L-2014-114, Proposed Change to Turkey Point Units 3 and 4 Technical Specifications to Remove RCS Chemistry Requirements and Relocate to Licensee-Controlled Documents. License Amendment Request No. 233

Proposed Change to Turkey Point Units 3 and 4 Technical Specifications to Remove RCS Chemistry Requirements and Relocate to Licensee-Controlled Documents. License Amendment Request No. 233

ML14252A230
Person / Time
Site:	Turkey Point
Issue date:	08/29/2014
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-114
Download: ML14252A230 (20)

Text

PPL.

L-2014-114 10 CFR 50.90 August 29, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed Change to Turkey Point Technical Specifications to Remove RCS Chemistry Requirements and Relocate to Licensee-Controlled Documents License Amendment Request No. 233 Pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL) hereby requests an amendment to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4. The proposed amendment would remove Technical Specification (TS) Limiting Condition for Operation (LCO) 3/4.4.7, "Chemistry," and relocate the requirements to the Turkey Point Updated Final Safety Analysis Report (UFSAR) and related procedures. This proposed amendment is consistent with NUREG- 1431, "Standard Technical Specifications for Westinghouse Plants."

The Enclosure to this letter contains a description of the proposed change and includes a no significant hazards determination and environmental considerations.

The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration.

There are no new commitments made in this submittal.

Once approved, the amendment shall be implemented within 60 days of its receipt by FPL.

The Turkey Point Nuclear Safety Committee (PNSC) has reviewed the proposed license amendment. In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the State Designee of Florida.

If you have any questions or require additional information, please contact Robert Tomonto at 305-246-7327.

Florida Power & Light Company 9760 SW 34 4 th St., Florida City, FL 33035

Florida Power & Light Company L-2014-114 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on: rl,?/Ily Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 1 of 8 Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 233 PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS TO REMOVE RCS CHEMISTRY REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS ENCLOSURE

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 2 of 8 TABLE OF CONTENTS LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS TO REMOVE RCS CHEMISTRY REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS SECTION TITLE PAGE Cover Sheet 1 Table of Contents 2

1.0 Purpose and Scope

3 2.0 Background Information 3 3.0 Description of Proposed Change 3 4.0 List of Commitments 5 5.0 Conclusion 5 6.0 No Significant Hazards Consideration 6 7.0 Environmental Considerations 8 ATTACHMENTS 1.0 Marked-up Technical Specifications Pages 2.0 Retyped Technical Specifications Pages

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 3 of 8

1.0 Purpose and Scope

Florida Power & Light Company (FPL) proposes to revise the Turkey Point (PTN) Units 3 and 4 licensing basis by removing Technical Specification (TS)

Limiting Condition for Operation (LCO) 3/4.4.7, "Chemistry," and relocating the requirements to the Turkey Point Updated Final Safety Analysis Report (UFSAR) and related procedures. Changes to the UFSAR and procedures are controlled in accordance with 10 CFR 50.59. The change is consistent with NUREG-1431, "Standard Technical Specifications for Westinghouse Plants."

Note that plant-specific TS relating to Reactor Coolant System (RCS) chemistry were not included in the original version of NUREG-1431 because this TS did not meet the TS inclusion requirements as identified in the NRC letter from T. E.

Murley to W. S. Wilgus, dated May 9, 1988.

2.0 Background Information TS LCO 3/4.4.7, "Chemistry," provides limits on the oxygen, chloride, and fluoride content in the RCS to minimize corrosion. Per the TS Bases, RCS chemistry parameters ensure that corrosion of RCS components is minimized and reduces the potential for RCS leakage or failure due to stress corrosion.

Maintaining the chemistry within limits provides adequate corrosion protection to ensure the structural integrity of the RCS over the life of the plant.

3.0 Description of Proposed Change TS LCO 3/4.4.7, "Chemistry," is proposed for removal from the TS and relocation to the Turkey Point UFSAR and related procedures. Changes to the relocated requirements will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required.

Note that the proposed removal from the TS results in several TS pages being deleted.

