L-2022-181, Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5

Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5

ML22336A051
Person / Time
Site:	Turkey Point
Issue date:	12/01/2022
From:	Strand D Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2022-181
Download: ML22336A051 (1)

Text

{{#Wiki_filter:L-2022-181 10 CFR 50. 90

• FPL. 'HFHPEHU 

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

Response to Request for Additional Information Regarding License Amendment Request for the Technical Specifications Conversion to NUREG-1431, Revision 5

References :

1. Florida Power & Light Company (FPL) Letter L-2021-158 dated September 22, 2021, License Amendment Request for the Technical Specifications Conversion to NUREG-1431 Revision 5 (ADAMS Accession No. ML21265A370)

2. Florida Power & Light Company (FPL) Letter L-2022-010 dated January 19, 2022, License Amendment Request for the Technical Specifications Conversion to NUREG-1431 Revision 5 -

Request for Supplemental Information (RSI) Response (ADAMS Accession No. ML22019A067)

3. Florida Power & Light Company (FPL) Letter L-2022-158 dated March 30, 2022, License Amendment Request Revision 1 for the Technical Specifications Conversion to N UREG-1431 Revision 5 (ADAMS Access ion No. ML22089A195)

4. NRC Electronic Memorandum dated November 07, 2022, Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additiona l Information, Improved Technical Specifications Conversion,

Docket No. 50-250 and 50-251 (ADAMS Accession No. ML22311A475)

In Reference 1, as supplemented by References 2 and 3, Florida Power & Light Company (FPL) submitted an Improved Technical Specifications (ITS) conyersion License Amendment Request (LAR) for Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively.

FPL has not proposed any change in setpoints nor any change to the methodology used from the current licensing basis to calculate these setpoints as part of this proposed conversion to Improved Technical Specifications, however, in Reference 4, the NRC has determined that additional information is necessary to comp lete their review.

The enclosure to this letter provides FPL's response to the request for additional information (RAI). Attachment 1 to the enclosure provides the proposed Turkey Point Updated Final Safety Analysis Report (UFSAR) Section 7.2 insert. Attachment 2 to the enclosure provides the marked-up pages of Section 3.3 of the Turkey Point ITS Conversion LAR.

The supplements included in this RA I response provide additional information that clarifies the application, do not expand the scope of the applica tion as originally noticed, and should not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federa l Register.

This letter contains no new regulatory commi tments.

Florida Power & Light Company

9760 SW 344th Street, H o mestead, FL 33035 Turkey Po int Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 2 of 2

Should you have any quest ions regarding this submission, please contact Michael J. Davis at 319-851-7032.

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

Executed on the _/_ day of December 2022.

• Sincerely,

[) l c.__.,, ~ Dianne Stran d Genera l Manager Regu latory Affairs

Enclosure:

Response to Request for Additional Information (RAI) Regarding Turkey Point Improved Technical Specifications (ITS) conversion License Amendment Request (LAR)

Attachments:

1. Proposed Turkey Po int Updated Final Safety Analysis Report (UFSAR) Section 7.2 Insert

2. Turkey Point Improved Technical Specifications (ITS) Conversion License Amendment Request (LAR) Section 3.3 Marked-up Pages

cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Residen t Inspector, Turkey Point Nuclea r Plant Ms. Cindy Becker, Florida Department of Health Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Enclosure Page 1 of 11

Response to Request for Additional Information (RAI) Regarding Turkey Point Improved Technical Specifications (ITS) conversion License Amendment Request (LAR)

In electronic memorandums dated November 07, 2022 (Reference 1), the NRC staff of the Office of Nuclear Reactor Regulation (NRR) requested additional information (RAI) regarding the Turkey Point Improved Technical Specifications (ITS) conversion License Amendment Request (Reference 2), as indicated below. NextEra's response follows.

Background for RAI-1

The licensee proposes to apply TSTF-493, Clarify Application of Setpoint Methodology for LSSS Function Option A - Addition of [surveillance] Notes 1 and 2 to the Agreed Upon Functions, as part of its request to revise its CTS to ITS based on NUREG-1431, Revision 5. The Standard Technical Specifications (STS) include Option A of TSTF-493.

Surveillance Note 1 of TSTF-493, Option A, discusses the application of an as-found tolerance (AFT). Surveillance Note 2 of TSTF-493, Option A, also discusses the application of a predetermined AFT band about the limiting trip setpoint (LTSP), the nominal trip setpoint (NTSP), or the actual as-left field setting of the surveillance (Channel Calibration and Channel Operational Test). This surveillance as-left field setting must be within a predetermined as-left tolerance (ALT) band. Additionally, on page 7 of the front matter of the TSTF-493 traveler it states, in part, Implementation of [surveillance] Note 1 requires the licensee to calculate an as-found tolerance (limit).

In addition, the TSTF-493 traveler includes a Model Application for Adoption of TSTF-493 Option A (ML100710442), which states, in part, Additionally, to ensure proper use of the allowable value (AV), LTSP, and NTSP, the methodology for calculating the as-left and as-found tolerances must also be included in [the FSAR] [a document incorporated by reference in the FSAR] and listed in surveillance Note 2 as discussed in Section 3.1.2, below.

The NRC staff noted while reviewing Turkey Point Units 3 and 4s UFSAR, Section 7.2.2, System Design, the subsection for Setpoint Methodology discusses WCAP-17070 (whose scope and NRC approval was limited to the instruments impacted by the 2012 extended power update (EPU) license amendment).

As part of an information exchange with the NRC staff related to the ITS conversion request for Turkey Point, the licensee stated in its response to NRC question number MEH003 on the Certrec Portal that several protective functions use the methodology described in WCAP-12745, Rev. 0, 1990, and Rev. 1, 1996, as the instrument channel performance uncertainty/setpoint methodology of record. When the NRC staff reviewed the WCAP-12745 report, the staff found that the terms AFT and ALT, along with other terms clarifying the use and application of the setpoint and LSSS related terms in RIS 2006-17, are not described. It appears that the WCAP-12745 methodology states that the method used to determine whether the channel is functioning as required uses only the non-conservative direction of channel drift towards the AV, and not the two-sided comparison of the as-measured value against the bi-directional rack calibration accuracy term, as described in WCAP-17070. Further, it is not clear whether the magnitude of this error limit includes or does not include the same terms identified within the RIS or within the approved WCAP-17070.

The NRC staff needs information to understand how the licensee is implementing the proposed surveillance Notes 1 and 2 of TSTF-493, Option A for determining whether an instrument channel is functioning as required (as described in Option A of TSTF-493), since WCAP-12745 does not define these terms, (i.e., similar to how they have been established and described in WCAP-17070). If the licensee plans to use WCAP-12745 to identify how the channels will be determined to be functioning as required during a channel surveillance, the NRC staff expects that the licensees setpoint methodology for establishing and maintaining LSSS functional limits will clearly define how the key terms of ALT and AFT are established

Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 2 of 11

and used as surveillance acceptance criteria for the instrument Functions having an associated LSSS. Meeting this expectation will enable use of Notes 1 and 2 to reach a determination of acceptability for the application of TSTF-493 Option A for those associated instrument Functions.

RAI-1

Given the NRC staffs information needs described above, the license is requested to provide the following information for the LSSS instrument Functions specified by ITS Subsections 3.3.1 and 3.3.2:

a. A revised channel performance uncertainty evaluation methodology for TS related instrument Functions that are not within the scope of WCAP-17070, clearly describing how the as-found tolerance (AFT), as-left tolerance (ALT), Nominal Trip Setpoint (NTSP, or NSP), Safety Analysis Limit (SAL), Channel Statistical Allowance (CSA), Margin, Total Allowance (TA) and allowable value (AV) are defined and how each term relates to other terms, and how they are to be used in relation to the surveillance Notes (b) and (c) proposed to be included in ITS Tables 3.3.1-1 and 3.3.2-1, that are consistent with the definitions used in TSTF-493 Option A, and with RIS 2006-17.

FPL Response:

FPL has not proposed any change in setpoints nor any change to the methodology used from the current licensing basis in order to calculate these setpoints as part of this proposed conversion to Improved Technical Specifications for any instrument function associated with the Reactor Trip System (RTS) or the Engineered Safety Features Actuation System (ESFAS). The following discussion provides the uncertainty evaluation methodology described in WCAP-12745, Westinghouse Setpoint Methodology for Protection Systems - Turkey Point Units 3 & 4, and includes a concise description how the as-found tolerance (AFT), as-left tolerance (ALT), Nominal Trip Setpoint (NTSP or NSP), Safety Analysis Limit (SAL), Channel Statistical Allowance (CSA), Margin, Total Allowance (TA), and allowable value (AV) are defined and how each term related to other terms, and how they are to be used in relation to Footnotes (b) and (c) in ITS Tables 3.3.1-1 and 3.3.2-1.

The following definitions are derived from the information provided in WCAP 12745 and the companion bases document, WCAP-12201 Revision 2, Bases Document for Westinghouse Setpoint Methodology for Protection Systems.

As-Found Tolerance (AFT) - As-found refers to the condition a transmitter, process rack, module, or process instrument loop is found in after a period of operation (from WCAP-12201 Revision 2). The as-found tolerance is defined in WCAP-12745 Revision 0 and 1 as the most conservative trigger value that defines the difference between the trip setpoint and the allowable value. Two methods are presented in WCAP-12745, with the intention of isolating the rack allowances from the channel statistical accuracy.

=( + + + )

T2 = TA - ((A) + (S)2)1/2 - EA

Trigger value T1 is used as the limit for an as measured value to determine operability (i.e., Allowable Value). If the as measured value exceeds trigger value T1, the plant staff recalibrates the instrumentation. Using trigger value T1, a few conservative assumptions can be made for the purposes of rack calibration and surveillance checks. The rack measurement and testing (RMTE) term is discussed in WCAP-12745 and suggests that a conservative assumption for the error in terms of the as-found tolerance would be to assume the error is an integral part of the rack calibration accuracy (RCA) term. As discussed in WCAP-12201, the rack comparator setting accuracy (RCSA) term can be excluded for digital process racks or included in the RCA term for analog process racks. Thus, the as-found tolerance can be derived from the trigger value as:

= + for digital racks Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 3 of 11

= + + for analog racks

In WCAP-17070, Revision 3, it was assumed that rack drift (RD) would be small, and Westinghouse concluded that for digital racks it could be assumed that the RD term is zero. Therefore, the AFT formulation is given by:

= for digital racks
= + + for analog racks

If the AFT is exceeded, then the channel shall be evaluated to verify proper function as required before returning the channel to service.

For illustration, using the Pressurizer Water Level - High uncertainty values in Table 3-7 of WCAP-12745, Revision 0, the AFT would be calculated as follows:

AFT = RCA = 0.2 for digital racks AFT = RCA + RCSA + RD = 0.2 + 0.0 + 0.3 = 0.5 for analog racks

As a result, the AFT span for the Pressurizer Water Level - High setpoint would be the NTSP +/- AFT or 92% +/- 0.2% since the Pressurizer Water Level - High instrumentation utilizes the RTS digital rack.

As-Left Tolerance (ALT) - As-left refers to the condition a transmitter, process rack module, or process instrument loop is left in after calibration or bistable trip setpoint verification (from WCAP-12201 Revision 2). The as-left tolerance was assumed to be equivalent to the as-found trigger value excluding the drift tolerance. Thus, the ALT would be given as:

= + + 

Using this trigger values, a few conservative assumptions can be made for the purposes of rack calibration and surveillance checks. The RMTE term is discussed in WCAP-12745 and suggests that a conservative assumption for the error in terms of the as-found tolerance would be to assume the error is an integral part of the RCA term. As discussed in WCAP-12201, the RCSA term can be excluded for digital process racks or included in the RCA term for analog process racks. Thus, the as-left tolerance can be reduced to:

= for digital racks
= + for analog racks

The channel shall be reset to within the ALT around the NTSP at the completion of surveillance or be declared inoperable.

For illustration, using the Pressurizer Water Level - High uncertainty values in Table 3-7 of WCAP-12745, Revision 0, the ALT would be calculated as follows:

ALT = RCA = 0.2 for digital racks ALT = RCA + RCSA = 0.2 + 0.0 = 0.2 for analog racks

As a result, the ALT span for the Pressurizer Water Level - High setpoint would be the NTSP +/- ALT or 92% +/- 0.2%.

Nominal Trip Setpoint (NTSP) - The desired setpoint for the variable. Initial calibration and subsequent recalibration should be made at the nominal trip setpoint (specified as the nominal safety system setting in WCAP-12745, Revisions 0 and 1). This setpoint is specified in the Trip Setpoint column in CTS Tables 2.2-1 and 3.3-3.

Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 4 of 11

Safety Analysis Limit (SAL) - The setpoint value assumed in the safety analyses (from WCAP-12745, Revisions 0 and 1) and indicated in Table 3-23 of WCAP-12745, Rev. 0 and Table 3-9 of WCAP-12745, Rev. 1, as applicable.

Channel Statistical Allowance (CSA) - The calculated uncertainty for a channel. Equation 2.1 in WCAP-12745, Revisions 0 and 1 describes this as follows:

= + + ( + + ) + + + ( + + + ) + 
+ + 

Where: CSA = Channel Statistical Allowance PMA = Process Measurement Accuracy PEA = Primary Element Accuracy SCA = Sensor Calibration Accuracy SMTE = Sensor Measurement and Test Equipment Accuracy SD = Sensor Drift SPE = Sensor Pressure Effects STE = Sensor Temperature Effects RCA = Rack Calibration Accuracy RMTE = Rack Measurement and Test Equipment Accuracy RCSA = Rack Comparator Setting Accuracy RD = Rack Drift RTE = Rack Temperature Effects EA = Environmental Allowance BIAS = Bias values of known direction

Margin - The difference between the Total Allowance and the Channel Statistical Allowance. Equation 3.2 in WCAP-12745, Revisions 0 and 1 describes this as follows:

= 

Total Allowance (TA) - The difference between the safety analysis limit and the Nominal Trip Setpoint. Equation 3.1 in WCAP-12745, Revisions 0 and 1 describes this as follows:

= 

Allowable Value (AV) - The limiting value that the trip setpoint can have when tested periodically, beyond which the instrument channel is declared inoperable and corrective action must be taken (from ISA67.04-1987). A setting chosen to prevent exceeding a Safety Analysis Limit. Defined in WCAP-12745 as the Limiting Safety System Setting.

