Text

Application for Amends to Licenses DPR-31 & DPR-41,revising Definition of RTP from 2,200 Mwt to 2,300 Mwt.Proprietary TR WCAP-13719,Rev 2 & Nonproprietary TRs WCAP-13718,Rev 2 & WCAP-14276,Rev 1 Encl.Proprietary TR WCAP-13719 Withheld
	ML17353A501
Person / Time
Site:	Turkey Point
Issue date:	12/18/1995
From:	Hovey R; FLORIDA POWER & LIGHT CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17353A502	List: ML17353A501; ML17353A503; ML17353A504; ML17353A505; ML17353A506;
References
	L-95-245, NUDOCS 9512270307
	Download: ML17353A501 (66)
	v • d • e

PRIORI EY ACCELERATED RIDS Pl<OCI'.SSIiG) 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9512270307 DOC.DATE: 95/12/18 NOTARIZED: YES DOCKET g FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION HOVEY,R.J. Florida Power & Light Co.

RECIPIENT AFFILIATION F'ECIP.NAME

'f

SUBJECT:

Document Control Branch (Document Control Desk)

Application for amends to licenses DPR-31 & DPR-41,revising

~ R definition of RTP from 2,200 MWt to 2,300 MWt.Proprietary TR ,l WCAP-13719,Rev 2 & nonproprietary TRs WCAP-13718,Rev 2 &

WCAP-14276,Rev 1 encl. Proprietary TR WCAP-13719 withheld.

0 DISTRIBUTION CODE: APOID COPIES RECEIVED:LTR I ENCL Q icense SIZE: 7+5 TITLE: Proprietary Review Distribution Pre Operating & Opera zn R R NOTES: ~088-P7iP RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 CROTEAU,R 1 1 INTE : FILE CENT 01 1 1'GC/HDS3 1 0 EXTERNAL: NRC PDR gyp D

C NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE I3ELP US TO REDUCE 4VKSTE! CONTACT'I'IIE DOCL'i!EN'!'ONTROL DESk, ROOXI P 1-37 (EXT. 504-~033 ) TO F LI%1I NATE YOI.'R N'Ai!Lz F ROif DISTRIBUTION LIS'I'S I'OR DOC!.'MEN'I'S YOL DON" I'EI D!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 6 ENCL

OEC 181995 L-95-245 10 CFR 50.36 10 CFR 50.90 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 Pzoposed License Amendments Thermal Power U rate In accordance with 10 CFR 50.90, Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 be amended to revise the Turkey Point Units 3 and 4 definition of RATED THERMAL POWER from 2200 Megawatt-thermal (MWt) to 2300 MWt.

In order to operate at the higher power level, detailed evaluations of the Nuclear Steam Supply System (NSSS) (including Loss of Coolant Accident (LOCA), non-LOCA, Containment Responses and Dose Consequences), engineered safety features, power conversion, emergency power, support systems and environmental issues have been performed.

The results of these evaluations and analyses, where appropriate, as documented in the enclosed report WCAP-14276, confirm that Turkey Point Units 3 and 4 can safely operate at the increased power level.

In addition, FPL proposes changing Technical Specifications (TS) in the following Sections: TS 1.24, Definitions Rated Thermal Power; TS 2.1.1, Safety Limit Reactor Core; TS 2 ', Limiting Safety System Settings Reactor Trip System Instrumentation Setpoints; TS 3/4.2 Power Distribution Limits; TS 3/4.3.2 Engineered Safety Features Actuation System Instrumentation; TS 3/4.4 Reactor Coolant System; TS 3/4.5 Emergency Core Cooling Systems; TS 4.6.2.2 Emergency Containment Cooling System; TS 3/4.7 Plant Systems; TS 6.9.1.7 Core Operating Limits Report, and the associated BASES. The proposed revisions to the Technical Specifications are described in detail in the attachments.

The Revised Thermal Design Procedure (RTDP) methodology used in the Thermal Power Uprate Analyses has been previously approved by the NRC in Westinghouse topical report WCAP-11397-P-A. This methodology provides an increase in the Departure from Nucleate Boiling (DNB) margin by convoluting statistically the uncertainties on power, pressure, temperature, flow and the DNB correlation to define the Departure from Nucleate Boiling Ratio (DNBR) limit and core thermal limits. These uncertainties have been calculated for Turkey Point in Westinghouse topical report WCAP-13719, Revision 2, which is provided as an enclosure to this submittal.

FPL has determined that the proposed license amendments do not involve a significant hazards consideration pursuant to 10 CFR 50.92. A description of the amendments request is provided in Attachment 1.

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

9512270307 951218 ADQCK 05000250 PDR P PDR an FPL Group company

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l-L-95-245 Page 2 provides the proposed zevised Technical Specifications.

