ML16342B034
| ML16342B034 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/30/2016 |
| From: | John Lamb Plant Licensing Branch IV |
| To: | Becker C State of FL, Dept of Health |
| References | |
| L-2016-128 | |
| Download: ML16342B034 (33) | |
Text
1 NRR-PMDAPEm Resource From:
Lamb, John Sent:
Wednesday, November 30, 2016 9:23 AM To:
Becker, Cindy L Cc:
Klett, Audrey
Subject:
For the State of Florida Comments - Turkey Point AFW LARs Attachments:
LTR 30-2016.pdf; LTR 15-2016.pdf Importance:
High Ms. Becker:
The U.S. Nuclear Regulatory Commission plans to issue Amendments to Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Plant, Units 3 and 4 (Turkey Point) approximately on December 30, 2016, in response to the Florida Power & Light Company (FPL) application dated June 30, 2016 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML16194A342), as supplemented by letter dated November 15, 2016. See the attached letters to save searching through ADAMS.
Specifically, the proposed amendments would revise the Turkey Point Technical Specifications (TSs) TS 3/4.7.1.2, Auxiliary Feedwater System, to correct a non-conservative TS for Turkey Point.
If the State of Florida has any comments regarding these amendment requests, please e-mail me your comments by the close of business on December 15, 2016.
Thanks.
John 301-415-3100
Hearing Identifier:
NRR_PMDA Email Number:
3199 Mail Envelope Properties (John.Lamb@nrc.gov20161130092300)
Subject:
For the State of Florida Comments - Turkey Point AFW LARs Sent Date:
11/30/2016 9:23:20 AM Received Date:
11/30/2016 9:23:00 AM From:
Lamb, John Created By:
John.Lamb@nrc.gov Recipients:
"Klett, Audrey" <Audrey.Klett@nrc.gov>
Tracking Status: None "Becker, Cindy L" <Cindy.Becker@flhealth.gov>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 906 11/30/2016 9:23:00 AM LTR 30-2016.pdf 3459827 LTR 15-2016.pdf 63358 Options Priority:
High Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
L-2016-213 10 CFR 50.90 November 15, 2016 Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 RE:
Turkey Point Nuclear Plant, Units 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DPR-31 and DPR-41 Response to Request for Additional Information Regarding License Amendment Request 245, Change to the Technical Specifications to Address an Inoperable Steam Supply for the Auxiliary Feedwater Pumps
References:
- 1. Florida Power & Light Company letter L-2016-128, "Change to the Technical Specifications to Address an Inoperable Steam Supply for the Auxiliary Feedwater Pumps," June 30, 2016 (ML16194A342)
- 2. NRC E-mail from J. Lamb to M. Guth, "Turkey Point Nuclear Plant, Units 3 and 4 -
Request for Additional Information for License Amendment Request to Revise the Auxiliary Feedwater System Technical Specifications (CAC NOS. MF8068 AND MF8069)," October 27, 2016 (ML16228A004)
In Reference 1, Florida Power & Light Company (FPL) submitted license amendment request (LAR) 245 for Turkey Point Units 3 and 4 to correct a non-conservative Technical Specification (TS) by revising TS 3.7.1.2, Auxiliary Feedwater (AFW)
System, to require the operability of three AFW system steam supplies and to provide remedial measures for an inoperable steam supply.
In Reference 2, the NRC determined that additional information is needed to complete its review. The enclosure to this letter provides FPL's response to the request for additional information.
This response does not alter the conclusion in Reference 1 that the proposed changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and that there are no significant environmental impacts associated with the proposed changes.
This letter contains no new or revised regulatory commitments.
Turkey Point Nuclear Plant L-2016-213 Enclosure Page 1 of 3 Enclosure Response to Request for Additional Information (RAI) for License Amendment Request to Revise the Auxiliary Feedwater System Technical Specifications (CAC NOS. MF8068 AND MF8069)
Turkey Point Nuclear Plant L-2016-213 Enclosure Page 2 of 3 REQUEST FOR ADDITIONAL INFORMATION Table 3.7-3 describes the allowable plant configurations which satisfy the current Limiting Condition for Operation (LCO) 3.7.1.2 requirement of three operable auxiliary feedwater (AFW) pumps and associated flow paths. Table 3.7-3 is supplemented by 3 notes. Note 3 states:
If any local manual realignment of valves is required when operating the auxiliary feedwater pumps, a dedicated individual, who is in communication with the control room, shall be stationed at the auxiliary feedwater pump area. Upon instructions from the control room, this operator would realign the valves in the AFW system train to its normal operational alignment.
Notes 1 and 2 for the table are proposed to be rewritten to apply to the LCO statement, while Note 3 is proposed for deletion.
Federal Register Notice 58 FR 39132 contains the NRCs Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors. In reference to the four criteria listed in Title 10 of the Code of Federal Regulations, Part 50 (10 CFR), Section 36(c)2(ii), the Policy Statement states: LCOs which do not meet any of the criteria below may be proposed for removal from the Technical Specifications and relocation to licensee-controlled documents, such as the [Final Safety Analysis Report] FSAR. The Policy statement further states:
If a licensee elects to apply these criteria, the requirements of the removed specifications will be relocated to the FSAR or other licensee-controlled documents. Licensees are to operate their facilities in conformance with the descriptions of their facilities and procedures in their FSAR. Changes to the facility or to procedures described in the FSAR are to be made in accordance with 10 CFR 50.59.
Please provide a description of:
(1) Where the technical and administrative requirements proposed for removal from the TS, in this case the requirements for manual realignment of the AFW system, will be located or are currently located.
(2) The control process(es) that will be used for relocated technical and administrative requirements.
FPL RESPONSE Note 3 of LCO 3.7.1.2 requires a dedicated individual to be stationed at the AFW pump area in communication with the Control Room if local manual realignment of valves is required when operating the AFW pumps. The purpose of Note 3 is to ensure prompt system re-alignment upon direction from the Control Room when, during periodic testing, only one AFW train is available for operation.
Turkey Point Nuclear Plant L-2016-213 Enclosure Page 3 of 3 In Reference 1, FPL stated that Note 3 of LCO 3.7.1.2 is being removed because this configuration control mechanism is more aptly suited for plant procedures. More specifically, the requirements of Note 3 are implemented in the AFW surveillance procedures where local manual valve realignment is required when operating the AFW pumps. Proposed changes to these procedures are subject to the requirements of 10 CFR 50.59.
During an October 27, 2016 teleconference regarding the subject RAI, the NRC staff indicated that examples of applicable AFW procedures would be beneficial to its review. As examples, AFW procedures 3(4)-OSP-075.6, Auxiliary Feedwater Train 1 Backup Nitrogen Test, 3(4)-
OSP-075.7, Auxiliary Feedwater Train 2 Backup Nitrogen Test and 3(4)-OSP-075.9, AFW Overspeed Test, involve local component manipulations when operating the AFW pumps, where 3(4) denotes the Unit 3 and the Unit 4 AFW procedure. These procedures contain the following instruction in the Precautions section:
An operator shall remain in the AFW pump area and maintain communication with the Control Room until all AFW pumps are reset for normal operation.
The procedures are CONTINUOUS USE, meaning that, amongst other requirements, place-keeping each Precautions step using the circle/slash method is required prior to commencing work. Place-keeping ensures acknowledgement of the precautionary instruction and the expectation to abide by the prescribed level of use during the task. As such, FPL believes the above instruction is sufficient to ensure prompt realignment of the AFW system upon Control Room direction and thereby, Note 3 of LCO 3.7.1.2 can be removed.