ML11167A291
| ML11167A291 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/16/2011 |
| From: | Jason Paige Division of Operating Reactor Licensing |
| To: | Tomonto B Florida Power & Light Co |
| References | |
| Download: ML11167A291 (3) | |
Text
1 NRR-PMDAPEm Resource From:
Paige, Jason Sent:
Thursday, June 16, 2011 9:58 AM To:
Tomonto, Bob Cc:
Czaya, Paul; Everett, Ronald; Hanek, Olga
Subject:
Turkey Point Units 3 and 4: TSTF-448 LAR - Requests for Additional Information
- Bob,
Below are requests for additional information (RAI) regarding the Turkey Point TSTF-448, Control Room Habitability license amendment request. On June 2, 2011, the Nuclear Regulatory Commission (NRC) staff and Florida Power & Light Company (FPL) discussed the draft RAIs to gain a common understanding of the questions. During the call, it was concluded that FPL understood the questions but additional follow-up from FPL would be needed to ensure that the responses addressed the NRC staffs questions. On June 16, 2011, FPL notified the NRC that the questions could be formally issued. The below RAIs reflect the questions discussed during the June 2, 2011, call. FPL agreed upon providing its response within 30 days of the date of this email. If you have any questions, feel free to contact me.
- 1. On page 2 of 7 of Enclosure 1 to your letter dated July 16, 2010, it states that Turkey Point does not have an administrative control technical specification (TS) requirement for a ventilation filter testing program (VFTP), so the TS 4.7.5.d test flow rate is specified in lieu of the VFTP. As stated in the program and manuals section of the standard technical specifications (STSs) as modified by TSTF-448 Revision 3, Paragraph (d) of Section [5.5.18], Control Room Habitability Program, a differential pressure test is to be conducted between performances of inleakage testing for the purpose of providing input to a periodic assessment of the control room envelope (CRE) boundary. The technical analysis section of TSTF-448 Revision 3 on Page 8 provides an explanation of the basis for Paragraph (d), which was approved by the NRC staff and made available in the Federal Register dated January 17, 2007. The NRC staff understands that Turkey Point does not have a VFTP, nevertheless, all plants requesting the adoption of TSTF-448 should include in its request, a method to collect data that will serve as input to a periodic assessment of the CRE boundary.
The NRC staff is not clear how TS 4.7.5.d addresses the intent of TSTF-448 Revision 3, Paragraph (d) of Section [5.5.18] of your control room habitability (CRH) program. Justify how TS 4.4.5.d meets the intent of TSTF-448 Revision 3, TS 5.5.18.d or provide a method to collect data, and an explanation of how you intend to use it, that can be used as input to a periodic assessment of your CRE boundary.
The method should, to the extent practicable, provide information that can be used in a manner similar to that of Paragraph (d) of Section [5.5.18] of the programs and manuals section of the STSs as modified by Revision 3 of TSTF-448
- 2. On page 2 of 7 to address the issue of chemical and smoke hazards, FPL proposed that TS Action 3.7.5.b address the issue as follows:
Verify mitigating actions ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants are protected from chemical hazards and smoke.
The above language was proposed in TSTF-508 Revision 1, Revise Control Habitability Actions to Address Lessons Learned from TSTF-448 implementation, and by letter dated May 11, 2011, TSTF-508 was withdrawn. To be consistent with the intent of TSTF-448, Revision 3, acceptable wording is, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smoke hazards. In order to be consistent with the intent of TSTF-448, the NRC staff is requesting that FPL provide acceptable wording for TS Action 3.7.5.b.
2
- 3. On page 4 of 7 it states, For line item c of the TS 6.8.4.k Control Room Envelope Habitability Program elements, TSTF-448 recognizes that there may be plant-specific exceptions to the guidance for performance of the unfiltered air inleakage test. FPL identified the need for such an exception for Turkey Point based on its review of Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0, and the exception is included in the proposed amendment, which reads as follows:
AppropriateapplicationofASTME741shallincludetheabilitytotakeminorexceptionstothetest methodology.Theseexceptionsshallbedocumentedinthetestreport.
TheNRCstaffspositionisthatitisindeedacceptabletodocumentexceptionstoatestmethodologyinatest report.However,includingunidentifiedexceptionsintheTSsisnotconsistentwithTSTF448Revision3.The NRCstaffrequeststhatthelicenseeremovetheproposedlanguage,asstatedabove,fromyourrequestto adoptTSTF448.
- 4. On page 4 of 7, it states that in order to be consistent with line item (c) of the CRE Habitability Program elements, the proposed wording in the last sentence of line item d for the TS 6.4.8.k program elements is changed slightly from the wording in TSTF-448. The licensee proposed that the last sentence of line item d of the TS 6.4.8.k program elements reads, The results shall be trended and used as part of the periodic assessment of the CRE boundary. The NRC staff has determined that the proposed change to line item d is not consistent with the intent of TSTF-448. However, an acceptable compromise to the words in TSTF-448 Revision 3 is, the results shall be trended and assessed every [18] months. In order to be in compliance with the intent of TSTF-448 the NRC staff is requesting that FPL revise the requested amendment to include these suggested words.
- 5. The NRC staff is requesting that the TS bases be updated to be consistent with TSTF-448 Revision 3.
Jason Paige, Turkey Point Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Phone: (301) 415-5888
Hearing Identifier:
NRR_PMDA Email Number:
80 Mail Envelope Properties (Jason.Paige@nrc.gov20110616095800)
Subject:
Turkey Point Units 3 and 4: TSTF-448 LAR - Requests for Additional Information Sent Date:
6/16/2011 9:58:08 AM Received Date:
6/16/2011 9:58:00 AM From:
Paige, Jason Created By:
Jason.Paige@nrc.gov Recipients:
"Czaya, Paul" <Paul.Czaya@fpl.com>
Tracking Status: None "Everett, Ronald" <Ronald.Everett@fpl.com>
Tracking Status: None "Hanek, Olga" <Olga.Hanek@fpl.com>
Tracking Status: None "Tomonto, Bob" <Bob.Tomonto@fpl.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 5843 6/16/2011 9:58:00 AM Options Priority:
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