L-2017-049, Response to Request for Additional Information Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)

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Response to Request for Additional Information Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)
ML17090A331
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 03/31/2017
From: Summers T
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8221, CAC MF8222, L-2017-049
Download: ML17090A331 (16)
v • d • e


Text

L-2017-049 10 CFR 50.90 March 31, 2017 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 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS)

References:

1. Florida Power & Light Company letter L-2016-246, License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS), August 3, 2016 (ADAMS Accession No. ML16230A003)
2. NRR E-Mail Capture, Turkey Point LAR 246, CREVS TSs, Request for Additional Information (MF8221 and MF8222), December 5, 2016 (ADAMS Accession No. ML16340A037)
3. Florida Power & Light Company letter L-2017-013, Response to Request for Additional Information Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS), January 27, 2017 (ADAMS Accession No. ML17032A345)
4. NRR E-Mail Capture, Request for Information re. Turkey Point 3 & 4 LAR 246 -

CREVS TS (CACs MF8221 & MF8222), March 7, 2017, (ADAMS Accession No. ML17067A057)

In Reference 1, Florida Power & Light Company (FPL) submitted license amendment request (LAR) 246 for Turkey Point Units 3 and 4, which modifies Technical Specification (TS) 3.7.5, Control Room Emergency Ventilation System, by revising the Limiting Conditions for Operation, Required Actions, and Surveillance Requirements to reflect the current system design and to align the Turkey Point TS more closely with NUREG 1431, Standard Technical Specifications - Westinghouse Plants, Revision 4.0, (ADAMS Accession No. ML12100A222).

In Reference 2, the NRC determined that additional information was required to complete its review. In Reference 3, FPL responded to the additional information request Florida Power & Light Company 9760 SW 344 St., Homestead, FL 33035

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Page 2of2 documented in Reference 2. In Reference 4, the NRC determined that additional information is required to complete its review.

The enclosure to this letter provides FPL' s response to the request for additional information (RAI) documented in Reference 4. In addition, as discussed in the enclosure, FPL is modifying one of the proposed changes that were included in References 1 and 3. to the enclosure provides the affected TS page marked up to show the proposed changes. Attachment 2 provides the retyped (clean copy) TS page with revision bars to identify the proposed changes. Attachment 3 provides the affected TS Bases pages marked up to show the proposed changes. The TS marked up page, retyped (clean copy) TS page and TS Bases marked up pages supersede the corresponding pages provided in References 1and3. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment.

The supplements included in this response provide additional information that clarifies the application, do not expand the scope of the application as originally noticed, and should not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register.

This letter contains no new or revised regulatory commitments.

Should you have any questions regarding this submission, please contact Mr. Mitch Guth, Turkey Point Licensing Manager, at 305-246-6698.

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

Executed on March 31, 2017.

Sincerely, L- l ~--::::....--

Thomas Summers Regional Vice President - Southern Region Florida Power & Light Company

Enclosure:

Response to Request for Additional Information 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 Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Enclosure Page 1 of 6 Enclosure FPL Response to NRC Request for Additional Information (RAI) dated 3/7/17 Regarding LAR 246 - Changes to Technical Specifications 3/4.7.5 Control Room Emergency Ventilation System

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Enclosure Page 2 of 6 In an email memorandum dated March 7, 2017 the Radiation Protection and Consequence Branch (ARCB) of the NRC Office of Nuclear Reactor Regulation, requested the additional information listed below regarding LAR 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System. The NRC RAI and FPLs response follow:

ARCB RAI-5 The staff requests the licensee to either (1) explain how the proposed changes regarding the extension of the use of mitigating actions to Modes 5, 6, and during movement of irradiated fuel assemblies meet Title 10 of the Code of Federal Regulations (10 CFR), Section 20.1701, 10 CFR 20.1702, and the regulatory guidance in STS 3.7.10 of NUREG-1431, or (2) revise the proposed changes to remove the extension of the use of mitigating actions to Modes 5, 6, and during movement of irradiated fuel assemblies.