The relationship between the ALT/AFT values and the NTSP is depicted below for a digital system. An analog system is similar except the AFT range would be larger than the ALT range, not to exceed the Allowable Value. Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 5 of 11

Setpoint Relationships

SAL (Safety Analy s is Limit)

1rgin (Total Allowance) I TAt---

CSA (Channel Statistical Allowance) t + As Left / As Found Tolerance

RCA (0.5% span typical)

NTS (Nominal Trip Setpoint)

RCA (0.5% s pan typical)

* - As Left / As Found To lerance The stack up of the error terms that comprise the CSA and the relationship between the SAL, Margin, NTSP, and AV are shown below (from WCAP-12201 Revision 2).

sa.fety An a lysis Limi t 1------- --- { Margin { Process Measurement Accuracy { Primary Element Acc~racy { sensor Calibration Accuracy { Sensor Mea$urement & Test Equipmen t { Sensor Pressure Effects 1---------- { Sensor Temperature Eff ects { Sensor Drift { Env i ronmental Allowance { Rack Temperature Ef f e cts Allowable Val ue T1 :---------- { Rack COl!lparator Setting Accuracy Typical All owable Value T, : -- - - - **---- { Rack Calibration Accuracy Typical Allowable Value T, : -------- - - { Rack Measu r ement & Test Equipment { Rack Dr i ft Nominal 'l'rip setpoint 1- --... -----

b. Summaries of channel performance uncertainty calculations for instruments not within the scope of WCAP-17070 demonstrating how the use of the terms in Item a. above still ensures that the total allowance (TA) includes a positive margin beyond the CSA but still within the SAL.

Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 6 of 11

FPL Response:

FPL has not proposed any change in setpoints nor any change to the methodology used from the current licensing basis in order to calculate these setpoints as part of this proposed conversion to Improved Technical Specifications for any instrument function associated with the RTS or ESFAS. Therefore, the summary channel performance uncertainty calculations for the RTS and ESFAS instruments not within the scope of WCAP-17070 continue to be as shown in WCAP-12745 Revision 0 or Revision 1, as applicable. Under the heading Adoption of TSTF-493. Option A without Changes to Setpoint Values, in the Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-493, Revision 4, "Clarify Application of Setpoint Methodology for LSSS Functions, the notice states: Since no setpoint changes are being proposed, there is no need to provide the setpoint methodology for review or to provide any full or summary calculations.

A summary of the instrument setpoint uncertainties, NTSP, AV, SAL, TA, CSA, and margin for RTS and ESFAS instruments not within the scope of WCAP-17070 are provided in Table 3-23 of WCAP-12745, Rev. 0 and Table 3-9 of WCAP-12745, Rev. 1, as applicable. For instruments associated with a safety analysis limit (SAL), each summary performance uncertainty calculation shows zero or positive margin to the SAL beyond the CSA. The AV is the limiting safety system setting (LSSS) that ensures the automatic protective action will correct an abnormal situation before a safety limit is exceeded. Any revision of a NTSP under licensee control due to a reduction in the CSA can only reduce the margin between the NTSP and the AV. Although this NTSP change could result in a reduction in TA, this reduction does not adversely impact the margin between the LSSS and the SAL since the difference between the SAL and instrument AV (i.e., LSSS) cannot change without prior NRC approval, thus preserving the margin of the LSSS to the SAL (i.e., margin beyond the CSA).

The following lists the RTS and ESFAS instruments not within the scope of WCAP-17070 and the associated table in WCAP-12745 (including the applicable WCAP revision) that provides the specific summary channel performance uncertainty calculation:

RTS Trip Function Specific Summary WCAP-12745 Uncertainty Calculation Revision No. 2 b. Power Range Neutron Flux Low Table 3-1 0

3. Intermediate Range Neutron Flux Table 3-2 0

4. Source Range Neutron Flux Table 3-3 0

7. Pressurizer Pressure - Low Table 3-6 0

8. Pressurizer Pressure - High Table 3-6 0

9. Pressurizer Water Level - High Table 3-7 0

13. Undervoltage - 4.16 kV Buses A and B Table 3-11 0 14 Underfrequency RCPs Breakers Open Table 3-12 0

ESFAS Trip Function Specific Summary WCAP-12745 Uncertainty Calculation Revision No.

1. Safety Injection

c. Containment Pressure - High Table 3-14 0

d. Pressurizer Pressure - Low Table 3-15 0 Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 7 of 11

ESFAS Trip Function Specific Summary WCAP-12745 Uncertainty Calculation Revision No.

e. High Differential Pressure Between Steam Line Header and any Table 3-16 0 Steam Generator

f. Tavg - Low (Coincident for Steam Table 3-8 1 Line Flow -High)

2. Containment Spray

b. Containment Pressure - High, High Table 3-6 1

Coincident with Containment Table 3-14 0 Pressure - High

3. Containment Isolation

b. Phase B Isolation

(3) Containment Pressure - High, Table 3-6 1 High Coincident with Table 3-14 0 Containment Pressure - High

4. Steam Line Isolation

c. Containment Pressure - High, High Table 3-6 1

Coincident with Containment Table 3-14 0 Pressure - High

d. Tavg - Low (Coincident for Steam Table 3-8 1 Line Flow -High)

c. Based on information exchanged with the licensee, in some cases it appears that at least two setpoint methods have been applied to a single instrument. Explain why it is acceptable to use two different setpoint methods for a single instrument (e.g., Power Range Neutron Flux - High setpoint and Low setpoint).

FPL Response:

The Power Range Neutron Flux - High and Low instrument setpoint calculations initially used the NRC approved instrument setpoint methodology specified in WCAP-12745. It was determined that the Power Range Neutron Flux - High instrument required revision to support the extended power uprate (EPU). The NRC approved instrument setpoint methodology described in WCAP-17070 was used to revise the Power Range Neutron Flux - High instrument setpoint. Therefore, the uncertainty calculation associated with the Power Range Neutron Flux - High RTS function applies the method described in WCAP-17070 and the uncertainty calculation associated with the Power Range Neutron Flux - Low RTS function applies the method described in WCAP-12745, which is similar to the methodology described in WCAP-17070.

The acceptability for use of two instrument setpoint methodologies applied to a single instrument (e.g., Power Range Neutron Flux - High setpoint and Low setpoint) was established upon issuance of the EPU license amendments for PTN Units 3 and 4 representing the current licensing basis (NRC ADAMS Accession No. ML11293A365). FPL has not proposed any change in setpoints nor any change to the methodology used from the current licensing basis in order to calculate these setpoints as part of this Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 8 of 11

proposed conversion to Improved Technical Specifications for any instrument function associated with the RTS or ESFAS, including the Power Range Neutron Flux - High and Low instrument functions.

FPL recognizes that rack uncertainty values specified for Power Range Neutron Flux - High in Table 3-1 and summarized in Table 3-12 of WCAP-17070, Rev. 1 are more conservative than the rack uncertainty values specified for Power Range Neutron Flux - Low in Table 3-1 and summarized in Table 3-23 of WCAP-12745, Rev. 0. However, if the more conservative tolerances specified in WCAP-17070 were used to calculate the as-found and as-left tolerances for the Power Range Neutron Flux - Low RTS function, ITS Table 3.3.1-1 Footnotes (b) and (c) will require an evaluation of the instrument performance and recalibration based on a more restrictive instrument tolerance, which would continue to ensure that the automatic protective action will correct an abnormal situation before a safety limit is exceeded.

d. Description of information related to the updated channel performance uncertainty methodology provided by the licensee in above Item a that will be added into the appropriate section of the UFSAR, as was the case for the WCAP-17070 methodology. If the licensee does not plan to revise and resubmit the WCAP-12745 methodology topical report, then the UFSAR description should be sufficiently detailed to describe the technical relationships of how the AFT and ALT acceptance criterion described in the Tech Spec Table footnotes will be applied when using the specific values and terms that appear in WCAP-12745 where AFT and ALT do not appear. The UFSAR description should describe how the specific terms in WCAP-12745 are to be combined or derived to develop values for AFT and ALT that is consistent with the footnotes in the Tech Spec tables and the concepts within RIS 2006-17 and TSTF-493 Option A.

FPL Response:

Attachment 1 provides the proposed insert associated with UFSAR Section 7.2 to, in part, satisfy the requirements of Footnote (c) in ITS Tables 3.3.1-1 and 3.3.2-1. Footnote (c) states, in part, the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. The proposed insert to UFSAR Section 7.2 also includes the following:

A summary description of channel performance uncertainty methodology as described in WCAP-12745 and WCAP-17070, including a table listing each instrument and the associated methodology used to calculate the nominal trip setpoint (NTSP), allowable value (AV), as found tolerance (AFT), and as left tolerance (ALT) uncertainty values.

A description of technical relationship between the AFT and ALT and how the acceptance criterion for these instrument tolerances are derived for the referenced Reactor Trip System and Engineered Safety Feature Actuating System instrument functions.

The proposed insert to UFSAR Section 7.2 includes a description of how the AFT and ALT will be applied to meet the requirements specified in Footnotes (b) and (c) of ITS Tables 3.3.1-1 and 3.3.2-1.

Background for RAI-2 and RAI-3

Since 1992 in Revision 0 of NUREG-1431, Table 3.3.1-1 and Table 3.3.2-1 have included a Reviewers Note regarding the [Nominal] Trip Setpoint column, which states: Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit.

In NUREG-1431 Rev. 5, STS Bases pages B 3.3.1-3 and B 3.3.2-3 include the following statement:

[Note: Alternatively, a Technical Specification format incorporating an Allowable Value only column may be proposed by a licensee. In this, case, the [NTSP] value and the methodologies used to calculate the as-found and as-left tolerances must be specified in [insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 9 of 11

facility FSAR]. Changes to the actual plant trip setpoint or [NTSP] value would be controlled by 10 CFR 50.59 or administratively as appropriate, and adjusted per the setpoint methodology and applicable surveillance requirements.]

RAI-2

The licensee is requested to provide a technical explanation of how the setpoint study methodologies of record in WCAP-12745 Revisions 0 and 1, and WCAP-17070, Revision 1, justify omitting the Trip Setpoint column for the instrument Functions having LSSS values in ITS Table 3.3.1-1 and Table 3.3.2-1, while retaining the Allowable Value column in these tables. In addition, if the setpoint column is removed, and the existing methodologies are not applicable to all relocated setpoints, describe the programmatic controls that will be in place that would prevent those setpoints from being changed under licensee control via 10 CFR 50.59.

FPL Response:

The unit specific Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) instrument setpoint study methodology specified in WCAP-12745, Revisions 0 and 1, and WCAP-17070, Revision 1, allows the Technical Specifications to contain only the Allowable Value (AV) column because the trips setpoints are nominal values and not the instrument Operability values nor are the trip setpoints the limiting safety system settings (LSSS) upon which automatic protective action is relied to correct abnormal situations before a safety limit is exceeded.

The unit specific instrument setpoint methodology specified in WCAP-12745 states that for Turkey Point Units 3 and 4, the LSSS is the instrument AV. Thus, the AV is the instrument Operability value. The nominal trip setpoint (NTSP) is the instrument setting that a channel is reset, within the as-left tolerance (ALT), during channel calibration to ensure the AV is not exceeded between the calibration period. Since the calculated NTSP includes a two-sided tolerance that accounts for instrument drift between calibrations, and is not the instrument Operability value, the Trip Setpoint column, appropriately, is not included in the ITS. Additionally, relocation of the Trip Setpoint column is acceptable, as indicated in TSTF-493, Revision 4, Option A, due to the addition of Footnotes (b) and (c) of ISTS Tables 3.3.1-1 and 3.3.2-1 to selected instrument functions that protect safety analysis limits (SALs). These footnotes, which represent a more restrictive change to the CTS, ensure proper action is taken when an instrument channel is found to be outside the as-found tolerance (AFT) or cannot be reset to the ALT during a channel calibration. Note that FPL has not proposed any change in setpoints nor any change to the methodology used from the current licensing basis in order to calculate these setpoints as part of this proposed conversion to Improved Technical Specifications for any instrument function associated with the RTS or ESFAS. Instrument setpoints proposed for relocation are calculated using existing instrument setpoint methodologies.

As noted in ITS Tables 3.3.1-1 and 3.3.2-1, Footnote (c), the NTSP values will be specified in the Technical Requirements Manual and the methodologies used to calculate the AFT and ALT values will be summarized in the UFSAR referencing the applicable Westinghouse topical reports with the details on how to calculate the AFT and ALT values. Changes to the actual plant trip setpoint or the NTSP value, if different, and the methodologies used to calculate the AFT and ALT values will be controlled pursuant to the requirements of 10 CFR 50.59. Setpoint values will be adjusted per the setpoint methodology and applicable surveillance requirements. Any adjustment of a NTSP under licensee control that changes the overall instrument uncertainty between the NTSP and the SAL is limited to the margin between the NTSP and the AV and cannot adversely impact the margin between the LSSS and the SAL since the difference between the SAL and instrument AV (i.e., LSSS) cannot change without prior NRC approval, thus preserving the margin of the LSSS to the SAL.

Setpoint changes will be controlled pursuant to the requirements of 10 CFR 50.59. Any procedure change that represents a change to the current plant design, which a setpoint change would represent, requires a 10 CFR 50.59 review. In addition, an Applicability Determination is required for procedure changes other than editorial to ensure other regulatory requirements are addressed, as required. If the Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 10 of 11

existing methodologies are not applicable to a relocated setpoint and a change to the instrument function setpoint is determined to be needed, the procedure change process will require a 10 CFR 50.59 review performed to determine if prior NRC approval is required using the criteria specified in 10 CFR 50.59(c)(2). These criteria, in addition to retaining the AV for each RTS and ESFAS instrument function in Technical Specifications, are sufficient to ensure changes to trip setpoints under licensee control will not adversely impact the capability of the LSSS to automatically initiate protective action to correct an abnormal situation before a safety limit is exceeded. As a result, programmatic controls to prevent instrument function setpoints from being changed under licensee control via 10 CFR 50.59 is unnecessary.

