L-2019-192, License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements

License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements

ML19315A003
Person / Time
Site:	Turkey Point
Issue date:	11/04/2019
From:	Stamp B Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-192
Download: ML19315A003 (35)

Text

November 4, 2019 L-2019-192 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001 RE: Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DPR-31 and DPR-41 License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments modify the Turkey Point Technical Specifications (TS) by modifying the containment atmosphere radioactivity monitoring, containment ventilation isolation and Reactor Coolant System (RCS) leakage detection system requirements.

The enclosure to this letter provides FPL's evaluation of the proposed changes. Attachment 1 to the enclosure provides a mark-up of the existing TS pages to show the proposed changes. Attachment 2 provides existing TS Bases pages marked up to show the proposed changes. 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 license amendments.

FPL has determined that the proposed changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the proposed changes. The Turkey Point Onsite Review Group has reviewed the proposed license amendments. In accordance with 10 CFR 50.91 (b)(1 ), a copy of the proposed license amendments is being forwarded to the State designee for the State of Florida.

FPL requests the proposed changes are processed as a normal license amendment request with approval within one year of the submittal date. Once approved, the amendments will be implemented within 90 days.

This letter contains no regulatory commitments.

Should you have any questions regarding this submission, please contact Mr. Robert Hess, Turkey Point Licensing Manager, at 305-246-4112.

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

Executed on the '7'U day of November, 2019.

Sincerely,

,,;)5th~

Brian Stam ~

Site Director, Turkey Point Nuclear Plant Enclosure Attachments Florida Power & Light Company 9760 SW 344th Street, Homestead , FL 33035

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Page 2 of 2 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-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 1 of 33 EVALUATION OF THE PROPOSED CHANGES Turkey Point Nuclear Plant Unit 3 and Unit 4 License Amendment Request 270, Modify Containment Atmosphere Radioactivity Monitoring, Containment Ventilation Isolation and RCS Leakage Detection System Requirements 1.0

SUMMARY

DESCRIPTION ............................................................................................................. 2 2.0 DETAILED DESCRIPTION ............................................................................................................. 2 2.1 System Design and Operation ............................................................................................ 2 2.2 Current Requirements / Description of Proposed Change ................................................. 3 2.3 Reason for the Proposed Change ...................................................................................... 7

3.0 TECHNICAL EVALUATION

............................................................................................................ 7

4.0 REGULATORY EVALUATION

..................................................................................................... 14 4.1 Applicable Regulatory Requirements/ Criteria .................................................................. 14 4.2 No Significant Hazards Consideration .............................................................................. 14 4.3 Conclusion ........................................................................................................................ 17

5.0 ENVIRONMENTAL CONSIDERATION

........................................................................................ 17

6.0 REFERENCES

............................................................................................................................... 17

_______________________________________________ - Proposed Technical Specification Page (markup) - Proposed Technical Specification Bases Page (markup)

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 2 of 33 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments modify the Turkey Point Technical Specifications (TS) by modifying the containment atmosphere radioactivity monitoring, containment ventilation isolation and Reactor Coolant System (RCS) leakage detection system requirements.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.1.1 Containment Atmosphere Radioactivity Monitoring System Radiation monitoring instruments are located in and around the Units to detect and record radiation levels. Detected radiation levels in excess of desired setpoints initiate control room alarms. The radiation monitoring instruments operate in conjunction with regular and special radiation surveys and with chemical and radiochemical analyses performed by the plant staff to provide timely information for the continued safe operation of the Units and assurance that personnel exposure does not exceed 10 CFR 20 guidelines.

The containment air particulate radioactivity monitors, R-3-11 (Unit 3) and R-4-11 (Unit 4) (R-11), measure the containment air particulate beta radioactivity through continuous sampling of the containment atmosphere and transmit the detector outputs to the control room radiation monitoring system cabinets. The containment air particulate monitors ensure that the release rate through each containment vent during purging is maintained below specified limits. Each monitor has a measuring range of at least 10-9 to 10-6 Ci/cc. Upon the detection of high radioactivity, the containment air particulate monitors initiate closure of the containment purge supply and exhaust isolation valves and the containment instrument air bleed valves. The alarm setpoints for the containment air particulate radioactivity monitors are specified in the Turkey Point TS and set in accordance with the Turkey Point Offsite Dose Calculation Manual (ODCM).

The containment radioactive gas monitors, R-3-12 and R-4-12 (R-12), measure the gaseous beta radioactivity in the containments to ensure that the radiation release rate during containment purging is maintained below specified limits. The containment radioactive gas monitors take continuous air samples from the containment atmosphere after passing through the containment air particulate monitors, draw the samples through a closed, sealed system to a gas monitor assembly, and transmit the detector outputs to the control room radiation monitoring system cabinets. Each monitor has a measuring range of at least 10-6 to 10-3 Ci/cc. High radiation level initiates closure of the containment purge supply and exhaust isolation valves and the containment instrument air bleed valves. The alarm setpoints for the containment radioactivity gas monitors are specified in the Turkey Point TS and set in accordance with the Turkey Point ODCM.

2.1.2 Containment Purge System The Containment Purge System is designed to purge the containment atmosphere as determined necessary during power operation and for unlimited access during shutdown periods. The Containment Purge System includes provisions for

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 3 of 33 handling both supply and exhaust air. The supply system includes an outside air connection to roughing filters, a fan duct system and a 48-inch diameter supply penetration with two quick-closing butterfly valves. The exhaust system includes a 54-inch diameter exhaust penetration, a duct system, fan, roughing filters with connection to the plant vent and two quick-closing butterfly valves. The supply and exhaust penetration butterfly valves are aligned in-series, with one inside and one outside the containment, and equipped with air cylinder operators with spring returns. The containment purge supply and exhaust isolation valves function to maintain containment pressure between Turkey Point TS limits during normal plant operation and to reduce airborne radioactivity levels in containment. The purge supply and exhaust isolation valves, and instrument air bleed valves, close upon receipt of a manual Phase A containment isolation signal, a safety injection (SI) signal or upon detection of containment radioactivity in excess of the containment atmosphere particulate or radioactive gas monitor (R-11, R-12) pre-set levels. The isolation action serves to limit radioactivity releases to the environment to within levels consistent with safety analyses assumptions and thereby assure accidental offsite radiological doses are maintained below 10 CFR 100 limits.

2.1.3 RCS Leakage Detection System The Reactor Coolant System Leakage Detection System provides Control Room indication of reactor coolant system (RCS) leakage by equipment which monitors the radioactivity concentration in the containment atmosphere, auxiliary building ventilation exhaust, steam generator blowdown exhaust, and component cooling water loop liquid. This equipment includes containment air particulate and radioactive gas monitors R-11 and R-12, containment sump level monitors, component cooling water radiation monitor, and the reactor vessel head leakage detection system which is capable of sampling and analyzing each control rod drive mechanism (CRDM) cooler ventilation discharge and the containment atmosphere on an as-needed basis. In addition, the steam generator blowdown air ejector monitors function to detect primary-to-secondary system leakage. The basic design criterion is the detection of deviations from normal containment environmental conditions including air particulate activity, radio-gas activity, and in addition, in the case of gross leakage, the liquid inventory in the process systems and containment sump.

2.2 Current Requirements / Description of the Proposed Change 2.2.1 TS 3/4.3.2, Table 3.3-2, Engineered Safety Features Actuation System Instrumentation, specifies requirements for the FU 3.c, Containment Ventilation Isolation, instrument channels.

The proposed change adds a new footnote denoted by an asterisk (*) exempting the containment purge supply and exhaust isolation valves from the FU 3.c instrument channel requirements. The proposed change is as follows:

TABLE 3.3-2 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT

3) Containment Isolation

c. Containment Ventilation Isolation *

1) Containment New Asterisk (*)

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 4 of 33 Isolation Manual Phase A or Manual Phase B New Footnote

• Not applicable to Containment purge supply and exhaust isolation valves.

2.2.2 TS 3/4.3.2, Table 3.3-3, Engineered Safety Features Actuation System Instrumentation Trip Setpoints, specifies the setpoint requirements for the FU 3.c, Containment Ventilation Isolation, instrument channels.

The proposed change adds a new footnote denoted by an asterisk (*) exempting the containment purge supply and exhaust isolation valves from the FU 3.c channel setpoint requirements. The proposed change additionally revises the allowable and trip setpoint values for the FU 3.c.4 instrument channels by converting the measurement units from counts per minute (CPM) to micro-curies per cubic centimeter (µCi/cc) in the Allowable Value and Trip Setpoint columns of Table 3.3-3, and Note 2 of Table 3.3-3, Table Notations. The proposed change additionally deletes instrument numbers R-11 and R-12 in the Allowable Value and Trip Setpoint columns of Table 3.3-3. The proposed change is as follows:

TABLE 3.3-3 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT ALLOWABLE VALUE TRIP SETPOINT

3. Containment Isolation

c. Containment Ventilation Isolation *

4) Containment Radioactivity--High Particulate (R-11) Particulate (R-11) 6.8 x 105 CPM 6.1 x 105 CPM New Asterisk (*) 5.00 x 10-6 µCi/cc 4.49 x 10-6 µCi/cc Gaseous (R-12) Gaseous (R-12)

New Footnote See Note 2 See Note 2

• Not applicable to Containment purge supply and exhaust isolation valves.

TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS TABLE NOTATIONS (2) Containment Gaseous Monitor Setpoint = (3.2 x 104) CPM (1.11 x 10-3) µCi/cc (F)

Containment Gaseous Monitor Allowable Value = (3.2 x 104) CPM (1.22 x 10-3) µCi/cc (F)

Where F = Actual Purge Flow Design Purge Flow (35,000 CFM) 2.2.3 TS 3/4.3.2, Table 4.3-2, Engineered Safety Features Actuation System Instrumentation Surveillance Requirements, specifies surveillance requirements (SRs) for the FU 3.c, Containment Ventilation Isolation, instrument channels.

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 5 of 33 The proposed change adds a new footnote denoted by an asterisk (*) exempting the containment purge supply and exhaust isolation valves from the FU 3.c instrument channel SRs. The proposed change is as follows:

TABLE 4.3-2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS FUNCTIONAL UNIT

3) Containment Isolation (Continued)

c. Containment Venti-lation Isolation *

1) Containment Isolation New Asterisk (*)

Manual Phase A or Manual Phase B New Footnote

• Not applicable to Containment purge supply and exhaust isolation valves.