Basis for the Request The proposed changes would revise TS 3/4.7.5 ACTION b to allow movement of irradiated fuel upon verification that mitigating actions ensure control room envelope (CRE) occupant radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards with the CRE boundary inoperable in Modes 1 through 6 and during movement of irradiated fuel assemblies. Section 3.2 of the license amendment request (LAR) states:

In the case of an inoperable CRE boundary, the current TS ACTION 3.7.5.b does not require placing the Control Room in the emergency recirculation mode nor does the CREVS provide for a redundant component or train which assures CREVS specified functionality given a single failure. However Westinghouse STS ACTION 3.7.10.B provides for a ninety-day AOT [allowed outage time] without the suspension of irradiated fuel movement after first verifying within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed allowable limits and CRE occupants are protected from smoke hazards. In contrast, TS ACTION 3.7.5.b requires the suspension of irradiated fuel movement for the duration of the 90-day AOT even after first verifying within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed allowable limits and CRE occupants are protected from smoke hazards. FPL proposes for an inoperable CRE boundary for all plant MODES, the immediate suspension of fuel movement for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, during which mitigating actions would be verified to ensure CRE occupant exposures to radiological and chemical hazards will not exceed allowable limits and CRE occupants are protected from smoke hazards, and following which irradiated fuel movement may resume. Irradiated fuel movement would also be suspended if the 90-day AOT cannot be met. Though relaxing the requirement to suspend fuel movement for the duration of the 90-day AOT is less restrictive than the current Turkey Point TS, the proposed change maintains a commensurate level of safety when judged against the current regulatory standards established in the Westinghouse STS for an inoperable CRE boundary and is thereby reasonable.

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Enclosure Page 3 of 6 Westinghouse STS 3.7.10, Control Room Emergency Filtration System (CREFS), provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. STS 3.7.10 Action B is entered when one or more CREFS trains are inoperable due to an inoperable CRE boundary while in Modes 1, 2, 3, and 4. Action B allows ninety days to restore the inoperable CRE boundary to operable status, if actions are immediately taken to implement mitigating actions and CRE occupant exposure to radiological, chemical and smoke hazards is verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to not exceed limits. Action B is only entered in Modes 1 through 4. If the unit is in Modes 5, 6, or moving recently irradiated fuel assemblies then Action E is applicable and must be entered. STS 3.7.10 Action E is entered when one or more CREFS trains are inoperable due to an inoperable CRE boundary while in Modes 5 or 6 or during movement of recently irradiated fuel assemblies and requires immediately suspending movement of recently irradiated fuel assemblies. Action E takes immediate action to suspend activities that could result in a release of radioactivity that might require isolation of the CRE.

In its letter dated June 18, 2009 (ADAMS Accession No. ML091690643), the Technical Specifications Task Force (TSTF) submitted Traveler TSTF-508, Revision 1, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation, to the NRC for review and approval. TSTF-508 proposed the extension of the use of mitigating actions to Modes 5, 6, and during movement of recently irradiated fuel assemblies when one or more CREFS trains is inoperable due to an inoperable CRE boundary in Westinghouse STS 3.7.10, just as the licensee has requested in its LAR. During the review of TSTF-508, the staff requested additional information (ADAMS Accession No. ML110890817), in which the staff stated that the extension of the use of mitigating actions to Modes 5, 6, and during movement of recently irradiated fuel assemblies is not adequately justified and is not warranted for the following reasons:

  • Subpart H of 10 CFR Part 20, Standards for Protection against Radiation, provides the requirements for respiratory protections and controls to restrict internal exposure in restricted areas. Specifically, 10 CFR 20.1701 states that licenses shall use, to the extent practicable, process or engineering controls to control the concentration of radioactivity in the air. Use of other controls as described in 10 CFR 20.1702 is only allowed by regulation when it is not practicable to apply process or other engineering controls.
  • NEI 99-03, Appendix F, Compensatory Measures Allowable On An Interim Basis, Page -1, states:

