L-2009-016, License Amendment Request for Adoption of TSTF-511, Rev. 0, Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26
| ML091130227 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/13/2009 |
| From: | Jefferson W Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2009-016 | |
| Download: ML091130227 (12) | |
Text
FPL.
April 13, 2009 POWERING TODAY.
EMPOWERING TOMORROW.
L-2009-016 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555.
RE:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request for Adoption of TSTF-51 1, Rev. 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26."
In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Florida Power and Light (FPL) is submitting a request for an amendment to the Technical Specifications (TSs) for Turkey Point Units 3 and 4.
The proposed amendment would delete those portions of TSs superseded by 10 CFR Part 26, Subpart I. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-5 11, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." The availability of this TS improvement was announced in the Federal Register on December 30, 2008 (73 FR 79923) as part of the consolidated line item improvement process (CLIIP). provides an evaluation of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides the proposed TS changes in final typed format. Attachment 4 provides the regulatory commitment.
FPL requests approval of the proposed license amendment by August 31, 2009, to support implementation of TS changes concurrent with implementation of the new 10 CFR 26, Subpart I requirements by October 1, 2009. This letter contains one regulatory commitment as identified in Attachment 4.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Official. If you should have any questions regarding this submittal, please contact Robert J. Tomonto at (305) 246-7327.
an FPL Group company
L-2009-016 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on the day of A[IV'/
2009.
Sincerely, Turkey Point Nuclear Plant WJ/OIH Attachments:
- 1. Evaluation of Proposed Change
- 2. Proposed Technical Specification Change (Mark-Up)
- 3.
Proposed Technical Specification Change (Re-Typed)
- 4. List of Regulatory Commitments cc: Regional Administrator, Region II, USNRC USNRC Project Manager, Turkey Point Nuclear Plant Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Mr. William A. Passetti, Florida Department of Health
Turkey Point Units 3 and 4 L-2009-016 Docket Nos. 50-250 and 50-251 Page 1 of 5 Evaluation of Proposed Change License Amendment Request for Adoption of TSTF-5 11, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26."
1.0 Description 2.0 Proposed Change
3.0 Background
4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Determination 5.2 Applicable Regulatory Requirements/Criteria 6.0 Environmental Consideration 7.0 References
1.0 DESCRIPTION
The proposed amendment would delete those portions of Technical Specifications (TSs) superseded by 10 CFR Part 26, Subpart I. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-5 11, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26." Minor differences between the proposed plant specific TS changes, and the changes proposed by TSTF-5 11 are listed in section 2.0.
The availability of this TS improvement was announced in the Federal Register on December 30, 2008 (73 FR 79923) as part of the consolidated line item improvement process (CLIIP).
2.0 PROPOSED CHANGE
Consistent with the NRC approved Revision 0 of TSTF-5 11, the proposed TS changes delete those portions of TSs superseded by 10 CFR Part 26, Subpart I. This application is being made in accordance with the CLIIP. The Turkey Point Units 3 and 4 custom TSs contain work hour requirements in TS 6.8.5 instead of TS 5.2.2.d as found in the Westinghouse Standard TSs. The minor variations from the TS changes described in TSTF-5 11, Revision 0, remain bounded by the NRC Staff's model safety evaluation (SE) published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability and are required due to the custom nature of the Turkey Point TSs.
Turkey Point Units 3 and 4 L-2009-016 Docket Nos. 50-250 and 50-251 Page 2 of 5
3.0 BACKGROUND
The NRC issued a Federal Register notice (73 FR 16966, March 31, 2008) of the issuance of a final rule that amended 10 CFR Part 26. The revised regulations in 10 CFR Part 26, Subpart I supersede working hour restrictions contained in Turkey Point Units 3 and 4 TS 6.8.5. The background for this application is adequately addressed by the NRC Notice of Availability published on December 30, 2008 (73 FR 79923).