Regulatory and Technical Analysis RCS corrosion is a slow process which can be detected by in-service inspections or other means before significant degradation occurs. RCS chemistry is controlled to minimize corrosion over the long term. Although it is important to monitor and control RCS chemistry, limits and surveillance requirements do not meet the criteria of 10 CFR 50.36 for inclusion in the TS.

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 4 of 8 The NRC position on application of screening criteria to apply to TS LCO 3/4.4.7, "Chemistry," based on the Commission's Interim Policy Statement Criteria to Technical Specification Improvements is documented in a letter dated May 9, 1988 from T. E. Murley (NRC) to W. S. Wilgus (B&W Owners Group). The screening criteria were later incorporated into 10 CFR 50.36(c)(2)(ii), which contains the requirements for items that must be in the TS. An assessment of the current RCS chemistry TS requirements against the four criteria of 10 CFR 50.36(c)(2)(ii) is provided below.

(A) Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

The RCS chemistry limits are not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, the RCS chemistry limits do not meet Criterion 1.

(B) Criterion2. 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 RCS chemistry limits are not 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. Therefore, the RCS chemistry limits do not meet Criterion 2.

(C) Criterion3. 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.

The RCS chemistry limits are not 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. Therefore, the RCS chemistry limits do not meet Criterion 3.

(D) Criterion4. A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 5 of 8 The RCS chemistry limits are not a structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety. Therefore, the RCS chemistry limits do not meet Criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met for inclusion in the TS as a LCO, the RCS chemistry LCO and associated Applicability, Actions, and Surveillance Requirement may be removed from the TS and relocated to the UFSAR and related procedures. Following NRC approval of this proposed license amendment, changes to the relocated requirements will be controlled by the provisions of 10 CFR 50.59 to determine if prior NRC approval is required.

4.0 LIST OF COMMITMENTS NONE

5.0 CONCLUSION

Based on the above, removal of TS LCO 3/4.4.7, "Chemistry," from the TS and relocation to the Turkey Point UFSAR and related procedures does not adversely impact nuclear or public safety, plant safety, or the environment. This License Amendment Request is similar to a License Amendment Request approved by letter dated September 18, 2002 (ML022140131), "Hope Creek Generating Station - Issuance of Amendment Re: Relocation of Reactor Coolant System Chemistry Requirements (TAC No. MB4717)," and another License Amendment Request approved by letter dated July 23, 2008 (ML081400445), "Arkansas Nuclear One, Unit No. 2 - Issuance of Amendment Re: Technical Specification 3.4.7, 'Reactor Coolant System Chemistry' (TAC No. MD8313)."

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 6 of 8 6.0 NO SIGNIFICANT HAZARDS DETERMINATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazard if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

FPL is proposing that the Turkey Point Renewed Facility Operating Licenses be amended to remove Technical Specification (TS) Limiting Condition for Operation (LCO) 3/4.4.7, "Chemistry," and relocate the requirements to the Turkey Point Updated Final Safety Analysis Report (UFSAR) and related procedures. The proposed change is consistent with NUREG-1431, "Standard Technical Specifications for Westinghouse Plants."

FPL has reviewed this proposed license amendment and determined that its adoption would not involve a significant hazards consideration.

The basis for this determination is as follows:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The proposed change acts to remove current Reactor Coolant System (RCS) chemistry limits and monitoring requirements from the TS and relocate the requirements to the UFSAR and related procedures. Monitoring and maintaining RCS chemistry minimizes the potential for corrosion of RCS piping and components. Corrosion effects are considered a long-term impact on RCS structural integrity.

Because RCS chemistry will continue to be monitored and controlled, removing the current TS requirements and relocating the requirements to the UFSAR and related procedures will not present an adverse impact to the RCS and subsequently, will not impact the probability or consequences of an accident previously evaluated. Furthermore, once relocated to the UFSAR and related procedures, changes to RCS chemistry limits and monitoring requirements will be controlled in accordance with 10 CFR 50.59.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 7 of 8

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

No. The proposed change acts to remove current Reactor Coolant System (RCS) chemistry limits and monitoring requirements from the TS and relocate the requirements to the UFSAR and related procedures. The proposed change does not introduce new modes of plant operation and it does not involve physical modifications to the plant (no new or different type of equipment will be installed). There are no changes in the method by which any safety related plant structure, system, or component (SSC) performs its specified safety function. As such, the plant conditions for which the design basis accident analyses were performed remain valid.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of the proposed change. There will be no adverse effect or challenges imposed on any SSC as a result of the proposed change.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

No. Margin of safety is related to confidence in the ability of the fission product barriers to perform their accident mitigation functions.