The use of SCBA [self-contained breathing apparatus] and KI [potassium iodide] has been determined to be acceptable for addressing control room envelope integrity in the interim situation until the licensee remediates the issue. However, use of SCBA or KI in the mitigation of situations where in-leakage does not meet design basis limits is not acceptable as a permanent solution. 10 CFR 20.1701 essentially says that engineering/process controls shall be used to the extent practical. If not practical, then 10 CFR 20.1702 methods should be used. Therefore, the use of SCBAs should be a last resort. [emphasis added]

  • The use of KI and SCBA is not without risk. The allowance to use KI and SCBA was not previously extended to Modes 5 and 6 because another practical control (i.e., stopping fuel

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Enclosure Page 4 of 6 movement) existed. The staff does not believe that the proposed compensatory measures are appropriate given that the process control of stopping fuel movement is available.

The TSTF did not respond to the RAI; rather, it withdrew its request for NRC to approve TSTF-508. The licensees application does not appear to address how the proposed changes (i.e., to allow movement of irradiated fuel upon verification that the mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards while in Modes 5, 6, and during movement of irradiated fuel assemblies) meet the regulations or the regulatory guidance below and as stated in the basis for the TSTF-508 RAI.

Subpart H of 10 CFR Part 20, Standards for Protection against Radiation, provides the requirements for respiratory protections and controls to restrict internal exposure in restricted areas.

Specifically, 10 CFR 20.1701 states that licenses shall use, to the extent practical, process or engineering controls to control the concentration of radioactivity in the air. Use of other controls as described in 10 CFR 20.1702 is only allowed by regulation when it is not practical to apply process or other engineering controls.

The FHA source term per Regulatory Guide (RG) 1.183 is based on maximum full power operation of the core with, as a minimum, current licensed values for fuel enrichment, fuel burnup, and an assumed core power equal to the current licensed rated thermal power times the emergency core cooling system evaluation uncertainty. Because the FHA does not involve the entire core, the fission product inventory of each of the damaged fuel rods is determined by dividing the total core inventory by the number of fuel rods in the core. To account for differences in power level across the core, radial peaking factors from the facilitys core operating limits report or TSs is applied in determining the inventory of the damaged rods. Because FHA occurs while the facility is shutdown, radioactive decay from the time of shutdown may be modeled. The FHA for Turkey Point models the radioactive decay from the time of shutdown in development of the source term. This time is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and is reflected in Turkey Point TS 3/4.9.3, Decay Time.

Many plants that have adopted an AST develop their FHA source term using this method, and their radioactive decay from the time of shutdown varies from 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. This time is an initial condition of the FHA analysis, and plants cannot move irradiated fuel prior to this time; otherwise, they are operating outside their licensing basis, which is not allowed. This time is not shown in the STS. The FHA onsite and offsite radiological doses are calculated, using the source term discussed above and assume reductions in the amount of radioactive material released by engineered safety feature (ESF) filter systems in accordance with RG 1.183. These systems vary depending on location of the release (e.g., inside containment or the spent fuel pool) and the systems available at each plant, but they usually take credit for a CREFS and a fuel building filtration system for spent fuel pool releases.

Turkey Points approved FHA analysis is based on the failure of one fuel assembly and uses a radial peaking factor of 1.65 and a radioactive decay from the time of shutdown of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The analysis does not credit ESF filtration for the containment or spent fuel pool release, but it does credit a reduction of the radioactive material released from filtration by the CREVS 30 seconds after the

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Enclosure Page 5 of 6 occurrence of an FHA for releases in containment and 30 minutes after the occurrence of an FHA for releases in the spent fuel pool.