2.2.4 TS 3/4.3.3.1, Table 3.3-4, Radiation Monitoring Instrumentation for Plant Operations, specifies requirements for the FU 1.a, Containment Atmosphere Radioactivity - High, radiation monitoring instrument channels The proposed change revises the alarm/trip setpoint numerical values for the FU 1.a instrument channels by converting the measurement units from CPM to µCi/cc in the Alarm/Trip Setpoint column of Table 3.3-4, and Note 2 of Table 3.3-4, Table Notations. The proposed change is as follows:

TABLE 3.3-4 RADIATION MONITORING INSTRUMENTATION FOR PLANT OPERATIONS ALARM/TRIP FUNCTIONAL UNIT SETPOINT

1. Containment

a. Containment Atmosphere Particulate Radioactivity-High 6.1 x 105 CPM (Particulate or 4.49 x 10-6 µCi/cc Gaseous (See Note 1.)) Gaseous See Note 2 TABLE 3.3-4 (Continued)

TABLE NOTATIONS Note 2 Containment Gaseous Monitor Setpoint = (3.2 x 104) CPM (1.11 x 10-3) µCi/cc (F)

Where F = Actual Purge Flow Design Purge Flow (35,000 CFM) 2.2.5 TS 3/4.4.6.1, Reactor Coolant System Leakage - Leakage Detection Systems, specifies requirements for the containment atmosphere particulate (R-11) and gaseous (R-12) radioactivity monitoring systems. ACTION a of TS 3/4.4.6.1 applies when the R-11 and R-12 radioactivity monitoring systems are inoperable.

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 6 of 33 The proposed change modifies ACTION a of TS 3/4.4.6.1, by increasing the Completion Time to 30 days, by providing the option to obtain grab samples or conduct RCS water inventories, and by decreasing the RCS water inventory balance frequency to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The proposed change is as follows:

ACTION a) With both Particulate and Gaseous Radioactivity Monitoring Systems inoperable, operation may continue for up to 730 days provided:

1) A Containment Sump Level Monitoring System is OPERABLE;

2) Appropriate grab samples are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;, or

3) A Reactor Coolant System water inventory balance is performed at least once per 824* hours except when operating in shutdown cooling mode.

Otherwise, 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 />.

2.2.6 TS 3/4.6.1.7, Containment Systems - Containment Ventilation System, specifies the Limiting Condition for Operation (LCO), ACTIONS, applicable MODES and SRs for the containment purge supply and exhaust isolation valves.

The proposed change modifies the LCO to require the containment purge supply and exhaust isolation valves be maintained administratively sealed closed and deactivated or isolated by blind flange, and relatedly modifies the ACTIONS and SRs in recognition that the purge valves shall not be opened in MODES 1 through 4 or Unit shutdown must commence. The proposed change additionally extends to 72-hours the Completion Time to restore the purge valves to within the leakage limit of SR 4.6.1.7.2. The proposed change adds a footnote denoted by an asterisk

(*) exempting SR 4.6.1.7.1 and SR 4.6.1.7.2 when the associated purge supply and/or exhaust penetration(s) is isolated by blind flange. The proposed change additionally relocates the purge supply and exhaust valve leakage rate criteria to licensee control. The proposed change is as follows:

3.6.1.7 Each containment purge supply and exhaust isolation valve shall be OPERABLE and administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange.

a. The containment purge supply and exhaust isolation valves shall be sealed closed to the maximum extent practicable but may be open for purge system operation for pressure control, for environmental conditions control, for ALARA and respirable air quality considerations for personnel entry and for surveillance tests that require the valve to be open.

b. The purge supply and exhaust isolation valves shall not be opened wider than 33 or 30 degrees, respectively (90 degrees is fully open).

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 7 of 33 ACTION

a. With Specification 3.6.1.7 not met a containment purge supply and/or exhaust isolation valve(s) open for reasons other than given in 3.6.1.7.a above, close the open valve(s) or isolate the penetration(s) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, comply with Specification 3.6.1.7, or otherwise 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 />.

b. With a containment purge supply and/or exhaust isolation valve(s) having a measured leakage rate exceeding the limits of Specification 4.6.1.7.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 72-hours, otherwise 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 />.

SURVEILLANCE REQUIREMENTS New Asterisk (*)

4.6.1.7.1 Each containment purge supply and exhaust isolation valve shall be verified to be administratively sealed closed and deactivated sealed closed or open in accordance with Specification 3.6.1.7.a in accordance with the Surveillance Frequency Control Program.

4.6.1.7.2 In accordance with the Surveillance Frequency Control Program, each containment purge supply and exhaust isolation valve shall be demonstrated OPERABLE by verifying that the measured leakage rate is less than or equal to 0.05 La within limit when pressurized to Pa.

4.6.1.7.3 In accordance with the Surveillance Frequency Control Program, the mechanical stop on each containment purge supply and exhaust isolation valve shall be verified to be in place and that the valves will open no more than 33 or 30 degrees, respectively. DELETED New Footnote

• Performance of SR 4.6.1.7.1 and SR 4.6.1.2 are not required when the associated purge supply and/or exhaust penetration(s) is isolated by blind flange.

2.3 Reason for the Proposed Change The proposed license amendments accommodate planned upgrades to plant equipment and modify TS requirements that otherwise provide marginal benefit to safety.

3.0 TECHNICAL EVALUATION

The proposed license amendments modify the containment atmosphere radioactivity monitoring, containment ventilation isolation and RCS leakage detection system requirements.

