ML19184A100

NRR E-mail Capture - Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 266

ML19184A100
Person / Time
Site:	Turkey Point
Issue date:	07/03/2019
From:	Michael Wentzel Plant Licensing Branch II
To:	Hess R Florida Power & Light Co
References
L-2019-LLA-0024
Download: ML19184A100 (5)

Text

NRR-DRMAPEm Resource From: Wentzel, Michael Sent: Wednesday, July 3, 2019 10:09 AM To: Hess, Robert Cc: Buckberg, Perry; 'Hanek, Olga'; 'Catron, Steve'; Mack, Jarrett; Kilby, Gary

Subject:

Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 266 (EPID L-2019-LLA-0024)

Dear Mr. Hess:

By letter dated February 14, 2019 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML19045A617), Florida Power & Light Company (the licensee) submitted License Amendment Request (LAR) 266 for Turkey Point Nuclear Generating Units Nos. 3 and 4. The proposed amendments would revise the Technical Specifications (TSs) to clarify certain TS requirements for when one Unit is outside the applicability of certain TSs.

The staff of the Nuclear Regulatory Commissions (NRCs) Technical Specifications and Reactor Systems branches are reviewing the application and have identified areas where additional information is needed to support their review. The NRC staffs Request for Additional Information (RAI) is provided below. A draft copy of the RAI was provided to your staff on June 20, 2019. Based on a clarification call with the licensees staff on July 2, 2019, the NRC staff has withdrawn draft RAI #4, as it is unnecessary for the staff to complete its review.

As discussed with your staff on the July 2, 2019 call, the NRC staff requests your response to the RAI within 30 days of the date of this email.

If you have any questions, please contact Perry Buckberg at (301) 415-1383 or perry.buckberg@nrc.gov.

Sincerely, Michael Wentzel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 266 EPID L-2019-LLA-0024 FLORIDA POWER & LIGHT COMPANY 1

TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251

Background

The licensees proposed change (shown in bold text) modifies the following specific LCOs by adding a new Defueled condition:

• The footnote associated with limiting condition for operation (LCO) in TS 3.5.2, ECCS Subsystems-Tavg Greater than or Equal to 350°F, item a, is modified to add the Defueled condition:

• Only three Safety Injection (SI) pumps (two associated with the unit and one from the opposite unit), each capable of being powered from its associated OPERABLE diesel generator#, with discharge flow paths aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5,or 6, or Defueled.

• TS 3.5.2 Action e is modified to add the Defueled condition:

With one of the three required Safety Injection pumps or its associated discharge flow opposite unit in MODE 4, 5,or 6, or Defueled .

• The LCO and Action in TS 3.7.1.3, Condensate Storage Tank, are modified to add the Defueled condition:

Opposite Unit in MODES 4, 5,or 6, or Defueled

• The footnote associated with the two-hour completion time in TS 3.8.2.1, D.C. Sources -

Operating, Action b, is modified to add the Defueled condition:

• Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5,or 6, or Defueled and each of the remaining required battery chargers is capable of being powered from its associated diesel generator(s).

• The footnote associated with the LCO in TS 3.8.3.1, Onsite Power Distribution - Operating, regarding tie breakers between redundant buses is modified to add the Defueled condition:

• • With the opposite unit in MODE 5,or 6, or Defueled, its 480-Volt Load Center can be cross-tied under conditions specified in Specification 3.8.3.2.a.

• The footnote associated with the two-hour completion time in TS 3.8.3.1, Onsite Power Distribution - Operating, Action d, is modified to add the Defueled condition:

• Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5, or, 6, or Defueled and each of the remaining required battery chargers is capable of being powered from its associated diesel generator(s).

2

Regulatory Basis for RAIs The regulations at 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit state, in part:

Whenever a holder of a license, including a construction permit and operating license under this part, and an early site permit, combined license, and manufacturing license under part 52 of this chapter, desires to amend the license or permit, application for an amendment must be filed with the Commission, as specified in §§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

RAI #1 The licensees proposed change adds a new Defueled, condition as stated above. The licensee justifies the Regulatory Requirement/Criteria for the change as follows:

The proposed change to the TS is consistent with the requirements of 10 CFR 50.36. 10 CFR 50.36, Technical specifications, requires that the TS include limiting conditions for operation, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The TS must also include surveillance requirements to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The proposed change to the TS is consistent with the requirements of 10 CFR 50.36.

The NRC Commissions Final Policy Statement on Technical Specifications Improvements presents the policy of the Nuclear Regulatory Commission (NRC) with respect to the scope and purpose of Technical Specifications for nuclear power plants as required by 10 CFR 50.36. It establishes a specific set of objective criteria (Section IV) as guidance for determining which regulatory requirements and operating restrictions should be included in Technical Specifications. Regarding the licensees proposed addition of a defueled condition in the Technical Specifications, the licensee states, The proposed change to the TS is consistent with the requirements of 10 CFR 50.36.

a. When a shutdown unit is in a defueled condition, please explain how the proposed change complies with the 10 CFR 50.36 regulation.

b. Please confirm, based on a review of your current licensing basis, that there are no safety requirements, accidents or events which would need to be reanalyzed if the proposed change is implemented.

RAI #2 LCO 3.5.2a requires that the Emergency Core Cooling System (ECCS) equipment and flow paths shall be OPERABLE with four Safety Injection (SI) pumps, each capable of being powered from its associated OPERABLE diesel generator, with discharge flow paths aligned to the RCS cold legs.*

The footnote states:

• Only three Safety Injection (SI) pumps (two associated with the unit and one from the opposite unit), each capable of being powered from its associated OPERABLE diesel generator#, with discharge flow paths aligned to the RCS cold leg are required if the opposite unit is in MODE 4, 5, or 6.

The proposed change adds Defueled condition to Modes 4,5 or 6 as 4,5,6, or Defueled.

3

Please provide an explanation on how the ECCS equipment and flow paths are ensured OPERABLE when the opposite unit is in a Defueled, condition consistent with current requirements in Mode 4, 5 or 6.

Similarly, provide an explanation for the addition of the Defueled, condition in LCO 3.7.1.3 and LCO 3.8.3.1, as stated in the LAR.

RAI #3 Section 1.0 of the LAR states, The proposed change clarifies that shutdown also includes the Defueled condition.

Please explain how this LAR statement is a correct statement since Shutdown Operational Mode, as specified in TS Table 1.2, does not specify inclusion of a Defueled condition.

4

Hearing Identifier: NRR_DRMA Email Number: 86 Mail Envelope Properties (BL0PR0901MB32502CD3965151DF2357BCD7E7FB0)

Subject:

Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information Regarding License Amendment Request 266 (EPID L-2019-LLA-0024)

Sent Date: 7/3/2019 10:08:58 AM Received Date: 7/3/2019 10:08:58 AM From: Wentzel, Michael Created By: Michael.Wentzel@nrc.gov Recipients:

"Buckberg, Perry" <Perry.Buckberg@nrc.gov>

Tracking Status: None

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

Tracking Status: None

"'Catron, Steve'" <Steve.Catron@fpl.com>

Tracking Status: None "Mack, Jarrett" <Jarrett.Mack@fpl.com>

Tracking Status: None "Kilby, Gary" <Gary.Kilby@fpl.com>

Tracking Status: None "Hess, Robert" <Robert.Hess@fpl.com>

Tracking Status: None Post Office: BL0PR0901MB3250.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 7635 7/3/2019 10:08:58 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: