information that is proprietary to Westinghouse Electric Company; and is supported by an affidavit signed by Westinghouse, the owner of the proprietary information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of 10 CFR Section 2.390 of the Commission's regulations. Enclosure 1 B contains the non-proprietary version of Enclosure 1A. provides the Westinghouse Nuclear Advisory Letter NSAL-96-004 as requested. A, FPL Letter ENG-LCM-04-256, PTN 3 Engineering Evaluation PTN-ENG-SEIJ 073 for Section 4.2 Platform Considerations for Westinghouse Licensing Report WNA-LI-00026-FPL Regarding Steam/Feedwater Flow Mismatch Reactor Trip, December 17, 2004, also contains information that is proprietary to Westinghouse Electric Company.
an FPL Group company
L-2005-171 10 CFR 50.90 10 CFR 2.390 Page 2 of 3 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Supplemental Information Regarding the Proposed License Amendments for Reactor Trip System Technical Specifications Changes B contains the non-proprietary version of Enclosure 3A. is FPL letter ENG-LCM-04-251, PTN3 Design Configuration Documents for Feedwater Control Sensor Segregation, dated December 15, 2004.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-05-2031 or CAW-05-1958 as appropriate, and should be addressed to J. A. Gresham, Manager of Regulatory Compliance and Plant Licensing, Westinghouse Electric Company, P. 0. Box 355, Pittsburgh, Pennsylvania 15230-0355.
A list of Attachments and Enclosures to this letter is provided herein as a roadmap of all the attached documents.
Please contact Mr. Walter J. Parker, Licensing Manager, Turkey Point Units 3 and 4 at 305-246-6632, if there are any additional questions.
Very truly yours, TerryO. n Vice President Turkey Point Nuclear Plant Enclosures & Attachments cc:
Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager, Turkey Point (3 copies of Enclosure 1A and Enclosure 3A)
W. A. Passetti, Florida Department of Health
L-2005-171 10 CFR 50.90 10 CFR 2.390 Page 3 of 3 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Supplemental Information Regarding the Proposed License Amendments for Reactor Trip System Technical Specifications Changes List of Attachments and Enclosures to L-2005-171 A B A B Florida Power and Light Turkey Point Units 3 and 4 Responses to the NRC's Request for Supplemental Information Regarding the Proposed License Amendments for Reactor Trip System Technical Specifications Changes Florida Power and Light Turkey Point Units 3 and 4 Supplemental Licensing Input for Deletion of Steam / Feedwater Flow Mismatch Reactor Trip WNA-LI-00049-FPL-P Florida Power and Light Turkey Point Units 3 and 4 Supplemental Licensing Input for Deletion of Steam / Feedwater Flow Mismatch Reactor Trip WNA-LI-00049-FPL-NP Westinghouse Nuclear Safety Advisory Letter NSAL-96-004 Control and Protection Interaction August 14, 1996 FPL Letter ENG-LCM-04-256 PTN 3 Engineering Evaluation PTN-ENG-SEIJ-04-073 for Section 4.2 Platform Considerations for Westinghouse Licensing Report WNA-LI-00026-FPL Regarding Steam/Feedwater Flow Mismatch Reactor Trip December 17, 2004 FPL Letter ENG-LCM-04-256 PTN 3 Engineering Evaluation PTN-ENG-SEIJ-04-073 for Section 4.2 Platform Considerations for Westinghouse Licensing Report WNA-LI-00026-FPL Regarding Steam/Feedwater Flow Mismatch Reactor Trip December 17, 2004 FPL Letter ENG-LCM-04-251 PTN 3 Design Configuration Documents for Feedwater Control Sensor Segregation December 15, 2004 CAW-05-2031, Application for Withholding Proprietary Information from Public Disclosure
L-2005-1 71 Page 1 of 4 Florida Power and Light Company Turkey Point Units 3 and 4 Responses to the NRC's Request for Supplemental Information Regarding the Proposed License Amendments For Reactor Trip System Technical Specifications Changes
L-2005-171 Page 2 of 4 FPL Response to NRC Requested Information By letter dated March 22, 2005 (Reference 1), Florida Power & Light Company (FPL) requested amendments to Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and
- 4. The proposed amendments would revise the Turkey Point Units 3 and 4 Technical Specifications (TS) for several Reactor Trip System functional units. By email dated June 21, 2005, the NRC issued a request for supplemental information regarding FPL's Operating License amendment requests.
The following are the responses to the five (5) items of requested information.
