Text

Proposed Changes to Turkey Point Technical Specifications (TS) Regarding Non-Conservative Action and Surveillance Requirement in TS 3/4.5.2 License Amendment Request No. 212 Resubmission
	ML14337A013
Person / Time
Site:	Turkey Point
Issue date:	11/13/2014
From:	Kiley M; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2014-222, TAC MF0084, TAC MF0085
	Download: ML14337A013 (22)
	v • d • e

0 L-2014-222 10 CFR 50.90 November 13, 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 Changes to Turkey Point Technical Specifications (TS) Regarding Non-Conservative Action and Surveillance Requirement in TS 3/4.5.2 License Amendment Request No. 212 Resubmission

References:

(1) NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," December 29, 1998 (Accession Number ML031110108)

(2) Florida Power & Light Company letter L-2012-368, "License Amendment Request No.

212 Regarding Potential Non-Conservative Action and Surveillance Requirement in Technical Specification 3.5.2 on ECCS Subsystems," dated October 30, 2012 (Accession Number ML12307A019)

(3) Electronic Mail from Audrey Klett, NRC Project Manager for Turkey Point Nuclear Plant, to Turkey Point Licensing Department, "Request for Additional Information (RAI) for Turkey Point LAR 212 (TACs MF0084 and MF0085)," dated November 7, 2013 (Accession Number ML14013AO05)

(4) Florida Power & Light Company letter L-2014-060, "Withdrawal of License Amendment Request No. 212: Potential Non-Conservative Action and Surveillance Requirement in Technical Specification 3.5.2 on ECCS Subsystems," dated March 26, 2014 (Accession Number ML14104B433)

A non-conservative Technical Specification (TS) Action and Surveillance Requirement (SR) have been identified that required imposing administrative controls in accordance with Administrative Letter 98-10 (Reference 1) regarding TS 3/4.5 2, "ECCS Subsystems - Tavg Greater Than or Equal To 350'F." In Reference 2, Florida Power & Light Company (FPL) proposed TS changes to address non-conservative TS contained in TS 3/4.5.2. In addition, TS changes were proposed to TS 3/4.8.1.1, "Electrical Power Systems - A.C. Sources - Operating,"

and TS 3/4.5 2 to address overlapping requirements for electrical power supply to the high head safety injection pumps.

Aool Florida Power & Light Company 9760 SW 3 44th St., Florida City, FL 33035

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Page 2 of 2 By Reference 3, the NRC staff requested additional information (RAI) regarding the FPL application. After discussion with the NRC staff regarding the RAI and proposed changes, FPL submitted Reference 4. In Reference 4, FPL withdrew the Reference 2 application to restructure the request and proposed changes and resubmit a revised application at a later date. Pursuant to 10 CFR 50.90, FPL hereby requests a License Amendment to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 to address non-conservative TS contained in TS 3/4.5.2.

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

The proposed changes have 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 these changes involve no significant hazards consideration.

There are no new commitments made in this submission.

Although this request is neither outage related nor required by any specific date, a prompt review is requested. Once approved, the amendment shall be implemented within 60 days of its receipt by FPL.

The Turkey Point Plant Nuclear Safety Committee 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.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November

/3, 2014 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 Docket Nos. 50-250 and 50-251 License Amendment Request No. 212 L-2014-222 Enclosure Page 1 of 12 Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 212 PROPOSED CHANGES TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING NON-CONSERVATIVE ACTION AND SURVEILLANCE REQUIREMENT IN TS 3/4.5.2 ENCLOSURE

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 2 of 12 TABLE OF CONTENTS LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING NON-CONSERVATIVE ACTION AND SURVEILLANCE REQUIREMENT IN TS 3/4.5.2 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 Changes 4

4.0 List of Commitments 8

5.0 Conclusion 8

6.0 No Significant Hazards Consideration 9

7.0 Environmental Considerations 11 8.0 References 12 ATTACHMENTS 1.0 Marked-up Technical Specifications Pages 2.0 Retyped Technical Specifications Pages

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 3 of 12

1.0 Purpose and Scope

Florida Power & Light Company (FPL) proposes to revise Turkey Point Units 3 and 4 Technical Specification (TS) 3/4.5.2, "ECCS Subsystems - Tavg Greater Than or Equal To 350'F," to correct a non-conservative Action and Surveillance Requirement (SR).

Specifically, changes are proposed to correct TS 3.5.2 Action 'a' such that the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Allowed Outage Time (AOT) will not apply to TS Limiting Condition for Operation (LCO) 3.5.2.d when the suction flow path from the Refueling Water Storage Tank (RWST) is inoperable. A new Action 'h' is proposed to restore the suction flow path from the RWST to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Action

'a' would also be revised to clarify that it is only applicable to Residual Heat Removal (RHR) heat exchangers and the suction flow paths from the containment sump. Other TS Actions in LCO 3.5.2 address the remaining Emergency Core Cooling System (ECCS) equipment and flow paths.

A provision in SR 4.5.2.a permits restoration of power to listed isolation valves for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for temporary operation of the isolation valves for surveillance and maintenance. This provision would be changed to one hour to address this non-conservatism.

Editorial changes are also proposed for consistency and clarity.

2.0 Background Information A non-conservative TS Action and SR have been identified that required imposing administrative controls in accordance with Administrative Letter 98-10 (Reference 1) regarding TS 3/4.5 2, "ECCS Subsystems - Tavg Greater Than or EqualTo 350'F." TS 3/4.5.2 is applicable in MODES 1, 2, and 3 and specifies the Operability, Actions, and SRs for the High Head Safety Injection (HHSI) pumps, RHR pumps, RHR heat exchangers, and the associated discharge and suction source flow paths for the HHSI pumps and the RHR pumps. TS LCO 3.5.2 also specifies diesel generator power requirements for HHSI pumps.

The Safety Injection System is a system shared between Turkey Point Units 3 and 4.

There are four HHSI pumps available for Turkey Point Units 3 and 4. The RHR system is not shared between Turkey Point Units 3 and 4; rather, it has two RHR pumps per unit.

TS 3/4.5.2 was included in Turkey Point Units 3 and 4 TS Amendments 137 and 132 that were issued on August 28, 1990 (Reference 2), which converted the original custom TS to the revised TS based on Standard Technical Specifications (STS) for Westinghouse-designed plants (Reference 3).

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 4 of 12 Turkey Point Units 3 and 4 TS Amendments 101 and 95 were issued on February 22, 1984 (Reference 4), which added valves 863A and 863B to the existing list of valves required to have their power removed. Turkey Point Units 3 and 4 TS Amendments 101 and 95 also changed the provision to allow restoration of power for a limited time to comply with the TS SR. The temporary period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months was unchanged; the change only identified that temporary restoration of power may be necessary under limited circumstances to provide flexibility in the surveillance and maintenance of the valves.

3.0 Description of Proposed Changes The proposed TS changes involve TS 3.5.2 Action 'a', new TS 3.5.2 Action 'h', and the provision in SR 4.5.2.a. Editorial changes are also proposed in LCO 3.5.2, including its associated Actions and Notes, for consistency and clarity.

Proposed TS 3.5.2 Action 'a' would be changed to specifically require:

With one RHR heat exchanger or suction flow path from the containment sump inoperable, restore the inoperable RHR heat exchanger or suction flow path from the containment sump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

New TS 3.5.2 Action 'h' is proposed for LCO 3.5.2.d:

With the suction flow path from the refueling water storage tank inoperable, restore the suction flow path to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The provision in SR 4.5.2.a is being changed to read:

To permit positive valve position indication for surveillance or maintenance purposes in the event that the continuous valve position indication is unavailable in the control room, power may be restored to these valves for a period not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Editorial changes are proposed to LCO 3.5.2, TS 3.5.2 Action 'c', TS 3.5.2 Action 'd',

TS 3.5.2 Action 'e', TS 3.5.2 Action 'g', and the single star (*) and pound (#) footnotes to provide consistency and clarity. These editorial changes are described in more detail with an associated discussion below.

LCO 3.5.2 consists of the following and five subparts a through e.

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 5 of 12 3.5.2 The following Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE:

LCO 3.5.2.a would be revised as follows:

a.

