ML20084G562
| ML20084G562 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/20/2020 |
| From: | Ellen Brown NRC/NRR/DORL/LPL2-2 |
| To: | Mack J Florida Power & Light Co |
| References | |
| Download: ML20084G562 (5) | |
Text
From:
Brown, Eva Sent:
Friday, March 20, 2020 10:11 AM To:
Mack, Jarrett; Hess, Robert Cc:
Hanek, Olga
Subject:
ACTION: Turkey Point Containment Radiation Monitors Request for Additional Information Attachments:
0240 RAI final.docx
- Jarrett, Apologies for not getting this to you yesterday.
By letter dated November 4, 2019 (the submittal), (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19315C003), Florida Power & Light Company (the licensee) submitted a license amendment request for Turkey Point Nuclear Plant, Units 3 and 4 (TPN). The proposed amendment revises technical specifications (TS) for the containment atmosphere radioactivity monitoring, containment ventilation isolation and reactor coolant system (RCS) leakage detection system requirements. The NRC staff has determined that the attached additional information is needed to complete its review of the proposed amendment.
On Tuesday, March 17, 2020, you indicated that a 30 day response time from the date of this correspondence would be acceptable. Should this change, such that more time is needed, please contact me prior to exceeding the agreed upon time.
Thanks.
Eva Brown, Senior Project Manager - Turkey Point Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Nuclear Regulatory Commission (301) 415-2315 (w)
(301) 415-1222 (f)
Hearing Identifier:
NRR_DRMA Email Number:
491 Mail Envelope Properties (MN2PR09MB4732A8C7090AB0C14925A599EFF50)
Subject:
ACTION: Turkey Point Containment Radiation Monitors Request for Additional Information Sent Date:
3/20/2020 10:11:00 AM Received Date:
3/20/2020 10:11:00 AM From:
Brown, Eva Created By:
Eva.Brown@nrc.gov Recipients:
"Hanek, Olga" <olga.hanek@fpl.com>
Tracking Status: None "Mack, Jarrett" <jarrett.mack@fpl.com>
Tracking Status: None "Hess, Robert" <Robert.Hess@fpl.com>
Tracking Status: None Post Office:
MN2PR09MB4732.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1153 3/20/2020 10:11:00 AM 0240 RAI final.docx 50295 Options Priority:
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REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTAINMENT RADIATION MONITORING INSTRUMENTATION FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251 By letter dated November 4, 2019 (the submittal), (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19315C003), Florida Power & Light Company (the licensee) submitted a license amendment request for Turkey Point Nuclear Plant, Units 3 and 4 (TPN). The proposed amendment revises technical specifications (TS) for the containment atmosphere radioactivity monitoring, containment ventilation isolation and reactor coolant system (RCS) leakage detection system requirements.
Paragraph 50.36(c)(3) of Title 10 of the Code of Federal Regulations (10 CFR), states that Surveillance Requirements are requirements relating to test, calibration, or inspection 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.
Option B of Appendix J to 10 CFR Part 50 (10 CFR 50), requires assurance that leakage through containment or systems and components penetrating containment does not exceed allowed leakage rates specified in the TS.
The 1967 Proposed General Design Criteria (GDC-1967) 15 - states that protection systems shall be provided for sensing accident situations and initiating necessary engineered safety features. GDC-1967 16 states that means shall be provided to detect significant uncontrolled leakage from the reactor coolant pressure boundary. GDC-1967 17 states that means shall be provided for monitoring the containment atmosphere and the facility effluent discharge paths for radioactivity release from normal operations, anticipated transients, and accident conditions.
Existing TPN TS Limiting Condition for Operating (LCO) 3.6.2, Reactor Coolant System, Operational Leakage, contains the limitations on operational leakage and include a one gallon per minute (gpm) unidentified leakage requirement and a 10 gpm identified leakage requirement. The containment radiation gaseous and effluent monitors (R-11 and R-12) for TPN support this determination.
The NRC staff has determined that additional information is needed to complete its review of the proposed amendment.
- 1. As discussed in Regulatory Guide 1.45, May 1973, the sensitivity and response time of each leakage detection system employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour.
Section 3.1 of the Enclosure to the submittal requests the conversion of the units of measure from counts per minute (cpm) to micro curies per cubic centimeter (µCi/cc) for the R-11 and R-12 radiation monitors and indicates the change is administrative in nature as FPLs design control program was used. A review of the ODCM, Rev. 26 submitted with the 2018 Annual Radiological Effluent Report (L-2019-017) finds that the methodology and parameters for determining the setpoints for each of its TS identified functions is similarly not provided for the Radioactive Gaseous Effluent Monitoring Instrumentation, Operability and Alarm/Trip Setpoints for the R-11 and R-12 containment purge isolation radiation monitors.