Independent of the radioactive decay from the time of shutdown discussed above, some licensees have chosen to adopt an additional decay time. This decay time, Tnofilter, is also radioactive decay from the time of shutdown, with the difference being that the onsite and offsite radiological doses calculated for an FHA using this decay time usually do not consider reductions in the amount of radioactive material released by ESF filter systems. Specifically, the onsite radiological doses calculated for an FHA do not credit reduction from the CREFS. This decay time (Tnofilter) is associated with the term recently irradiated fuel assemblies described and used in the STS. Prior to expiration of this decay time (Tnofilter), the CREFS is needed to maintain onsite radiological doses below the 10 CFR 50.67 limits. The STS reflect this decay time (Tnofilter) by requiring the CREFS Limiting Conditions for Operation to be met during movement of recently irradiated fuel assemblies; thus, STS applicability is during movement of recently irradiated fuel assemblies.

Turkey Points approved FHA analysis does not include an analysis that shows that the onsite and offsite radiological doses meet the limits stated in 10 CFR 50.67 using the additional decay time discussed in the previous paragraph (Tnofilter) to determine the FHA source term, and no credit for filtration by the CREVS or other ESF filter systems. Therefore, Turkey Points proposed TS applicability of during movement of irradiated fuel assemblies is the equivalent of STSs during movement of recently irradiated fuel assemblies.

FPL Response to ARCB-RAI-5 Based upon the above discussion, FPL acknowledges that TS 3.7.5, ACTION b, as proposed in References 1 and 2 of ARCB RAI-5, does not provide a commensurate level of safety during MODES 5, 6 and during the movement of irradiated fuel assemblies when compared to the requirements of NUREG-1431, Revision 4, Standard Technical Specifications - Westinghouse Plants [Westinghouse STS]. Specifically Westinghouse STS 3.7.10, ACTION E, requires the immediate suspension of irradiated fuel movement in the event of an inoperable Control Room Envelope (CRE) boundary during MODES 5, 6 and during the movement of irradiated fuel assemblies, and thereby takes immediate action to suspend activities that could result in a release of radioactivity that might require isolation of the CRE during these operational modes. As such, FPL hereby withdraws the request to extend the use of mitigating actions to MODES 5, 6, and during the movement of irradiated fuel assemblies in the event of an inoperable CRE boundary and instead proposes the immediate suspension of irradiated fuel movement for the duration of CRE boundary inoperability during these operational modes. This revised proposal for TS 3.7.5, ACTION b assures a commensurate level of safety when judged against the regulatory standards established in Westinghouse STS 3.7.10, ACTION E, for an inoperable CRE boundary during MODES 5, 6 or during the movement of irradiated fuel assemblies, and is thereby reasonable.

Revising TS 3.7.5, ACTION b, to require the immediate suspension of irradiated fuel movement in the event of an inoperable CRE boundary during MODES 5, 6 or during movement of irradiated fuel assemblies does not alter the conclusion in References 1 and 2 of ARCB RAI-5

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Enclosure Page 6 of 6 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.

Attachment 1 to this enclosure provides the affected TS 3/4.7.5 page marked up to show the proposed changes. Attachment 2 provides the retyped (clean copy) TS 3/4.7.5 page with revision bars to identify the proposed changes. Attachment 3 provides the affected TS Bases pages marked up to show the proposed changes. The TS marked up page, retyped (clean copy)

TS page and TS Bases marked up pages supersede the corresponding pages provided in References 1 and 2 of ARCB RAI-5. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment.

ARCB RAI-5

References:

1. Florida Power & Light Company letter L-2016-246, License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS), August 3, 2016 (ADAMS Accession No. ML16230A003)
2. Florida Power & Light Company letter L-2017-013, Response to Request for Additional Information Regarding License Amendment Request 246, Changes to Technical Specifications 3/4.7.5, Control Room Emergency Ventilation System (CREVS), January 27, 2017 (ADAMS Accession No. ML17032A345)

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Attachment 1 ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION PAGES (MARKUP)

(1 page follows)

LIMITING CONDITION FOR OPERATION (continued) following which movement of irradiated fuel may resume,

b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary, immediately suspend all movement of irradiated fuel in the spent fuel pool, and immediately initiate action to implement mitigating actions, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits, and CRE occupants are protected from smoke hazards, and restore CRE boundary to OPERABLE status within 90 days., or:

. Within With the above requirements not met, immediately suspend all movement of irradiated fuel and be in at least 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 /> for one Unit, or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for both Units, and in COLD SHUTDOWN with the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary during MODES 5, 6 or during the movement of irradiated fuel assemblies, immemdiately suspend all movement of irradiated fuel.