1 contains a single copy of Westinghouse Report, WCAP-14276, Revision 1, entitled "Florida Power and Light Company Turkey Point Units 3 and 4 Uprating Licensing Report." WCAP-14276 is a non-proprietary topical report. Enclosure 2 contains a single copy of Westinghouse proprietary report, WCAP-13719, Revision 2, entitled "Westinghouse Revised Thermal Design Procedure Instrument Uncertainty Methodology for Florida Power & Light Company Turkey Point Units 3 and 4" and a single copy of the Westinghouse non-proprietary report, WCAP-13718, Revision 2. Enclosure 3 includes a Westinghouse authorization letter, CAW-95-890, accompanying affidavit, Proprietary Information Notice, and Copyright Notice.

Since Enclosure 2 contains information proprietary to Westinghouse Electric Corporation, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.790 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to the copyright oz proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-95-890 and should be addressed to N. J. Liparulo, Manager of Nuclear Safety & Regulatory Activities, Westinghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

In accordance with 10 CFR 50.91(b)(1), a copy of these proposed license amendments is being forwarded to the State Designee for the State of Florida.

The proposed amendments have been reviewed by the 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. Hove Vice President Turkey Point Plant Attachments Enclosures (3)

C

~ ~

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L-95-245 Page 3 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 R. P. Croteau, Project Manager, USNRC, Washington, D.C.

STATE OF FLORIDA )

) ss.

COUNTY OF DADE )

Robert J. Hovey being first duly sworn, deposes and says:

That he is Vice President, Turkey Point Nuclear 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. Ho ey Subscribed and sworn to before me this yl, d of ~s Acr, 1995.

+;=

JAMES E. ImORR

)a+< MY COLIMISSIOII 8 CC 4S4XO EXPIRES: Jsnwy 22, 1999 Bcebd 1hu Nabs PuMc Undue~

4c Jc Name of Notary Pub ic (Type or Print)

NOTARY PUBLIC, in and for the County of Dade, State of Florida My Commission expires Commission No. Cc Robert J. Hovey is personally known to me.

ATTACHMENT1 DESCRIPTION OF AMENDMENTS REQUEST

)

e

L-95-245 Page 1 of 17 DESCRIPTION OF AMENDMENTS RE UEST

1.0 INTRODUCTION

Florida Power and Light Company has undertaken a comprehensive program to increase the allowed rated thermal power for Turkey Point Units 3 and 4 from 2200 MWt to 2300 MWt.

This program is documented in WCAP-14276, "Florida Power and Light Company Turkey Point Units 3 and 4 Uprating Licensing Report." This topical report provides the following criteria which formed the basis for the Turkey Point thermal power uprate:

The review encompassed the aspects of Nuclear Steam Supply System (NSSS) and Balance of Plant (BOP) design and operation which are impacted by the power uprating. The scope of this review included the NSSS and BOP safety analyses, the functional capability of the systems for normal and abnormal plant operations and design basis accidents, and the mechanical design of NSSS and BOP components and structures.

2. Safety analyses were performed to Updated Final Safety Analysis Report (UFSAR) quality standards, and evaluated in accordance with criteria and standards that apply to the current Turkey Point Units 3 and 4 operating licenses.

3. Equipment structural designs were evaluated in accordance with the regulatory requirement, codes and standards to which the equipment was originally built.

The proposed plant changes to Turkey Point for the thermal power uprate program involve minor hardware changes.

The proposed changes are adrhessed and grouped as follows, and considered as such in the , "Determination of No Significant Hazards Consideration":

~ License Condition Rated Thermal Power Core Safet Limits Reactor Tri S stem Instrumentation Tri Set pints En ineered Safet Features Actuation S stem SFAS Instrumentation Tri Set pints De arture from Nucleate Boilin DNB Parameters and Reactor Coolant Pum RCP Breaker Position

~TrI

L-95-245 Page 2 of 17 The comprehensive thermal power uprate program undertaken by FPL resulted in revisions to the definition of RATED THERMAL POWER, core safety limits, DNB parameters, RCP breaker position trip function, reactor trip setpoints and ESFAS trip setpoints, The use of the Revised Thermal Design Procedure (RTDP) methodology, the change in peaking factors, and the other changes associated with the uprating (including increased rated thermal power) have resulted in changes to core safety limits and reactor trip and ESFAS trip setpoints. Analyses that are affected by these proposed changes have been reanalyzed or evaluated and the acceptance criteria as indicated in WCAP-14276 are met. The revised setpoints reflect the analysis input assumptions, and consequently the acceptable analysis results justify their revision.

The RTDP methodology has been previously approved by the NRC in Westinghouse topical report WCAP-11397-P-A (reference 1). By letters L-95-131 and L-95-250 (references 2 and 8), FPL submitted a proposed revision to the Turkey Point Units 3 and 4 Technical Specifications to implement the Revised Thermal Design Procedure, The proposed changes to the Reactor Protection System (RPS) and ESFAS trip setpoints are based on the use of the RTDP methodology as documented in WCAP-13719, Revision 1 (reference 3). In support of the thermal power uprate, Westinghouse generated a Revision 2 to WCAP-13719 (reference 4) to address changes to the RPS and ESFAS setpoints as a result of the increase in power level.

