ML062420034
| ML062420034 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/31/2006 |
| From: | Moroney B NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Stall J Florida Power & Light Co |
| Moroney B, NRR/DORL, 415-3974 | |
| References | |
| TAC MC1389, TAC MC1390 | |
| Download: ML062420034 (5) | |
Text
August 31, 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 NUCLEAR PLANT, UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT REQUEST (TAC NOS. MD1389 AND MD1390)
Dear Mr. Stall:
By letter dated April 27, 2006, Florida Power & Light Company requested amendments to the technical specifications (TSs) for Turkey Point Nuclear Plant, Units 3 and 4, regarding steam generator tube integrity, based on TS Task Force traveler TSTF-449.
The U.S. Nuclear Regulatory Commission staff has reviewed your requests and finds that a response to the enclosed Request for Additional Information is needed before we can complete the review.
This request was discussed with members of your staff and on August 24, 2006, Ms. Olga Hanek agreed that a response would be provided by October 16, 2006. If you have any questions, please contact me at (301) 415-3974.
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
Enclosure:
Request for Additional Information cc w/encl: See next page
August 31, 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 NUCLEAR PLANT, UNITS 3 AND 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT REQUEST (TAC NOS. MD1389 AND MD1390)
Dear Mr. Stall:
By letter dated April 27, 2006, Florida Power & Light Company requested amendments to the technical specifications for Turkey Point Nuclear Plant, Units 3 and 4, regarding steam generator tube integrity, based on TS Task Force traveler TSTF-449.
The U.S. Nuclear Regulatory Commission staff has reviewed your requests and finds that a response to the enclosed Request for Additional Information is needed before we can complete the review.
This request was discussed with members of your staff and on August 24, 2006, Ms. Olga Hanek agreed that a response would be provided by October 16, 2006. If you have any questions, please contact me at (301) 415-3974.
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
Enclosure:
Request for Additional Information cc w/encl: See next page Distribution:
PUBLIC LPL2-2 R/F RidsNrrPMBMoroney RidsNrrDorlLpl2-2 RidsNrrLABClayton RidsNrrDciCsgb RidsOgcRp RidsRgn2MailCenter RidsAcrsAcnwMailCenter RidsNrrDorlDpr YDiaz-Castillo, NRR ADAMS ACCESSION No.: ML062420034 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA CSGB/BC LPL2-2/BC NAME BMoroney BClayton AHiser by memo dated JDixon-Herrity DATE 8/30/06 8/30/06 07/17/06 8/31/06 OFFICIAL RECORD COPY
Enclosure REQUEST FOR ADDITIONAL INFORMATION TURKEY POINT NUCLEAR PLANT, UNIT NOS. 3 AND 4 STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT DOCKET NOS. 50-250 AND 50-251 By letter dated April 27, 2006, Florida Power & Light Company requested an amendment to the Turkey Point Nuclear Plant, Units 3 and 4, technical specifications (TSs) regarding steam generator (SG) tube integrity, based on TS Task Force traveler TSTF-449.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed this request and finds that the following additional information is needed to complete the review.
1.
On pages 6 and 15 of Enclosure 2, the proposed revisions to TS Table 3.3-4, Action 26-3, and TS 3.4.6.1, Action a.3, add the statement per Surveillance Requirement 4.4.6.2.1.c. The purpose of adding this statement is not clear since Surveillance Requirement (SR) 4.4.6.2.1.c has no additional details. In addition, the proposed revisions to these action statements require the Reactor Coolant System (RCS) water inventory balance to be performed at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, which appears to conflict with the 24-hour requirement in the current SR 4.4.6.2.1.c and the proposed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in the current application. Please explain the purpose of adding this statement or discuss your plans to remove it.
2.
On page 17 of Enclosure 2, the proposed revision to SR 4.4.6.2.1.c changes the frequency of performing the RCS water inventory balance from 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Even though TSTF-449 states a frequency of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, this change must be justified on a plant-specific basis. Please provide a technical justification for why this change is acceptable for Turkey Point or modify your proposed TS to be consistent with your current TS with respect to this issue.
3.
The current Bases for TS 3/4.4.4.6.2 (as shown on page 4 of Enclosure 4) states that the dosage contribution from the tube leakage will be limited to a small fraction of Title 10, Code of Federal Regulations (10 CFR), Part 100 dose guideline values.
However, on pages 7 and 12 of Enclosure 4, the proposed Bases state that the dose consequences are within the limits of 10 CFR Part 100 as well as 10 CFR Part 50.67.
Please clarify whether the current NRC approved accident source term is based on Part 100 (which is referenced in the current TS Bases), Part 50.67, or both?
4.
It is the NRC staffs understanding that the accident analysis for Turkey Point assumes that accident induced leakage does not exceed 500 gallons per day (gpd) in any one of the three SGs and the total leakage from all SGs does not exceed 1 gallon per minute (gpm) at accident conditions. There are five instances (pages 7, 8, 12, 13, and 18 of ) where the accident induced leakage assumption is cited in the Bases. The accident analysis assumptions discussed on these pages vary and in some cases could be potentially misinterpreted. Please confirm the staffs understanding of your accident analysis assumptions concerning primary-to-secondary leakage and discuss your plans to modify the proposed Bases to more clearly define your accident analysis leakage assumptions. In addition, on page 13 of Enclosure 4, there is a statement that the 500 gpd primary-to-secondary leakage in each SG at accident conditions is relatively inconsequential. This statement appears to contradict the previous paragraph and other portions of your submittal. Please clarify.
5.
On page 8 of Enclosure 4, the last sentence of the third paragraph states that the accident induced leakage rate assumption conservatively bounds the expected total accident primary-to-secondary leakage based on the allowable operational leakage rate as an initial condition and considers any leakage changes as a result of the accident induced changes in primary-to-secondary pressure differential. This statement appears to imply that, by satisfying the operating leakage limit, the accident induced leakage limit would never be exceeded. Since operating experience indicates that this is not the case, please discuss your plans to remove or modify this statement. In addition, discuss your plans to include the definition of accident induced leakage into the Bases. The definition is in TSTF-449 (The accident induced leakage rate includes any primary to secondary leakage existing prior to the accident in addition to primary to secondary leakage induced during the accident).
6.
On pages 14 and 17 of Enclosure 4, there appear to be two typographical errors. The first is under the paragraph for IDENTIFIED LEAKAGE toward the end of the first sentence. The sentence reads:... and is well with in the capability... The sentence should read:... and is well within the capability... The second one is under the list of References. Reference 6 should be 10 CFR 50.67 instead of 10 CFR 50.76.
7.
On page 17 of Enclosure 4, you stated that the 150-gpd limit is measured at room temperature as described in Reference 1. Please confirm that this is the correct reference. In addition, discuss your plans to cite Reference 5 at this location since Reference 5 also discusses this issue.
8.
There are several proposed changes to the Bases for the Reactor Coolant System leakage section that go beyond TSTF-449. Please confirm that all of the proposed changes are consistent with your current design and licensing bases. If they are not consistent, please provide a technical justification for the differences or discuss your plans to remove them.
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