The proposed change acts to remove current Reactor Coolant System (RCS) chemistry limits and monitoring requirements from the TS and relocate the requirements to the UFSAR and related procedures. The proposed change will maintain limits on RCS chemistry parameters and will continue to provide associated monitoring requirements. The proposed change does not physically alter any SSC. There will be no effect on those SSCs necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling ratio (DNBR) limits, loss of cooling accident peak cladding temperature (LOCA PCT), or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Conclusion:

Based on the above, FPL concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10

Turkey Point Units 3 and 4 L-2014-114 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 233 Page 8 of 8 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

7.0 ENVIRONMENTAL CONSIDERATION

S 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment of an operating license for a facility requires no environmental assessment, if the operation of the facility in accordance with the proposed amendment does not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in a significant increase in individual or cumulative occupational radiation exposure. FPL has reviewed this license amendment request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination is as follows.

Basis This change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1. As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does not involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed amendment does not change or modify the design or operation of any plant systems, structures, or components. The proposed amendment does not affect the amount or types of gaseous, liquid, or solid waste generated onsite. The proposed amendment does not directly or indirectly affect effluent discharges.

3. The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure. The proposed amendment does not change or modify the design or operation of any plant systems, structures, or components. The proposed amendment does not directly or indirectly affect the radiological source terms.

Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 233 PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS TO REMOVE RCS CHEMISTRY REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS ATTACHMENT 1 MARKED-UP TECHNICAL SPECIFICATIONS PAGES This coversheet plus 4 pages

INDEX LIMITING CONDITIONS FOR OPER.ATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION Startup and Power Operation ......................................................................... 3/44-1 H ot Stand by ................................................................................................... 3/4 4-2 Hot Shutdown ................................................................................................. 3/4 4-3 Cold Shutdown - Loops Filled ......................................................................... 3/4 4-5 Cold Shutdown - Loops Not Filled .................................................................. 3/4 4-6 3/4.4.2 SAFETY VALVES S h utd ow n ................................................................................................... 3/4 4-7 O pe ra ting ................................................................................................... 3/4 4-8 3/4.4.3 PRESSURIZER .............................................................................................. 3/4 4-9 314.4.4 RELIEF VALVES ............................................................................................ 3/4 4-10 3/4.4.5 STEAM GENERATOR (SG) TUBE INTEGRITY ............................................ 3/4 4-12 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection Systems ........................................................................... 3/4 4-13 Operational Leakage ...................................................................................... 314 4-14 TABLE 3.4-1 REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES..... 3/4 4-17 3/4.4.7 TABLE 3.4-2 "4MiE M 1T,' ,, v=.. = .. ................................................................. .. . .. . ...............

TABLE 4.4-3 RE",CTOR,

,*Q....COOLANdT TO .CYSTErA. .PT.D C.L ..EM:TR', LILM;TC °UL"'-;~LLAt'C.E SPECIFIC ACTIVITY.......................................... ............................................

3/4.4.8 314 4-21 TABLE 4.4-4 REACTOR COOLANT SPECIFIC ACTIVITY SAMPLE AND ANALYSIS PR O G RA M ................................................................................................... 3/4 4-22 TURKEY POINT - UNITS 3 & 4 vii AMENDMENT NOS.4"0AND N&6

REACTOR COOLANT SYSTEM 3/4.4.7 ,&GHA+&-R' D.L.FTrED

"*IMIIN CNDITION FOR OPERATION .

3.4.7 Th eactor Coolant System chemistry shall be maintained within the limits specified in Ta .4-2.

API TCBII At all times.