Given that an NRC approved methodology for the conversion was not indicated in the submittal to support that the proposed TS allowable value and Trip Setpoint values have been accurately determined, the licensee is requested to provide the following information:
- a. A discussion outlining the methodology used for establishing the setpoints for these monitors for each function. This discussion should include any relevant assumptions and/or conversion factors;
- b. The calibration efficiency factor(s) and the isotope(s) to which the monitors are calibrated (e.g., Xe-133, Kr-85, Co-60, Rb-88, etc.); and,
- c. A discussion addressing the effect the revised setpoints will have on the alarms and the operators response to the alarms. This includes how the alarms, as well as the setpoints, are displayed and viewed by the operators in the control room.
- 2. Section 3.1.1 discusses that the proposed conversions are administrative in nature. The NRC staff reviewed the submittal, the TS and existing ODCM. The TS LCO 6.14.2.a.1 requires the development of sufficient information to support the changes(s) together with the appropriate analyses or evaluations justifying the changes.
For the following table of proposed changes, provide information detailing how the converted values were derived to satisfy TS 6.14.2.a.1. The information should include, but not be limited to, allowable value, nominal trip setpoint, the basis for selection, and any limitations pertaining to the conversions.
TS Table Affected Requirement Current Proposed 3.3-3 Functional Unit 3.c.4 Containment RadioactivityHigh Allowable Value 6.8x105 CPM Setpoint 6.1x105 CPM Allowable Value 5.00x10-5 µCi/cc Setpoint 4.49x10-6 µCi/cc 3.3-3 Note 2 Setpoint 3.2x104 CPM Allowable Value 3.5x104 CPM Setpoint 1.11x10-3 µCi/cc Allowable Value 1.22x10-3 µCi/cc 3.3-4 Functional Unit 1.a Containment RadioactivityHigh Setpoint 6.1x105 CPM Setpoint 4.49x10-6 µCi/cc 3.3-4 Note 2 Setpoint 3.2x104 CPM Setpoint 1.11x10-3 µCi/cc
- 3. Section 11.2.3, Radiation Monitoring System of the TPN Updated Final Safety Analysis Report (UFSAR) includes a description of the Process Radiation Monitoring System.
The UFSAR states that the function of these monitors includes measuring radioactivity in the containment and to ensure that the release rate during purging is maintained below specified limits. Section 11.2.3 of the UFSAR states that the high radiation level for each channel initiates closure of the containment purge supply and exhaust duct valves. The UFSAR further states that the alarm setpoints for the R-11 and R-12 containment radiation monitors are derived from Table 3.3-3 of the TS and set in accordance with the methodology and parameters from the TPN ODCM.
Section 3.3 of the Enclosure to the submittal discusses that the containment purge supply and exhaust duct valves will be maintained in an administratively-controlled closed position or that a blind flange will be installed in Modes 1-4. Therefore, the R-11 and R-12 monitors will no longer function to initiate closure of the containment purge supply and exhaust valves. As a result, the current TS alarm/trip setpoints should no longer be necessary to ensure that the release rate during purging is maintained below specified limits, making the setpoints immaterial with respect to effluent control during purging.
However, the NRC staff identified that the R-11 and R-12 monitors remain credited for identification of RCS Leakage per TS 3/4.4.6, Reactor Coolant System Leakage. Describe how the existing setpoints continue to support detection of RCS leakage at the operational limits identified in the TS.
- 4. Section 3.3.3 of the Enclosure to the submittal discusses the proposed revisions to the purge valve TS SRs. This proposed change essentially creates two separate conditions that, in accordance with 10 CFR 50.36, need to be verified and maintained via surveillance requirements. The first condition is when the valves are administratively sealed closed and deactivated and the second condition is when the associated penetration(s) are isolated by blind flange. In addition, the licensee is proposing the addition of a footnote to TS 3/4.6.1.7, which states:
[p]erformance of SR 4.6.1.7.1 and SR 4.6.1.7.2 are not required when the associated purge supply and/or exhaust penetration is isolated by blind flange.
Discuss how the proposed TS SRs in SR 4.6.1.7 demonstrate operability of each containment purge supply and exhaust isolation valve, when the associated purge supply and/or exhaust penetration(s) is isolated by a blind flange.