4.0 TECHNICAL ANALYSIS
FPL has reviewed the SE published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. FPL has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to Turkey Point Units 3 and 4. 10 CFR Part 26, Subpart I, supersedes existing worker fatigue guidance. 10 CFR Part 26, Subpart I, distinguishes between work hour controls and fatigue management and strengthens the requirements for both.
Under the new rule, work hour restrictions include not only work hour limitations for rolling 24-hour, 48-hour, and 7-day periods, but also include a required minimum break between work periods and varying required minimum days off. Additionally, Subpart I confines the use of waivers (deviations from restrictions) to situations where overtime is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility. Subpart I also strengthens reporting requirements. Finally, the new rule's work hour control scope includes certain operating and maintenance personnel, as well as individuals directing those operating and maintenance personnel, health physics and chemistry personnel who are a part of the on-site emergency response organization minimum shift complement, the fire brigade member who is responsible for understanding the effects of fire and fire suppressants on safe shutdown capability, and certain security personnel.
The proposed change removes working hour limits imposed in the TS in order to support compliance with 10 CFR Part 26, Subpart I. Work hour controls and fatigue management requirements have been incorporated into the NRC's regulations; therefore, it is unnecessary to have work hour control requirements in the TSs.
Removal of the Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I, requirements, even if the Technical Specification change is implemented prior to the October 1, 2009 deadline.
Along with this LAR, FPL has submitted a commitment to comply with 10 CFR Part 26 concurrently with the implementation of the Technical Specification change.
Turkey Point Units 3 and 4 L-2009-016 Docket Nos. 50-250 and 50-251 Attachment I Page 3 of 5 5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS DETERMINATION FPL has reviewed the no significant hazards determination published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. FPL has concluded that the determination presented in the notice is applicable to Turkey Point Units 3 and 4.
FPL has evaluated the proposed changes to the TSs using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:
Criterion 1: The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26.
Removal of the Technical Specification requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I, requirements. The proposed change does not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected. Worker fatigue is not an initiator of any accident previously evaluated. Worker fatigue is not an assumption in the consequence mitigation of any accident previously evaluated.
Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2: The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident From Any Accident Previously Evaluated.
The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. Working hours will continue to be controlled in accordance with NRC requirements. The new rule allows for deviations from controls to mitigate or prevent a condition adverse to safety or as necessary to maintain the security of the facility. This ensures that the new rule will not unnecessarily restrict working hours and thereby create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not alter the plant configuration, require new plant equipment to be installed, alter accident analysis assumptions, add any initiators, or effect the
Turkey Point Units 3 and 4 L-2009-016 Docket Nos. 50-250 and 50-251 Page 4 of 5 function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
Criterion 3: The Proposed Change Does Not Involve a Significant Reduction in a Margin of Safety.
The proposed change removes Technical Specification restrictions on working hours for personnel who perform safety related functions. The Technical Specification restrictions are superseded by the worker fatigue requirements in 10 CFR Part 26. The proposed change does not involve any physical changes to the plant or alter the manner in which plant systems are operated, maintained, modified, tested, or inspected. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change. The proposed change will not result in plant operation in a configuration outside the design basis. The proposed change does not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition. Removal of plant-specific Technical Specification administrative requirements will not reduce a margin of safety because the requirements in 10 CFR Part 26 are adequate to ensure that worker fatigue is managed.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, FPL concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on December 30, 2008 (73 FR 79923)
FPL has reviewed the NRC staff's model SE published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to Turkey Point Units 3 and 4.
The proposed change eliminates the plant-specific Technical Specification administrative controls on working hours. The Technical Specification guidance has been superseded by 10 CFR Part 26.