3.1 Modify Containment Atmosphere Radioactivity Monitoring Requirements The proposed change revises the allowable and trip setpoint values for the Containment particulate (R-11) and gaseous (R-12) radioactivity monitor instrument channels by converting the measurement units from CPM to µCi/cc. The proposed change additionally deletes instrument numbers, R-11 and R-12, in the Allowable Value and Trip Setpoint columns of TS 3/4.3.2, Table 3.3-3. The proposed change also exempts the containment

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 8 of 33 purge supply and exhaust isolation valves from the containment ventilation isolation instrumentation requirements of TS 3/4.3.2, Table 3.3-2, Table 3.3-3 and Table 4.3-2.

3.1.1 Revise R-11, R-12 Instrument Measurement Units The proposed change revises the setpoint numerical values for the FU 3.c.4 instrument channels of TS 3/4.3.2, Table 3.3-3, and the FU 1.a instrument channels of TS 3/4.3.3.1, Table 3.3-4, by converting the measurement units from CPM to µCi/cc. Containment particulate and gaseous radioactivity monitors, R-11 and R-12, perform the functions specified in TS 3/4.3.2, Table 3.3-3, FU 3.c.4 and TS 3/4.3.3.1, Table 3.3-4, FU 1.a. The proposed change to convert the measurement units from CPM to µCi/cc accommodates planned upgrades to the R-11 and R12 instruments. The proposed change is implemented by converting the values specified in columns Allowable Value and Trip Setpoint and in Note 2 of TS 3/4.3.2, Table 3.3-3, FU 3.c.4 and column Alarm/Trip Setpoint and Note 2 of TS 3/4.3.3.1, Table 3.3-4, FU 1.a. The converted setpoint numerical values, identified in the TS mark-up pages (Attachment 1) and Section 2.0 of this amendment request, were verified in accordance with FPLs design control program. The proposed change is thereby administrative in nature since the current values in CPM are equivalent to the proposed values in µCi/cc, and no changes are proposed to the applicable regulatory requirements.

3.1.2 Remove R-11, R-12 Instrument Numbers The proposed change deletes the instrument numbers, R-11 and R-12, in the Allowable Value and Trip Setpoint columns of Table 3.3-3 for the FU 3.c.4 instrument channels. The proposed change precludes the need for a license amendment should it become desirable to revise the instrument numbers in the future. The proposed change is administrative in nature since no changes are proposed to the instrument functions (particulate and gaseous radioactivity monitoring) or the applicable regulatory requirements.

3.1.3 Exempt Purge Valve Isolation Instrumentation Requirements The proposed change adds a new footnote applicable to the FU 3.c instrument channels of TS 3/4.3.2, Table 3.3-2, Table 3.3-3 and Table 4.3-2. The footnote exempts the containment purge supply and exhaust isolation valves from the containment ventilation isolation instrumentation requirements of TS 3/4.3.2, Table 3.3-2, Table 3.3-3 and Table 4.3-2. As discussed in Section 3.3 of this amendment request, the containment purge supply and exhaust isolation valves will be maintained administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange in MODES 1 through 4. Maintaining the subject valves administratively sealed closed and deactivated or isolating by blind flange assures the penetration(s) will perform their containment ventilation isolation function without reliance on engineering safety features actuation system instrumentation. As such, the FU 3.c instrument channels are no longer subject to TS inclusion as an LCO pursuant to Criterion 3 of 10 CFR 50.36(c)(2)(ii) since the containment ventilation isolation function is satisfied without the assistance of the FU 3.c instrumentation. Thereby, only the containment instrument air bleed isolation valves remain applicable to the FU 3.c requirements of TS 3/4.3.2, Tables 3.3-2, 3.3-3 and 4.3-2. The proposed change is implemented by adding an asterisk (*) to the FU 3.c instrument channel columns of TS 3/4.3.2, Tables 3.3-2, 3.3-3 and 4.3-2 and the new footnotes. Exempting the purge supply and exhaust valves from the FU 3.c instrument requirements is appropriate since the change is consistent with the proposed change to maintain the containment purge supply

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 9 of 33 and exhaust isolation valves administratively sealed closed and deactivated or isolate the associated penetration(s) by blind flange in MODES 1 through 4, as discussed in Section 3.3 of this amendment request.

3.2 Modify RCS Leakage Detection Requirements The proposed change modifies ACTION of TS 3/4.4.6.1 for the condition of the R-11 and R-12 radioactivity monitors both inoperable by increasing the Completion Time from 7 days to 30 days, providing an option to either analyze containment atmosphere grab samples or conduct RCS water inventory balances, and decreasing the frequency of RCS water inventory balances from every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.2.1 Increase ACTION Completion Time The proposed change to increase the Completion Time from 7 days to 30 days is based on the availability of an operable containment sump level monitoring system for the detection of unidentified leakage and the performance of additional leakage detection activities such as RCS water inventory balances and containment atmosphere monitoring via grab sample analyses. For the condition of R-11 and R-12 both inoperable, ACTION a of TS 3/4.4.6.1 currently allows 7 days of continued operation provided the containment sump level monitoring system is operable, containment atmosphere grab samples are analyzed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and RCS water inventory balances are conducted every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. However, the unavailability of R-11 and R-12 does not diminish the effectiveness of these other, RCS leakage detection methods. A 30-day Completion Time would provide a reasonable period to evaluate the cause of the dual inoperability and conduct work planning and repair. During this time, monitoring the containment sump level along with conducting more frequent RCS water inventory balances and/or containment atmospheric monitoring via grab sample analyses would provide suitable and diverse methods of RCS leakage detection. As such, extending the Completion Time to 30 days will not adversely impact safety since RCS leakage monitoring would not be interrupted for the duration of R-11, R-12 inoperability. The proposed change is consistent with Westinghouse STS 3.4.15, ACTION B (Reference 6.1) which allows continued operation for 30 days for the condition of the containment atmosphere radioactivity monitoring instrumentation requirement not met.

