ML17090A125

NRR E-mail Capture - Request for Additional Information Re. Turkey Point TSTF-505 LAR 236 (CACs MF5455 and MF5456)

ML17090A125
Person / Time
Site:	Turkey Point
Issue date:	03/30/2017
From:	Audrey Klett Plant Licensing Branch II
To:	Guth M Florida Power & Light Co
References
MF5455, MF5456
Download: ML17090A125 (3)

Text

1 NRR-PMDAPEm Resource From:

Klett, Audrey Sent:

Thursday, March 30, 2017 4:33 PM To:

'Mitch.Guth@fpl.com' Cc:

Mack, Jarrett; 'Gary.Kilby@fpl.com'; 'Hanek, Olga' (Olga.Hanek@fpl.com)

Subject:

Request for Additional Information Re. Turkey Point TSTF-505 LAR 236 (CACs MF5455 and MF5456)

Hi Mitch, By application dated December 23, 2014 (L-2014-369), as supplemented by letters L-2016-116, L-2016-136, and L-2017-006, dated June 16, and August 11, 2016, and February 9 2017, respectively,[1] Florida Power &

Light Company (the licensee) requested changes to the Technical Specifications (TSs) for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point), which are contained in Appendix A of Renewed Facility Operating Licenses DPR-31 and DPR-41. The licensee proposed to adopt, with plant-specific variations, the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF [Risk Informed TSTF]

Initiative 4b.[2] The NRC published in the Federal Register (FR) a notice of availability of the model safety evaluation for plant-specific adoption of TSTF-505, Revision 1 on March 15, 2012 (77 FR 15399).

On February 24 and 25, 2016, the U.S. Nuclear Regulatory Commission (NRC) staff and its contractors from the Pacific Northwest National Laboratory participated in a regulatory audit at the NextEra Energy Offices in Juno Beach, Florida. The staff performed the audit to ascertain the information needed to support its review of the application and develop requests for additional information (RAIs), as needed. On June 21, 2016,[3] the staff issued an audit summary. By electronic mail (e-mail) dated April 14, April 18, and June 1, 2016,[4] the NRC sent the licensee RAIs. By letters dated June 16, and August 11, 2016, the licensee responded to the RAIs.

By letter dated November 15, 2016,[5] the staff informed the TSTF of its decision to suspend NRC approval of TSTF-505, Revision 1 because of concerns identified during the review of plant-specific license amendments requesting adoption of the traveler. The staffs letter also stated that it would continue reviewing applications already received and site-specific proposals to address the staffs concerns. By letter dated February 9, 2017, the licensee supplemented its application to address the staffs concerns in the NRC letter dated November 15, 2016. In its letter, the licensee proposed a solution to address the NRC staffs concern on the reductions in safety margin and defense-in-depth that were not adequately evaluated for the loss of function conditions permitted in TSTF-505, Revision 1.

The NRCs Instrumentation and Control Branch (EICB) reviewed the supplement dated February 9, 2017, and identified areas where it needs additional information to support its review. The RAI is provided below and is numbered sequentially from the RAIs in the e-mail dated April 14, 2016. As discussed with Mr. Gary Kilby of the licensees staff on March 30, 2017, the staff requests the licensee to respond to the RAI within 30 days of the date of this email.

EICB RAI 7 The licensees supplement dated February 9, 2017, revised the licensees application to exclude the use of the loss of function provisions in TSTF-505, Revision 1; however, the staff identified the remaining functions that appear to include a loss of function.

A. In its supplement dated February 9, 2017, the licensee proposed a new Action 27 in TS Table 3.3-2 that would allow a RICT for the condition when one required instrument channel is inoperable. The proposed Action 27 now states, With one channel inoperable, restore the inoperable channel to

2 OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 />.

TS Table 3.3-2, Functional Unit 3.b.1 (i.e., the Containment Isolation, Phase B Isolation, Manual Initiation function) requires 2 channels to trip and states, Both buttons must be pushed simultaneously to actuate. The licensees proposed Action 27 for Functional Unit 3.b.1 is for one channel inoperable (i.e., when one of the two buttons is inoperable). Therefore, the staff requests the licensee to explain why this condition of the Manual Initiation function (i.e., one manual push button inoperable) is not considered a loss of function and justify why extended operation in this condition is acceptable.

B. In its supplement dated February 9, 2017, the licensee proposed a RICT in Action 18 in TS Table 3.3-2 for when the number of OPERABLE channels is one less than the total number of channels. Action 18 is applicable for Functional Unit 7, Loss of Power, in TS Table 3.3-2. Functional Unit 7.a is for a loss of voltage on the 4.16 kilovolt Buses A and B, has two channels per bus, and requires two channels per bus to trip. The licensees proposed RICT in Action 18 is for when one channel is inoperable.

Therefore, the staff requests the licensee to explain why this condition (i.e., loss of one channel of loss of power indication) of Functional Unit 7.a is not considered as a loss of function and justify why extended operation in this condition is acceptable.

[1] Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML15029A297, ML16180A178, ML16243A104, and ML17060A249, respectively.

[2] ADAMS Accession No. ML111650552.

[3] ADAMS Accession No. ML16154A012.

[4] ADAMS Accession Nos. ML16105A459, ML16110A004, and ML16154A339, respectively.

[5] ADAMS Accession No. ML16281A021.

Audrey Klett Project Manager NRR/DORL/LPLII-2 301-415-0489

[1] Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML15029A297, ML16180A178, ML16243A104, and ML17060A249, respectively.

[2] ADAMS Accession No. ML111650552.

[3] ADAMS Accession No. ML16154A012.

[4] ADAMS Accession Nos. ML16105A459, ML16110A004, ML16154A339, respectively.

[5] ADAMS Accession No. ML16281A021.

Hearing Identifier:

NRR_PMDA Email Number:

3424 Mail Envelope Properties (Audrey.Klett@nrc.gov20170330163200)

Subject:

Request for Additional Information Re. Turkey Point TSTF-505 LAR 236 (CACs MF5455 and MF5456)

Sent Date:

3/30/2017 4:32:35 PM Received Date:

3/30/2017 4:32:00 PM From:

Klett, Audrey Created By:

Audrey.Klett@nrc.gov Recipients:

"Mack, Jarrett" <Jarrett.Mack@fpl.com>

Tracking Status: None

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

Tracking Status: None

"'Hanek, Olga' (Olga.Hanek@fpl.com)" <Olga.Hanek@fpl.com>

Tracking Status: None

"'Mitch.Guth@fpl.com'" <Mitch.Guth@fpl.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 5885 3/30/2017 4:32:00 PM Options Priority:

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No Reply Requested:

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