ML061080598

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Issuance of License Amendments 229 & 225 Adoption of Technical Specification Task Force Travelers
ML061080598
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 05/26/2006
From: Moroney B
Plant Licensing Branch III-2
To: Stall J
Florida Power & Light Co
Moroney Brenden 301-415-3974
Shared Package
ML061500230 List:
References
TAC MC5840, TAC MC5841, TAC MC6027, TAC MC6028, TAC MC6029, TAC MC6030, TAC MC6031, TAC MC6032, TAC MC6033, TAC MC6034, TAC MC6035, TAC MC6036, TAC MC6037, TAC MC6038, TAC MC6039, TAC MC6040
Download: ML061080598 (19)


Text

May 26, 2006 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 ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELERS (TAC NOS. MC5840, MC5841 AND MC6027 THROUGH MC6040)

Dear Mr. Stall:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 229 to Renewed Facility Operating License No. DPR-31 and Amendment No. 225 to Renewed Facility Operating License No. DPR-41 for the Turkey Point Plant, Units 3 and 4, respectively.

The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated January 20, 2005, as supplemented by letter dated July 5, 2005.

Specifically, the amendments revise several Turkey Point Unit 3 and 4 TSs to adopt the following TS Task Force (TSTF) change travelers that have been generically approved by the NRC:

TSTF-5, Rev. 1, Delete safety limit violation notification requirements.

TSTF-93, Revision 3, Change the Frequency of Pressurizer Heater Testing from 92 Days to [18] Months.

TSTF-258, Rev. 5, Changes to Section 5.0, Administrative Controls.

TSTF-299, Rev. 0, Administrative Controls Program 5.5.2.b Test Interval and Exception.

TSTF-308, Rev. 1, Determination of Cumulative and Projected Dose Contributions in RECP.

TSTF-361, Rev. 2, Allow standby SDC/RHR/DHR [Shutdown Cooling/Residual Heat Removal/Decay Heat Removal] loop to be inoperable to support testing.

The January 20, 2005, submittal also proposed adoption of TSTF-95 and TSTF-101.

Subsequently, by letters dated October 13, 2005, and March 22, 2006, Florida Power and Light Company withdrew the requests to adopt TSTF-101 and TSTF-95, respectively.

J. Stall May 26, 2006 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/

Brendan T. Moroney, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 229 to DPR-31
2. Amendment No. 225 to DPR-41
3. Safety Evaluation cc w/enclosures: See next page

J. Stall May 26, 2006 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/

Brendan T. Moroney, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251

Enclosures:

1. Amendment No. 229 to DPR-31
2. Amendment No. 225 to DPR-41
3. Safety Evaluation cc w/enclosures: See next page Distribution:

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  • No Legal Objection NRR-058 OFFICE LPL2-2/PM LPL2-2/LA ITSB/BC IOLB/BC SPWB/BC OGC LPL2-2/BC NAME BMoroney BClayton TBoyce by memo dated DTrimble by memo dated JNakoski by memos dated SHamrick*

MMarshall DATE 5/25/06 5/25/06 2/24/06 11/17/05 6/27/05 and 7/5/05 5/18/06 5/26/06 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. 229 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 January 20, 2005, as supplemented by letter dated July 5, 2005, 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:

(1)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 229, 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/

Michael L. Marshall, Jr., Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 26, 2006

FLORIDA POWER AND LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT PLANT UNIT NO. 4 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 225 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 January 20, 2005, as supplemented by letter dated July 5, 2005, 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:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, 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.

(2)

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

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael L. Marshall, Jr., Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 26, 2006

ATTACHMENT TO LICENSE AMENDMENT AMENDMENT NO. 229 RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AMENDMENT NO. 225 RENEWED FACILITY OPERATING LICENSE NO. DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace page 3 of Renewed License No. DPR-31 with the attached page 3.

Replace page 3 of Renewed License No. DPR-41 with the attached page 3.

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 xv xv xvi xvi 2-1 2-1 3/4 4-9 3/4 4-9 3/4 9-9 3/4 9-9 6-2 6-2 6-5 6-5 6-12 6-12 6-14 6-14 6-16 6-16 6-17 6-17 6-18 6-18

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 229 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 225 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER & LIGHT COMPANY TURKEY POINT PLANT, UNITS 3 AND 4

1.0 INTRODUCTION

By a letter dated January 20, 2005, as supplemented by letter dated July 5, 2005, Florida Power & Light Company (FPL, the licensee), submitted a request for amendments to Renewed Operating License Nos. DPR-31 and DPR-41 for Turkey Point Plant, Units 3 Unit 4, respectively. The proposed amendments requested changes to the Turkey Point Units 3 and 4 technical specifications (TSs) to incorporate generically approved TS Task Force (TSTF) change travelers TSTF-5R1, TSTF-93R3, TSTF-95R0, TSTF-101R0, TSTF-258R5, TSTF-299R0, TSTF-308R1, and TSTF-361R2.

Subsequently, by letters dated October 13, 2005, and March 22, 2006, the licensee withdrew the requests to adopt TSTF-101 and TSTF-95, respectively. Therefore, this safety evaluation will only address the remaining six TSTFs.

Specifically, the proposed changes would do the following:

A.

TSTF-5, Rev. 1, Delete safety limit violation notification requirements. The proposed change deletes notification, reporting, and restart requirements from the TSs if a safety limit is violated. Section 6.7 of the Turkey Point TSs is deleted and is being replaced with the term, DELETED, and the references to TS 6.7.1 are being deleted from TS 2.1.

B.

TSTF-93, Rev. 3, Change the Frequency of Pressurizer Heater Testing from 92 Days to [18] Months. The proposed change to TS 3.4.3, Pressurizer, revises the pressurizer heater testing frequency in Surveillance 4.4.3.2 from 92 days to 18 months and eliminates details on how the test is performed.

C.

TSTF-258, Rev. 5, Changes to Section 5.0, Administrative Controls. The proposed change revises the Administrative Controls section of the TSs to adopt several improvements to unit staffing, work hour limitations, and Radioactive Effluent Controls Program (RECP), and reporting.

D.

TSTF-299, Rev. 0, Administrative Controls Program 5.5.2.b Test Interval and Exception. The proposed change clarifies the meaning of refueling cycle for system integrated leak test intervals in the Primary Coolant Sources Outside Containment program in TS 6.8.4.a. In addition, the proposed change also specifies that the provisions of TS 4.0.2 are applicable to these test intervals.

E.

TSTF-308, Rev. 1, Determination of Cumulative and Projected Dose Contributions in RECP. The proposed change to TS 6.8.4.f, Radioactive Effluent Controls Program, clarifies the requirements for the determination of cumulative and projected dose contributions from radioactive effluents.

F.

TSTF-361, Rev. 2, Allow standby SDC/RHR/DHR [Shutdown Cooling/Residual Heat Removal/Decay Heat Removal] loop to be inoperable to support testing.

The proposed change adds a note to the RHR requirements during Mode 6 low water level operations (TS 3.9.8.2) which allows one required RHR loop to be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided the other RHR loop is operable and in operation.

The supplement dated July 5, 2005, provided additional information that clarified the application, did not expand the scope of the application as noticed, and did not require a change to the no significant hazards determination as published in the Federal Register on March 15, 2005 (70 FR 12747).

2.0 REGULATORY EVALUATION

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, FPL has requested that the Turkey Point Units 3 and 4 TSs be modified to incorporate the changes in the identified TSTF change travelers, which have been approved by the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff generically for the Standard Technical Specifications (STSs) for Westinghouse plants, NUREG-1431.

Section 182a of the Atomic Energy Act requires that TSs be included in nuclear power plant operating licenses. In 10 CFR Part 50, Section 36, the NRC established its regulatory requirements related to the content of TSs. On February 6, 1987, the NRC issued an Interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, setting forth criteria for use in determining the content of TSs. During the period 1989 to 1992, utility groups and NRC Staff developed improved STSs. On July 22, 1993, the NRC issued its Final Policy Statement, that described the safety benefits of the improved STSs, and encouraged licensees to use the improved STSs as a basis for plant specific license amendments, and for complete conversion to plant specific improved STSs.

Since Revision 1 of the STSs was published in 1995, the industry and the NRC staff have identified additional STSs improvements. These improvements are proposed by the industry TSTF and referenced by a TSTF number. Following industry acceptance and NRC staff approval, the NRC incorporates the Traveler into the STSs. In most cases, these changes are generally applicable to individual plants and may be adopted by license amendment into plant-specific TSs. The Turkey Point TSs are not based on the improved STSs. However, these Travelers, including the justification accepted by the NRC, are applicable to the Turkey Point TSs.

TSTF-5, Revision 1, was approved by letter from C.I. Grimes (NRC) to J. Davis (Nuclear Energy Institute [NEI]) dated September 27, 1996.

TSTF-93, Revision 3, was approved on October 3, 1997, and was incorporated in Revision 2 of NUREG-1431, dated April 2, 2002.

TSTF-258, Revision 5, was approved by letter from W.D. Beckner (NRC) to J. Davis (NEI) dated June 29, 1999.

TSTF-299, Revision 0, was approved by letter from W.D. Beckner (NRC) to A.R. Pietrangelo (NEI) dated October 31, 2000.

TSTF-308, Revision 1, was approved on June 27, 2000, as referenced in the NRC Safety Evaluation contained in the letter from G.S. Vissing (NRC) to P.E. Katz (Calvert Cliffs) dated July 16, 2003.

TSTF-361, Revision 2, was approved by letter from W.D. Beckner (NRC) to A.R. Pietrangelo (NEI) dated October 31, 2000.

3.0 TECHNICAL EVALUATION

The proposed changes to the Turkey Point Units 3 and 4 TSs are evaluated below.

A.

TSTF-5 deleted STS Safety Limit Violation action 2.2.3, which required notifying the NRC Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with 10 CFR 50.72; action 2.2.4, which required notifying the [Plant Superintendent and Vice President - Nuclear Operations] within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; action 2.2.5, which required submitting a Licensee Event Report to the NRC, the [offsite review function], and the [Plant Superintendent, and Vice President - Nuclear Operations] pursuant to 10 CFR 50.73 within 30 days; and action 2.2.6, which stated that operation of the unit shall not be resumed until authorized by the NRC. These STS requirements are identical to requirements in Turkey Point TS Section 6.7, Safety Limit Violation, which are referenced in TS Section 2.1, Safety Limits.

The proposed change deletes requirements from TSs that are duplicative or contained in other regulations. For example, 10 CFR 50.36(c)(l)(i)(A) states, If any safety limit is exceeded, the reactor must be shut down. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not be resumed until authorized by the Commission. The licensee shall retain the record of the results of each review until the Commission terminates the license for the reactor, except for nuclear power reactors licensed under § 50.21(b) or § 50.22 of this part. For these reactors, the licensee shall notify the Commission as required by

§ 50.72 and submit a License Event Report to the Commission as required by § 50.73.

The proposed amendment adopts the Traveler with no significant changes. The Turkey Point TS requirements proposed for deletion are equivalent to the STS requirements that were deleted by TSTF-5. The remaining Turkey Point TS requirements for Safety Limit Violations are equivalent to STS requirements.

B.

TSTF-93 revised STS Surveillance Requirement 3.4.9.2, which states, Verify capacity of each required group of pressurizer heaters is > [125] kW.

The pressurizer maintains reactor coolant system (RCS) pressure. The pressurizer is a surge tank where liquid and vapor are maintained in a saturated equilibrium at system pressure. Equilibrium is maintained by a combination of electrical immersion heaters, located in the lower section of the pressurizer vessel, and spray nozzles located in the upper section of the pressurizer vessel. The electrical immersion heaters, keep the water in the pressurizer at RCS system saturation temperature. Pressurizer heaters used to maintain the saturation temperature are typically referred to as proportional heaters and the heaters used to respond to transients are typically referred to as backup heaters.

TSTF-93 modified the surveillance frequency of the pressurizer heaters by adding a Reviewers Note which states, The frequency for performing pressurizer heater capacity testing shall be either 18 months or 92 days, depending on whether or not the plant has dedicated safety-related heaters. For dedicated safety-related heaters, which do not normally operate, 92 days is applied. For non-dedicated safety-related heaters, which normally operate, 18 months is applied. In its submittal, the licensee confirmed that the Turkey Point pressurizer heaters are nondedicated safety-related heaters, which normally operate.

NUREG-1366, Improvements to Technical Specification Surveillance Requirements, Section 6.6, Pressurizer Heaters, states, Most pressurizer heaters are in constant use, both the proportional and to some extent the backup heaters. Therefore, operators should be aware of problems that may arise with pressurizer heaters. In addition, pressurizer heaters are fairly reliable. The licensee stated that the TSs surveillance tests for both units for the last 5 years were reviewed to assess the historical test results and the performance of the pressurizer heaters. The results of the review confirmed that the TS surveillance requirement was always met. The NRC recommended in NUREG-1366 that pressurizer heaters be tested once each refueling interval at plants that meet this criterion.