3.2.2 Reduce Redundant ACTIONS The proposed change to either analyze grab samples of the containment atmosphere or conduct RCS water inventory balances, in lieu of performing both as currently required by ACTION a of TS 3/4.4.6.1, is based on the functional redundancy of the two activities. Though the monitoring methods differ, the RCS water inventory balance and the grab sample analyses are both methods of detecting RCS leakage. Moreover, either of these activities in conjunction with monitoring the containment sump level provide suitable effectiveness and diversity in obtaining early warning of RCS leakage during the period of R-11, R-12 inoperability. The proposed change is implemented by truncating the containment grab sample analysis requirement of ACTION a.2 with an or, and conjoining with the RCS inventory balance requirement of ACTION a.3. The proposed change is consistent with Westinghouse STS 3.4.15, ACTION B (Reference 6.1) which requires either containment air grab sample analyses or RCS water inventory balances for the condition of the containment atmosphere radioactivity monitoring instrumentation requirement not met.

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 10 of 33 3.2.3 Modify ACTION for RCS Water Inventory Balance Frequency The proposed change to decrease the frequency of RCS water inventory balances from every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is based on the low likelihood of undetected RCS leakage during any 24-hour period. SR 4.4.6.2.1 requires the performance of RCS water inventory balances and verification of steam generator primary to secondary leakage within limit every 72-hours in accordance with the Surveillance Frequency Control Program (SFCP). In addition, containment atmosphere radioactivity monitoring and containment sump level monitoring are performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in accordance with the SFCP. As such, conducting RCS water inventory balances every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> imposes more frequent monitoring for RCS leakage than the 12-hour containment atmosphere radioactivity monitoring the RCS water inventory balances are meant to replace. The absence of containment atmosphere radioactivity monitoring due to R-11 and R-12 both inoperable neither increases the likelihood of RCS leakage nor diminishes the effectiveness of either RCS water inventory balances or containment air grab sample analyses every 24-hours combined with containment sump level monitoring every 12-hours.

Conducting RCS water inventory balances every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> distracts station resources from more safety significant activities with no benefit to safety given the diversity and effectiveness of the other RCS leakage detection methods required by ACTION a. The proposed change is consistent with Westinghouse STS 3.4.15, ACTION B (Reference 6.1) which provides the option of performing RCS water inventory balances every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the condition of the containment atmosphere radioactivity monitoring instrumentation requirement not met.

3.3 Modify Containment Ventilation System Requirements The proposed change modifies the LCO of TS 3/4 3.6.1.7, Containment Ventilation System, to require the containment purge supply and exhaust isolation valves be maintained administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange and relatedly modifies the ACTIONS and SRs in recognition that the valves shall not be opened in MODES 1 thru 4. The proposed change additionally modifies the ACTIONS to allow 72-hours to restore the purge valves to within the leakage limit of SR 4.6.1.7.2. The proposed change adds a footnote denoted by an asterisk (*) exempting SR 4.6.1.7.1 and SR 4.6.1.7.2 when the associated purge supply and/or exhaust penetration(s) is isolated by blind flange. The proposed change additionally relocates the purge valve leakage rate criteria to licensee control.

3.3.1 Modify Purge Valve LCO The proposed change modifies the LCO to require the containment purge supply and exhaust isolation valves be maintained administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange in MODES 1 through 4. These spring-return valves will be administratively sealed closed and deactivated by purging instrument air from the valve actuators and removing power to the actuator solenoid valves to prevent inadvertent actuation.

Otherwise, the associated penetration will be isolated by blind flange featuring double o-ring gaskets. The proposed change is implemented by modifying LCO 3.6.1.7 to state that the valves shall be administratively sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange and by deleting LCO 3.6.1.7.a and LCO 3.6.1.7.b, which specify conditions for opening the valves in MODES 1 through 4. The proposed change to maintain the valves administratively sealed closed and deactivated would eliminate disturbances to the seating surfaces normally caused by valve actuations that follow satisfactory Type-C testing. The proposed change to isolate the associated penetration(s) by blind

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 11 of 33 flange featuring double o-ring gaskets would provide the requisite redundant barriers for containment purge penetration leakage subject to Type-B testing in accordance with the Containment Leakage Testing Program of TS 6.8.4.h. The proposed change thereby enhances purge valve leakage performance in a manner consistent with safety analysis assumptions for containment leakage.