10 CFR Part 26, Subpart I, "Managing Fatigue," contains requirements for managing worker fatigue at operating nuclear power plants. 10 CFR 50.36 provides, among other things, the regulatory requirements for the content in the Administrative Controls section
Turkey Point Units 3 and 4 L-2009-016 Docket Nos. 50-250 and 50-251 Page 5 of 5 of the TSs. The inclusion of requirements to control working hours and manage fatigue is not required to be in the Administrative Controls by 10 CFR Part 50.36. Because the requirement to control working hours and manage fatigue is provided in 10 CFR Part 26, Subpart I, it is unnecessary for the TSs to contain similar controls.
6.0 ENVIRONMENTAL CONSIDERATION
FPL has reviewed the environmental evaluation included in the safety evaluation (SE) published on December 30, 2008 (73 FR 79923) as part of the CLIIP Notice of Availability. FPL has concluded that the staff's findings presented in that evaluation are applicable to Turkey Point Units 3 and 4. The proposed amendment changes recordkeeping, reporting, or administrative procedures. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 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 amendment.
7.0 REFERENCES
- 1. Federal Register Notice, Final Rule 10 CFR Part 26 published on March 31, 2008.
- 2. TSTF-51 1, Revision 0, "Eliminate Working Hour Restrictions from TS 5.2.2 to Support Compliance with 10 CFR Part 26."
- 3. Federal Register Notice, Notice of Availability published on December 30, 2008 (73 FR 79923)
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2009-016 Page 1 of 2 Proposed Technical Specification Change (Mark-Up)
Page 6-18b
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2009-016 Page 2 of 2 PROCEDURES AND PROGRAMS (Continued)
- d.
Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube repair criteria. For Unit 3 during Refueling Outage 23 and the subsequent operating cycles until the next scheduled inspection, and for Unit 4 during Refueling Outage 23 and the subsequent operating cycles until the next scheduled inspection, the portion of the tube below 17 inches from the top of the hot leg tubesheet is excluded from inspection when the alternate tube repair criteria in Specification 6.8.4.j.c.1 is implemented. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation shall be performed to determine the type and location of flaws to which the tube may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.
- 1.
Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.
- 2.
Inspect 100% of the tubes at sequential periods of 120, 90, and, thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outages nearest the end of the period. No SG shall operate for more than 48 effective full power months or two refueling outages (whichever is less) without being inspected.
- 3.
If crack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.
~L.1Ie.
Provisions for monitoring operational primary-secondary leakage.
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TURKEY POINT - UNITS 3 & 4 6-18b AMENDMENT NOS. 2,3 AND 2-2
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2009-016 Page 1 of 2 Proposed Technical Specification Change (Re-Typed)
Page 6-18b
Turkey Point Units 3 and 4 L-2009-016 Docket Nos. 50-250 and 50-251 Page 2 of 2 ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)
- d.
Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube repair criteria. For Unit 3 during Refueling Outage 23 and the subsequent operating cycles until the next scheduled inspection, and for Unit 4 during Refueling Outage 23 and the subsequent operating cycles until the next scheduled inspection, the portion of the tube below 17 inches from the top of the hot leg tubesheet is excluded from inspection when the alternate tube repair criteria in Specification 6.8.4.j.c.1 is implemented. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. An assessment of degradation shall be performed to determine the type and location of flaws to which the tube may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.
1.
Inspect 100% of the tubes in each SG during the first refueling outage following SG replacement.
- 2.
Inspect 100% of the tubes at sequential periods of 120, 90, and, thereafter, 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs. In addition, inspect 50% of the tubes by the refueling outage nearest the midpoint of the period and the remaining 50% by the refueling outages nearest the end of the period. No SG shall operate for more than 48 effective full power months or two refueling outages (whichever is less) without being inspected.
- 3.
If crack indications are found in any SG tube, then the next inspection for each SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever is less). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.
- e.
Provisions for monitoring operational primary-secondary leakage.
6.8.5 DELETED TURKEY POINT - UNITS 3 & 4 6-1 8b AMENDMENT NOS-AND
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2009-016 Page 1 of 1 List of Regulatory Commitments Commitment:
Removal of the plant-specific TS requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements. This commitment will be completed no later than October 1, 2009.