MODES 1,2, 3 and 4:

a. With any one or mo chemistry parameter in excess of' Steady-State Limit but within its Transient Limit, restore e parameter to within its S y-State Limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY withi he next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> an COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and

b. With any one or more chemistry par r in excess of its Transient Limit, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in CO UTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

At All Other Times:

With the concentration of eit chloride or fluoride in the Rcor Coolant System in excess of its Steady-State Lim it for m than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or in excess of its sient Limit, reduce the pressurizer pressure to lerss than equal to 500 psig, if applicable, and perfo an engineering evaluation to determine teef of the out-of-limit condition on the structural inte of the Reactor Coolant System; dete e that the Reactor Coolant System remains acceptable continued operation prior to increasin e pressurizer pressure above 500 psig or prior to proceeding MODE 4.

SURVEI L I... ... ... ...

4. The Reactor Coolant System chemistry shall be determined to be within the limits by analysis thos rameters at the frequencies specified in Table 4.4-3.

TURKEY POINT - UNITS 3 &4 3/4 4-18 AMENDMENT NOS.ift AND ,S&I

TABLE 3.4-2 STEADY STATE LIMIT S0.10 ppm

_<0.15 ppm ppm S0.15 ppm *1.50 ppm 250°F.

7 it not applicable with average reactor coolant Not required when reactor is defueled and RCS f TURKEY POINT - UNITS 3 & 4 3 /A4-19 AMENDMENT NOS.46QmANDWO I

TABLE 4.4-3 E L. OL' 11>T~f TEM.

Cl l~l3i~f 1MI3 3UVLILAIIE RQUIR1.1J2M At least 5 times per week not to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> between samp At least 5 times per week n o exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> between mp Fluoride" At least 5 times per w not to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> bet een samp les M6 t required with average reactor coolant temperature less than o Not required when reactor is defueled and RCS forced circulation TURKEY POINT - UNITS 3 & 4 3/4 4-20 AMENDMENT NOS. .6Q.AND -66.1

Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 233 PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS TO REMOVE RCS CHEMISTRY REQUIREMENTS AND RELOCATE TO LICENSEE-CONTROLLED DOCUMENTS ATTACHMENT 2 RETYPED TECHNICAL SPECIFICATIONS PAGES This coversheet plus 4 pages

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION Startup and Power Operation ......................................................................... 3/4 4-1 Hot Standby ................................................................................................... 3/4 4-2 Hot Shutdown ................................................................................................. 3/4 4-3 Cold Shutdown - Loops Filled ......................................................................... 3/4 4-5 Cold Shutdown - Loops Not Filled .................................................................. 3/4 4-6 3/4.4.2 SAFETY VALVES S h u td ow n ................................................................................................... 3/4 4-7 O p e ra tin g ................................................................................................... 3/4 4-8 3/4.4.3 PRESSURIZER ............................................................................................. 3/4 4-9 3/4.4.4 RELIEF VALVES ............................................................................................ 3/4 4-10 3/4.4.5 STEAM G ENERATO R (SG) TUBE INTEGRITY ............................................ 3/4 4-12 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection System s ........................................................................... 3/4 4-13 Operational Leakage ...................................................................................... 3/4 4-14 TABLE 3.4-1 REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES ............ 3/4 4-17 3/4.4.7 DELETED TABLE 3.4-2 DELETED TABLE 4.4-3 DELETED 3/4.4.8 SPECIFIC ACTIVITY ...................................................................................... 3/4 4-21 TABLE 4.4-4 REACTOR COOLANT SPECIFIC ACTIVITY SAMPLE AND ANALYSIS PROG RAM ................................................................................................... 3/4 4-22 TURKEY POINT - UNITS 3 & 4 vii AMENDMENT NOS. AND

REACTOR COOLANT SYSTEM 3/4.4.7 DELETED TURKEY POINT - UNITS 3 & 4 3/4 4-18 AMENDMENT NOS. AND

TABLE 3.4-2 DELETED TURKEY POINT - UNITS 3 & 4 3/4 4-19 AMENDIVIENTNOS. AND

TABLE 3.4-3 DELETED TURKEY POINT - UNITS 3 & 4 3/4 4-20 AMENDMENT NOS. AND