3.3.2 Extend Completion Time to 72-Hours The proposed change modifies ACTION a by applying the existing 4-hour Completion Time to the condition of proposed LCO 3.6.1.7 not met and modifies ACTION b by extending the Completion Time from 24-hours to 72-hours for the condition of purge valve leakage in excess of SR 4.6.1.7.2. As discussed in Section 3.3.1 of this amendment request, proposed LCO 3.6.1.7 requires the purge valves are maintained sealed closed and deactivated or the associated penetration(s) shall be isolated by blind flange. Applying the existing 4-hour Completion Time to the condition of LCO 3.6.1.7 not met is consistent with the existing requirement to close the open purge valve or isolate the penetration when the LCO cannot be met. Hence, the proposed change to ACTION a maintains the existing margin of safety by requiring prompt action or commencing Unit shutdown if the containment purge ventilation isolation function cannot be assured.

The proposed change to extend the Completion Time to 72-hours for the condition of purge valve leakage in excess of SR 4.6.1.7.2 is based upon the historically substantial margin that exists between the Type B & C leakage limit of 0.60 La [ =

166,355 standard cubic centimeters per minute (sccm)] and the combined Type B

& C maximum pathway measured leakage determined in accordance with TS 6.8.4.h. As can be seen from historical testing summarized in the tables below, the margin between the 0.60 La leakage limit and the combined Type B & C maximum pathway leakage rate during years 2009 through 2019 ranged between 70% to 87% of the 0.60 La leakage limit (see last columns).

Unit 3 Combined Type B&C vs. Type B&C Leakage Limit (0.60 La)

Combined Type Margin between Combined Type B&C Leakage Combined Unit 3 B&C Leakage in percent Type B&C Leakage Outage/ Year of 0.60 La* and 0.60 La (sccm) (%) (sccm) (%)

PT3-24 / 2009 29,032 17.6% 137,147 82.4%

PT3-25 / 2011 23,314 14.1% 142,900 85.9%

PT3-26 / 2012 27,499 16.6% 138,690 83.4%

PT3-27/ 2014 32,498 19.7% 133,660 80.3%

PT3-28 / 2015 35,397 21.4% 130,744 78.6%

PT3-29 / 2017 41,688 25.2% 124,415 74.8%

PT3-30 / 2018 42,804 25.9% 123,292 74.1%

[* 0.60 La = 166,355 sccm]

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 12 of 33 Unit 4 Combined Type B&C vs. Type B&C Leakage Limit (0.60 La)

Combined Type Margin between Combined Type B&C Leakage Combined Unit 4 B&C Leakage in percent Type B&C Leakage Outage/ Year of 0.60 La

• and 0.60 La (sccm) (%) (%) (sccm)

PT4-25 / 2010 39,313 23.8% 126,804 76.2%

PT4-26 / 2011 33,446 20.2% 132,707 79.8%

PT4-27 / 2013 39,295 23.8% 126,822 76.2%

PT4-28 / 2014 48,584 29.4% 117,477 70.6%

PT4-29 / 2016 43,535 26.3% 122,557 73.7%

PT4-30 / 2017 22,282 13.5% 143,938 86.5%

PT4-31 / 2019 48,422 29.3% 117,640 70.7%

[* 0.60 La = 166,355 sccm]

The containment purge penetrations (supply and exhaust) are Type-C tested by pressurizing the annulus between the inner and outer purge isolation valves. In determining the combined Type B & C maximum pathway (i.e. as-left) leakage required by TS 6.8.4.h, the total purge penetration leakage rate is applied (rather than the highest single valve leakage rate as with most penetrations housing two isolation valves). Even with this conservatism, the above tables exhibit the substantial margin (i.e. >117,000 sccm) that routinely exists between the combined Type B & C maximum pathway leakage and the 0.60 La leakage limit. From a historical testing perspective, the purge valve leakage limit of 0.05 La currently specified in SR 4.6.1.7.2 equates to 13,860 sccm whereby mid-cycle purge valve leakage test failures have ranged from 15,000 to 35,000 sccm. Hence, a 24-hour Completion Time for a marginal reduction in the margin to the 0.60 La leakage limit is not commensurate with the impact of the failure on safety. Moreover, the 24-hour Completion Time is unreasonably burdensome since it does not allow for repairs that may result from discovery, requires rescheduling of planned activities that may contribute to plant risk such as TS surveillances and preventive maintenance, and can warrant power reductions requiring around-the-clock coverage to accommodate repairs inside the containment building. Additionally, a review of industry licensing actions reveals numerous requests for Notice of Enforcement Discretion (NOED) prompted by unanticipated purge valve leakage test failures that could not be remedied within 24-hours. The proposed change to extend the Completion Time to 72-hours would provide for orderly maintenance planning and repair, and thereby reduce requests for short-notice regulatory authorization to avoid plant shutdown. Thereby, the proposed change to extend the Completion Time from 24-hours to 72-hours for purge valve leakage in excess of the SR 4.6.1.7.2 specified limit is reasonable since it would reduce unanticipated challenges to station and NRC resources without compromising safety.

3.3.3 Revise Purge Valve Surveillance Requirements (SRs)

The proposed change modifies SR 4.6.1.7.1 by replacing the option to verify the subject valves are open in accordance with LCO 3.6.1.7.a with a requirement to verify the valves are administratively sealed closed and deactivated in accordance

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 13 of 33 with the SFCP. The proposed change is acceptable since, consistent with the current LCO 3.6.1.7.a, the proposed change verifies the LCO requirement is being met in accordance with the SFCP.

The proposed change modifies SR 4.6.1.7.2 by relocating the purge valve leakage rate criterion of 0.05 La to the Containment Leakage Rate Testing Program of TS 6.8.4.h. The bases for the proposed change is that the purge valve leakage criterion does not satisfy the four criteria of 10 CFR 50.36c(2)(ii) for TS inclusion.