~ Available Volume Chan e for Condensate Stora e Tank and the Demineralized Water Stora e Tank and Reduced Safet In'ection SI Pum Dischar e Head Re uirement FPL evaluated and modified these parameters to more accurately reflect plant conditions needed to operate at the uprated conditions and to include additional operating margin where appropriate. The analyses and evaluations support the revised TS values.

~ Pressurizer and Main Steam Safet Valve Set oint Tolerances The pressurizer and main steam safety valve setpoint tolerances were increased. The reanalysis supported the revised values. These values provide flexibility and margin in valve testing.

L-95-245 Page 3 of 17

~ 0 eration at Reduced Power with Ino erable Main Steam Safet Valves MSSVs Since the maximum allowable power range neutron flux high setpoint is based on the nominal Nuclear Steam Supply System (NSSS) power rating of the plant (including reactor coolant pump heat), a reanalysis was performed to establish the revised values.

Service Period for Heatu and Cooldown Pressure-Tem erature Limit Curves The increased vessel fluence resulting from higher core power required a revision to the service period for the heatup/cooldown curves. The existing curves were verified to be acceptable for the revised service period.

Modification to Surveillance Re uirement for Emer enc Containment Coolin ECC S stem To ensure that the acceptance criteria for containment integrity, component cooling water system operation and post-LOCA long-term containment analyses are met for the uprated power conditions, the TS Surveillance Requirement was modified.

Control Room Emer enc Ventilation S stem The Technical Specifications issued with the operating license for Turkey Point Units 3 and 4 did not include any Limiting Condition for Operation associated with the Control Room Emergency Ventilation System. The Atomic Energy Commission (AEC) requested inclusion of such Technical Specifications in 1974 (reference 5) and provided model Technical Specifications for inclusion in the Turkey Point plant licenses. These model Technical Specifications were based on the removal of greater than or equal to 90% radioactive methyl iodide. The Technical Specifications approved by the NRC in April 1982 (reference 6) included a methyl iodide removal efficiency of 90%.

To assure consistency between testing efficiency and analysis assumptions for post-accident control room doses, the required methyl iodide removal efficiency is being increased to 99%. This increase is consistent with the recommendations of Regulatory Guide 1.52 (reference 7), and supports the analysis for post-accident control room doses. Since this change is clearly conservative, personnel safety will not be adversely impacted.

L-95-245 Page 4 of 17

'""~H"'"'""

0 eratin Limits Re ort COLR and Editorial Corrections Generic Letter (GL) 88-16, dated October 4, 1988, encouraged licensees to amend the Technical Specifications related to cycle specific parameters. The GL provided guidance for relocation of certain cycle-dependent core operating limits from a licensee's Technical Specifications to the COLR. This would allow changes to the values of the core operating limits without prior NRC approval (i.e., license amendment), as long as an NRC approved methodology for the parameter limit calculation is followed. The Large Break Loss of Coolant Accident (LBLOCA) was analyzed at the uprated core power level with the increased F~ and F>H peaking factors. The proposed Technical Specification changes will relocate these cycle specific peaking factors from the Technical Specifications to the COLR. In addition, editorial changes are made to ensure consistency and accuracy within the Technical Specifications.

L-95-245 Page 5 of 17 2.0 PROPOSED TECHNICAL SPECIFICATION CHANGES FPL proposes to change the following Technical Specifications in support of the proposed amendments:

A. License Condition Rated Thermal Power Core Safet Limits Reactor Tri S stem Instrumentation Tri Set pints ESFAS Instrumentation Tri Set pints DNB Parameters and RCP Breaker Position Tri License Condition 3.A for 0 eratin License DPR-31 and DPR-41

",Maximum Power Level": Change the License Condition to read as follows:

". . applicant is authorized to operate the facility at reactor core power

~

levels not in excess of 2300 megawatts (thermal)."

Justification: FPL has evaluated the increase in rated thermal power from 2200 MWt to 2300 MWt. WCAP-14276 documents the results. Reanalysis or evaluation including LBLOCA, Small Break LOCA (SBLOCA), containment response, radiological consequences and non-LOCA analyses, have concluded that Turkey Point Units 3 and 4 are acceptable for operation at the uprated condition. Analysis (when appropriate) and evaluation of NSSS and Balance of Plant (BOP) systems and components have concluded that the systems and components are acceptable for operation at the uprated power level. The pertinent plant aspects for Turkey Point Units 3 and 4 have been reviewed and it has been concluded that both units can safely operate at the increased power level.

2. TS 1.24 Definition of "RATED THERMAL POWER": Change 2200 MWt to 2300 MWt to reflect the new uprated power level.

Justification: FPL has evaluated the increase in rated thermal power from 2200 MWt to 2300 MWt. WCAP-14276 documents the results. Reanalysis or evaluation including LBLOCA, SBLOCA, containment response, radiological consequences and non-LOCA analyses, have concluded that Turkey Point Units 3 and 4 are acceptable for operation at the uprated condition. Analysis (when appropriate) and evaluation of NSSS and BOP systems and components have concluded that the systems and components are acceptable for operation at the uprated power level. The pertinent plant aspects for Turkey Point Units 3 and 4 have been reviewed and it has been concluded that both units can safely operate at the increased power level.

L-95-245 Page 6 of 17

3. TS Fi ure 2.1-1 "Reactor Core Safet Limits - Three Loo s in fl i ": i flfl flfl-fl *fl* fl fl i K iflfl operating conditions at the uprated power level.

Justification: New core safety limits have been generated to include the effects of the proposed uprating. Factors such as increased power level, revised flowrate, and increased peaking factors were included in the revised core safety limits. In addition, new overtemperature bT (OTBT) and overpower bT (OPbT) protection lines were developed to ensure the core limits are not violated. Reanalysis of those transients, such as rod withdrawal at power, which use OTBT as the primary reactor trip, has shown that the acceptance criteria as established in WCAP-14276 have been met. The revised core limits include the use of the RTDP methodology. By letters L-95-131 and L-95-250 (references 2 and 8), FPL submitted a proposed revision to the Technical Specifications to include the implementation of the RTDP methodology for Turkey Point.

4. TS Table 2.2-1 "Reactor Tri S stem Instrumentation Tri Set pints" Functional Unit 5 Overtem erature dT Revise the following values:

(a) Changes to NOTE 1 (1) Kl from "1.25" to "1.24",

(2) K2 from "0.016" to "0.017",

(3) T from "<574.2 F" to "<577.2 F",

(4) K~ from "0.0011" to "0.001",

(5) Limits of percent rated thermal power change "46%" to "50%" (negative),

(6) bT trip setpoint reduction from "1.5%" to "0.0%" (negative), and bT trip setpoint reduction from "2.3%" to "2.19%" (positive).

(b) Change to NOTE 2 (1) change % of instrument span from "0.73%" to "0.84%."

Justification: The revised core safety limits of TS Figure 2.1-1 required changes to the overtemperature bT (OTBT) setpoints. The use of the RTDP methodology and the inclusion of Turkey Point specific instrument uncertainties have resulted in revisions to the other values (such as allowance, etc.) associated with the OTbT trip function. These revised setpoints were used in the accident analysis to verify their acceptability. The accident analysis criteria established in WCAP-14276 have been met. Modification to inputs for the f(b,l) function are consistent with the use of the current Relaxed Axial

L-95-245 Page 7 of 17 Offset Control (RAOC) strategy employed at Turkey Point.

The RTDP methodology has been previously approved by the NRC in Westinghouse topical report WCAP-11397-P-A (reference 1). By letters L 131 and L-95-250 (references 2 and 8), FPL submitted a proposed revision to the Turkey Point Units 3 and 4 Technical Specifications to implement RTDP.

The proposed changes to the RPS and ESFAS trip setpoints are based on the use of the RTDP methodology as documented in WCAP-13719, Revision 1 (reference 3). In support of the thermal power uprate, Westinghouse generated a Revision 2 to WCAP-13719 to adda:ss changes to the RPS and ESFAS setpoints as a result of the increase in the power level.

TS Table 2.2-1 "Reactor Tri S stem Instrumentation Tri Set pints" Functional Unit 6 - Over ower hT Change the following:

(a) Changes to NOTE 3 (1) K6 from "0.00232" to "0.0016", and (2) T from "= Indicated T at RATED THERMAL POWER (Calibration temperature for dT instrumentation, ( 574.2 F)" to

"< 577.2 F (Nominal Tavg at RATED THERMAL POWER)".

(b) Change to NOTE 4 (1) the % of instrument span from "0.4%" to "0.96%".

Justification: The revised core safety limits of TS Figure 2.1-1 required changes to the overpower dT (OPbT) setpoints. The revised setpoints have been evaluated and found to be appropriate. The use of the RTDP methodology and the inclusion of Turkey Point specific instrument uncertainties have resulted in revisions to the other values (such as allowance, etc.) associated with the OPbT trip function. These revised setpoints (with uncertainties) were used in accident analyses to verify their acceptability. All accident analysis acceptance criteria continue to be met.

The RTDP methodology has been previously approved by the NRC in Westinghouse topical report WCAP-11397-P-A (reference 1). By letters L 131 and L-95-250 (references 2 and 8), FPL submitted a proposed revision to the Turkey Point Units 3 and 4 Technical Specifications to implement RTDP.

The proposed changes to the RPS and ESFAS trip setpoints are based on the use of the RTDP methodology as documented in WCAP-13719, Revision 1 (reference 3). In support of the thermal power uprate, Westinghouse generated a Revision 2 to WCAP-13719 (reference 4) to a'ddress changes to the RPS and

L-95-245 Page 8 of 17 ESFAS setpoints as a result of the increase in the power level.

6. TS Table 2.2-1 "Reactor Tri S stem Instrumentation Tri Set pints" Functional Unit 10 - Reactor Coolant Flow-Low Change the following:

(a) Loop design flowrate from "89,500 gpm" to "85,000 gpm" in

footnote.

Justification: The reduced loop flowrate accounts for an analyzed increase in the percentage of steam generator tubes plugged. The effects of the reduced flow have been accounted for in the revised core safety limits and in the accident analysis. Since the criteria indicated in WCAP-14276 have been met, the use of the reduced flowrate is acceptable.

7. TS Table 2.2-1 "Reactor Tri S stem Instrumentation Tri Set pints" Functional Unit 11 - Steam Generator Water Level - Low-Low and Functional Unit 12 - Steam Generator Water Level - Low Change the following:

(a) Allowable Value from "8.9%" to "8.15%".

Justification: Turkey Point specific uncertainties were used to modify these values in accordance with Westinghouse NRC-approved setpoint methodology of WCAP-12745 (reference 9). Accident analyses, such as the loss of normal feedwater event, have verified their acceptability since all acceptance criteria indicated in WCAP-14276 have been met.

8. TS Table 3.3-3 "En ineered Safet Features Actuation S stem Instrumentation Tri Set pints" Functional Unit 1 Safet In ection Functional Unit 4 Steamline Isolation and Functional Unit 6 Auxiliar Feedwater.

Change the following values:

(a) 1.f (Steam Line Flow-High) Trip Setpoint from "120% to "114%",

1.f (Steam Line Flow-High) Allowable Value from "42.6%" to "44%", and (Steam Line Flow High) Allowable Value from "122.6%" to "116.5%".

L-95-245 Page 9 of 17 (b) 4.d. (Steam Line Flow-High) Trip Setpoint from "120%" to "114%",

4.d. (Steam Line Flow-High) Allowable Value from "42.6%" to "44%", and 4.d. (Steam Line Flow High) Allowable Value from "122.6%" to "116.5%".

(c) 6.b (Steam Generator Water Level-Low-Low) Allowable Value from "8.9%" to "8.15%".

Justification: Turkey Point specific calculations have resulted in changes to various engineered safety features (ESF) functions. Analyses have been performed in accordance with the methodology of WCAP-12745 (reference 9).

All affected changes have been found acceptable with respect to accident analysis. Adequate margin is maintained for all trip functions.

9. TS 3.2.5 "DNB Parameters" and Associated BASE~S Revise the following:

(a) TS 3.2.5a. from "576.6" to "581.2",

(b) TS 3.2.5b. from "2209" to "2200",

(c) TS 3.2.5c. from "277,900" to "264,000", and (d) Revise the BASES to address the above proposed change and the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months surveillance criteria for RCS flow.

Justification: By applying Turkey Point specific instrument uncertainties and values for Ta, Pressure and Flow associated with the uprating, appropriate indicated values of Tavg, Pressure and Flow have been calculated. Also included in the flow value is a loop design flow reduction of 4500 gpm. The revised DNB parameters have been analytically verified and their effects have been included in the revised core thermal limits of TS Figure 2.1-1.

The RTDP methodology has been approved by the NRC in Westinghouse topical report WCAP-11397-P-A (reference 1). By letters L-95-131 and L 250 (references 2 and 8), FPL submitted a proposed revision to the Turkey Point Units 3 and 4 Technical Specifications to implement RTDP. The proposed changes to the DNB parameters are based on the us'e of the RTDP methodology as documented in WCAP-13719, Revision 1 (reference 3). In support of the thermal power uprate, Westinghouse generated a Revision 2 to WCAP-13719 (reference 4) to address changes to the RPS and ESFAS setpoints as a result of the increase in the core power level.

L-95-245 Page 10 of 17 The Reactor Coolant System (RCS) Flow limit has been reduced to 264,000 gpm. This limit is based on a Thermal Design Flow (TDF) limit of 255,000 gpm (85,000 gpm per loop) which assumes a Steam Generator tube plugging level of 20%. The above limit also includes a 3.5% RCS flow measurement uncertainty.

The Surveillance Requirement associated with the RCS flow rate has been clarified to more closely resemble the original intent of the surveillance. The indicated RCS flow rate must be greater than the TDF plus instrument channel uncertainties (including parallax errors). The proposed surveillance also takes advantage of the additional margin gained.

10. TS BASES Pa e B 2-7 Reactor Coolant Puin Breaker Position Tri Delete the following sentence:

"No credit was taken in the accident analyses for operation of these trips."

Justification: Credit is taken for the RCP Breaker Position Trip. The Turkey Point plant underfrequency signal does not directly result in a reactor trip, but rather it trips the RCP breakers which in turn trip the reactor. Therefore, RCP Breaker Position Trip is credited and assumed for reactor trip.

L-95-245 Page 11 of 17 B. Available Volume Chan e for Condensate Stora e Tank and the Demineralized Water Stora e Tank and Reduced Safet In ection S Pum Dischar e Head Re uirement TS 3.7.1.3 "Condensate Stora e Tank" and Associated BASES TS 3.7.1.6 "Standb Steam Generator Feedwater S stem" and Associated BASES.

Revise the following:

(a) TS 3.7.1.3 - change "185,000" to "210,000",

(b) TS 3.7.1.3 - change "370,000" to "420,000",

(c) TS 3/4.7.1.3 ACTION and SURVEILLANCE REQUIREMENTS statements - substitute the word "indicating" for the word "containing",

and add the word "indicated,"

(d) TS 3.7.1.6 - change "60,000" to "135,000", and (e) TS 3.7.1.6, ACTION c. - add the word "indicated."