Four OPERABLE Safety Injection (SI) pumps, each capable of being powered from its associated OPERABLE diesel generator?, with discharge flowpaths aligned to the RCS cold legs,*

The word OPERABLE is deleted from LCO 3.5.2.a because it is redundant to LCO 3.5.2, which requires ECCS equipment and flow paths to be OPERABLE. The words 'flow paths' are added to specifically include them in the operability requirement.

LCO 3.5.2.b would be revised as follows:

b.

Two OPERALE RHR heat exchangers, The word OPERABLE is deleted from LCO 3.5.2.b because it is redundant to LCO 3.5.2 which requires ECCS equipment and flow paths to be OPERABLE.

LCO 3.5.2.c would be revised as follows:

c.

Two OPERABLE RHR pumps with discharge flow paths aligned to the RCS cold legs, The word OPERABLE is deleted from LCO 3.5.2.c because it is redundant to LCO 3.5.2 which requires ECCS equipment and flow paths to be OPERABLE. The words 'flow paths' are added to specifically include them in the operability requirement.

TS 3.5.2 Action 'd' would be revised as follows:.

d.

n OPERA flow path capable of taking suction from the refueling water storage tank as defined in Specification 3.5.4, and The word OPERABLE is deleted from LCO 3.5.2.d because it is redundant to LCO 3.5.2 which requires ECCS equipment and flow paths to be OPERABLE.

LCO 3.5.2.e would be revised as follows:

e.

Two OPERABLE flow paths capable of taking suction from the containment sump.

The word OPERABLE is deleted from LCO 3.5.2.e because it is redundant to LCO 3.5.2 which requires ECCS equipment and flow paths to be OPERABLE.

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 6 of 12 TS 3.5.2 Action 'c' would be revised as follows:

c.

With one of the four required Safety Injection pumps or its associated discharge flow path inoperable and the opposite unit in MODE 1, 2, or 3, restore the pump orflowpath to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .***

TS 3.5.2 Action 'c' is revised to include the discharge flow path associated with each SI pump consistent with LCO 3.5.2.a.

TS 3.5.2 Action 'd' would be revised as follows:

d.

With two of the four required Safety Injection pumps or their associated discharge flow paths inoperable and the opposite unit in MODE 1, 2, or 3, restore one of the two inoperable pumps orflow paths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This ACTION applies to both units simultaneously.

TS 3.5.2 Action 'd' is revised to include the discharge flow path associated with each SI pump consistent with LCO 3.5.2.a.

TS 3.5.2 Action 'e' would be revised as follows:

e.

With one of the three required Safety Injection pumps or its associated discharge flow path inoperable and the opposite unit in MODE 4, 5, or 6, restore the pump orflow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

TS 3.5.2 Action 'e' is revised to include the discharge flow path associated with each SI pump consistent with LCO 3.5.2.a as modified by the single star (*) footnote for one unit in Modes 1, 2 or 3 and the other unit in Modes 4, 5, or 6.

TS 3.5.2 Action 'g' would be revised as follows:

g.

With an ECCS subsystem inoperable due to an RHR pump or its associated discharge flow path being inoperable, restore the inoperable RHR pump or its associated discharge flow path to OPERABLE status within 7 days or be in as least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 7 of 12 TS 3.5.2 Action 'g' is revised to include the discharge flow path associated with each RHR pump consistent with LCO 3.5.2.c.

Footnote

would be revised as follows:

Only three OPERABLE Safety Injection (SI) pumps (two associated with the unit and one from the opposite unit), each capable of being powered from its associated OPERABLE diesel generators, with discharge flow paths aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.

The word OPERABLE is deleted from footnote

because it is redundant to LCO 3.5.2 which requires ECCS equipment and flow paths to be OPERABLE. The words 'flow paths' are added to specifically include them in the operability requirement.

Footnote 4 would be revised as follows:

4Inoperability of the required EDGl.s diesel generators does not constitute inoperability of the associated Safety Injection pumps.

The acronym EDG's (emergency diesel generators) is replaced by the words 'diesel generators' for consistency with the LCOs, Actions, and footnotes where the words diesel generators are used in TS 3/4.5.2. The acronym EDG's is neither defined nor used elsewhere in TS 3/4.5.2. The acronym EDG is commonly used to refer to standby (emergency) diesel generators used to power plant equipment in the event offsite power is lost.