The ITS Conversion LAR is revised, as shown in Attachment 2, to include a more restrictive change in ITS 3.3.1 and ITS 3.3.2 Discussion of Changes (DOCs). A revised markup of the associated CTS pages is also included with the M DOC showing where Footnotes (b) and (c) of ISTS Tables 3.3.1-1 and 3.3.2-1 are added to additional functional units in CTS Tables 4.3-1 and 4.3-2. A justification for deviation (JFD-7) is also added to ITS 3.3.2 that provides justification for not including the footnotes to the Auxiliary Feedwater - Bus Stripping ESFAS instrument Function (ITS 3.3.2-1, Function 6.d).

RAI-3

In ITS Subsections 3.3.4, 3.3.5, and 3.3.6, the licensee proposed to remove trip setpoint values from the current TS while retaining the current TS allowable values in the ITS. These changes are described in the removed detail discussions of change (designated as LA DOCs). Specifically, the changes and their justifications are in LA01 (ITS 3.3.4), LA02 (ITS 3.3.5), and LA02 (ITS 3.3.6). The details in all three LA DOCs are similar; however, there are references in the DOCs that are either not specific or appear inapplicable to these ITS subsections. For example, there are references to NRC-approved power uprate amendments that do not appear to affect the instrumentation Functions in ITS Subsections 3.3.4, 3.3.5, and 3.3.6. Also, references to Regulatory Guide 1.105 and industry standard ANSI/ISA-RP67.04 do not have revision numbers; this is vital as each revision has varying content. The licensee is requested to revise these DOCs to provide only relevant justification for removal of trip setpoint values and include revision numbers of the applicable regulatory guidance and industry standard documents to which it is committed in the current licensing basis for Turkey Point Units 3 and 4.

FPL Response:

FPL has revised the referenced Section 3.3 discussion of changes (DOCs), as necessary, to provide relevant justification for removal of trip setpoint values and include revision numbers of the applicable regulatory guidance and industry standard documents to which it is committed in the current licensing basis for PTN Units 3 and 4, where applicable. Additionally, the following responses provide additional clarification associated with the Section 3.3 DOC revisions.

ITS 3.3.4 LA01 response.

In ITS 3.3.4, the nominal trip setpoint proposed for relocation to a licensee-controlled document is Functional Unit 9.e, "Control Room Air Intake Radiation Level." The basis for the setpoint of this monitor is NRC 10 CFR 50, Appendix A, GDC 19, Control Room." GDC 19 requires that adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) total effective dose equivalent (TEDE), for the duration of the accident. ITS 3.3.4 DOC LA01 is revised as shown in Attachment 2.

ITS 3.3.5 LA02 Response

Two less restrictive removal of detail changes (ITS 3.3.5 DOCs LA01 and LA02) are related to moving the Loss of Power Emergency Diesel Generator Start instruments from CTS 3.3.2,"Engineered Safety Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Page 11 of 11

Features Actuation System Instrumentation," to ITS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation." DOC LA02 is associated with moving the Trip Setpoints and associated requirements to the Technical Requirements Manual (TRM) and DOC LA01 is associated with renaming the Nominal Trip Setpoints as Allowable Values for CTS 3.3.2 associated with Functional Unit 7.

Because the 480-volt undervoltage and degraded voltage LOP DG start functions do not specify explicit Allowable Values in CTS, FPL determined to retain the trip setpoints in ITS consistent with current licensing basis. ITS 3.3.5 DOC LA01 will be replaced with DOC A09 describing the elimination of the Allowable Value column and the associated # footnote stating that the trip setpoint is the allowable value for the identified Loss of Voltage and Degraded Voltage functional units (CTS Table 3.3-3 Functional Units 7.a, 7.b, and 7.c). ITS 3.3.5 DOC LA02 will be deleted because the 480-volt undervoltage and degraded voltage trip setpoints are being retained in ITS. ITS 3.3.5 DOC LA03 will be revised to DOC LA01.

See Attachment 2 for the revised CTS markups, DOCs, ISTS markups, JFDs, and ISTS Bases markups.

ITS 3.3.6 LA02 Response

FPL has revised ITS 3.3.6 DOC LA02 providing the requested change and information.

See Attachment 2 for revised ITS 3.3.6 DOC LA02.

References:

1. NRC Electronic Memorandum dated November 07, 2022, Turkey Point Nuclear Generating Unit Nos. 3 and 4, Request for Additional Information, Improved Technical Specifications Conversion, Docket No.

50-250 and 50-251

2. Florida Power & Light Company (FPL) Letter L-2021-158 dated September 22, 2021, License Amendment Request for the Technical Specifications Conversion to NUREG-1431 Revision 5 (ADAMS Accession No. ML21265A370)

Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Attachment 1 Page 1 of 4

Proposed Turkey Point Updated Final Safety Analysis Report (UFSAR) Section 7.2 Insert

(3 pages follow)

Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Attachment 1 Page 2 of 4

7.2.7 REACTOR TRIP SYSTEM (RTS) AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) SETPOINT METHODOLOGY

Westinghouse topical reports WCAP-17070, Revision 1, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Power Uprate to 2644 MWt - Core Power), (Reference 5) and WCAP-12745, Revisions 0 and 1, "Westinghouse Setpoint Methodology For Protection Systems Turkey Point Units 3 & 4," (Reference 6) provide the NRC approved methodologies used to calculate the RTS and ESFAS instrument nominal trip setpoint (NTSP) values, Allowable Values (AVs), and the as-found tolerance (AFT) and as-left tolerance (ALT) values.

The AFT is calculated by summing the instrument rack uncertainty terms; rack calibration accuracy (RCA), rack drift (RD), rack comparator setting accuracy (RCSA) (for analog instruments), and rack measurement and testing equipment (RMTE) uncertainty (for analog instruments). The ALT is calculated by summing the instrument rack uncertainty terms excluding rack draft. For digital systems, rack drift is assumed to be zero, therefore, the AFT and ALT are equivalent. This method of calculating the AFT and ALT is conservative since sensor uncertainties are not included in the AFT/ALT calculations.

Currently, a limiting trip setpoint (LTSP) is not calculated for the RTS and EFSAS instrument functions and the NTSP is considered the LTSP. Future adjustments to instrument calculations may be required as a result of instrument component changes. As a result, a less conservative LTSP may be established thereby allowing for additional instrument margin being available to maintain the trip setting at the existing NTSP. In this event, the NTSP may be more conservative than the LTSP. If an LTSP is established for an instrument, the AFT and ALT will be maintained around the more conservative NTSP. Table 7.2-4 provides a list of important RTS and ESFAS Functions, some of which are associated with variables on which a safety limit has been placed, and the setpoint methodology used.

The total channel uncertainty (Channel Statistical Allowance (CSA) plus instrument margin) methodology is specified in WCAP-12745 and WCAP-17070. Both methodologies calculate the CSA utilizing the square root sum of the squares (SRSS) methodology for combining uncertainty terms that are random and independent except where an interaction between two parameters exists. This methodology produces a resultant error value which has the same level of probability as the individual terms being combined. An arithmetic summation, which is more conservative, is used where an interaction between two parameters exists. A minimum level of random error probability of 95% is used for instrument error analysis. This 95% probability means that the error exhibited by a component or loop must be less than or equal to its established error at least 95% of the time. The 95% probability represents the deviation value from the mean which encompasses 95% of all measurement variations. Statistically, the 95% value can be shown to be +/-1.96 times standard deviation. For simplicity, a value equal to two times standard deviation (i.e. 2) is normally used.

WCAP-12745 continues to be an NRC approved methodology to determine the NTSP, AV, AFT, and ALT for instrument Function setpoints currently calculated using this setpoint methodology. However, since WCAP-17070 is a more contemporary methodology, revision of the instrument setpoints for any instrument Function listed in Table 7.2-4 must be revised utilizing the latest revision of this methodology.

Technical Specification Application of RTS and ESFAS Instrument Setpoints

Certain RTS and ESFAS instrument Functions contain footnotes in Technical Specification Tables 3.3.1-1 and 3.3.2-1 related to channel operational tests and channel calibrations. The following is a summary discussion related to application of Technical Specification Tables 3.3.1-1 and 3.3.2-1 Footnotes (b) and (c).

If an instrument trip setting is found within the ALT during a channel operational test or channel calibration, no further action is required for the instrument surveillance. If the instrument trip setting is found outside the ALT but within the AFT during a channel calibration, the instrument trip setting is reset to within the Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Attachment 1 Page 3 of 4

ALT, and no further action is required for the instrument surveillance. If the instrument trip setting is found outside the ALT but within the AFT during a channel operational test, the instrument trip setting must not be reset to within the ALT, and additional monitoring may be required to ensure the instrument does not exceed the AFT.

If the instrument trip setting is found outside the AFT but conservative with respect to the Allowable Value, the channel is Operable, but considered degraded. The degraded condition must be further evaluated during performance of the surveillance. This evaluation, as a minimum, consists of resetting the instrument trip setting to the NTSP (within the ALT) and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel is Operable and can be restored to service at the completion of the surveillance. Also, for channels determined to be Operable but degraded after returning the channel to service, the performance of these channels will be evaluated under the plant Corrective Action Program (CAP). Entry into the CAP will ensure required review and documentation of the condition.

If the instrument trip setting is found non-conservative to the Allowable Value, the channel is inoperable until the instrument setting is reset to the NTSP (within the ALT), and any evaluations necessary to return the channel to service are completed. The instrument setting may be more conservative than the NTSP provided the AFT and ALT are applied to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance.

Table 7.2-4 Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrument List of Methodologies Instrument Function Methodology Power Range Neutron Flux - High WCAP-17070 Power Range Neutron Flux - Low WCAP-12745 Intermediate Range Neutron Flux WCAP-12745 Source Range Neutron Flux WCAP-12745 Overtemperature T WCAP-17070 Overpower T WCAP-17070 Pressurizer Pressure - Low WCAP-12745 Pressurizer Pressure - High WCAP-12745 Pressurizer Water Level - High WCAP-12745 Reactor Coolant Flow - Low - Single WCAP-17070 Loop Reactor Coolant Flow - Low - Two WCAP-17070 Loop Steam Generator (SG) Water Level - WCAP-17070 Low Low Steam Generator (SG) Water Level - WCAP-17070 Low Steam Flow/Feedwater Flow Mismatch WCAP-17070 Undervoltage - 4.16 kV Buses A and B WCAP-12745 Underfrequency RCPs Breakers Open WCAP-12745 Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Attachment 1 Page 4 of 4

Table 7.2-4 Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrument List of Methodologies Instrument Function Methodology Turbine Trip - Emergency Trip Header WCAP-17070 Pressure Containment Pressure - High WCAP-12745 High Differential Pressure Between Steam Line Header and any Steam WCAP-12745 Generator Steam Line Flow - High WCAP-17070 Tavg - Low WCAP-12745 Steam Generator Pressure - Low WCAP-17070 Containment Pressure - High High WCAP-12745 SG Water Level - High High WCAP-17070

Turkey Point Nuclear Plant L-2022-181 Docket Nos 50-250 and 50-251 Attachment 2 Page 1 of 45

Turkey Point Improved Technical Specifications (ITS) Conversion License Amendment Request (LAR) Section 3.3 Marked-up Pages

(44 pages follow)

DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION

Applicability are entered, the SRs are performed in a timely manner. These changes are designated as more restrictive because additional requirements are being imposed that were not in the CTS.

Insert DOC M05 Note: DOC M04 was added in response to RAI MEH-008

~

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES

LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 2.2.1 requires the RTS instrumentation and interlock setpoints shown in Table 2.2-1 to be OPERABLE with the Trip Setpoints set consistent with the values shown in the Trip Setpoint column of Table 2.2-1. In addition, CTS 2.2.1 ACTIONs require that with an RTS Instrumentation or Interlock Setpoint less conservative than the value shown in the Trip Setpoint column of Table 2.2-1, verify the setpoint is more conservative than the value in the Allowable Value column and within the calibration tolerance. When the setpoint is less conservative than the Allowable Value, the setpoint is adjusted consistent with the Trip Setpoint value of Table 2.2-1 and determination is made within 12 hours that the affected channel is OPERABLE; or the channel is declared inoperable and the applicable ACTION statement requirements of CTS 3.3.1 applied. CTS Table 2.2-1 specifies both the Trip Setpoints and Allowable Values for the RTS Instrumentation Functional Units. ITS 3.3.1 requires the RTS instrumentation for each Function in Table 3.3.2-1 to be OPERABLE. ITS Table 3.3.1-1 specifies only the Allowable Values for the RPS Instrumentation Functions. The Allowable Values represent the OPERABILITY limit of the channels in ITS. This changes the CTS by moving the Trip Setpoints and the requirement to adjust the Trip Setpoints when necessary to the Technical Requirements Manual (TRM).

The purpose of the trip setpoint requirements is to ensure the plant is shutdown to protect against violating core design limits, breaching the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents. Pursuant to 10 CFR 50.36(c)(1)(ii)(A), if it is determined that an automatic protective device for a variable on which a safety limit has been placed (i.e., limiting safety system setting) does not function as required, appropriate action is taken to ensure the abnormal situation is corrected before a safety limit is exceeded, which may include shutting down the reactor. The PTN Instrument Setpoint Methodology calculates nominal trip setpoints (NTSPs) using methods consistent with the guidance provided in NRC Regulatory Guide (RG) 1. 105, "Setpoints for Safety Related Instrumentation," and ANSI/ISA Standard 67.04, "Setpoints for Nuclear Safety-Related Instrumentation." Additionally, pre-defined limits ( double-sided Operability (as-found) limits and as-left limits) are determined for each instrument consistent with the guidance provided in NRC RG 1.105 and ANSI/ISA-RP67.04, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation." The instrument Operability limit band in plant uncertainty calculations is synonymous with the as-found acceptance criteria band specified in ITS and is centered about the nominal equipment setting (clarified in

Turkey Point Unit 3 and Unit 4 Page 6 of 16 ITS 3.3.1 DOC M05 Insert

M05 CTS 2.2.1 Action a. states that with a Reactor Trip System Instrumentation or Interlock Setpoint less conservative than the value shown in the Trip Setpoint column but more conservative than the value shown in the Allowable Value column of Table 2.2-1, adjust the setpoint consistent with the Trip setpoint value within permissible calibration tolerance. CTS 2.2.1 Action b, states with the Reactor Trip System Instrumentation or Interlock Setpoint less conservative than the value shown in the Allowable Values column of Table 2.2-1, either: 1) Adjust the Setpoint consistent with the Trip Setpoint value of Table 2.2-1 and determine within 12 hours that the affected channel is OPERABLE; or 2) Declare the channel inoperable and apply the applicable ACTION statement requirement of Specification 3.3.1 until the channel is restored to OPERABLE status with its setpoint adjusted consistent with the Trip Setpoint value. ITS 3.3.1 ACTIONS do not contain these requirements. However, ITS Table 3.3.1-1 Footnote (b) states that if the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. ITS Table 3.3.1-1 Footnote (c) states that the instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual and UFSAR Section 7.2, respectively. CTS Table 4.3-1 Table Notations (a) and (b) are like the proposed footnotes but apply to only a few selected RTS instrument functions. This changes the CTS by adding requirements to additional RTS instruments which will require a specific location be identified where the methodology for determining the double-sided NTSP instrument tolerance bands are located. This also changes the CTS by adding to additional RTS instrument functions the requirement that the channel be evaluated and verified it is functioning as required when discovered outside the as-found tolerance before returning the channel to service instead of allowing 12 hours to determine the channel is Operable. This change is applied to the following RTS functions:

• Functional Unit 2.b, Power Range, Neutron Flux - Low (ITS Function 2.b),
• Functional Unit 3, Intermediate Range Neutron Flux (ITS Function 3),
• Functional Unit 4, Source Range Neutron Flux (ITS Function 4),
• Functional Unit 7, Pressurizer Pressure - Low (ITS Function 7),
• Functional Unit 8, Pressurizer Pressure - High (ITS Function 8),
• Functional Unit 9, Pressurizer Water Level - High (ITS Function 9),
• Functional Unit 13, Undervoltage - 4.16kV Busses A and B (ITS Function 13), and
• Functional Unit 14, Underfrequency - Trip of Reactor Coolant Pump Breaker(s)

Open (ITS Function 14).

The purpose of ITS Table 3.3.1-1 Footnotes (b) and (c) is to address a concern that the Technical Specification Surveillance Requirements for limiting safety system settings (LSSS) may not provide adequate assurance that instruments will actuate safety functions at the point assumed in the applicable safety analysis as identified in Regulatory Issue Summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels. The proposed change

Page 1 of 2 ITS 3.3.1 DOC M05 Insert

clarifies the Technical Specification requirements to ensure that automatic protective action will correct an abnormal situation before a safety limit is exceeded. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the evaluation is to ensure confidence in the channel performance prior to returning the channel to service. For channels with as-measured setpoints exceeding the as-found tolerance criteria requiring evaluation but allowed to be returned to service, the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. This change is considered a more restrictive change because additional requirements have been added to Surveillance Requirements for specific RTS instrument functions.

Page 2 of 2

DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION

This change is acceptable because the SRs remain unchanged. The ITS "Frequency" column reflects the current SRs in CTS Table 4.3-2 including Note (1) for what is required to be performed for these Functional Units. This change is designated as administrative because it does not result in technical changes to the CTS.

A07 CTS Table 4.3-2 includes a column designating the MODES that each Surveillance is required to be met. ITS Table 3.3.2-1 does not provide this specific column but includes this information in the Applicable MODES or other Specified Conditions column. This changes the CTS by combining the information in CTS Table 3.3-2, "Applicable Modes," and CTS Table 4.3-2 Modes for which Surveillance is Required," columns specifically stating when a Surveillance is required to be met into one table in ITS.

CTS 4.0. 1 states that SRs shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation (LCO), unless otherwise stated in the individual SR. ITS SR 3.0.1 states that SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. For these Functional Units the MODES for which the surveillance must be met from CTS Table 4.3-2 are the same as that in the "Applicable MODES" column from CTS Table 3.3-2 with any exceptions stated in the applicable SRs. This change is designated as administrative because it does not result in technical changes to the CTS.

A08 CTS Table 3.3-2, ACTION 21, states, in part, to take the ACTION required by Specification 3. 7.1. 5 when steam isolation channels are not restored within the designated Complete Time. This statement is unnecessary as LCO 3.0.6 (Safety Function Determination Program) provides the appropriate guidance and requirements relevant to inoperable Technical Specification support systems with respect to the potential impact on the associated Technical Specification supported system. This changes the CTS by removing this statement from CTS ACTION 21.

LCO 3.0.6 refers to Specification 5.5. 14, "Safety Function Determination Program (SFDP)." Specification 5.5.14 states, in part, that upon entry into LCO 3.0.6, an evaluation shall be made to determine if a loss of safety function exists. Additionally, other appropriate limitations and remedial or compensatory actions may be identified to be taken as a result of the support system inoperability and corresponding exception to entering supported system Condition and Required Actions. Therefore, the SFPD provides sufficient controls when a Technical Specification support system in inoperable. This change is designated as administrative because the SFPD will ensure appropriate supported system Conditions and Required Actions are entered when necessary.

Insert ITS 3.3.2 DOC A09

Turkey Point Unit 3 and Unit 4 Page 4 of 14 ITS 3.3.2 DOC A09 Insert

A09 CTS Table 3.3-3 includes two columns, Allowable Value and Trip Setpoint, for Functional Unit 6.d, "Auxiliary Feedwater - Bus Stripping." The value specified in these columns' states, "See Item 7. below for all Bus Stripping Allowable Values/Trip Setpoints," Item 7 below is the Loss of Power instruments. ITS states to see LCO 3.3.5, "LOP EDG Start Instrumentation," for Trip Setpoints. This changes the CTS by changing the direction provided to where the required setpoint values are located.

The purpose of CTS Table 3.3-3 is to provide the setpoint values for those instruments considered to be part of the Engineered Safety Features Actuation System (ESFAS). ITS moves this Function from the ESFAS instrumentation group to the Loss of Power (LOP) Emergency Diesel Generator (EDG) Start instrumentation group because the LOP DG start instrumentation is only required for the Engineered Safety Features (ESF) Systems to function in an accident if a loss of offsite power also occurs or the voltage degrades to point that prevents proper operation of ESF equipment. Therefore, no technical change is proposed, only changing the location reference where the setpoint information is located. This change is designated as administrative because it does not result in technical changes to the CTS. DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION

The purpose of CTS Table 4.3-2 "MODES for which Surveillance is required" column is to ensure that SRs are met during the MODES or other specified conditions where the Functional Unit is required to be OPERABLE, unless otherwise specified in the individual SRs. This change is acceptable because the MODES in which the Functional Units surveillance is required will match the MODES in which the Functional Unit is required to be OPERABLE. This change is designated as more restrictive because additional MODES of Applicability are applied to when Functional Unit 1.a (Safety Injection, Manual Initiation) surveillance is required.

Insert ITS 3.3.2 DOC M04 Note: DOC M03 was added in response to RAI MEH-008

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES

LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-2 has three columns stating various requirements for each function labeled, "TOTAL NO. OF CHANNELS," "CHANNELS TO TRIP," and "MINIMUM CHANNELS OPERABLE." ITS Table 3.3.2-1 does not retain the "TOTAL NO. OF CHANNELS" or "CHANNELS TO TRIP" columns. This changes the CTS by moving the information of the "TOTAL NO. OF CHANNELS" and "CHANNELS TO TRIP" columns to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS Table 3.3-2 Functional Unit 5.c, (Feedwater Isolation, Steam Generator Water Level -- High-High) contains a footnote (# # # #) that states, "Steam Generator overfill protection is not part of the Engineered Safety Features Actuation System (ESFAS), and is added to the Technical Specifications only in accordance with NRC Generic Letter 89 19." ITS Table 3.3.2-1 Function 5.b, (Feedwater Isolation, SG Water Level - High High (P-14)) does not provide this information. This changes the CTS by moving the details of required switch operation for actuation to the ITS Bases.

Turkey Point Unit 3 and Unit 4 Page 6 of 14 ITS 3.3.2 DOC M04 Insert

M04 CTS 3.3.2 Action a. states that with an ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Trip Setpoint column but more conservative than the value shown in the Allowable Value column of Table 3.3-3, adjust the setpoint consistent with the Trip setpoint value within permissible calibration tolerance. CTS 3.3.2 Action b, states with the ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Allowable Values column of Table 3.3-3, either: 1) Adjust the Setpoint consistent with the Trip Setpoint value of Table 3.3-3 and determine within 12 hours that the affected channel is OPERABLE; or 2)Declare the channel inoperable and apply the applicable ACTION statement requirement of Table 3.3-2 until the channel is restored to OPERABLE status with its setpoint adjusted consistent with the Trip Setpoint value. ITS 3.3.2 ACTIONS do not contain these requirements. However, ITS Table 3.3.2-1 Footnote (b) states that if the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service. ITS Table 3.3.2-1 Footnote (c) states that the instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in the Technical Requirements Manual and UFSAR Section 7.2, respectively. CTS Table 4.3-2 Table Notations (a) and (b) are like the proposed footnotes but apply to only a few selected ESFAS instrument functions. This changes the CTS by adding requirements to additional ESFAS instruments which will require a specific location be identified where the methodology for determining the double-sided NTSP instrument tolerance bands are located. This also changes the CTS by adding to additional ESFAS instrument functions the requirement that the channel be evaluated and verified it is functioning as required when discovered outside the as-found tolerance before returning the channel to service instead of allowing 12 hours to determine the channel is Operable. This change is applied to the following ESFAS functions:

• Functional Unit 1.c. Safety Injection Containment Pressure - High (ITS Function 1.c),
• Functional Unit 1.d, Safety Injection Pressurizer Pressure - Low (ITS Function 1.d),
• Functional Unit 1.e, High Differential Pressure Between the Steam Line Header and any Steam Line (ITS Function 1.e),
• Functional Unit 1.f, Tavg - Low (coincident with Steam Line Flow - High) (ITS Function 1.f),
• Functional Unit 2.b, Containment Spray Containment Pressure High-High Coincident with Containment Pressure - High (ITS Function 2.b),
• Functional Unit 3.b.3), Containment Isolation Phase B Containment Pressure High-High Coincident with Containment Pressure - High (ITS Function 3.b.(3)),
• Functional Unit 4.c, Steam Line Isolation Containment Pressure High-High Coincident with Containment Pressure -High (ITS Function 4.c),
• Functional Unit 4.d, Tavg - Low (coincident with Steam LineFlow - High) (ITS Function 4.d),

Page 1 of 2 ITS 3.3.2 DOC M04 Insert

The purpose of ITS Table 3.3.2-1 Footnotes (b) and (c) is to address a concern that the Technical Specification Surveillance Requirements for limiting safety system settings (LSSS) may not provide adequate assurance that instruments will actuate safety functions at the point assumed in the applicable safety analysis as identified in Regulatory Issue Summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels. The proposed change clarifies the Technical Specification requirements to ensure that automatic protective action will correct an abnormal situation before a safety limit is exceeded. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the evaluation is to ensure confidence in the channel performance prior to returning the channel to service. For channels with as-measured setpoints exceeding the as-found tolerance criteria requiring evaluation but allowed to be returned to service, the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. This change is considered a more restrictive change because additional requirements have been added to Surveillance Requirements for specific EFSAS instrument functions.

Page 2 of 2 CTS ESFAS Instrumentation 3.3.2

Table 3.3.2-1 (page 9 of 11) Engineered Safety Feature Actuation System Instrumentation

APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE

6. Auxiliary Feedwater

6.b. i -~ G Water Level - 1,2,3 f3} per SG SR 3.3.2. Trip SetpointsSetpoints Low Low SR 3.3.2. SR 3.3.2. 7 SR 3.3.2.

6.c.

6.d. 7 0

f:. Undervoltage f3l per bus l SR 3.3.2.7 ?!; f6Qj% bus f70j% bus Reastor Coolant SR 3.3.2.Q~ \\IGltage \\IGltage P-Ymp SR 3.3.2A0

6.e. ~ rip of all Main 1,2 Cr J t SR 3.3.2.~ 0 Feedw ~ter !breakers) SR 3.3.2.Qtl$l ~ H-psig Pumps ~ SR 3.3.2.10 0

h, Auxiliary f2} SR 3.3.2.1 ::. f20.a3j fpsiaj f l fpsiaj Feedwater Pump SR 3.3.2.7 Sustion Transfer SR 3.3.2.Q~ on Sustion Pressure Low

1-, Automatic Switcho,.*er to Containment Sump

a,. Automatic 2-tfa+As G SR 3.3.2.2 Astuation Logic SR 3.3.2.4 and Astuation SR 3.3.2.6 Relays

Action b. 1, (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to Table 4.3-2 Note (al verify that it is functioning as required before returning the channel to service.

Action a, The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Table 4.3-2 ( c) Note (b) Setpoint (NTSP) at the completion of the surveillance ; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in * * * }0 reference or the name of any document incorporated into t~h_e_fa_ c_ il_it~y _F_S_/1._R_ b~~~* r_ e_fe_ r_e_nc_ e~j. ~----------~ _ the Technical Requirements Manual and UFSAR Section 7.2, respective! REVIEVIJER'S NOTE } Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by 0 the unit.

\\IVestinghous etS7_T_u_rk-ey-Po-i-nt_U_n-it_3_a-nd_U_n-it-4~] 3.3.2-19 ~----~ RM STS.a Amendment Nos. XXX and YYY 1.----..J 0 JUSTIFICATION FOR DEVIATIONS ITS 3.3.2, ENGINEERED SAFETY FEATURES ACTUATION SYSTEM (ESFAS) INSTRUMENTATION

1. The Improved Standard Technical Specifications (ISTS) contain bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. Where an addition/deletion has occurred, subsequent alpha-numeric designators have been changed for any applicable affected ACTIONS, SURVEILLANCE REQUIREMENTS, FUNCTIONS, and Footnotes.