Justification: Operation at the uprated power conditions required that tanks such as the condensate storage tank (CST) and the demineralized water storage tank (DWST) have minimum volumes available so that their design safe shutdown functions can be met. Analyses have verified that the proposed minimum volumes meet the requirements for their design safe shutdown functions.

Thermal power uprate analysis results show increased emergency feedwater flow and volume delivery requirements. This requires increased CST and DWST reserve volumes and a corresponding change in the Technical Specifications. This also presents an opportunity to clarify existing text by using consistent terminology and distinguishing between the minimum usable volume required for delivery and the minimum indicated volume, which includes allowance for instrument uncertainties and a portion deemed unusable.

The proposed changes to the TS BASES section for DWST and CST include a discussion of the minimum indicated volume and the basis for which the Technical Specification value is developed.

L-95-245 Page 12 of 17

2. TS 4.5.2 - "Emer enc Core Coolin S stem" and Associated BASES Make the following changes:

(a) TS 4.5.2c.1) change "1126 psid" to "1083 psid" (for normal alignment or Unit 4 SI pumps aligned to Unit 3 RWST), and change "1156 psid" to "1113 psid" (for Unit 3 SI pumps aligned to Unit 4 RWST).

Justification: Analysis has supported a reduction in the pump discharge head.

This reduction in required head will provide margin for meeting SI pump test acceptance criteria and also provide available margin should pump degradation occur.

C. Pressurizer and Main Steam Safet Valve Set oint Tolerances I. TS 3 4.2.1 - "Safet Valves" TS 3.4.2.2 - "Safet Valves" TS Table 3.7 "Steam Line Safet Valves Per Loo " and Associated BASES for TS 3/4.4.2 and 3/4.7.1.1.

Change the following:

(a) TS 3.4.2.1 and 3.4.2.2: Increase the pressurizer safety valve tolerances from "+1%" to "+2%, - 3%",

(b) TS 3.4.2.1, 3.4.2.2: Add the footnote "All valves tested must have "as-left" lift setpoints that are within 1% of the lift setting value."

(c) TS Table 3.7-2; Change MSSVs lift setting tolerances from "+ 1%" to

"+ 3%",

(d) TS Table 3.7.2: Add the footnote "Allvalves tested must have "as-left" lift setpoints that are within + 1% of the lift setting value listed in Table 3.7-2."

Justification: The use of increased tolerances has been accommodated in the accident analysis in WCAP-14276. Valve operability is not affected by these proposed changes. The valves will continue to perform their intended safety functions.

FPL proposes the use of the "+ 3%" tolerance for the "as-found" acceptance criteria for the main steam safety valves and "+2%, -3%" tolerance for the "as-found" acceptance criteria for the pressurizer safety valves. The proposed changes require that the pressurizer and main steam safety valve setpoints be restored to within + 1% of their nominal setpoints following testing.

L-95-245 Page 13 of 17 D. 0 eration at Reduced Power with Ino erable Main Steam Safet Valves MSSVs TS Table 3.7 "Steam Line Safet Valves Per Loo ". Change the following maximum allowable power level with inoperable main steam line safety valves (MSSV):

(a) For one inoperable MSSV (per steam line), reduce the maximum allowable power level from "56%" to "53%", and (b) For two inoperable MSSV (per steam line), reduce the maximum allowable power level from "35%" to "33%".

Justification: Turkey Point's Technical Specification 3/4.7.1.1 is based on an algorithm which defines the maximum power level at which the plant is allowed to operate as a function of the available MSSV relief capacity. This algorithm as identified in the BASES Section for TS 3/4.7.1.1 is used to calculate the maximum allowable power level specified in TS Table 3.7-1.

Included in this algorithm is the nominal NSSS power rating of the plant, which is currently assumed as 2208 MWt (including reactor coolant pump heat). As a result of the thermal power uprate, the nominal Nuclear Steam Supply System (NSSS) power rating of the plant (including reactor coolant pump heat) will be changed from 2208 MWt to 2308 MWt.

E. Service Period for Heatu and Cooldown Pressure-Tem erature Limit Curves TS Fi ure 3.4 "RCS Heatu Limitations 60 F/Hr - A licable U To 19 EFPY" TS Fi ure 3.4 "RCS Heatu Limitations 100 oF/Hr - A tieable U To 19 EFPY" and TS Fi ure 3.4 "RCS Cooldown Limitations 100 F/Hr - A licable U To 19 EFPY" and Associated BASES. Change the following:

(a) Service period from "20 EFPY" to "19 EFPY".

Justification: The changes in neutron fluence resulting from the proposed Turkey Point Units 3 and 4 thermal power uprating have been evaluated and their impact on reactor vessel integrity has been determined. Fluence projections on the vessel were calculated for the uprated power level and calculations were performed for the revised fluences on vessel integrity. It was determined that the current heatup and cooldown curves contained in the Technical Specifications are applicable for the uprated conditions for a service period to 19 EFPY.

0 L-95-245 Page 14 of 17 F. Modification to Surveillance Re uirement for Emer enc Containment Coolin

~Setem

1. TS 4.6.2.2 - "Emer enc Containment Coolin S stem" and Associated BASES. Revise TS 4.6.2.2b.1) to read:

"Verifying that two emergency containment cooling units start automatically on a safety injection (SI) test signal, and ..."

Justification: The proposed configuration will ensure that the acceptance criteria for containment integrity, component cooling water system operation and post-LOCA long term containment response are met. The auto-start of all three ECC units on an SI signal is no longer required. For containment integrity safety analyses and component cooling water system thermal analyses, a maximum of two ECCs can receive an automatic start signal following generation of an SI signal without exceeding component cooling water system temperature limits during injection and/or recirculation phases of a LOCA. To support post-LOCA long-term containment pressure/temperature analyses, a minimum of one ECC is required to start immediately with a second ECC unit starting within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following the event. The thiid (swing) ECC is required to be operable for manual starting following a postulated LOCA event for containment pressure/temperature suppression. This has been confirmed by evaluations.

The proposed changes to the TS BASES address the proposed plant configuration.

G. Control Room Emer enc Ventilation S stem

1. TS 4.7.5c.2 "Control Room Emer enc Ventilation S stem." Revise the methyl iodide removal efficiency from "90%" to "99%."

Justification: The Technical Specifications issued with the operating license for Turkey Point Units 3 and 4 did not include any Limiting Condition for Operation associated with the Control Room Emergency Ventilation System.

The Atomic Energy Commission (AEC) requested inclusion of such Technical Specifications in 1974 (reference 5) and provided model Technical Specifications for inclusion in the Turkey Point plant licenses. These model Technical Specifications were based on the removal of greater than or equal to 90% radioactive methyl iodide. The Technical Specifications approved by the NRC in April 1982 (reference 6) included a methyl iodide removal efficiency

L-95-245 Page 15 of 17 of 90%.

To assure consistency between testing efficiency and analysis assumptions for control room doses post-accident, the required methyl iodide removal efficiency is being increased to 99%. This increase is consistent with the recommendations of Regulatory Guide 1.52 (reference 7), and supports the analysis for control room doses post-accident. Since this change is clearly conservative, personnel safety will not be adversely impacted.

H. ~Ri fF dFgpU i f i ~ if' C 0 eratin Limits Re ort COLR and Editorial Corrections TS 3.2.2 - "Heat Flux Hot Channel Factor" TS 3.2.3 - "Nuclear Enthal Rise Hot Channel Factor" TS 6.9.1.7 - "Core 0 eratin Limits Re ort" COLR And Associated BASES for TS 2.1.1 3/4.2.1 3/4.2.2 and 3/4.2.3.

Revise the following:

(a) TS 3.2.2 - Relocate the specific F~ value to the COLR, (b) TS 3.2.3 - Relocate the specific values for F~ and the Power Factor multiplier to the COLR, (c) TS 6.9.1.7-Add the appropriate wording to reflect the inclusion of F~(Z) and F~ in the COLR, (2) Add the following statement - "4. Nuclear Enthalpy Rise Hot Channel Factor for Specification 3/4.2.3", and (3) Update references to be consistent with the current analyses.

Justification: Generic Letter 88-16, dated October 4, 1988, encouraged licensees to amend the TS related to cycle specific parameters. The GL provided guidance for relocation of certain cycle-dependent coze operating limits from a licensee's Technical Specifications to the COLR. This would allow changes to the values of the core operating limits without prior NRC approval (i.e., license amendment), as long as an NRC approved methodology for the parameter limit calculation is followed. The proposed TS changes will relocate cycle specific parameter limits from the TS to the COLR. In accordance with the recommendations of GL 88-16, FPL proposes the addition

L-95-245 Page 16 of 17 of the Heat Flux Hot Channel Factor IF~(Z)], and Nuclear Enthalpy Rise Hot Channel Factor (F~) to the COLR.

These parameters are added to the Axial Flux Difference, Rod Bank Insertion Limits and the K(Z) curve currently included in the COLR in accordance with TS 6.9.1.7.

The Core Operating Limit Report (COLR) is an appropriate document for compiling F~ and F~. The increased peaking factors (Fg = 2.35 and F~ =

1.64) will be maintained in the COLR. These values have been justified based on the thermal power uprate analysis.

The proposed changes to the TS BASES address the relocation of the peaking factors from the Technical Specifications to the COLR.

2. TS BASES 3/4.7.1.4 - Correct the abbreviation for "Dose Conversion Factor" to read "DCF".

Justification: The proposed editorial change is made to ensure consistency within the Technical Specifications.