1) With the requirements not met, be in at least 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 in 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 />.
2) If this ACTION applies to both units simultaneously, be in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in 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 />.

MODES 5 and 6:

c. With the Control Room Emergency Ventilation System inoperable++, immediately suspend all operations involving CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, or positive reactivity changes. This ACTION shall apply to both units simultaneously.

SURVEILLANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that the control room air temperature is less than or equal to 120°F;
b. In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes***;
c. In accordance with the Surveillance Frequency Control Program or (1) after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system that may have an adverse effect on the functional capability of the system, or (4) after complete or partial replacement of a filter bank by:

++ If action per ACTIONS a.4, a.6, a.7, a.8, or a.9 is taken that permits indefinite operation and the system is placed in recirculation mode, then CORE ALTERATIONS, movement of irradiated fuel in the spent fuel pool, and positive reactivity changes may resume.

      • As the mitigation actions of TS 3.7.5 Action a.5 include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS 4.7.5.c, d and f g.

TURKEY POINT - UNITS 3 & 4 3/4 7-21 AMENDMENT NOS. 263 AND 258

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Attachment 2 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION PAGES (CLEAN COPY)

(1 page follows)

PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (continued)

b. With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary during MODES 1, 2, 3 or 4, immediately suspend all movement of irradiated fuel and immediately initiate action to implement mitigating actions. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant radiological and chemical hazards will not exceed limits and CRE occupants are protected from smoke hazards, following which movement of irradiated fuel may resume, and restore CRE boundary to OPERABLE status within 90 days.

With the above requirements not met, immediately suspend all movement of irradiated fuel and be in at least 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 /> for one Unit, or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for both Units, and in 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 />.

With the Control Room Emergency Ventilation System inoperable due to an inoperable CRE boundary during MODES 5, 6 or during the movement of irradiated fuel assemblies, immediately suspend all movement of irradiated fuel.

SURVEILLANCE REQUIREMENTS 4.7.5 The Control Room Emergency Ventilation System shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by verifying that the control room air temperature is less than or equal to 120°F;
b. In accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes**;
c. In accordance with the Surveillance Frequency Control Program or (1) after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following exposure of the filters to effluents from painting, fire, or chemical release in any ventilation zone communicating with the system that may have an adverse effect on the functional capability of the system, or (4) after complete or partial replacement of a filter bank by:
    • As the mitigation actions of TS 3.7.5 Action a.5 include the use of the compensatory filtration unit, the unit shall meet the surveillance requirements of TS 4.7.5.b, by manual initiation from outside the control room and TS 4.7.5.c, d and f.

TURKEY POINT - UNITS 3 & 4 3/4 7-20 AMENDMENT NOS. AND

Turkey Point Nuclear Plant L-2017-049 Docket Nos. 50-250 and 50-251 Attachment 3 xx ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARKUP)

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REVISION NO.: PROCEDURE TITLE: PAGE:

20 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 173 of 211 PROCEDURE NO.:

0-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical Specification Bases (Page 156 of 194) 3/4.7.5 (Continued) immediately suspend the movement of irradiated fuel, and If the unfiltered inleakage of potentially contaminated air past the CRE Upon Boundary and into the CRE can result in CRE occupant radiological dose determination greater than that calculated in the dose analyses or in inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE Boundary within 90 days when in MODES 1, 2, 3, or 4.