4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

5. The Nominal Trip Setpoints (NTSPs) are located in the Technical Requirements Manual as stated in Footnote (c).

Insert JFD 7

Turkey Point Unit 3 and Unit 4 Page 1 of 1 Insert JFD 7

7. The ESFAS Auxiliary Feedwater (AFW) Loss of Offsite Power start function (ISTS Table 3.3.2-1, Function 6.e) includes Footnotes (b) and (c) associated with SR 3.3.2.9 (CHANNEL CALIBRATION). ITS Table 3.3.2-1, Function 6.d, "Auxiliary Feedwater - Bus Stripping," does not include these footnotes to the CHANNEL CALIBRATION (ITS SR 3.3.2.6). These footnotes are included in the ISTS to address the concern identified in Regulatory Issue Summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels, when relocating trip setpoints as part of TSTF-493, Option A. The CTS does not provide an Allowable Value for the 480 V loss of voltage and degraded voltage instruments, which provide the bus stripping function for the AFW start. The trip setpoint for the 480 V loss of voltage and degraded voltage instrument functions represents the Operability value and does not contain an as-found and as-left tolerance. Therefore, the trip setpoints are being retained in the ITS for these functions. When the voltage is discovered outside the trip setpoint limit defined in ITS, the instrument is declared inoperable and appropriate action is taken in accordance with ITS 3.3.2 and 3.3.5, Loss of Power (LOP) Emergency Diesel Generator (EDG) Start Instrumentation. In addition, the AFW start on bus stripping is not assumed as a primary start signal in a design basis accident or transient. The AFW start on low steam generator level, main feedwater pump trip, and safety injection ensure safety analysis limits are not exceeded. In addition, the 480 V undervoltage and degraded voltage instrument functions are not specifically used in the PTN safety analysis as noted in Table 3-23 of WCAP-12745, Westinghouse Setpoint Methodology for Protection Systems - Turkey Point Units 3 & 4, Revision 0. Based on the information provided herein, the footnotes are unnecessary to ensure action is taken and, therefore, are not included in the ITS for the ESFAS Auxiliary Feedwater - Bus Stripping instrument function.

DISCUSSION OF CHANGES ITS 3.3.4, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) INSTRUMENTATION

channel be evaluated to verify that it is functioning as required before the channel is returned to service. This changes the CTS by requiring the channel to be verified OPERABLE prior to placing the channel back in service.

The purpose of the Required Actions when the channel is found to be outside the allowable value is to make the proper adjustments to place the channel back within the allowable value. The proposed change requires the channel to be evaluated to be OPERABLE prior to placing the channel back in service versus placing the channel back in service and then evaluating the channel is OPERABLE within 12 hours. This change is acceptable because the purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. This change is classified as More Restrictive because more stringent Required Actions are being incorporated.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES

LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.3.3 requires the CRE:VS instrumentation to be Insert ITS 3.3.4 DOC LA01 OPERABLE: with their Trip Setpoints set consistent with the values shown in the Trip Setpoint column. l=lowever, CTS ACTIONs require that with Instrumentation Setpoint less conservafr,e than the value shown in the Trip Setpoint column, the setpoint is verified to be more conservative than the *,alue in the Allowable Value column and within the calibration tolerance. VVhen the setpoint is less conservati v e than the Allowable Value, the setpoint is adjusted consistent with the Trip Setpoint value of Table 3.3 3 and determined 1Nithin 12 hours that the affected channel is OPERABLE:; or the channel is declared inoperable and the applicable ACTION statement requirements of Table 3.3 1 applied. GTS 3.3.2 specifies both the Trip Setpoints and Allo1Nable Values for the Engineered Safety Features Actuation System (E:SFAS) Instrumentation Functional Units. ITS 3.3. 4 requires the CRE:VS instrumentation for each Function in Table 3.3.4 1 to be OPERABLE ITS Table 3.3.4 1 specifies only the Allowable Values for the E:SFAS Instrumentation Functions. The Allowable Values represent the OPERABILITY limit of the channels in ITS. This changes the CTS by mo 1, ing the Trip Setpoints to the Technical Requirements Manual (TRM).

The purpose of actuation setpoints is to ensure the mitigation of and minimi2:e the consequences of accidents. The PTN Instrument Setpoint Methodology calculates nominal trip setpoints (NTSPs) using methods consistent with the

Turkey Point Unit 3 and Unit 4 Page 3 of 7 DISCUSSION OF CHANGES ITS 3.3.4, CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) INSTRUMENTATION

guidance provided in NRG Regu latory Guide (RG) 1. 106, " Setpoints for Safety Re lated Instrumentation," and ANS I/ ISA Standard 67.04, " Setpoints for Nuc lear Safety Re lated Instrumentation." Additionally, pre defined limits (doub le sided Operabi lity (as found) limits and as left limits) are determined for eaol:I instrument consistent *.vitl:I tl:le guidance provided in NRG RG 1. 106 and ANS I/ I SA RP67.04,

" Metl:lodologies for tl:le Determination of Setpoints for Nuc lear Safety Re lated Instrumentation." Tl:le instrument Operabi lity limit band in p lant uncertainty oa lou lations is synonymous witl:I tl:le as found aooeptanoe criteria band specified in ITS and is centered about tl:le nomina l eeiuipment setting (c larified in oa lou lations as tl:le NTSP). Tl:le PTN Instrument Setpoint Metl:lodologies, inc luding tl:le metl:lod of determining instrument uncertainties, were revie1.ved by tl:le NRG during tl:le re*1iew of tl:le power uprate to 2300 M1.'A (NRG ADAMS Accession Nos. ML013390234) and tl:le E)Etended Po 1Ner Uprate (EPU) (NRG ADAMS Accession Nos. ML11293A366). In tl:le NRG staff's approva l of tl:le 2300 M1t*A power uprate amendment tl:le NRG staff tl:le staff determined tl:lat tl:le proposed setpoint ol:langes were acceptab le because tl:le staff l:lad previous ly re*1iewed and appro *,1ed tl:le setpoint metl:lodology used to determine tl:le setpoint (VVCAP 1274 6). I n tl:le NRG staff's approva l of tl:le PTN EPU amendment tl:le NRG staff determined tl:lat tl:le PTN setpoint metl:lodolo gy ('AfGAP 17070) was acceptab le for tl:lis license amendment because tl:le setpoint oa lou lation provide adeeiuate safety mar g ins between tl:le Allowab le Va lue (NI) and A llowab le Limit (AL), as well as adeeiuate safety margin between tl:le NTSP and AL.

Tl:le remova l of tl:lese details for meetin g Teol:lnioa l Specification reeiuirements from tl:le Teol:lnioa l Specifications is acceptab le because tl:lis type of information is not necessary to be inc luded in tl:le Teol:lnioa l Specifications to pro*1ide adeeiuate protection of pub lic l:lealtl:I and safety. Tl:le ITS retains tl:le AV associated witl:I tl:le ESFAS Instrumentation, wl:liol:I are designated as tl:le Operabi lity limits for tl:le reeiuired instrument Functions. Footnotes (b) and (o) in Tab le 3.3.4 1 ensure ol:lanne l performance continues to *1erify tl:lat tl:le ol:lanne l will bel:lave in aooordanoe witl:I safety ana lysis assumptions and tl:le ol:lanne l performance assumptions in tl:le setpoint metl:lodolo gy consistent witl:I tl:le NRG guidance specified in R I S 2006 17. A lso, tl:lis ol:lange is acceptab le because tl:lese types of procedura l details will be adeeiuate ly controlled in tl:le Teol:lnioa l Reeiuirements Manua l (TRM). Any ol:lan ges to tl:le TRM are made under 10 GF R 60.6 9, wl:liol:I ensures ol:lan g es are pro perly eva luate d. Tl:lis ol:lan ge is desig nated as a less restrictive remo*,a l of deta il ol:lan g e because procedura l details for meetin g Teol:lnioa l Specification reeiuirements are bein g removed from tl:le Teol:lnioa l Specifications.

LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.3-2, ACTION 248, Part 2.a, requires the CREVS to immediately be placed in the recirculation mode "with ONE Control Room emergency recirculating fan operating." ITS 3.3.4, Required Action 8.1. 1, does not contain this level of detail. This changes the CTS by relocating this detail to the Technical Specification Bases.

The removal of this detail for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not

Turkey Point Unit 3 and Unit 4 Page 4 of 7 ITS 3.3.4 DOC LA01 Insert

CTS 3.3.2 requires the CREVS instrumentation (Functional Unit 9) to be OPERABLE with Trip Setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-3. CTS 3.3.2 Action a requires that with Instrumentation Setpoint less conservative than the value shown in the Trip Setpoint column but more conservative than the value shown in the Allowable Value column, adjust the Setpoint consistent with the Trip Setpoint value within the permissible calibration tolerance. When the setpoint is less conservative than the Allowable Value, the setpoint is adjusted consistent with the Trip Setpoint value of Table 3.3-3 and determined within 12 hours that the affected channel is OPERABLE; or the channel is declared inoperable and the applicable ACTION statement requirements of Table 3.3-2 applied. CTS 3.3.2 specifies both the Trip Setpoints and Allowable Values for the Engineered Safety Features Actuation System (ESFAS) Instrumentation Functional Units and includes Functional Unit 9.e, Air Intake Radiation Level. ITS 3.3.4 requires the CREVS instrumentation for each Function in Table 3.3.4-1 to be OPERABLE and specifies the Allowable Value for ESFAS Instrumentation Function 1, Air Intake Radiation Level. The Allowable Value (AV) represents the Operability limit of the channels in ITS. This changes the CTS by moving the Trip Setpoints to the Technical Requirements Manual (TRM).

The purpose of the Control Room Air Intake Radiation Monitor is to isolate the control room from unfiltered outside atmosphere and start the Control Room Emergency Ventilation System. The removal of these details for performing surveillance requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the AV associated with the instrumentation, which is designated as the Operability limit for the required instrument Functions.

The CREVS air intake radiation monitor actuation setpoint is determined in accordance with 10 CFR 50, Appendix A, General Design Criteria (GDC) 19, Control room. At PTN, in MODES 1, 2, 3, and 4, the radiation monitor actuation of the CREVS is a backup for the safety injection (SI) actuation signal. However, if a rod ejection accident does not result in an SI actuation, the radiation monitor actuates CREVS to ensure control room habitability. The radiation monitor actuation of the CREVS in MODES 5 and 6, and during movement of irradiated fuel assemblies in containment is the primary means to ensure control room habitability in the event of a fuel handling accident.A fuel handling accident occurring in the spent fuel pit area is mitigated bymanually placing CREVS in the emergency radiation protection mode of operation within 30 minutes; therefore, radiation monitor actuation is not credited for a fuel handling accident in the spent fuel pit area.

GDC 19 requires that adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) total

Page 1 of 2 ITS 3.3.4 DOC LA01 Insert

effective dose equivalent (TEDE), for the duration of the accident. Assuming accident conditions last for 31 days, the resulting dose rate necessary to reach 5 rem TEDE would be 6.7 millirem per hour (mr/hr)., or conservatively a continuous dose rate of 6.0 mr/hr for the duration of the accident. The setpoint calculation performed for the control room air intake radiation monitor uses this limiting value of 6.0 mr/hr. An initial margin of 1.0 mr/hr from the limit was used in the setpoint determination providing ananalytical limit of 5.0 mr/hr. Using the square root sum-of-the-squares setpoint determination method of WCAP-12201, Bases Document for Westinghouse Setpoint Methodology for Protection Systems, Turkey Point Units 3 & 4, Revision 1, with applicable errors, the channel statistical allowance (CSA) was determined to be 1.10 mr/hr resulting in a calculated trip setpoint of 3.9 mr/hr. Additional margin of 1.9 mr/hr was added resulting in a trip setpoint of 2.0 mr/hr. The AV was determined using the rack calibration accuracy, rack maintenance and test equipment error and rack drift error of 0.83 mr/hr resulting in an AV of 2.83 mr/hr.

This change is acceptable because the AV retained in ITS is bounded by the calculated limiting setpoint of 3.9 mr/hr and, therefore, continues to provide adequate protection to prevent control room occupants from receiving a dose in excess of regulatory requirements and preserves the margin to GDC-19 control room dose limit. Additionally, the trip setpoint value proposed for relocation will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because an instrument trip setpoint being removed from the Technical Specifications

Page 2 of 2 ITS ITS 3.3.5 8 with their Trip Setpoints INSTRUMENTATION set consistent with the values shown in the 3/4.3.2 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION Trip Setpoint column

LCO 3.3.5

~-----, for each EDG required by LCO 3.8.1, "AC Sources - Operating." A08 Applicability APPLICABILITY : As shewn in Table 3.3 2,. ~-----~ ~

Y MODES 1, 2, 3, and 4 1---------~---~-----\\J AC ~ ION : / [ Add proposed ACTIONS Note ) B

a. With an ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Trip Setpoint column but more conservative than the value shown in the Allowable Value column of Table 3.3-3, adjust the Setpoint consistent with the Trip Setpoint value within } - permissible calibration tolerance. ( see ITS 3.3.2 b. With an ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Allowable Value column of Table 3.3-3, either:

1. Adjust the Setpoint consistent with the Trip Setpoint value of Table 3.3-3 and determine within 12 hours that the affected channel is OPERABLE ; or

2. Declare the channel inoperable and apply the applicable ACTION statement requirements of Table 3.3-2 until the channel is restored to OPERABLE status with its setpoint adjusted consistent with the Trip Setpoint value.

ACTION A C. With an ESFAS instrumentation channel or interlock inoperable, take the ACTION shown in Table 3.3-2.

------------ NOTE------------ 8 Refer to Table 3.3.5-1 to determine which SRs apply for each LOP EDG Start Function.

SURVEILLANCE REQUIREMENTS I

SR 3.3.5.1 4.3.2. 1 Each ESFAS instrumentation channel and interlock and the automatic actuation logic and relays shall be SR 3.3.5.2 demonstrated OPERABLE by performance of the ESFAS Instrumentation Surveillance Requirements specified in SR 3.3.5.3 Table 4.3-2.