Turkey Point TSs Surveillance Requirement 4.4.3.2 currently states, The capacity of each of the above required groups of pressurizer heaters shall be verified by energizing the heaters and measuring circuit current at least once per 92 days. The licensee proposes to revise the Surveillance Requirement to be consistent with the STSs by stating, The capacity of each of the above required groups of pressurizer heaters shall be verified to be at least 125 kW at least once per 18 months. The proposed change deletes the specific instructions on how to perform the surveillance. The licensee plans to include information on acceptable methods for performing the surveillance in a revision to the TSs Bases. This should be done in accordance with the licensees TS Bases Control Program.

The STS Surveillance Requirement affected by this Traveler and the proposed Turkey Point Surveillance Requirement are equivalent.

C.

TSTF-258 made seven change to the Administrative Controls section of the STSs.

It deleted, in STS 5.2.2, requirements for a licensed operator to be present in the control room when fuel is in the reactor vessel and for a senior licensed operator to be in the control room when either unit is in Modes 1, 2, 3, or 4, since 10 CFR 50.54(k) and (m) require this.

It eliminated details from working hour limitations from STS 5.2.2.

It clarified the requirements for the Shift Technical Advisor (STA) function in STS 5.2.2.

It modified the unit staff requirements in STS 5.3 to add elements required to be in the TSs by 10 CFR 55.4.

It revised the RECP in STS 5.5.4 to be consistent with 10 CFR Part 20 and to make other improvements.

It revised the RECP in STS 5.6.4 to eliminate the requirement to report challenges to the pressurizer power operated relief valves and safety valves.

It revised the High Radiation Area requirements in STS 5.7 based on 10 CFR Part 20 and the letter from C. Grimes (NRC) to J. Davis (NEI) dated April 9, 1997.

TSTF-258 deleted requirements in STS 5.2.2 for a licensed operator to be present in the control room when fuel is in the reactor vessel and for a senior licensed operator to be in the control room when either unit is in Modes 1, 2, 3, or 4. These requirements appear in Turkey Point TSs 6.2.2.b and 6.2.2.c. The deleted requirements are not needed in the TSs since the requirements of 10 CFR 50.54(m)(2)(iii) and 50.54(k) adequately provide for shift manning. As required by 10 CFR 50.54(m)(2)(iii), when a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by the units technical specifications, each licensee shall have a person holding a senior operator license for the nuclear power unit in the control room at all times. In addition to this senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times. Further, 10 CFR 50.54(k) requires An operator or senior operator licensed pursuant to part 55 of this chapter shall be present at the controls during the operation of the facility. The requirements will be met through compliance with these regulations and are not required to be reiterated in the TSs.

TSTF-258 eliminated specific working hour limitations from STS 5.2.2. Turkey Point TS 6.8.5 is being revised to delete the requirement that controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the plant manager or his designee to ensure that excessive hours have not been assigned.

There is no guidance in Generic Letter (GL) 82-12, Nuclear Power Plant Staff Working Hours, that discusses these additional controls. The additional requirement to have the plant manager (or his designee) review individual overtime on a monthly basis is unnecessary since sufficient administrative controls and policies exist, as well as the role of the individuals supervisors, in preventing excessive or abuse of overtime. The requirement for the monthly review by the plant manager or his designee is being replaced by a requirement to perform a periodic independent review.

TSTF-258 clarified the requirements for the STA function in STS 5.2.2. Turkey Point TS 6.2.3.1 is being revised to eliminate the title of Shift Technical Advisor so that it does not imply that the STA and the Shift Supervisor must be different individuals.

Option1 of the Commission Policy Statement on Engineering Expertise on Shift (50 FR 43621, dated October 28, 1985) is satisfied by assigning an individual with specified educational qualifications to each operating crew as one of the Senior Reactor Operators (perferably the shift supervisor) required by 10 CFR 50.54(m)(2)(i) to provide the technical expertise on shift. This change is also consistent with note *** of Table 6.2-1, Minimum Shift Crew Composition. In addition, the requirement that the advisor have a bachelors degree or equivalent in a scientific or engineering discipline is being deleted. Educational requirements are specified in the Policy Statement on Engineering Expertise on Shift, which is referenced in TS 6.2.3, and do not need to be repeated in the TSs. Eliminating this phrase is consistent with the STS requirements.

TSTF-258 modified the unit staff requirements of STS 5.3 to add elements required to be in the TSs by 10 CFR 55.4. The definitions in 10 CFR 55.4 state: Actively performing the functions of an operator or senior operator means that an individual has a position on the shift crew that requires the individual to be licensed as defined in the facilitys technical specifications, and that... TSTF-258 added to STS 5.3, For the purpose of 10 CFR 55.4, a licensed Senior Operator and a licensed reactor operator are those individuals who, in addition to meeting the requirements of TS 5.3.1, perform the functions described in 10 CFR 50.54(m). A similar paragraph is added to Turkey Point TS 6.3. The proposed new paragraph (TS 6.3.3) references 10 CFR 55.4 and ensures that there is no misunderstanding when complying with 10 CFR 55.4 requirements.

Adding this paragraph is also consistent with the recommendations in the April 9, 1997, letter from C. Grimes (NRC) to J. Davis (NEI).

TSTF-258 revised the RECP in STS 5.5.4 to be consistent with 10 CFR Part 20 and to make other improvements. Turkey Point TS 6.8.4.f.2 is being revised to specify a limit, conforming to ten times the concentration values in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2402. Enclosure 3 to GL 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual (ODCM) or to the Process Control Program, provided model TSs that satisfied the requirements of 10 CFR 20.106, which was the current applicable regulatory requirement at the time.

The Turkey Point TS requirements are consistent with GL 89-01. In 1991, 10 CFR Part 20 was revised. The change to TS 6.8.4.f.2 is intended to eliminate all possible confusion or improper implementation of the revised 10 CFR Part 20 requirements.

TSs 6.8.4.f.7 and 6.8.4.f.10 are being revised to include editorial clarifications that do not change the intent of the requirements and to be more consistent with the STSs. The provisions of TS 4.0.2 are being applied to the RECP surveillance frequencies to allow for scheduling flexibility. TS 4.0.2 permits a 25-percent extension of the specified frequency (31 days). Allowing a 25-percent extension of the frequency of performing the cumulative dose and projected dose calculation will have no effect on the outcome of the calculations. TS 4.0.3 also specifies the requirements for a missed Surveillance Requirement. Adding these requirements to the RECP establishes consistency with the other Surveillance Requirements in the TSs, and is consistent with the STSs and the changes made by TSTF-258.

TSTF-258 revised the monthly operating report requirements in STS 5.6.4 to eliminate the requirement to report challenges to the pressurizer power operated relief valves and safety valves. The proposed amendment requested removal of this requirement from TS 6.9.1.5. However, subsequent to the current submittal, Amendments 228 and 224, dated January 13, 2006 (ML053490250) deleted TS 6.9.1.5 in its entirety. Therefore, the proposed adoption of this part of TSTF-258 needs no further consideration.

D.

TSTF-299 revised the Primary Coolant Sources Outside Containment program in STS 5.5.2. The Primary Coolant Sources Outside Containment program requires that the program include integrated leak test requirements for each system at refueling cycle intervals or less. TSTF-299 revised the program to require the integrated leak test requirements for each system at least every 18 months. In addition, the program was modified to state that the requirements of Surveillance Requirement 3.0.2 are applicable.

The fixed testing frequency of 18 months is more precise than the existing frequency of at least once per refueling cycle and is more consistent with similar requirements in the Turkey Point TSs. The system leak testing is similar to a Surveillance Requirement.

TS 4.0.2 permits Surveillance Requirement frequencies to be extended by 25 percent.

For consistency with the other Surveillance Requirements, the provisions of TS 4.0.2 are being applied to the system leak testing. The applicability of TS 4.0.2 only applies to the Surveillance Requirement sections (Sections 4.1 through 4.10). The TS 4.0.2 provision also provides the needed flexibility to perform the leak testing during a refueling outage should the previous fuel cycle be extended due to a lengthy forced shutdown. The revised test interval combined with the provisions of TS 4.0.2 is equivalent to the existing requirement, provided the interval between refueling outages is no greater than 22.5 months (18 months plus 25 percent) for plants on an 18-month fuel cycle. Since Turkey Point Units 3 and 4 are on an 18-month fuel cycle, this change is administrative.

The justification presented in the Traveler is applicable to Turkey Point. The Traveler is being adopted by Turkey Point with no significant changes.

E.

TSTF-308 revised the RECP requirements for the determination of cumulative and projected dose contributions to describe the actual intent of the requirement (STS 5.5.4.e). The STSs stated, Determination of cumulative and projected dose contributions from radioactive effluent for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days. TSTF-308 revised the requirement to state, Determination of cumulative dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days. Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days.