Specifically, the leakage rate criterion is not instrumentation installed to detect and indicate in the Control Room significant abnormal degradation of RCS pressure boundary, and thereby does not satisfy Criterion 1. Though containment integrity is credited in accident analyses as an initial condition, the purge valve leakage criterion equates to 5% of the allowable containment leakage such that purge valve leakage test failures do not challenge the containment leakage assumed in plant safety analyses. Thereby, the criterion is not a process variable, design feature or operating restriction that is an initial condition assumed in any accident or transient analyses which challenges fission product barrier integrity, and thereby does not satisfy Criterion 2. The leakage criterion is not a SSC that is part of the primary success path to mitigate a design basis accident or transient challenging fission product barrier integrity, and thereby does not satisfy Criterion 3. As discussed in References 6.2 and 6.3 of this amendment request, industry operating experience (OE) revealed reliability concerns with containment purge valves equipped with resilient seats. The proposed change retains the more frequent leakage testing requirement of SR 4.6.1.7.2, which the NRC imposed on licensees in response to the OE but without added restrictions on the leakage criterion. In addition, purge valve leakage performance is not modeled in the Turkey Point probabilistic risk assessment (PRA). As such, the purge valve leakage criterion is not a SSC which OE or PRA has shown to be significant to public health and safety, and thereby does not satisfy Criterion 4. Consistent with the NRC Final Policy Statement on TS Improvements (Reference 6.4), the purge valve leakage rate criterion is appropriate for relocation to licensee control whereby future changes will be subject to 10 CFR 50.59. The proposed change is consistent with Westinghouse STS 3.6.3.7 (Reference 6.1), which doesnt specify leakage criteria for containment purge valves with resilient seats, and is thereby reasonable.

The proposed change adds an asterisk (*) to SR 4.6.1.7.1 and SR 4.6.1.7.2 and adds a new footnote denoted by the asterisk (*) exempting SR performance when the associated containment purge penetration(s) is isolated by blind flange. The proposed footnote is appropriate since by the sealing the associated containment purge penetration(s) with a double o-ring blind flange and subjecting the flange to Type B testing in accordance with the Containment Leakage Rate Testing Program of TS 6.8.4.h., containment purge ventilation isolation is assured and the purge valve leakage reliability issues identified in References 6.2 and 6.3 are resolved.

The proposed change deletes SR 4.6.1.7.3, which requires verification of the mechanical stop positions to ensure the that the purge supply and exhaust isolation valves cannot be opened beyond the limits established in plant safety analyses. The proposed change is acceptable since, as discussed in Section 3.3.1 of this amendment request, the purge valves will be administratively sealed closed and deactivated or the associated penetration will be isolated by blind flange in MODES 1 through 4, thereby negating the need to verify disc travel restrictions applicable to design basis loss of coolant accident (LOCA) analyses.

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4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c)(2)(i) states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition is met.

10 CFR 50.36(c)(2)(ii) states that a limiting condition for operation must be established for each item meeting one or more of the four criteria specified therein.

10 CFR 50, Appendix J, Option B, provides assurance that leakage through containments or systems and components penetrating containments does not exceed allowable leakage rates specified in the TS, and that the integrity of the containment structure is maintained during its service.

1967 Proposed General Design Criteria (GDC) 13 states that means shall be provided for monitoring or otherwise measuring and maintaining control over the fission process throughout core life under all conditions that can reasonably be anticipated to cause variations in reactivity of the core.

1967 Proposed GDC 15 states that protection systems shall be provided for sensing accident situations and initiating necessary engineered safety features.

1967 Proposed GDC 16 states that means shall be provided to detect significant uncontrolled leakage from the reactor coolant pressure boundary.

1967 Proposed GDC 17 states that means shall be provided for monitoring the containment atmosphere and the facility effluent discharge paths for radioactivity released from normal operations, anticipated transients and accident conditions.

1967 Proposed GDC 49 states the reactor containment structure, including access openings and penetrations, shall be designed so that any leakage of radioactive materials from the containment structure will not result in undue risk to the public.

1967 Proposed GDC 53 states that penetrations requiring closure for containment functions shall be protected by redundant valving and associated apparatus.

The proposed license amendments do not alter the manner in which the station is operated and maintained, consistent with 10 CFR 50.36, 10 CFR 50, Appendix J, Option B, and 1967 Proposed GDC(s) 13, 15, 16, 17, 49 and 53. All applicable regulatory requirements will continue to be satisfied as a result of the proposed change.

4.2 No Significant Hazards Consideration The proposed license amendments modify the Turkey Point Technical Specifications by modifying the containment atmosphere radioactivity monitoring, containment ventilation isolation and Reactor Coolant System leakage detection system requirements. As required by 10 CFR 50.91(a), FPL evaluated the proposed change using the criteria in 10 CFR 50.92 and determined that the proposed change does not involve a significant hazards consideration. An analysis of the no significant hazards consideration is presented below:

(1) Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 15 of 33 Response: No The proposed amendments revise the containment particulate and gaseous radioactivity monitors, R-11 and R-12, requirements by converting the setpoint measurement units to accommodate planned equipment upgrades. The proposed change modifies the RCS leakage detection requirements by extending the Completion Time and limiting the required leakage detection methods to more closely align with NUREG-1431, Revision 4, for R-11 and R-12 both inoperable.