TURKEY POINT - UNITS 3 & 4 3/4.3-13 AMENDMENT NOS. 176 AND 170 Page 1 of 10

DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) EMERGENCY DIESEL GENERA TOR (EDG) START INSTRUMENTATION

of relaying being inoperable on a given bus. In addition, the ITS term "bypassed" is being retained in lieu of the CTS phrase "out of service" with respect to the removal of a channel from operation.

When both channels on a given bus are inoperable, ITS 3.3.5, Required Action 8.1, requires restoring one channel within 1 hour. The 1-hour Completion Time is appropriate because the inadvertent loss of both channels on a given bus could be indicative of a common mode failure. However, when channels are intentionally removed from service for testing, the CTS 8-hour allowance is appropriate since no common mode failure is presented. Although there is no "bypass" circuit associated with the protective relays, adopting the "bypassed" term is acceptable since this term can be defined as circumvent, which in this case would mean removing the relay from service (such that testing can be performed without the risk of an inadvertent actuation). The ITS Bases will contain clarity in this respect. This change is designated as administrative because it does not result in technical changes to the CTS.

A08 CTS Table 3.3-2 and ITS 3.3.5 require the EOG LOP functions to be OPERABLE in MODES 1, 2, 3, and 4. Because the ITS separates the EOG LOP functions for the ESFAS requirements of ITS 3.3.2, the CTS LCO is modified to clearly state that the OPERABILITY of the LOP functions are directly associated with the EOG start requirements of LCO 3.8.1, "AC Sources - Operating." This changes the CTS by providing clarification with respect to EOG LOP OPERABILITY requirements.

ITS 3.3.5 governs the LOP relaying requirements to ensure the automatic start of a respective EOG in LOP events. However, the ITS EOG LOP Applicability of MODES 1, 2, 3, and 4 could mislead the user in assuming the EOG LOP functions are required to be OPERABLE even when the respective EOG is inoperable. Therefore, the LCO is modified to clearly state that these functions are required to be OPERABLE when the associated EOG is required to be OPERABLE in accordance with LCO 3.8. 1. Because the EOG requirements of ITS 3.8.1 are Applicable in the same operating modes (MODES 1, 2, 3, and 4) as ITS 3.3.5, the addition of the subject clarifying statement does not result in a change to any Technical Specification requirements. Therefore, this change is designated as administrative because it does not result in technical changes to the CTS.

Insert ITS 3.3.5 DOC A09

MORE RESTRICTIVE CHANGES

None

RELOCATED SPECIFICATIONS

None

Turkey Point Unit 3 and Unit 4 Page 3 of 8 ITS 3.3.5 DOC A09 Insert

A09 CTS 3.3.2 requires that the Engineered Safety Features Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-2 be OPERABLE with their Trip Setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-3. Included in CTS Tables 3.3-2 and 3.3-3 are three instrument groups associated with Function 7, "Loss of Power:" Function 7.a, 4.16 kV Busses A and B (Loss of Voltage); Function 7.b, 480 V Load Centers 3A, 3B, 3C, 3D and 4A, 4B, 4C, 4D Undervoltage; Function 7.c, 480 V Load Centers 3A, 3B, 3C, 3D and 4A, 4B, 4C, 4D Degraded Voltage. In addition, CTS Table 3.3-3, Functions 7.a, 7.b, and 7.c, Allowable Value column includes footnote # that states, "If no Allowable Value is specified, as indicated by [ ], the trip setpoint shall also be the allowable value." The Allowable Value for CTS Table 3.3-3, Function 7.a is listed as N.A. The Allowable Value for CTS Table 3.3-3, Functions 7.b and 7.c contain [ ]. ITS LCO 3.3.5 requires two channels per bus of the LOP EDG start instrumentation for each Function in Table 3.3.5-1 to be OPERABLE. ITS Table 3.3.5-1 lists the Functions associated with CTS Table 3.3-3 Functions 7.a, 7.b, and 7.c, as Functions 1, 2, and 3, respectively, with the column designated as Trip Setpoint. This changes the CTS by designating only a Trip Setpoint column for the LOP EDG Start Functions; Function 1, Loss of Voltage; Function 2, Undervoltage; and Function 3, Degraded Voltage, eliminating the Allowable Value column and the # footnote.

The purpose of Function 7 in CTS Tables 3.3-2 and 3.3-3 is to automatically isolate the associated train safety buses from the offsite power and start the associated EDG and reenergize the buses from the onsite EDGs when either; a loss of offsite power (4.16 kV loss of voltage), a 480 V load center undervoltage (coincident with safety injection signal), or a degraded voltage condition occurs. The trip setpoint range provides the minimum and maximum voltage and time delays necessary to ensure the EDGs start on a loss of offsite power and isolate the safety buses on a safety injection signal concurrent with an undervoltage or degraded voltage condition to ensure the LOP DG start instrumentation, in conjunction with the engineered safety feature (ESF) systems powered from the EDGs, provide unit protection in the event of any of the analyzed accidents in which a loss of offsite power is assumed. Note that the 480 V undervoltage and degraded voltage instrument functions are not specifically used in the PTN safety analysis as noted in Table 3-23 of WCAP-12745, Westinghouse Setpoint Methodology for Protection Systems - Turkey Point Units 3 & 4, Revision 0.

Since the Allowable Value and Trip Setpoint are equivalent for the 480 V load center undervoltage and degraded voltage Functions, as stated in the # footnote in CTS Table 3.3-3, specifying both an Allowable Value and Trip Setpoint is redundant and unnecessary. The Trip Setpoint value represents the Operability value for these instrument functions and when exceeded will result in CTS 3.3.2 (ITS LCO 3.3.5) not met requiring action in accordance with CTS 3.0.2 (ITS LCO 3.0.2). Because the Allowable Value and Trip Setpoint values are equivalent for the LOP EDG start instrumentation, when an instrument channel is less conservative than the Trip Setpoint, it is also less conservative than the Allowable Value. Therefore, in this condition, the instrument channel is declared inoperable. As a result, CTS 3.3.2 Action b.2 would apply requiring the application of Action 18 of CTS Table 3.3-2 until the channel is restored to OPERABLE status with its setpoint adjusted consistent with the Trip Setpoint value. Deletion of the Allowable Value Setpoint column eliminates a redundant column without providing any technical change and is therefore acceptable. This change

Page 1 of 2 ITS 3.3.5 DOC A09 Insert

represents a presentation change and is designated as administrative because it does not result in technical changes to the CTS.

Page 2 of 2 DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) EMERGENCY DIESEL GENERA TOR (EDG) START INSTRUMENTATION

REMOVED DETAIL CHANGES

(Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.3.2. 1 requires the ESFAS instrumentation and interlosl<s setpoints to be set sonsistent with the Trip Setpoint va lues shoi.*m in Tab le 3.3 3. CTS 3.3.2. 1 Astion a is required to be entered when the setpoint is less sonservative than the A llo*.vab le Va lue. The shannel is to be deslared inoperab le unti l adjusted sonsistent *.vith the Trip Setpoint va lue. CTS Tab le a.a a spesifies the Trip Setpoints and /\\llowab le Va lues for the E SFAS Instrumentation Funstions. ITS a.a.a requires the LOP EOG Start Instrumentation Funstions to be OPERABLE ITS SR a.a.a.a spesifies the Allowab le Va lues for the LOP EOG Start I nstrumentation Funstions. This shanges the CTS by movin g the Trip Setpoints and assosiated requirements to the Teshnisa l Requirements Manua l (TRM).

The remova l of these details for meeting Teshnisa l Spesifisation requirements from the Teshnisa l Spesifisations is asseptab le besause this type of information is not nesessary to be insluded in the Teshnisa l Spesifisations to provide adequate protestion of pub lis hea lth and safety. The ITS still retains the A llowab le Va lues assosiated with the LOP E OG Start Instrumentation. A lso, this shange is asseptab le besause these types of prosedura l details will be adequate ly sontrolled in the TRM. Any shanges to the TRM are made under 10 CFR a0.a9, *.vhish ensures shanges are proper ly eva luated. This shange is desig nated as a less restristive remova l of detail shan g e besause prosedura l details for meetin g Teshnisa l Spesifisation requirements are being removed from the Teshnisa l Spesifisations.

(Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CT S 3.3.2 req uires the E n g ineered S afety Feature Astuation System (ESFAS) instrumentation shanne ls and interlos l<s sho 1.vn in Tab le 3.3 2 to be OPERABLE with their Trip Setpoints set sonsistent with the va lues shown in the Trip Setpoint so lumn of Tab le 3.3 3. l=lowever, CTS 3.3.2 ACT IOP.~ on ly requires a determination of OPERAB I LITY with an ESFAS Instrumentation or lnterlosl< Trip Setpoint less sonservative than the va lue shown in the Allowab le Va lue so lumn of Tab le 3.3 3. \\AA,en the setpoint is less sonservatii,e than the A llowab le Va lue, the setpoint is adjusted sonsistent with the Trip Setpoint va lue of Tab le a.a a and determine within 12 hours that the affested shanne l is OPERABLE; or the shanne l is deslared inoperab le and the app lisab le ACT ION statement requirements of Tab le 3.3 2 app lied. CTS Tab le a.a a spesifies both the Trip Setpoints and Allowab le Va lues for the ESFAS I nstrumentation Funstiona l Units. In addition, for Funstiona l Unit 7, Tab le a.a 3 Note# states that if no A llowab le Va lue is spesified, as indisated by [ ], the trip setpoint sha ll a lso be the a llowab le 1, 1a lue. ITS 3.3.e requires the LOP EOG Start instrumentation for cash Funstion in Tab le a.a.a 1 to be OPERABLE ITS Tab le 3.3.e 1 spesifies on ly the Allowab le Va lues for the ESFAS Instrumentation Funstions. The A llowab le Va lues represent the OPERAB I LITY limit of the shanne ls in IT S. T h is shanges th e CTS b y renamin g the Funstiona l Unit 7 Nomina l Trip Setpoints as A llowab le Va lues and by movin g the Trip Setpoints to the Teshnisa l Requirements Manua l (TR M ).

Turkey Point Unit 3 and Unit 4 Page 4 of 8 DISCUSSION OF CHANGES ITS 3.3.5, LOSS OF POWER (LOP) EMERGENCY DIESEL GENERA TOR (EDG) START INSTRUMENTATION

The purpose of actuation setpoints is to ensure the mitigation of and minimi:z:e the oonsequenoes of aooidents. The PTN Instrument Setpoint Methodology oaloulates nominal trip setpoints (NTSPs) using methods consistent 'Nith the guidance pro *;ided in NRG Regulatory Guide (RG) 1. 1 Oe, " Setpoints for Safety Related Instrumentation," and /\\NSl.tlS/\\ Standard 67.04, " Setpoints for Nuclear Safety Related Instrumentation." / \\dditionally, pre defined limits (douele sided Operaeility (as found) limits and as left limits) are determined for cash instrument consistent with the guidance pro *;ided in NRG RG 1. 1 Oe and /\\NSl.tlS/\\ RP67.04,

" Methodologies for the Determination of Setpoints for Nuclear Safety Related Instrumentation." The instrument Operaeility limit sand in plant uncertainty oaloulations is synonymous with the as found aooeptanoe criteria sand specified in ITS and is oentered aeout the nominal equipment setting (clarified in oaloulations as the NTSP). The PTN Instrument Setpoint Methodologies,

including the method of determining instrument uncertainties, were re¥ie1Ned ey the NRG during the re¥iew of the power uprate to 2300 M*.v:t (NRG /\\DAMS

/\\ooession Nos. ML013390234) and the Ex-tended Po 1Ner Uprate (EPU) (NRG
/\\DAMS /\\ooession Nos. ML11203/\\365). In the NRG staff's appro¥al of the 2300 M1.v:t power uprate amendment the NRG staff the staff determined that the proposed setpoint changes were aooeptaele eeoause the staff had pre¥iously

1 re¥ieNed and appro ¥ed the setpoint methodology used to determine the setpoint (\\AJC/\\P 12745). In the NRG staff's appro ¥al of the PTN EPU amendment the NRG staff determined that the PTN setpoint methodology (\\AJC/\\P 17070) was aooeptaele for this license amendment eeoause the setpoint oaloulation proYide adequate safety margins eetween the /\\llo*Naele Value (N/) and /\\llowaele Limit (.'\\L), as well as adequate safety margin eet\\veen the ~ffSP and.'\\L.

The remoYal of these details for meeting Teohnioal Speoifioation requirements from the Teohnioal Speoifioations is aooeptaele eeoause this type of information is not necessary to ee included in the Teohnioal Speoifioations to pro 1;ide adequate protection of puelio health and safety. The ITS retains the.'\\llowaele Values associated 'Nith the ESF/\\S Instrumentation, whioh are designated as the Operaeility limits for the required instrument Functions. Footnotes (a) and (13) in Tasia 3.3.2 1 ensure channel performance continues to Yerify that the channel will eehaYe in aooordanoe with safety analysis assumptions and the channel performance assumptions in the setpoint methodology consistent with the ~~RC guidance specified in RIS 2006 17..'\\lso, this change is aooeptaele eeoause these types of procedural details will ee adequately controlled in the TRM. Any changes to the TRM are made under 10 GFR 50.50, whioh ensures changes are properly e*;aluated. This change is designated as a less restriotiYe remoYal of detail change eeoause procedural details for meeting Teohnioal Speoifioation requirements are acing remoYed from the Teohnioal Speoifioations. LA01 ~ (Type 1 - Removing Details of System Design and System Description, Including Design Limits) ITS 3.3.5 Table 3.3.5-1, in part, lists the required undervoltage and degraded voltage tests for the 480 V load centers, which are to include a configuration coincident with the EDG breaker open. CTS 3.3.2 Table 4.3-2 does not include this configuration. This changes the CTS by moving the EDG breaker open detail to the Technical Specification Bases.