Reference
- 1.
Letter from Mr. T. 0. Jones (FPL) to NRC Document Control Desk, 'Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251, Proposed License Amendment, Reactor Trip System Technical Specifications Changes," dated March 22, 2005, letter number L-2005-006.
Request 1 Provide a 10 CFR 50.36 evaluation of the proposed TS requirements deletion regarding the steam/f eedwater flow mismatch with steam generator water level - low reactor trip.
FPL Response to Request 1 The Commission's regulatory requirements related to the content of the Technical Specifications (TS) are set forth in 10 CFR 50.36. This regulation requires that the TS include items in five specific categories. These categories include 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation (LCOs), 3) surveillance requirements (SRs), 4) design features, and 5) administrative controls.
10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TS. These criteria are as follows:
- 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
- 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.
- 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.
- 4. A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Existing LCOs and related SRs included as TS requirements which satisfy any of the criteria stated above must be retained in the TS. Those TS requirements which do not satisfy these
L-2005-1 71 Page 3 of 4 criteria may be removed from the TS and relocated to other licensee controlled documents as appropriate.
The steam/feedwater flow mismatch coincident with steam generator (SG) water level - low reactor trip is not credited in the Updated Final Safety Analysis Report (UFSAR) transient and accident analyses. The primary purpose of this trip function is to protect against potential adverse control and protection system interactions for the SG water level - low-low reactor trip function. This protection is no longer needed due to the installation of the Median Signal Selection (MSS) function into the Feedwater Control System. The MSS function prevents a single failed signal from initiating a feedwater transient that challenges the SG water level - low-low reactor trip function.
The steam/feedwater flow mismatch coincident with SG water level - low reactor trip function does not meet Criterion 1 because it is not installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary.
The steam/feedwater flow mismatch coincident with SG water level - low reactor trip function does not meet Criterion 2 because it does not involve 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.
The steam/feedwater flow mismatch coincident with SG water level - low reactor trip function does not meet Criterion 3 because it is no longer needed as part of the reactor trip system (RTS) in any design basis transient or accident analyses; and is no longer needed for RTS functionality. The steam/feedwater flow mismatch coincident with SG water level - low reactor trip function is intended to protect against postulated adverse control and protection system interaction. However, with the addition of the MSS to the Feedwater Control System, the potential for an adverse control and protection system interaction is eliminated. The MSS itself is not part of the RTS. The MSS does not provide protection for any postulated accident; and does not need to be covered by TS.
The steam/feedwater flow mismatch and low SG water level reactor trip function is not a structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety and, therefore, does not meet Criterion 4.
In conclusion, the steamn/feedwater flow mismatch coincident with SG water level - low reactor trip function does not meet any of the criteria set forth in 10 CFR 50.36(c)(2)(ii) for inclusion in the TS.
Reauest 2 Provide an explanation of the existing feedwater instrumentation system, from the reactor protection and control point of view, including the limitations of the existing system for which the proposed TS change has been requested, specifically addressing adverse effect of the existing control and protection system interaction and how it will be eliminated by the new Median Signal Selector (MSS).
L-2005-171 Page 4 of 4 FPL Response to Request 2 The requested information is attached as Enclosures 1 A (proprietary version) and 1 B (non-proprietary version).
Request 3 Provide a copy of Reference 14, 'Westinghouse Nuclear Safety Advisory Letter, NSAL-96-004,
'Control and Protection Interaction,' 8/14/96," to Enclosure 1, "Licensing Input for Deletion of Steam/Feedwater Flow Mismatch Reactor Trip."
FPL Response to Reauest 3 The requested letter is attached as Enclosure 2.
Request 4 Provide a copy of Reference 15, "FPL Letter ENG-LCM-04-256, 12/17/04, 'PTN 3 Engineering Evaluation PTN-ENG-SEIJ-04-073 for Section 4.2 Platform Considerations for Westinghouse Licensing Report WNA-LI-00026-FPL Regarding Steam/Feedwater Flow Mismatch Reactor Trip,"' to Enclosure 1.
FPL Response to Request 4 The requested letter is attached as Enclosures 3A (proprietary version) and 3B (non-proprietary version).
Request 5 Provide a copy of Reference 16, UFPL Letter ENG-LCM-04-251, 12/15/04, 'PTN 3 Design Configuration Documents for Feedwater Control Sensor Segregation,"' to Enclosure 1.
FPL Response to Request 5 The requested letter is attached as Enclosure 4.