3., TSvalid is BASES for Pa e B 3/4 2 Delete the following sentence: "The current tube plugging levels up to 5%".

limit Justification: The analysis in WCAP-14276 assumed up to 20% steam generator tube plugging level for the Small Break LOCA and non-LOCA Analyses, while the Large Break LOCA analysis performed using the BASH Evaluation Model assumed a 5% steam generator tube plugging level. Upon NRC approval of the Westinghouse Best Estimate Large Break LOCA (BELOCA) methodology, FPL intends to reanalyze the Large Break LOCA event using the BELOCA methodology and assuming a 20% tube plugging level. This sentence is deleted since the statement is unnecessary in the context of the Technical Specifications BASES.

L-95-245 Attachment 1 Page 17 of 17

3.0 REFERENCES

WCAP-11397-P-A, "Revised Thermal Design Procedure", dated April 1989.

2. Letter, T. F. Plunkett (FPL) to USNRC, "Proposed License Amendments-Implementation of the Revised Thermal Design Procedure and Steam Generator Water Level Low-Low Setpoint", L-95-131, dated May 5, 1995.

3. WCAP-13719, Revision 1, "Westinghouse Revised Thermal Design Procedure Instrument Uncertainty Methodology for Florida Power & Light Company Turkey Point Units 3 and 4", dated January 1995.

4. WCAP-13719, Revision 2, "Westinghouse Revised Thermal Design Procedure Instrument Uncertainty Methodology for Florida Power & Light Company Turkey Point Units 3 and 4", dated September 1995.

5. Letter, G. Lear (AEC) to R. E. Uhrig (FPL), "Installed Filter Systems", dated December 10, 1974.

6. Letter, M. Grotenhius (USNRC) to R. E. Uhrig (FPL), "Issuance of License Amendments 83 and 77 for Operating Licenses DPR-31 and DPR-41", dated April 9, 1982.

7. Regulatory Guide 1.52, Revision 2, "Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants", dated March 1978.

8. Letter, T. F. Plunkett (FPL) to USNRC, "Proposed License Amendments-Implementation of the Revised Thermal Design Procedure and Steam Generator Water Level Low-Low Setpoint", L-95-250, dated September 28, 1995.

~

9 WCAP-12745, "Westinghouse Setpoint Methodology for Protection Systems for Florida Power & Light Company Turkey Point Units 3 and 4 Thermal Uprate Project",

dated December 1995.

ATTACHMENT2 DETERMINATIONOF NO SIGNIFICANT HAZARDS CONSIDERATION

L-95-245 Page 1 of 24 DETERMINATIONOF NO SIGNIFICANT HAZARDS CONSIDERATION

1.0 BACKGROUND

Florida Power and Light Company (FPL) proposes to uprate the core thermal output of Turkey Point Units 3 and 4 from 2200 MWt to 2300 MWt.

Detailed evaluations of the Nuclear Steam Supply System (NSSS) (including Loss of Coolant Accident (LOCA), non-LOCA, Containment Responses and Dose Consequences), engineered safety features (ESF), power conversion, emergency power, support systems and environmental issues have been performed. A thorough review and assessment of applicable criteria for NSSS systems and components (i.e., steam generator, reactor vessel, pressurizer, etc.) have concluded that the applicable criteria are met for these system components. The results of these evaluations and analyses (when appropriate), show that Turkey Point Units 3 and 4 can safely operate at the increased power level and the conditions associated with the increased power level.

Certain Technical Specifications require revision to accommodate the thermal power uprate.

All proposed design and Technical Specification changes have been verified to be acceptable at the proposed uprated conditions.

The proposed Technical Specification changes are divided into eight groups. Explanations of the rationale for the group categorization will follow. This submittal includes a "No Significant Hazards" evaluation for each of the eight groups.

The groupings are as follows:

1) Technical Specification changes associated with the uprated power level, the revised core safety limits, revised DNB parameters, Engineered Safety Features Actuation System (ESFAS) and reactor trip setpoint changes, and Reactor Coolant Pump (RCP) Breaker Position Trip, will be evaluated together. The safety of these proposed changes are verified by the accident analyses that were completed in support of the uprated power.

Parameters associated with the uprated conditions provide direct input into accident analyses. The revised core safety limits and revised DNB parameters are key accident analysis parameters necessary to ensure analysis criteria are met. The flow reduction included in the DNB parameters is also direct analysis input. The acceptability of the revised ESFAS and reactor trip setpoints (including OTbT and OPbT) are verified by these same accident analyses. A single "No Significant Hazards Evaluation" will be provided for these proposed changes.

L-95-245 Page 2 of 24

2) Technical Specification changes associated with reducing the SI pump discliarge head requirement and increasing usable volume requirements for the Demineralized Water Storage Tank (DWST) and the Condensate Storage Tank (CST) will be addressed together.

Operation at the uprated power level required FPL to ensure that systems necessary for the safe operation of Turkey Point Units 3 and 4 meet their intended function. During the comprehensive review, it was determined that the lower limits for several storage tank volumes should be increased. The systems in which these changes have been proposed have been verified to be acceptable for operation at the increased power level, The reanalysis effort afforded FPL the opportunity to provide margin in the required head for delivered SI flow. This decrease in head has been found acceptable from a systems performance perspective and provides SI pump testing margin as well as margin to account for any possible future pump degradation.