Turkey Point Unit 3 and Unit 4 Page 5 of 8

~

LOP 00 Start Instrumentation 3.3.5

SURVEILLANCE REQUIREMENTS continued

SURVEILLANCE FREQUENCY

Table 4.3-2 SR 3.3.5.2 Perform TADOT. [ [31] days

GR

In accordance with the Surveillance Frequency Control Program ] 0

Table 4.3-2 SR 3.3.5.3 Perform CHANNEL CALIBRATION with [Nominal [ [18] months Trip Setpoint and Allowable Value] as follows: GR

a. [ Loss of voltage Allowable Value > [2912] V and

< [ ] V with a time delay of [OJ~]* [ ] second. In accordance with the Loss of voltage Nominal Trip Setpoint [2975] V Surveillance

11.'ith a time delay of [0. 8] :t [ ] second. ] Frequency Control Program ] b. [ Degraded voltage Allo\\*1able Value > [3683] V 5 and < [ ] V with a time delay of [20] :t [ ] seconds.

Degraded voltage Nominal Trip Setpoint [3746] V 1Nith a time delay of [20] :t [ ] seconds. 1

+-4--------------------< [ INSERT 1 I 0

VVestinghouse ~ TS T-ur-ke_y_P-oin_t_U-nit_3_a-nd_U_n-it 4~] ~-------; Rev.t5.0 3.3.5-3 I Amendment Nos. XXX and YYY J----.J 0 0 INSERT 1

Tables Table 3.3.5-1 (page 1 of 1) 3.3-2, Loss of Power (LOP) Emergency Diesel Generator (EOG) Start Instrumentation 3.3-3, and 4.3-2

FUNCTION SURVEILLANCE REQUIREMENTS

1. 4. 16 kV Buses A and B TRIP SETPOINT 7.a ( Loss of Voltage)

a. Bus Undervoltage SR 3. 3.5.2 NA SR 3. 3.5.3

2. 480 V Load Centers (Undervoltage)

a. Bus Undervoltage SR 3. 3.5. 1 SR 3. 3.5.2

1) Load centers 3A and 4D SR 3. 3.5.3.:: 427 V and ::. 433 V 7.b

2) Load center 38.:: 435 V and ::. 441 V

3) Load centers 3C, 3D, 48,.::431 Vand ::.437V and 4C

4) Load center 4A.:: 432 V and ::. 438 V

b. Time Delay - Load centers 3A, SR 3. 3.5. 1 2: 9 and ::. 11 seconds 38, 3C, 3D, 4A, 48, 4C, and 4D SR 3. 3.5.2 SR 3. 3.5.3

3. 480 V Load Centers (Degraded Voltage) 7.c a. Bus Undervoltage SR 3. 3.5. 1 SR 3. 3.5.2

1) Load center 3A SR 3. 3.5.3.::421 Vand ::.427V

2) Load center 38.:: 424 V and ::. 430 V

3) Load center 3C.:: 434 V and ::. 440 V

4) Load center 3D.:: 432 V and ::. 438 V

5) Load center 4A.:: 427 V and ::. 433 V

6) Load center 48.:: 433 V and ::. 439 V

7) Load center 4C and 4D.::431 Vand ::.437V

b. Time Delay - Load centers 3A, SR 3. 3.5. 1 2: 30 and ::. 90 seconds 38, 3C, 3D, 4A, 48, 4C, and 4D SR 3. 3.5.2 SR 3. 3.5.3

Insert Page 3.3.5-3 JUSTIFICATION FOR DEVIATIONS ITS 3.3.5, LOSS OF POWER (LOP) EMERGENCY DIESEL GENERA TOR (EDG) START INSTRUMENTATION

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

3. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description. Where an addition/deletion has occurred, subsequent alpha-numeric designators have been changed for any applicable affected ACTIONS, SURVEILLANCE REQUIREMENTS, FUNCTIONS, and Footnotes.

4. ISTS 3.3.5, Required Action B. 1, is associated with two inoperable Loss of Power (LOP) Emergency Diesel Generator (EOG) Start Instrumentation channels and states "Restore all but one channel per bus to OPERABLE status." The phrase "all but one" is replaced with "at least one" in Turkey Point Nuclear Generating Station (PTN) Improved Technical Specification (ITS) 3.3.5, Required Action B.1. If the licensee restored both inoperable channels within the 1-hour Completion Time of ISTS 3.3.5, Required Action B.1, this would result in a violation of the Technical Specifications since the wording "all but one" does not permit restoring both channels to an OPERABLE status within the stated Completion Time. Because nuclear and public safety are enhanced with both channels OPERABLE, revising Required Action B. 1 to require restoration of "at least" one channel would permit the licensee to restore both inoperable channels to an OPERABLE status if possible.

Insert JFD 5

~

Turkey Point Unit 3 and Unit 4 Page 1 of 1 ITS 3.3.5 JFD 5 Insert

5. ISTS SR 3.3.5.3 requires performance of a CHANNEL CALIBRATION with [Nominal Trip Setpoint and Allowable Value], listing the necessary Allowable Value (AV) and Trip Setpoint ranges with bracketed information and/or values that are generic to Westinghouse plant designs. ISTS SR 3.3.5.3 includes voltage and time delay ranges for both the AV and the nominal Trip Setpoint for loss of voltage and degraded voltage LOP EDG start instrumentation. CTS Table 3.3-3 includes 480 V undervoltage, and 480 V degraded voltage functional units with only voltage and time delay values for Trip Setpoints and includes a Note stating the AVs are the same as the Trip Setpoints. Since the Trip Setpoints are the Operability values for the LOP EDG Start instrumentation, there is no reason to duplicate these values as AVs in the Specification. ITS retains the Trip Setpoint values consistent with the current licensing basis and provides Table 3.3.5-1 that lists the 4.16 kV loss of voltage, 480 V undervoltage, and 480 V degraded voltage Functions only listing the Trip Setpoints as are listed in CTS. The brackets in ITS SR 3.3.5.3 are removed and the ISTS information is deleted and replaced with a Trip Setpoint column in ITS Table 3.3.5-1 to reflect the current licensing basis. A Note is added to the Surveillance Requirements table directing the user to Table 3.3.5-1 consistent with other ISTS instrument Specifications containing a Table listing the Functions.

~

LOP 00 Start Instrumentation 0 B 3.3.5

B 3.3 INSTRUMENTATION ~ ~

B 3.3.5 Loss of Power (LOP) Diesel Generator fOOt Start Instrumentation 0

BASES

BACKGROUND ~ s provide a source of emergency power when offsite power is 0 either unavailable or is insufficiently stable to allow safe unit operation. Undervoltage protection will generate a LOP start if a loss of voltage -GF occurs on 4. 16 kV Bus A or B, an * *. There are twp LQE_ undervoltage condition occurs on safety related load centers, or a start signals,--ooe for each 4.16 kV vital bus. ~ degraded voltage occurs on the safety related load centers Three undervoltage relays with inverse time characteristics are provided on each 4160 Class 1 E instrument bus for detecting a sustained I INSERT 1 ~ graded voltage condition or a loss of bus voltage. The relays are combined in a t\\vo out of three logic to generate a LOP signal if the []d] volta g e is below 75% for a short time or below 90 ~ r a long time. The

• LOP start actuation is described in FSAR, Section. (Ref. 1 ).

The A llowa ble Va lue in son junot ion w ith the trip setpoint and LCO 1 establishes the threshold for Engineered Safety Features Actuation 0

~~ ~ ystem (ESFAS) action to prevent exceeding acceptable limits such that Trip Setpoint
~~ ~ e c of Design Basis Accidents (DBAs) will be acceptable.

The A llowa bl e Va lue is consI value such that a channel is 1 OPERABLE if the setpoint is found not to excee A llowab le Va lue 0 during the CHANNEL CALIBRATION. Note that a lthou §J h a shanne l is OPERABLE under these sirsurnstanses, the setpoint rnust be left adjusted to within the estab lished sa libration to leranse band of the 1 setpoint in assordanse with unsertainty assurnptions stated in the 0 referensed setpo int rnethodo lo §J y, (as left sriteria) and sonf irrned to be operat in §J w ithin the statistisa l a llo 1Nanses of the unserta inty terrns assi§J ne d.

A llowab le Va lues a ~ Start Instrumentation Setpoints 0

REVIEVVER ' S NOTE Alternatively, a TS format incorporating an Allowable Value only may be proposed by a licensee. In this case the Nominal Trip Setpoint value is located in the TS Bases or in a licensee controlled document outside the TS. Changes to the trip setpoint value would be controlled by 10 CFR 50.59 or administratii1ely as appropriate, and adjusted per the 2 setpoint methodology and applicable surveillance requirements. At their option, the licensee may include the trip setpoint in the surveillance requirement as shown, or suggested by the licensee's setpoint methodology.

VVestinghouse.STS B 3. - 3.5-1 0

~ Turkey Point Unit 3 and Unit 4 J Rev. ~ 0 [ Revision XXX ITS 3.3.5 0 INSERT 1

The relaying scheme for Bus A is independent of that for Bus B. Load shedding, EOG start, and sequencing will occur for both buses only upon a concurrent loss of voltage on each bus. To provide reliability, the two instantaneous undervoltage relays are connected across two secondaries of the potential transformer for each bus. Thus, failure of a single relay or voltage source would not cause a spurious transfer. Therefore, undervoltage on one bus alone is sufficient for the separation of that system from offsite sources, while the other bus, if not disturbed, would still be fed from offsite sources.

An undervoltage monitoring system on the 480V safety related load centers is provided so that load center undervoltage concurrent with a SIS would initiate transfer to onsite power. A set of two instantaneous undervoltage relays on each safety related load center are installed to monitor the load center voltage. The two relays in each load center are connected in an AND logic and when actuated due to a undervoltage concurrent with a SIS and an open EOG breaker would initiate a sequencer time delay. After timing out, the sequencer will initiate load shedding, onsite power connection and sequencing of the necessary loads.

In addition to the load center undervoltage concurrent with safety injection signal protection scheme as described above, a degraded voltage without a safety injection signal protection scheme also monitors load center voltages. This scheme upon detection of load center degraded voltage initiates a signal to the sequencers which transfers power on the 480V safety related load center buses from off-site power to on-site power sources. Each load center bus has two inverse time relays (one per channel) to protect against large transient voltage drops of short duration and two (one per channel) definite time-delay relays to protect for degraded voltage over long durations. These four protective relays for each load center are interconnected in a two-out-f-two channel trip logic such that the logic trips if degraded voltage is detected by either Channe 1 inverse time or definite time delay relay concurrently with either Channel 2 inverse time or de nite time delay relay. This relay logic circuitry is interlocked with "a" contacts of the 4.16 kV br aker feeding that load center and the 480 volt load center main (incoming) breaker (manually perated). The interlock with the 4.16 kV and 480V load center breakers disables this circuit w en one or both of the applicable breakers are opened to take that load center out of service f r maintenance. A sequencer logic interlock with a closed EOG breaker disables this inverse ti e and definite time-delay relay logic circuit once the EOG is connected to the 4. 16 kV bus an the startup and auxiliary transformer breakers are open.

Note that TS only requires the definite time delay relays.

Insert Page 83.3.5-1

~ Start Instrumentation 0 B 3.3.5

BASES

BACKGROUND (continued)

8 The Trip Setpoints used in the relays are based on the analytical limits presented in FSAR, Chapter (Ref ). The selection of these trip 0 1 se pom s 1s sue a a equa e pro ection is provided when all sensor and processing time delays are taken into account.

~ Setpoints Trip Setpoint adjusted consistent with the requirements of the Allowable 1 Vak:fe ensure that the consequences of accidents will be acceptable, 0 providing the unit is operated from within the LCOs at the onset of the
~ accident and that Trip Setpoints the equipment functions as designed.
~ Ai 11n111nbln Halues and/or Nominal Trip Setpoints are specified for each 0

[Table 3*3*5-1 l Function in*sR 3.3.5.3. Nominal Trip Setpoints are also specified in the unit specific setpoint calculations. The trip setpoints are seleGted to ensure that the setpoint measured by the suFYeillance procedure does not 0 1

~ e*ceed the Trip SetpointAllowable Value if the relay is perfor~g as required. If the
~ measured setpoint does not exceed the Allo 1*..able Value, the relay is considered OPERABLE. Operation 1*..ith a trip setpoint less conseFYative than the nominal Trip Setpoint, but within the Allowable Value, is 1 acceptable provided that operation and testing is consistent with the 0 assumptions of the unit specific setpoint calculation (Ref. 3).

APPLICABLE ~ start instrumentation is required for the Engineered Safety 0 SAFETY Features (ESF) Systems to function in any accident with a loss of offsite ANALYSES power. Its design basis is that of the ESF Actuation System (ESFAS).

lli§] Accident analyses credit the loading of the 00 based on the loss of offsite power during a loss of coolant accident (LOCA). The actual start has }0 historically been associated with the ESFAS actuation. The loading has been included in the delay time associated with each safety system com onent re uirin su lied ower following a loss of offsite power. }0 The analyses assume a non-mechanistic loading, which does not explicitly account for each individual component of loss of power detection and subsequent actions.

EOG The re uired channels of LOP start instrumentation, in conjunction with the ESF systems powered from the s, provide unit protection in }0 the event of any of the analyzed accidents discussed in Reference 2, in which a loss of offsite power is assumed.

~ The delay times assumed in the safety analysis for the ESF equipment
~ include the 4lo second QG start delay, and the appropriate sequencing 0 delay, if applicable. The response times for ESFAS actuated equipment in LCO 3.3.2 "En ineered Safet Feature Actuation System (ESFAS)

Instrumentation," include the appropriate loading and sequencing 0 delay.