During the period that the CRE boundary is considered inoperable in MODES 1, 2, 3, or 4, the operators are required to immediately initiate action to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to for verify that in the event of a DBA, the mitigating actions will ensure that MODES CRE occupant radiological exposures will NOT exceed the calculated 1, 2, 3 dose in the radiological dose consequence analyses, and that CRE and 4 occupants are protected from hazardous chemicals and smoke.

Previous surveys of offsite and onsite chemicals identified that NO hazardous chemicals present a hazard to Control Room habitability.

Thus, the mitigating action for chemical hazards may verify that the chemical hazards analyses are current and require NO toxic gas protection for the CRE occupants. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowable outage time (AOT) is reasonable based on the low probability of a DBA occurring during this time period and the use of mitigating actions. The 90 day AOT is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactors and maintain them in a safe shutdown condition in the event of a DBA. The 90 day AOT is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

, following which irradiated fuel movement may resume Upon determination that the CRE boundary is inoperable when in MODES 5, 6, or during the movement of irradiated fuel, all movement of irradiated fuel must be immediately suspended and must remain suspended for the duration of inoperability. Suspending irradiated fuel movement during these operational modes suspends activities that could result in a release of radioactivity that might require isolation of the CRE.

REVISION NO.: PROCEDURE TITLE: PAGE:

20 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 174 of 211 PROCEDURE NO.:

0-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical Specification Bases action must(Page 157 of be taken 194) immediately to suspend all operations that could result in a release of radioacitivy that might require isolation 3/4.7.5 (Continued) of the CRE, such as movement of irradiated fuel, and In MODES 1, 2, 3, or 4, if the inoperable CREVS or the CRE Boundary the cannot be restored to OPERABLE status within the associated required following AOT, the unit must be placed in a MODE that minimizes the accident 30 risk. To achieve this status, the unit must be placed in at least MODE 3 (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 MODE 5 (COLD SHUTDOWN) within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If the inoperability applies to both units simultaneously, be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and in MODE 5 within 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />. The AOTs are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

This does NOT preclude the movement of fuel to a safe position.

In MODE 5 or 6, with the CREVS inoperable for an inoperable CRE Boundary or for other reasons, action must be taken immediately to suspend all operations that could result in a release of radioactivity that might require isolation of the CRE, such as movement of irradiated fuel.

This places the unit in a condition that minimizes the accident risk.

This does NOT preclude the movement of fuel to a safe position.

These ACTION requirements apply to both units simultaneously.

Operations that, in the absence of a compensation adjustment, add positive reactivity are acceptable when, combined with other concurrent actions that add negative reactivity, the overall net reactivity addition is zero or negative. For example, a positive reactivity addition caused by temperature increases or decreases is acceptable if it is concurrent with a negative reactivity addition (i.e., boration and/or rod movement, if authorized) such that the overall, net reactivity addition is zero or negative.

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20 TECHNICAL SPECIFICATION BASES CONTROL PROGRAM 175 of 211 PROCEDURE NO.:

0-ADM-536 TURKEY POINT PLANT ATTACHMENT 2 Technical Specification Bases (Page 158 of 194) 3/4.7.5 (Continued) f Surveillance Requirement (SR) 4.7.5.g verifies the OPERABILITY of the CRE Boundary by testing for unfiltered air inleakage past the For CRE boundary and into the CRE. It verifies that the unfiltered air MODES inleakage into the CRE is NO greater than the flow rate assumed in 1, 2, 3 the dose analyses. When unfiltered air inleakage is greater than the and 4, assumed flow rate, ACTION b must be entered when a unit is in MODES 1-4 and ACTION c must also be entered when a unit is in MODE 5 or 6). ACTION b allows time to restore the CRE boundary to OPERABLE status provided mitigating actions are taken while in MODES 1-4, that ensures that the CRE remains within the licensing basis habitability limits for the occupants following an accident. The details of the testing are specified in the Control Room Envelope Habitability Program.

For MODES 5, 6 and during the movement of irradiated fuel, ACTION b requires that all movement of irradiated fuel be suspended immediately and remain suspended for the duration of inoperability.

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