Regulatory and Technical Analysis TS 3.5.2 Action 'a' is applicable to required ECCS components or flow paths except for inoperable Safety Injection Pump(s) or an inoperable RHR pump. TS 3.5.2 Action 'a' would be changed to exclude an inoperable suction flow path from the RWST by providing actions specific for one RHR heat exchanger or suction flow path from the containment sump being inoperable.

Turkey Point Units 3 and 4 ECCS configuration has common suction piping from the RWST such that failure of an isolation valve could render both HHSI and/or RHR trains inoperable. Loss of the suction flow path from the RWST places Turkey Point Units 3 and 4 in a condition outside of the accident analysis; therefore, new TS 3.5.2 Action 'h' is proposed with actions consistent with the actions specified in LCO 3.0.3 to place the affected unit in the lowest mode (HOT SHUTDOWN) for which TS LCO 3.5.2 is no longer applicable. Together, the proposed change to TS 3.5.2 Action 'a' and the new TS 3.5.2 Action 'h' address the current non-conservative TS Action 'a' applicability to the suction flow path from the RWST.

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 8 of 12 The provision to permit temporary operation of isolation valves for surveillance or maintenance purposes in SR 4.5.2.a is being changed. Turkey Point Units 3 and 4 TS Amendments 101 and 95 (Reference 4) included this provision because the Control Room did not receive positive position indication for valves whose power has been removed to prevent a single failure problem. This omission was identified as a potential problem in itself in that if the position of one of these valves were to be changed at some time after power was removed, the Control Room would have no positive indication of the realignment. Plant modifications have been implemented, which were described in Turkey Point Units 3 and 4 TS Amendments 101 and 95 as being prepared to provide for single continuous position indication in the Control Room. The change to this provision to permit power to be restored to these valves for a period not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in order to provide positive valve position indication for surveillance or maintenance purposes in the event that the continuous valve position indication is unavailable in the Control Room addresses the non-conservative TS SR.

Editorial changes are proposed to LCO 3.5.2, TS 3.5.2 Action 'c', TS 3.5.2 Action 'd',

TS 3.5.2 Action 'e', TS 3.5.2 Action 'g', and the single star (*) and pound (#) footnotes to provide consistency and clarity.

4.0 LIST OF COMMITMENTS NONE

5.0 CONCLUSION

This License Amendment Request addresses non-conservative TS 3.5.2 Action 'a' by changing its scope to exclude an inoperable suction flow path from the RWST and by proposing a new TS 3.5.2 Action 'h', which specifies actions consistent with those specified in LCO 3.0.3 for an inoperable suction flow path from the RWST. This License Amendment Request also addresses non-conservative SR 4.5.2.a by changing the provision to permit power to be restored to any of the isolation valves for a period not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in order to provide positive valve position indication for surveillance or maintenance purposes in the event that the continuous valve position indication is unavailable in the Control Room. The editorial changes proposed to LCO 3.5.2, TS 3.5.2 Action 'c', TS 3.5.2 Action 'd', TS 3.5.2 Action 'e', TS 3.5.2 Action 'g', and the single star (*) and pound (#) footnotes provide consistency and clarity of existing requirements. Administrative controls established in response to the non-conservative TS will remain in place until the License Amendment Request is approved by the NRC and implemented.

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 9 of 12 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 Technical Specification (TS) changes that involve TS 3.5.2 Action 'a',

new TS 3.5.2 Action 'h', and the provision in SR 4.5.2.a to address non-conservative TS requirements. Editorial changes are also proposed for consistency and clarity.

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 TS changes involve TS 3.5.2 Action 'a', new TS 3.5.2 Action 'h', and the provision in SR 4.5.2.a to address non-conservative TS requirements. Editorial changes are also proposed for consistency and clarity.

These changes do not affect any precursors to any accident previously evaluated and subsequently, will not impact the probability or consequences of an accident previously evaluated. Furthermore, these changes do not adversely affect mitigation equipment or strategies.

