ML17268A254
| ML17268A254 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/06/2017 |
| From: | Michael Wentzel Plant Licensing Branch II |
| To: | Nazar M Florida Power & Light Co |
| Klett A DORL/LPL2-2 301-415-0489 | |
| References | |
| CAC MG0143, CAC MG0144 | |
| Download: ML17268A254 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division Florida Power & Light Company Mail Stop EXIJB 700 Universe Blvd.
Juno Beach, FL 33408 October 6, 2017
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF LICENSE AMENDMENT REQUEST 255 FOR THE RELOCATION OF THE REQUIREMENTS FOR EXPLOSIVE GAS MONITORING, GAS DECAY TANKS, AND STANDBY STEAM GENERATOR FEED PUMPS (CAC NOS. MG0143 AND MG0144)
Dear Mr. Nazar:
By letter L-2017-110 dated August 23, 2017 (Agencywide Documents Access and Management System Accession No. ML17235B008), Florida Power & Light Company (the licensee) requested amendments to the Technical Specifications of Renewed Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Unit Nos. 3 and 4, respectively.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this license amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR),
whenever a holder of a license desires to amend the license, an application for an amendment must be filed with the Commission, as specified in 1 O CFR 50.4, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRG staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that the licensee supplement the application to address the information requested in the enclosure within 13 days of the date of this letter. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.
The information requested and the associated timeframe in this letter were discussed in a conference call with Mr. Steve Catron on October 5, 2017.
If you have any questions, please contact me at (301) 415-6459 or Michael.Wentzel@nrc.gov.
Docket Nos. 50-250 and 50-251
Enclosure:
Supplemental Information Needed cc w/enclosure: Distribution via Listserv Sincerely, l
Michael J. Wentz, roject Manager Plant Licensing Bra ch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUPPLEMENTAL INFORMATION NEEDED LICENSE AMENDMENT REQUEST FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
Background
By letter L-2017-110 dated August 23, 2017 (Agencywide Documents Access and Management System Accession No. ML172358008), Florida Power & Light Company (the licensee) requested amendments to the Technical Specifications (TSs) of Renewed Facility Operating License Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point 3 and 4), respectively.
Insufficiencies Section 50.36, "Technical Specifications," of Title 10 of the Code of Federal Regulations (10 CFR), requires, in part, that each Operating License issued by the Commission contain TSs that include limiting conditions for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met Section 50.36(c)(2)(ii) of 10 CFR provides the four criteria to define the scope of equipment and parameters to be included in the TS LCOs. Criterion 4 states, "A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety."
NUREG-1431, "Standard Technical Specifications -Westinghouse Plants," includes LCOs for the following systems identified as meeting Criterion 4:
the remote shutdown systems for control room evacuation the reactor coolant system loops in Modes 4 and 5 for decay heat removal and boron mixing the residual heat removal system for coolant circulation in Mode 6 These systems support essential safety functions such as decay heat removal and reactivity management.
As noted in the licensee's request, the Standby Feedwater System is specifically credited for the auxiliary feedwater (AFW) decay heat removal function should the AFW pumps not be available.
For fires affecting the AFW pumps, credit is also taken for the Standby Feedwater System. The system also supports the decay heat removal function above Residual Heat Removal entry conditions and below the reactor coolant system temperature necessary for adequate steam pressure to operate the turbine-driven AFW pumps. Further, because the AFW pumps are all steam-driven and located in a single fire area at Turkey Point, they could be susceptible to other common cause failure modes.
Enclosure Based on the above, the safety-significance for the Standby Feedwater System may be much greater than a typical non-safety system. The licensee's request does not provide a discussion of the safety-significance of these particular functions for Turkey Point 3 and 4. The licensee's request simply states that the standby feedwater system "does not include SSCs [structures, systems, and components] which operating experience or probabilistic risk assessment have shown to be significant to public health and safety," and indicates that relocation of the system requirements to licensee controlled documents does not change the system nor its operation and maintenance. The request does not include the basis for concluding the Standby Feedwater System is not significant to public health and safety.
Provide the basis for concluding the Standby Feedwater System is not significant to public health and safety. The basis should include an assessment of operating experience and risk insights and a discussion of the safety significance of the functions identified above.
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF LICENSE AMENDMENT REQUEST 255 FOR THE RELOCATION OF THE REQUIREMENTS FOR EXPLOSIVE GAS MONITORING, GAS DECAY TANKS, AND STANDBY STEAM GENERATOR FEED PUMPS (CAC NOS. MG0143AND MG0144) DATED OCTOBER 6, 2017 DISTRIBUTION:
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OFFICE NRR/DORULPL2-2/PM NRR/DORL/LPL2-2/LA NAME MWentzel BClayton DATE 09/26/17 09/26/17 OFFICE NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME UShoop (FSaba for)
MWentzel DATE 10/05/17 10/06117 OFFICIAL RECORD COPY
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RDennig 09/20/17
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