VVestinghouse.STS B 3. -3.5-2 I Revision XXX 0

~ Turkey Point Unit 3 and Unit 4 J Rev. ~ 0
~ Start Instrumentation 0 B 3.3.5

BASES

APPLICABLE SAFETY ANALYSES (continued)

1 EOG 1The LOP tiG start instrumentation channels satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

--=L~C~O~--~ ~ The LCO for LOP 00 start instrumentation requires that (three] channels 0 two channels per bus ae- ~ 1:1&-8f-l~;A4Ae-"*8i&-E~~~~RG-eeeFc!ae~IGfl:aee Functions shall 4.16 KV bus and both ~ -for loss of voltage for --~-EO-G~b-e~ O.PERABLE in MODES 1, 2, 3, and 4 when the LOP GIG start loss of voltage and instrumentation supports safety systems associated with the ESFAS. lA degraded voltage for MODES 5 and 6, the (three] channels must be OPERABLE whene 11er the 480 v load centers associated DG is required to be OPERABLE to ensure that the automatic p start of the DG is available when needed. A channel is OPERABLE witR

~ a trip Trip Setpoint setpoint v ah :Je outside its salieration toleranse eandp rovided the trip 1
~ setpoint "as-found" value does not exceed its associated /\\llow aeld! Value 0 and pro 11ided the trip setpoint " as left" v alue is adjuste d to a *1alu e w ithin the " as left" salibration toleranse band of the Nominal Trip Setpoint. A-t$ 0 1
~ setpoint may ee set more sonservati>1e than the Nominal Trip Setpoint as
@Qj nesessary in response to plant sonditions. Loss of the LOP 00 Start 0 Instrumentation Function could result in the delay of safety systems initiation when required. This could lead to unacceptable consequences during accidents. During the loss of offsite power the DG powers the motor driven auxiliary feedwater pumps. Failure of these pumps to start would lea11e only one turbine driven pump, as 'Nell as an increased potential for a loss of decay heat removal through the secondary system.

APPLICABILITY I EOG ¥ he LOP 00 Start Instrumentation Functions are required in MODES 1, 0 2, 3, and 4 because ESF Functions are designed to provide protection in these MODES. Actuation in MODE 5 or 6 is required whene 1*1er the required DG must be OPERABLE so that it can perform its function on a LOP or degraded power to the vital bus.

ACTIONS REVIEWER ' S NOTE In TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation," the loss of power function was not included in the generic e11aluations approved in either WCAP 10271, as supplemented, 2 or \\/\\ICAP 14333. In order to apply relaxations similar to those in VI/CAP 10271, as supplemented, or VVCAP 14 333, licensees must submit plant specific evaluations for NRG review and approval.

C:J ln the Trip Setpoint event a channel's trip setpoint is found nonconservative with 1 respect to the Allow abl a Value, or the channel is found inoperable, then 0 the function that channel provides must be declared inoperable and the LCO Condition entered for the particular protection function affected.

VVestinghouse.STS B 3. - 3.5-3 0

~ Turkey Point Unit 3 and Unit 4 J Rev. ~ 0 [ Revision XXX illfil----,
----r5P 00 Start Instrumentation B 3.3.5

BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.5.3

SR 3.3.5.3 is the performance of a CHANNEL CALIBRATION.

The setpoints, as well as the response to a loss of voltage and a degraded voltage test, shall include a single point verification that the trip occurs within the required time delay, as shown in Reference 1.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy. T here is a plant speoifio pro gram whioh 1.ierifies that the instrument ohanne l 1 funotions as required ey 1.ierifying the as left and as found setting are 0 oonsistent with those estaelished ey the setpoint methodo logy.

[ The Frequency of [18] months is based on operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an [18] month calieration interval in the determination of 4 the magnitude of equipment drift in the setpoint analysis.

GR

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

ILih. -- r=---fa.27 REFERENCES 1 :-=-'-+F SAR, Section ~ - - 00 IU1, r----{ill 2 :-+i=SAR, Chapter ~ - 00

~ \\OiC,'\\P 12746 aAa 1.oJC/1,P 17Q7Q I
&- Plant specific setpoint methodology y. 0

VVestinghouse.STS B 3.3.5-7 I Revision XXX 0

~ Turkey Point Unit 3 and Unit 4 ] Rev.~ 0 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement for the number of required channels and the appropriate Condition to enter if a required channel becomes inoperable. Also, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 ( Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.3.2 requires the ESFAS instrumentation ehannels anel interloel<s shown in Table 3.3 2 to be OPERABLE with their Tri13 ~,,~ t13oints Insert ITS 3.3.6 DOC LA02set eonsistent with the v alues shown in the Tri13 Set13oint eolumn of ~ Table 3.3 3. l=lowev er, CTS 3.3.2 ACTION only requires a eletermination of OPERABILITY with an ESF-/\\S Instrumentation or lnterloel< Tri13 Set13oint less eonservative than the value sho'fm in the Allowable Value eolumn of Table 3.3 3. When the set13oint is less eonservative than the Allo1Nable Value, the set13oint is aeljusteel eonsistent with the Tri13 Set13oint value of Table 3.3 3 anel eletermine within 12 hours that the a#eeteel ehannel is OPERABLE; or the ehannel is eleelareel ino13erable anel the a1313lieable ACTION statement requirements of Table 3.3 2 a1313lieel. CTS Table 3.3 3 s13eeifies both the Tri13 Set13oints anel Allowable Values for the ESF/\\S Instrumentation Functional Units.

CTS 3.3.3. 1 requires raeliation monitoring instrumentation channels sho 1Nn in Table 3.3 4 to be OPER A BLE with their A larm/Tri13 Set13oints within the s13esifieel limits. CTS Table 3.3 4 only s13esifies Alarm/Tri13 Set13oints. 'Mth the Alarm/Tri13 Set13oint value e*seeeleel, the Tri13 Set13oint must be aeljusteel to within the limit

1Nithin 4 hours or the channel is eleslareel ino13erable. This S13eeifieation is largely reelunelant to the requirements of CTS 3.3.2 abo v e, both in11olv ing the same raeliation monitors : one gaseous anel one 13artisulate containment atmos13here raeliation monitor (only one of which is requireel to be OPERABLE).

ITS 3.3.e requires the Containment Ventilation Isolation instrumentation for eash Function in Table 3.3.e 1 to be OPERABLE ITS Table 3.3.e 1 s13esifies only the Allo1Nable Values for the Containment Ventilation Isolation Instrumentation Functions. The Allo\\*,*able Values re13resent the OPERABILITY limit of the channels in ITS. This changes the CTS by moving the Tri13 Set13oints anel assosiateel information from CTS 3.3.2 anel CTS 3.3.3. 1 to the TRM.

The 13ur13ose of actuation set13oints is to ensure the mitigation of anel minimi:z:e the sonsequenees of assielents. The PTN Instrument Set13oint Methoelology saleulates nominal tri13 set13oints (NTSPs) using methoels consistent 1Nith the guielanee 13rovieleel in NRG Regulatory Guiele (RG) 1. 106, " Set13oints for Safety Relateel Instrumentation," anel ANSIJISA Stanelarel e?.04, " Set13oints for Nuclear Safety Relateel Instrumentation." /\\elelitionally, 13re elefineel limits (elouble sieleel

Turkey Point Unit 3 and Unit 4 Page 4 of 6 DISCUSSION OF CHANGES ITS 3.3.6, CONTAINMENT VENTILATION ISOLATION INSTRUMENTATION

Operability (as found) limits and as left limits) are determined for cash instrument sonsistent with the guidanse pro Yided in NRG RG 1. 106 and ANSI/I SA RP67.04,

" Methodologies for the Determination of Setpoints for Nuslear Safety Related Instrumentation." The instrument Operability limit band in plant unsertainty salsulations is synonymous with the as found asseptanse sriteria band spesified in ITS and is sentered about the nominal equipment setting (slarified in salsulations as the NTSP). The PTN Instrument Setpoint Methodologies,

insluding the method of determining instrument unsertainties,,.,,ere rev iewed by the NRG during the reYiew of the power uprate to 2300 M1.vt (NRG ADi'\\MS Assession Nos. ML013390234) and the E>c-tended Power Uprate (EPU) (NRG ADAMS Assession Nos. ML11293A366). In the NRG staff's appro 1, 1al of the 2300 M1nt power uprate amendment the NRG staff the staff determined that the proposed setpoint shanges were asseptable besause the staff had pre11iously re11ie1.Yed and appro 1, 1ed the setpoint methodology used to determine the setpoint (\\'\\'CAP 12746). In the NRG staff's approval of the PTN EPU amendment the NRG staff determined that the PTN setpoint methodology (WGAP 17070) was asseptable for this lisense amendment besause the setpoint salsulation pro Yide adequate safety margins between the Allo1.vable Value (/\\¥) and Allowable Limit (AL), as well as adequate safety margin between the NTSP and AL.

The remoYal of these details for meeting Teshnisal Spesifisation requirements from the Teshnisal Spesifisations is asseptable besause this type of information is not nesessary to be insluded in the Teshnisal Spesifisations to pro Yide adequate protestion of publis health and safety. The ITS retains the A llowable Values assosiated with the Containment Ventilation Isolation Instrumentation, whish are designated as the Operability limits for the required instrument Funstions. Also, this shange is asseptable besause these types of prosedural details will be adequately sontrolled in the TRM. A ny shanges to the TRM are made under 10 GFR 60.69, whish ensures shanges are properly eYaluated. This shange is designated as a less restris1:i¥e remo 1, al of detail shange besause prosedural details for meeting Teshnisal Spesifisation requirements are being remoYed from the Teshnisal Spesifisations.

LESS RESTRICTIVE CHANGES

L01 CTS 3.3.3.1 Table 3.3-4 (Category 4 - Relaxation of Required Action) ACTION 27 Part 1 requires that grab samples of the containment atmosphere be obtained and analyzed once per 24 hours when both the gaseous and particulate containment radiation monitors are inoperable in MODE 5 or 6. Part 2 of this Action requires the containment atmosphere to be monitored via area radiation monitors. If these Actions are not met, further Action is taken to isolate any open containment penetrations. ITS 3.3.6 is not Applicable in MODE 5 or 6 and does not contain Actions for MODE 5 or 6 (absent the movement of recently irradiated fuel within the containment building). This changes the CTS by not retaining these Actions in the ITS.

ITS 3.3.6 provides Required Actions and Completion Times when both the gaseous and particulate containment radiation monitors are inoperable in MODES 1, 2, 3, and 4, and during the movement of recently irradiated fuel in the

Turkey Point Unit 3 and Unit 4 Page 5 of 6 ITS 3.3.6 DOC LA02 Insert

CTS 3.3.2 requires the ESFAS instrumentation channels and interlocks shown in Table 3.3-2 to be OPERABLE with their TripSetpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-3. However, CTS 3.3.2 ACTION only requires a determination of OPERABILITY with an ESFAS Instrumentation or Interlock Trip Setpoint less conservative than the value shown in the Allowable Value column of Table 3.3-3. When the setpoint is less conservative than the Allowable Value, the setpoint is adjusted consistent with the Trip Setpoint value of Table 3.3-3 and determine within 12 hours that the affected channel is OPERABLE; or the channel is declared inoperable and the applicable ACTION statement requirements of Table 3.3-2 applied. CTS Table 3.3-3 specifies both the Trip Setpoints and Allowable Values for the ESFAS Instrumentation Functional Units. In addition, CTS 3.3.3.1 requires radiation monitoring instrumentation channels shown in Table 3.3-4 to be OPERABLE with their Alarm/Trip Setpoints within the specified limits. CTS Table 3.3-4 only specifies Alarm/Trip Setpoints. With the Alarm/Trip Setpoint value exceeded, the Trip Setpoint must be adjusted to within the limit within 4 hours or the channel is declared inoperable. This Specification is redundant to the requirements of CTS 3.3.2 for containment radioactivity instrumentation (Functional Unit 3.c.4), both involving the same radiation monitors: one gaseous and one particulate containment atmosphere radiation monitor (only one of which is required to be OPERABLE). ITS 3.3.6 requires the Containment Ventilation Isolation instrumentation for each Function in Table 3.3.6-1 to be OPERABLE. ITS Table 3.3.6-1 specifies only the Allowable Values for the Containment Ventilation Isolation Instrumentation Functions. The Allowable Values represent the Operability limit of the channels in ITS. This changes the CTS by moving the Trip Setpoints of the containment radioactivity instrumentation and associated information from CTS 3.3.2 and CTS 3.3.3.1 to the Technical Requirements Manual (TRM).

The purpose of containment radioactivity ESFAS actuation instrumentation is to automatically initiate containment ventilation isolation (i.e., close the containment instrument air bleed valves). The containment ventilation isolation is automatically initiated by a safety injection signal or a containment radioactivity high signal. A number of design bases accidents (DBAs) do not credit the containment ventilation isolation on a containment radioactivity high signal as a primary initiator because either containment purge is assumed to be in operation during the event or the safety injection actuation signal is assumed to isolate the containment ventilation system. The setpoints for the containment radioactivity monitors were determined in WCAP-12745, Westinghouse Setpoint Methodology for Protection Systems - Turkey Point Units 3 & 4, Rev. 0, approved by the NRC per License Amendment 146/141 (NRC ADAMS Accession No. ML013380196). The Westinghouse methodology for determining the Allowable Value for a function is consistent with the requirements of NRC Regulatory Guide 1.105 (no revision number was provided in the WCAP-12745 correspondence although Revision 2 was the current revision of the time) and ISA S67.04-1987. PTN License Amendment 293/286 changed the units of the

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setpoints from cpm to µCi/cc due to a change in the type of radiation monitors. Shutdown DBAs do not credit the containment high radiation actuation signal for containment ventilation isolation.

FPL has not proposed any change in the setpoint proposed for relocation nor any change to the methodology used from the current licensing basis in order to calculate the setpoint as part of this change. A summary of the instrument setpoint uncertainties, nominal trip setpoint (NTSP), Allowable Value (AV), safety analysis limit (SAL), total allowance (TA), channel statistical analysis (CSA), and margin for the containment radioactivity monitoring instrumentation are provided in Table 3-23 and a specific summary channel performance uncertainty calculation provided in Table 3-20 of WCAP-12745, Rev. 0.

The removal of these details for meeting Technical Specification requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS retains the AV associated with the Containment Ventilation Isolation Instrumentation, which are designated as the Operability limit for the required instrument Function. Any revision of the NTSP under licensee control that reduces the overall CSA, and thereby the TA between the NTSP and the SAL can only reduce the margin between the NTSP and the AV (i.e., Operability limit). This margin reduction does not adversely impact the margin between the AV and the SAL since the instrument AV cannot change without prior NRC approval, thus preserving the margin between the Operability limit (i.e., AV) and the SAL. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TRM. Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

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