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

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

No. The proposed TS changes involve TS 3.5.2 Action 'a', new TS 3.5.2 Action 'h', and the provision in SR 4.5.2.a to address non-conservative TS requirements. Editorial changes are also proposed for consistency and clarity.

The proposed changes provide better assurance that the ECCS systems, subsystems, and components are properly aligned to support safe reactor operation consistent with the licensing basis requirements. The proposed changes do not introduce new modes of plant operation and do not involve physical modifications to the plant (no new or different type of equipment will

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 10 of 12 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 changes do 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 TS changes involve TS 3.5.2 Action 'a', new TS 3.5.2 Action 'h', and the provision in SR 4.5.2.a to address non-conservative TS requirements.

Editorial changes are also proposed for consistency and clarity. The proposed changes provide better assurance that the ECCS systems, subsystems, and components are properly aligned to support safe reactor operation consistent with the licensing basis requirements. The proposed changes do not physically alter any SSC. There will be no effect on those SSCs necessary to assure the accomplishment of specified 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 changes do 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 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

Turkey Point Units 3 and 4 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 11 of 12

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 L-2014-222 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 212 Page 12 of 12

8.0 REFERENCES

1. NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety," December 29, 1998 (Accession Number ML031110108)

2. G. E. Edison, Sr. (NRC) to J. H. Goldberg (FPL), "Turkey Point Units 3 and 4 -

Issuance of Amendments RE: Replacement of Current Technical Specifications with Revised Technical Specifications (TAC NOS. 63038 and 63039, 55915 and 55916, 55384 and 55385, 71864 and 71865)" August 28, 1990 (Accession Number ML013370513)

3. NUREG-0452, Revision 4, Standard Technical Specifications for Westinghouse Pressurized Water Reactors, November 1981 (Accession Number ML102590431)

4. D. G. McDonald (NRC) to J. W. Williams, Jr. (FPL), February 22, 1984 (Accession Number MLO 13410472)

Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 212 PROPOSED CHANGES TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING NON-CONSERVATIVE ACTION AND SURVEILLANCE REQUIREMENT IN TS 3/4.5.2 ATTACHMENT 1 MARKED-UP TECHNICAL SPECIFICATIONS PAGES This coversheet plus 3 pages

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - T.,g GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION 3.5.2 The following Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE:

a.

Four OPRABL& Safety Injection (SI) pumps, each capable of being powered from its associated OPERABLE diesel generator#, with discharge aligned to the RCS cold legs,*

b.

Two OPERA06E RHR heat exchangers, flow paths

c.

Two OPERABL4 RHR pumps with discharge a tigned to the RCS cold legs,

d.

Ai OPERA86S flow path capable of taking suction from the refueling water storage tank as defined in Specification 3.5.4, and

e.

Two GQPERA1L-S flow paths capable of taking suction from the containment sump.

RHR heat APPLICABILITY: MODES 1, 2, and 3"*.,.....

exchanger, IKIRHR heat exchanger or suction flow ACTION:

Ipath from the containment sump Isuction

a.

With a9w-ne Of tho r~quirod ECCS sefmpGnontc Or flOW pathsnoperable,r

.. foy.njoctiOn PUF.p(. ) Or

.pG..

ble RHR pu. mp, restore the inoperable.e..P R....or flow pathE to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and ir¶A HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

1from the containment sump

b.

In the event the ECCS is actuated and injects water in the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date since January 1, 1990.

or its associated discharge flow path

c.

With one of the four required Safety Injection pumps inoperable and the opposite unit in MODE 1, 2, or 3, restore the pump to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and N HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .***

-or flow path Iflow paths--

Only three OPERAB-66 Safety Injection (SI) pumps (two associated with the unit and one from t opposite unit),

each capable of being powered from its associated OPERABLE diesel generator, with discharge aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.

"The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 3 for the Safety Injection flow paths isolated pursuant to Specification 3.4.9.3 provided that the Safety Injection flow paths are restored to OPERABLE status prior to Tavg exceeding 3800F. Safety Injection flow paths may be isolated when Tavg is less than 380'F.

- - The provisions of Specifications 3.0.4 and 4.0.4 are not applicable.

Inoperability of the required EDG's does not constitute inoperability of the associated Safety Injection pumps.

