ML16110A004

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NRR E-mail Capture - Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455 & MF5456)
ML16110A004
Person / Time
Site: Turkey Point  
Issue date: 04/18/2016
From: Audrey Klett
Plant Licensing Branch II
To: Guth M
Florida Power & Light Co
References
MF5455, MF5456
Download: ML16110A004 (2)


Text

1 NRR-PMDAPEm Resource From:

Klett, Audrey Sent:

Monday, April 18, 2016 4:17 PM To:

Guth, Mitch Cc:

Kilby, Gary; Cross, William; Hanek, Olga

Subject:

Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455 &

MF5456)

Hi Mitch, By application dated December 23, 2014 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML15029A297), Florida Power & Light Company (FPL, the licensee) submitted License Amendment Request (LAR) No. 236 for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point).

The proposed amendments would revise the Technical Specifications (TSs) to Implement TS Task Force (TSTF)-505, Revision 1, Provide Risk-Informed Extended Completion Times RITSTF [Risk-Informed TSTF]

Initiative 4b.

The U.S. Nuclear Regulatory Commissions (NRCs) Balance of Plant Branch (SBPB) staff reviewed the application and identified areas where it needs additional information to support its review. The staffs request for additional information (RAI) is provided below. As discussed with Ms. Olga Hanek of the licensees staff on April 18, 2016, the NRC is requesting the licensee to respond to the RAI within 60 calendar days of April 14, 2016.

SBPB RAI-1 In the event of one inoperable main steam isolation valve (MSIV), the current TS 3.7.1.5 requires entry into Hot Standby after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Turkey Point LAR proposed to revise the TS to require entry into MODE 2, after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As a basis for this change, the LAR indicates TSTF-505 contains incorrect structure, and in order to establish the correct structure for Turkey Point TS 3.7.1.5, FPL proposes that the required actions (RAs) for one or more inoperable MSIVs in Mode 1 require entering Mode 2, rather than Modes 3 and 4, if the MSIVs are not restored to operable status within the completion time (CT). While these changes are consistent with the STSs, this is a deviation from the current TS and allows an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in MODE 2. The staff is unable to locate a clear justification for this mode change. Please provide a technical justification for the proposed change from Hot Standby to MODE 2.

In addition, the LAR indicates this change aligns the Turkey Point TSs with TSTF-505 and is appropriate because it provides a subsequent RA if entry into Mode 2 is required because two or more inoperable MSIVs in Mode 1 are not restored to operable status within the CT. For complete alignment with TSTF-505, the staff finds the following actions missing from proposed TS change: (1) TSTF-505 includes a [8] hours completion time for closing MSIV for one or more MSIVs inoperable in MODE 2 or 3, but the proposed change to TS 3.7.1.5 does not specify a time limit for closing an inoperable MSIV in Modes 2 or 3; and (2) TSTF-505 includes a condition to verify MSIV is closed once per 7 days, but the proposed TS is missing any action for MSIV closure verification. Please provide an explanation why the LAR did not request adoption of the completion time and periodic MSIV closure verification.

Hearing Identifier:

NRR_PMDA Email Number:

2790 Mail Envelope Properties (Audrey.Klett@nrc.gov20160418161600)

Subject:

Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455

& MF5456)

Sent Date:

4/18/2016 4:16:39 PM Received Date:

4/18/2016 4:16:00 PM From:

Klett, Audrey Created By:

Audrey.Klett@nrc.gov Recipients:

"Kilby, Gary" <Gary.Kilby@fpl.com>

Tracking Status: None "Cross, William" <WILLIAM.CROSS@fpl.com>

Tracking Status: None "Hanek, Olga" <Olga.Hanek@fpl.com>

Tracking Status: None "Guth, Mitch" <Mitch.Guth@fpl.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 2800 4/18/2016 4:16:00 PM Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

1 NRR-PMDAPEm Resource From:

Klett, Audrey Sent:

Monday, April 18, 2016 4:17 PM To:

Guth, Mitch Cc:

Kilby, Gary; Cross, William; Hanek, Olga

Subject:

Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455 &

MF5456)

Hi Mitch, By application dated December 23, 2014 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML15029A297), Florida Power & Light Company (FPL, the licensee) submitted License Amendment Request (LAR) No. 236 for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point).

The proposed amendments would revise the Technical Specifications (TSs) to Implement TS Task Force (TSTF)-505, Revision 1, Provide Risk-Informed Extended Completion Times RITSTF [Risk-Informed TSTF]

Initiative 4b.

The U.S. Nuclear Regulatory Commissions (NRCs) Balance of Plant Branch (SBPB) staff reviewed the application and identified areas where it needs additional information to support its review. The staffs request for additional information (RAI) is provided below. As discussed with Ms. Olga Hanek of the licensees staff on April 18, 2016, the NRC is requesting the licensee to respond to the RAI within 60 calendar days of April 14, 2016.

SBPB RAI-1 In the event of one inoperable main steam isolation valve (MSIV), the current TS 3.7.1.5 requires entry into Hot Standby after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Turkey Point LAR proposed to revise the TS to require entry into MODE 2, after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As a basis for this change, the LAR indicates TSTF-505 contains incorrect structure, and in order to establish the correct structure for Turkey Point TS 3.7.1.5, FPL proposes that the required actions (RAs) for one or more inoperable MSIVs in Mode 1 require entering Mode 2, rather than Modes 3 and 4, if the MSIVs are not restored to operable status within the completion time (CT). While these changes are consistent with the STSs, this is a deviation from the current TS and allows an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in MODE 2. The staff is unable to locate a clear justification for this mode change. Please provide a technical justification for the proposed change from Hot Standby to MODE 2.

In addition, the LAR indicates this change aligns the Turkey Point TSs with TSTF-505 and is appropriate because it provides a subsequent RA if entry into Mode 2 is required because two or more inoperable MSIVs in Mode 1 are not restored to operable status within the CT. For complete alignment with TSTF-505, the staff finds the following actions missing from proposed TS change: (1) TSTF-505 includes a [8] hours completion time for closing MSIV for one or more MSIVs inoperable in MODE 2 or 3, but the proposed change to TS 3.7.1.5 does not specify a time limit for closing an inoperable MSIV in Modes 2 or 3; and (2) TSTF-505 includes a condition to verify MSIV is closed once per 7 days, but the proposed TS is missing any action for MSIV closure verification. Please provide an explanation why the LAR did not request adoption of the completion time and periodic MSIV closure verification.

Hearing Identifier:

NRR_PMDA Email Number:

2790 Mail Envelope Properties (Audrey.Klett@nrc.gov20160418161600)

Subject:

Request for Additional Information - Turkey Point 3 & 4 LAR-236 (CACs MF5455

& MF5456)

Sent Date:

4/18/2016 4:16:39 PM Received Date:

4/18/2016 4:16:00 PM From:

Klett, Audrey Created By:

Audrey.Klett@nrc.gov Recipients:

"Kilby, Gary" <Gary.Kilby@fpl.com>

Tracking Status: None "Cross, William" <WILLIAM.CROSS@fpl.com>

Tracking Status: None "Hanek, Olga" <Olga.Hanek@fpl.com>

Tracking Status: None "Guth, Mitch" <Mitch.Guth@fpl.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 2800 4/18/2016 4:16:00 PM Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received: