L-95-216, Application for Amends to Licenses DPR-31 & DPR-41,revising TS Index to Delete Bases Re Administrative Controls & Reviews

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Application for Amends to Licenses DPR-31 & DPR-41,revising TS Index to Delete Bases Re Administrative Controls & Reviews
ML17353A452
Person / Time
Site: Turkey Point  
Issue date: 11/22/1995
From: Hovey R
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17353A453 List:
References
L-95-216, NUDOCS 9511300200
Download: ML17353A452 (12)


Text

P R.IC3 R.IMY'CCELERATEDRIDS PROCESSING

'L REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9511300200 DOC.DATE: 95/11/22 NOTARIZED: YES FACIL:50-250'urkey Point Plant, Unit 3, Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION HOVEY,R.J.

Florida Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

DOCKET g

05000250 05000251

SUBJECT:

Application for amends to Licenses DPR-31

& DPR-41,revising TS index to delete bases re administrative controls reviews.

DISTRIBUTION CODE:

AOOID COPIES RECEIVED: LTR I ENCL f SIZE: 7+

TITLE: OR Submittal: General Distribution'OTES:

RECIPIENT ID CODE/NAME PD2-1 LA CROTEAU,R INTERN ': FILE CENTER~01 RR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS3 EXTERNAL: NOAC COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

0 1

1 RECIPIENT ID CODE/NAME PD2-1 PD NRR/DE/EMCB NRR/DSSA/SPLB NUDOCS-ABSTRACT NRC PDR COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 NiOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACTTHE DOCUWIENTCONTROL DESK, ROOM PI-37 (EXT. 504-2083 ) TO ELIlill.PATE YOUR 4AX1E PRO%I DISTRIBUTIONLISTS I'OR DOCLIvIENTSYOU DON"I'EED!

TOTAL NUMBER OF COPIES REQUIRED LTTR 12 ENCL 11

NOV 22 1995 L-95-216 10 CFR 550.36 10 CFR 550.90 U.

S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555 Gentlemen:

Re:

Turkey Point Units 3 and 4

Docket Nos.

50-250 and 50-251 Proposed License Amendments Removal of Technical Specifications BASES from Technical S ecifications Index In accordance with 10 CFR 550.90, Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to modify the Turkey Point Units 3 and 4

Technical Specifications (TS).

The purpose of these amendments is to revise the TS Index to delete reference to the BASES since, in accordance with 10 CFR 550.36(a),

the BASES are not a part of the TS required by 10 CFR 550.36.

Changes to the TS BASES,will be made under administrative controls and reviews.

A description of the amendments request is provided in Attachment l.

FPL has determined that the proposed license amendments do not involve a significant hazards consideration pursuant to 10 CFR 550.92.

The no significant hazards determination in support of the proposed Technical Specifications changes is provided in Attachment 2.

Attachment 3

provides the proposed revised Technical Specifications.

In accordance with 10 CFR 550.91(b)(1),

a copy of.these proposed license amendments are being forwarded to the State Designee for the State of Florida.

The proposed license amendments have been reviewed by Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.

Should there be any questions on this request, please contact us.

Very truly yours, Robert J.

Hovey Vice President Turkey Point Plant EJW/RJT Attachments cc:

S.

D. Ebneter, Regional Administrator, Region II, USNRC T. P.

Johnson, Senior Resident Inspector, USNRC, Turkey Point W. A. Passetti, Florida Department of Health and Rehabilitative Services Al,nr, rq

'51}300200 951'122 PDR ADOCK 05000250 P.,

PDR WIG'tg @~~AC stM~A4,2~

el 4 an FPL Group company

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STATE OF FLORIDA COUNTY OF DADE

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) ss.

)

Robert J.

Hovey being first duly sworn, deposes and says:

That he is Vice President, Turkey Point Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

Robert J.

Hove Subscribed and sworn to before me this

~if day f

995.

,"qe'"."ru'"a JAMES E KNORR I,:

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MYCOMMISSIONICC 434'o,-

EXPIRES: Januay 22, 1BcA

"~p;p, Bonded Thu Notuy Publo Undennrca

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Par oa o/R Name of Notary Public (Type or Print)

NOTARY PUBLIC, in and for the County of Dade, State of Florida My Commission expires Commission No.

c"c",

> +Roc Robert J.

Hovey is personally known to me.

p I

P ~d,t l

f'f

L-95-216 Attachment 1

Page 1

ATTACHMENT 1 DESCRIPTION OF AMENDMENTS RE GEST Description and Purpose The proposed amendments revise the Turkey Point Units 3 and 4

Technical Specifications (TS) to remove the reference to the TS BASES from the TS Index since, in accordance with 10 CFR 550.36(a),

the BASES are not a part of the TS required by 10 CFR 550.36.

Changes to the TS BASES will be made under administrative controls and reviews.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

Background

Title 10 CFR 550.36, "Technical Specifications, " addresses the categories of technical specifications to be included in each facility's operating license.

Title 10 CFR 550.36(a)

states,

"(a]

summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications."

Pursuant to 10 CFR 550.36(a),

FPL proposes that the Index of the Turkey Point Units 3 and 4

TS be revised to delete reference to the BASES.

Discussion and Description of Proposed Changes The following changes in plant TS, shown in Attachment 3, are proposed:

1.

DELETE reference to BASES section of Index foz Section 2, Safety Limits and Limiting Safety System Settings on Index page iii.

2.

DELETE Index pages xv thzough xx that deal with Section 3/4 BASES documentation.

Justification:

Title 10 CFR 550.36(a)

states,

"[a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications."

Pursuant to 10 CFR 550.36(a),

FPL proposes that the Index of the Turkey Point Units 3 and 4

TS be revised to delete reference to the BASES.

Changes to the TS BASES will be controlled by a plant procedure under administrative controls and reviews.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

L-95-216 Attachment 1

Page 2

10 CFR 550.36 Applicability On July 17, 1995 (60 FR 36953),

the Nuclear Regulatory Commission (NRC) amended its regulations pertaining to TS for nuclear power reactors.

The rule codifies criteria for determining the content of TS.

Licensees may voluntarily use the criteria as a basis to propose the relocation of existing TS that do not meet any of the criteria from the facility license to licensee-controlled documents.

The rule's set of objective criteria for determining which regulatory requirements and operating restrictions should be included in TS are addressed below as related to the proposed amendments.

(A)

Criterion 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 1 Anal sis All instrumentation required by current TS will continue to be addressed and required by the Turkey Point Units 3 and 4 TS.

The proposed changes will revise the Turkey Point Units 3 and 4 TS to remove the reference to the TS BASES from the TS Index.

The TS BASES will be controlled by a plant procedure using administrative guidelines and controls.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

These amendments do not propose changes to the TS affecting instruments specifically installed to detect excessive reactor coolant system leakage oz instrumentation installed to detect significant abnormal degradation of the reactor coolant pressure boundary.

(B)

Criterion 2.

A process

variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 2 Anal sis Process variables that have initial values assumed in the Design Basis Accident and Transient analyses, and which are monitored and controlled during power operation, will continue to be maintained as currently included in the Turkey Point TS.

Additionally, active design features (e,g.,

high pressure/low pressure system valves and interlocks) and operating restrictions (pressure/tempezatuze limits) needed to preclude unanalyzed accidents and transients, and as currently included in the TS, are not affected by these amendments.

The amendments will revise the Turkey Point Units 3 and 4

TS to remove the reference to the TS BASES from the TS Index.

The TS BASES will be controlled by a plant procedure using administrative guidelines and controls.

Proposed changes to the TS BASES will be evaluated in

L-95-216 Attachment 1

Page 3

accordance with 10 CFR 550.59.

No physical modifications to the facility are required to implement these proposed amendments.

(C)

Criterion 3.

A structure,

system, oz component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes t'e failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 Anal sis Structures,

systems, and components that aze part of the primary success path of the safety sequence
analysis, as well as those support and actuation systems that are necessary for items in the'primary success path to successfully function, are unaffected by these amendments.

The amendments will revise the Turkey Point Units 3 and 4

TS to remove the reference to the TS BASES from the TS Index.

The TS BASES will be controlled by a plant procedure using administrative guidelines and controls.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

No physical modifications to the facility aze required to implement these proposed amendments.

(D)

Criterion 4.

A structure,

system, or component which operating experience or probabili sti c risk assessment has shown to be significant to public health and safety.

Criterion 4 Anal sis The Turkey Point TS which address systems foz which operating experience and probabilistic safety assessment have generally shown to be significant to public health and safety and any other structures,

systems, or components that meet this criterion are not impacted by the proposed license amendments.

The amendments will revise the Turkey Point Units 3 and 4

TS to remove the 'reference to the TS BASES from the TS Index.

The TS BASES will be controlled by a plant procedure using administrative guidelines and controls.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

No physical modifications to the facility are required to implement these proposed amendments.

The proposed revisions to Turkey Point Units 3 and 4

TS are administrative in nature.

Since, per 10 CFR 550.36(a),

the BASES are not a part of the TS required by 10 CFR 550.36, reference to the BASES may be removed from the TS Index.

Changes to the TS BASES will be controlled by a plant procedure under administrative controls and reviews.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

L-95-216 Attachment 2

Page 1

ATTACHMENT 2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Description of Proposed License Amendments These amendments propose to revise the Turkey Point Units 3 and 4

Technical Specifications (TS) Index to delete reference to the BASES.

These changes do not affect plant design or the modes of plant operation.

The proposed revisions to Turkey Point Units 3 and 4

TS are administrative in nature.

Changes to the TS BASES will be controlled by a plant procedure under administrative controls and reviews.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

Introduction The Nuclear Regulatory Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 550.92 (c)).

A proposed amendment to an operating license for a facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendments would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Each standard is discussed below for the proposed amendments.

Discussion (1)

Operation of the facility in accordance with the proposed amendments would not involve a significant increase in the probability or consecpxences of an accident previously evaluated.

The proposed amendments are administrative in nature and do not affect assumptions contained in plant safety analyses, the physical design and operation of the plant, nor do they affect Technical Specifications that preserve safety analysis assumptions.

The Technical Specification

BASES, pez 10 CFR 550.36(a),

are not a part of the Technical Specifications.

Changes to the TS BASES will be controlled by a plant procedure under administrative controls and reviews.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

Therefore, the proposed change does not affect the probability or consequences of accidents previously analyzed.

(2)

Opexation of the facility in accordance with the proposed amendments would not create the possibility of a new or different kind of accident from any accident previously evaluated.

t II

L-95-216 Attachment 2

Page 2

The proposed amendments are administrative in nature.

The proposed amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated since the proposed amendments will not change the physical plant oz the modes of plant operation defined in the facility operating license.

No new failure mode is introduced due to the administrative

change, since the proposed change does not involve the addition or modification of equipment nor does it alter the design or operation of affected plant
systems, structures, or components.

(3)

Operation of the facility in accordance with the proposed amendments would not involve a significant reduction in a margin of safety.

The operating limits and functional capabilities of the affected

systems, structures, and components are unchanged by the proposed amendments.

The BASES information, per 10 CFR 550.36(a), is not a part of the Technical Specifications.

Changes to the TS BASES will be controlled by a plant procedure under administrative controls and reviews.

Proposed changes to the TS BASES will be evaluated in accordance with 10 CFR 550.59.

Therefore, the proposed change does not reduce any margin of safety.

Based on the above discussion, FPL has determined that the proposed amendments do not (1) involve a significant, increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore the proposed changes do not involve a significant hazards consideration as defined in 10 CFR 550.92.

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