TSTF-308 was proposed because there was concern that the text of this requirement could be misinterpreted to require determining projected dose contribution for the current calendar quarter and current calendar year every 31 days. The current Turkey Point wording in TS 6.8.4.f is the same as was specified in GL 89-01. GL 89-01 provided new programmatic controls for radioactive effluents and radiological environmental monitoring that were to be incorporated into the TSs to conform to the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I of 10 CFR Part 50. Prior to GL 89-01, the cumulative dose contributions were required to be determined every 31 days, and projected dose contribution for the current calendar quarter and current calendar year were required to be determined every 31 days.

The NRC Staffs draft STSs for 4-loop Westinghouse plants (documented in an August 14, 1987, letter to Texas Utilities) included Radioactive Effluent Technical Specifications. Surveillance Requirement 4.11.1.2 for liquid effluent states, Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days. Surveillance 4.11.1.3.1 for the liquid radioactive waste treatment system states, Doses due to liquid releases from each unit to unrestricted areas shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM when liquid radioactive waste treatment systems are not being fully utilized.

GL 89-01 appears to have combined these two surveillance requirements for cumulative and projected doses. In combining these requirements in GL 89-01, the new program element can be interpreted to require determining projected dose contribution for the current calendar quarter and current calendar year every 31 days. This was not the NRCs intention. TSTF-308 clarified the requirement by stating, Determination of cumulative dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days. Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days.

The justification presented in the Traveler is applicable to Turkey Point. The Traveler is being adopted by Turkey Point with no significant changes.

F.

TSTF-361 revised STS 3.9.6, which requires two RHR loops to be operable and one loop to be in operation in Mode 6 when the water level is less than 23 feet above the top of the reactor vessel flange. TSTF-361 added a note that allows one of the required RHR loops to be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for required surveillance testing, provided the other loop is operable and in operation.

Turkey Point TS 3.9.8.2 currently requires two independent RHR loops to be operable and one in operation when a unit is in Mode 6 with less than 23 feet of water above the top of the reactor vessel flange. It does not allow the nonoperating RHR loop to be made inoperable to support surveillance testing. The allowance is needed to provide the flexibility to perform surveillance testing while ensuring that there is reasonable time for operators to respond to and mitigate any expected failures. Therefore, to support required outage activities and still maintain the plant in a safe condition, the licensee requests that this footnote be added to TS 3.9.8.2.

The loss of one loop for a limited time will reduce the heat removal capability of the system. Therefore, plant configuration and activities need to be carefully considered before entering this condition. To ensure that appropriate considerations are addressed, the licensee plans to incorporate a concurrent change to its TS Bases. The proposed TS Bases change states, Specification 3.9.8.2 is modified by a footnote that allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided the other loop is OPERABLE and in operation. Prior to declaring the loop inoperable, consideration should be given to the existing plant configuration. This consideration should include the core time to boil, that there is no draining operation to further reduce RCS water level, and that the capability exists to inject borated water into the reactor vessel. This permits surveillance tests to be performed on the inoperable loop during a time when these tests are safe and possible. The NRC staff concluded that the proposed change to the TS Bases adequately addressed the concern and should be incorporated in accordance with the licensees TS Bases Control Program.

The justification presented in the Traveler is applicable to Turkey Point. The Traveler is being adopted by Turkey Point with no significant changes.

In summary, the NRC staff has reviewed the licensees proposed changes to the Turkey Point Units 3 and 4 TSs. The proposed changes are consistent with the STSs, satisfy the 10 CFR 50.36(c)(2)(ii) criteria, maintain safety consistent with the Turkey Point Units 3 and 4 safety analyses and, therefore, are acceptable for inclusion in the TSs.

4.0 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.

5.0 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 and change surveillance requirements.

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 amendments also relate to changes in record keeping, reporting, or administrative procedures or requirements. 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 (70 FR 12747). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). 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.

6.0 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 Contributors: T. Tjader K. Wood R. Pelton K. Martin Date: May 26, 2006

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

Mr. William E. Webster Vice President, Nuclear Operations Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.

Suite 220 Washington, DC 20004 T. O. Jones, Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 County Manager Miami-Dade County 111 Northwest 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission 9762 SW. 344th Street Florida City, Florida 33035 Mr. William A. Passetti, Chief 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 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Michael O. Pearce Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Walter Parker Licensing Manager Turkey Point Nuclear Plant 9760 SW 344th Street Florida City, FL 33035 Mark Warner, Vice President Nuclear Operations Support Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Rajiv S. Kundalkar Vice President - Nuclear Engineering Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420