The proposed change modifies the containment purge supply and exhaust isolation valve and associated containment ventilation isolation instrumentation requirements to reflect that the purge valves will be maintained administratively sealed closed and deactivated or the penetration isolated by blind flange in MODES 1 through 4, relocates the purge valve leakage criterion to licensee control and extends the Completion Time to 7-days under specified conditions. Converting the instrument measurement units is an administrative change since the revised setpoint values are equivalent to the current values and the applicable regulatory requirements are unchanged. Limiting the required leakage detection methods to either containment grab sample analyses or RCS inventory balances neither increases the likelihood of RCS leakage nor reduces the effectiveness of either, diverse RCS leakage detection method. Likewise, increasing the completion time for the condition of R-11 and R-12 both inoperable cannot reduce the effectiveness of the required RCS leakage detection methods. Maintaining the purge valves administratively sealed closed and deactivated or the penetration isolated by blind flange during the applicable MODES is consistent with the Turkey Point licensing basis and thereby cannot adversely impact plant safety analyses. Though the proposed change exempts the containment ventilation isolation instrumentation requirements for the purge supply and exhaust isolation valves, by maintaining the purge valves closed or the penetrations isolated in the applicable MODES, the purge valve containment ventilation isolation function is assured. Extending the purge valve leakage test Completion Time to 72-hours aligns the revised Completion Time with the impact on safety. Hence, the proposed changes will not affect any accident initiators or precursors or alter the design, conditions, or configuration of the facility as currently analyzed. All SSCs will continue to perform consistent with applicable requirements and safety analysis assumptions.

Therefore, this proposed change does not represent a significant increase in the probability or consequences of an accident previously evaluated.

(2) Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the R-11 and R-12 requirements by converting the setpoint measurement units. The proposed change modifies the RCS leakage detection requirements by extending the CT and limiting the required leakage detection methods to more closely align with NUREG-1431, Revision 4, for R-11 and R-12 both inoperable. The proposed change modifies the containment purge supply and exhaust isolation valve and associated containment ventilation isolation instrumentation requirements to reflect that the purge valves will be maintained administratively sealed closed and deactivated or isolated by blind flange in MODES 1 through 4. Converting the instrument measurement units cannot adversely affect safety. Limiting the required RCS leakage detection methods or increasing the Completion Time for the condition of R-11 and R-12

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 16 of 33 both inoperable neither introduces new accident initiators nor equipment failure modes. Maintaining the purge valves closed or isolated by blind flange and exempting the containment ventilation isolation requirements during MODES 1 through 4 cannot introduce new equipment failure modes or introduce new kinds of accidents. Extending the purge valve Completion Time to 72-hours consistent with the impact on safety cannot introduce new purge valve failure modes or new precursors to any accident. The proposed changes do not alter the types or increase the amounts of fission product effluents and no increase in individual or cumulative occupational exposure will occur as a result of the change. The proposed change aligns with all applicable regulations and NRC endorsed industry guidance for safe operation. Thereby, no new accident scenarios, transient precursors, failure mechanisms, or limiting single failures can result.

Therefore, the proposed amendments do not create the possibility of a new or different kind of accident from any previously evaluated.

(3) Do the proposed amendments involve a significant reduction in a margin of safety?

Response: No The proposed change revises the R-11 and R-12 requirements by converting the setpoint measurement units. The proposed change modifies the RCS leakage detection requirements by extending the Completion Time and limiting the required leakage detection methods to more closely align with NUREG-1431, Revision 4, for R-11 and R-12 both inoperable. The proposed change modifies the containment purge supply and exhaust isolation valve and associated containment ventilation isolation instrumentation requirements to reflect that the purge valves will be maintained administratively sealed closed and deactivated or isolated by blind flange in MODES 1 through 4. Converting the instrument measurement units cannot adversely affect safety. Limiting the required RCS leakage detection methods or increasing the CT for the condition of R-11 and R-12 both inoperable will not reduce the margin of safety since the proposed changes are consistent with the NRC endorsed NUREG-1431, Revision 4. Exempting the containment ventilation isolation instrumentation requirements cannot reduce the margin of safety since the change merely aligns the TS requirements with the licensing basis to assure containment ventilation isolation in MODES 1 through 4. Extending the purge valve Completion Time to 72-hours does not adversely impact safety since the safety analysis assumptions for Type B & C leakage remain valid with substantial margin. No instrument or system response times or acceptance criteria associated with any accident analyses are affected by the proposed change. No new or altered methods of assessing plant performance are introduced and accident analysis assumptions are unaffected. Thereby, no safety limits or limiting safety settings are challenged by the proposed change.

Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.

Based upon the above analysis, FPL concludes that the proposed license amendments do not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92, Issuance of Amendment, and accordingly, a finding of no significant hazards consideration is justified.

Turkey Point Nuclear Plant L-2019-192 Docket Nos. 50-250 and 50-251 Enclosure Page 17 of 33 4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

FPL has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set for in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 4.0, Volume 1, Specifications (ADAMS Accession No. ML12100A222) 6.2 NRC Generic Issue B-20, Containment Leakage Due to Seal Deterioration 6.3 NRC IE Circular 77-11, Leakage of Containment Isolation Valves with Resilient Seats, September 2, 1977 6.4 NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132)

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