-diesel ýgeneratorsý TURKEY POINT - UNITS 3 & 4 3/4 5-3 AMENDMENT NOS. 24-- AND 206

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Taro GREATER THAN OR EQUAL TO 350°F or their associated discharge LIMITING CONDITION FOR OPERATION flow paths

d.

With two of the four required Safety Injection pumps inoperable and the opposite unit in MODE 1, 2, or 3, restore one of the two inoperable pumps to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next hours and in HOT SHUTDOWN within the followina 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This ACTION applies to both u its iuneouslv.

or its associated discharge flow path or flow paths

e.

With one or tne three required batety injection pupinoperable an t e opposite unit in MODE 4, 5, or 6, restore the pump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 u

6IHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f.

With a required Safety Injection pump OPERABLEbut not capable of being powered from its associated diesel generator, restore the capability within 14 days or be in at least HOT STANDBY vw-ithibn thp L

nB A hmirgand in HCTSHUI IOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Jor its associated discharge flow pathI--

g.

With an ECCS subsystem inoperable due to an RH um being inoperable, restore the inoperable RHR puml4o OPERABLE status within 7 days or be in as least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

<- h. With the suction flow path from the refueling water storage tank inoperable, restore the suction flow path to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

p1 TURKEY POINT - UNITS 3 & 4 3/45-4 AMENDMENT NOS. 246 AND 209

EMERGENCY CORE COOLING SYSTEMS in the event that continuous valve position SURVILLNCE EQUREMETS indication is unavailable in the control roomI 4.5.2 Each ECCS component and flow path shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying by control room indication that th following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position 864A and B Supply from RWST to ECCS Open 862A and B RWST Supply to RHR pumps Open 863A and B RHR Recirculation Closed 866A and B H.H.S.I. to Hot Legs losed HCV-758*

RHR HX Outlet en

'positive valve position indication To permit l.-..,pe-y SPOli,- Of th68 V81Y8. for surveillance or maintenance purpose, power may be restored to these valves for a period not to exceed 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b.

At least once per 31 days by:

1)

Verifying that the ECCS piping is full of water by venting the ECCS pump casings and accessible discharge piping,

2)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position, and

3)

Verifying that each RHR Pump develops the indicated differential pressure applicable to the operating conditions in accordance with Figure 3.5-1 when tested pursuant to Specification 4.0.5.

c.

At least once per 92 days by:

1)

Verifying that each SI pump develops the indicated differential pressure applicable to the operating conditions when tested pursuant to Specification 4.0.5.

SI pump

>_ 1083 psid at a metered flowrate _> 300 gpm (normal alignment or Unit 4 SI pumps aligned to Unit 3 RWST), or

> 1113 psid at a metered flowrate > 280 gpm (Unit 3 SI pumps aligned to Unit 4 RWST).

Air Supply to HCV-758 shall be verified shut off and sealed closed once per 31 days.

TURKEY POINT - UNITS 3 & 4 3/4 5-5 AMENDMENT NOS. 4-9-AND 48 I

Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 212 PROPOSED CHANGES TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING NON-CONSERVATIVE ACTION AND SURVEILLANCE REQUIREMENT IN TS 3/4.5.2 ATTACHMENT 2 RETYPED TECHNICAL SPECIFICATIONS PAGES This coversheet plus 3 pages

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Tavg GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION 3.5.2 The following Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE:

a.

Four Safety Injection (SI) pumps, each capable of being powered from its associated OPERABLE diesel generator#, with discharge flow paths aligned to the RCS cold legs,*

b.

Two RHR heat exchangers,

c.

Two RHR pumps with discharge flow paths aligned to the RCS cold legs,

d.

A flow path capable of taking suction from the refueling water storage tank as defined in Specification 3.5.4, and

e.

Two flow paths capable of taking suction from the containment sump.

APPLICABILITY: MODES 1, 2, and 3**.

ACTION:

a.

With one RHR heat exchanger or suction flow path from the containment sump inoperable, restore the inoperable RHR heat exchanger or suction flow path from the containment sump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

In the event the ECCS is actuated and injects water in the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date since January 1, 1990.

c.

With one of the four required Safety Injection pumps or its associated discharge flow path inoperable and the opposite unit in MODE 1, 2, or 3, restore the pump or flow path to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .***

Only three Safety Injection (SI) pumps (two associated with the unit and one from the opposite unit), each capable of being powered from its associated OPERABLE diesel generator, with discharge flow paths aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.

- The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 3 for the Safety Injection flow paths isolated pursuant to Specification 3.4.9.3 provided that the Safety Injection flow paths arerestored to OPERABLE status prior to Tavg exceeding 3800F. Safety Injection flow paths may be isolated when Tavg is less than 3800F.

- - The provisions of Specifications 3.0.4 and 4.0.4 are not applicable.

Inoperability of the required diesel generators does not constitute inoperability of the associated Safety Injection pumps.

TURKEY POINT - UNITS 3 & 4 3/4 5-3 AMENDMENT NOS-AND

EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Tavg GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION

d.

With two of the four required Safety Injection pumps or their associated discharge flow paths inoperable and the opposite unit in MODE 1, 2, or 3, restore one of the two inoperable pumps or flow paths to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This ACTION applies to both units simultaneously.

e.

With one of the three required Safety Injection pumps or its associated discharge flow path inoperable and the opposite unit in MODE 4, 5, or 6, restore the pump or flow path to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f.

With a required Safety Injection pump OPERABLE but not capable of being powered from its associated diesel generator, restore the capability within 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

I

g.

With an ECCS subsystem inoperable due to an RHR pump or its associated discharge flow path being inoperable, restore the inoperable RHR pump or its associated discharge flow path to OPERABLE status within 7 days or be in as least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

h.

With the suction flow path from the refueling water storage tank inoperable, restore the suction flow path to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

TURKEY POINT - UNITS 3 & 4 3/4 5-4 AMENDMENTNOS. AND

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS component and flow path shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying by control room indication that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position 864A and B Supply from RWST to ECCS Open 862A and B RWST Supply to RHR pumps Open 863A and B RHR Recirculation Closed 866A and B H.H.S.I. to Hot Legs Closed HCV-758*

RHR HX Outlet Open To permit positive valve position indication for surveillance or maintenance purposes in the event that continuous valve position indication is unavailable in the control room, power may be restored to these valves for a period not to exceed 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

b.

At least once per 31 days by:

1)

Verifying that the ECCS piping is full of water by venting the ECCS pump casings and accessible discharge piping,

2)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position, and

3)

Verifying that each RHR Pump develops the indicated differential pressure applicable to the operating conditions in accordance with Figure 3.5-1 when tested pursuant to Specification 4.0.5.

c.

At least once per 92 days by:

1)

Verifying that each SI pump develops the indicated differential pressure applicable to the operating conditions when tested pursuant to Specification 4.0.5.

SI pump

> 1083 psid at a metered flowrate _ 300 gpm (normal alignment or Unit 4 Sl pumps aligned to Unit 3 RWST), or

_> 1113 psid at a metered flowrate >280 gpm (Unit 3 SI pumps aligned to Unit 4 RWST).

Air Supply to HCV-758 shall be verified shut off and sealed closed once per 31 days.

TURKEY POINT - UNITS 3 & 4 3/4 5-5 AMENDMENT NOS.

AND

v t e Letter Sequence Request
TAC:MF0084, (Withdrawn, Closed) TAC:MF0085, (Withdrawn, Closed)
Initiation Request Acceptance... Administration Questions 7 November 2013 Answers Results Withdrawal Other:
MONTHYEAR2014-11-13 [Table View]

L-2014-222, Proposed Changes to Turkey Point Technical Specifications (TS) Regarding Non-Conservative Action and Surveillance Requirement in TS 3/4.5.2 License Amendment Request No. 212 Resubmission

Text

References:

1.0 Purpose and Scope

1.0 Purpose and Scope

5.0 CONCLUSION

7.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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L-2014-222, Proposed Changes to Turkey Point Technical Specifications (TS) Regarding Non-Conservative Action and Surveillance Requirement in TS 3/4.5.2 License Amendment Request No. 212 Resubmission

Text

References:

1.0 Purpose and Scope

1.0 Purpose and Scope

5.0 CONCLUSION

7.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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