ML23095A007
| ML23095A007 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/04/2023 |
| From: | Strand D Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23095A006 | List: |
| References | |
| L-2023-043 | |
| Download: ML23095A007 (1) | |
Text
L-2023-043 10 CFR 50.90 10 CFR 50.91(b)(1)
April 4, 2023 Florida Power & Light Company 15430 Endeavor Drive, Jupiter, FL 33478 U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11545 Rockville Pike One White Flint North Rockville, MD 20852-2746 RE:
Turkey Point Nuclear Plant Units 3 and 4 Dockets 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 LICENSE AMENDMENT REQUEST REVISION 2 FOR THE TECHNICAL SPECIFICATIONS CONVERSION TO NUREG-1431 REVISION 5
References:
- 1.
Florida Power & Light Company (FPL) Letter L-2021-158, License Amendment Request for the Technical Specifications Conversion to NUREG-1431 Revision 5, September 22, 2021 (ADAMS Accession No. ML21265A371) (ADAMS Package Accession No. ML21265A370)
- 2.
NRC letter, Turkey Point Nuclear Plant, Units 3 And 4 - Supplemental Information Needed for Acceptance of Requested License Amendment Request Concerning Technical Specification Conversion to NUREG-1431, Revision 5 (EPID L-2021-LLI-0002), dated December 21, 2021 (ADAMS Accession Nos. ML21342A293)
- 3.
FPL Letter L-2022-010, License Amendment Request for the Technical Specifications Conversion to NUREG-1431 Revision 5 - Request for Supplemental Information (RSI) Response, January 19, 2022 (ADAMS Accession No. ML22019A067)
- 4.
FPL Letter L-2022-040, License Amendment Request Revision 1 for the Technical Specifications Conversion to NUREG-1431 Revision 5, March 30, 2022 (ADAMS Accession No. ML22089A196)
(ADAMS Package Accession No. ML22089A195)
In Reference 1, Florida Power & Light Company (FPL) requested amendments to Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point),
respectively. The license amendments would convert the Turkey Point current Technical Specifications (CTS) to Improved Technical Specifications (ITS) consistent with the Improved Standard Technical Specifications (ISTS) of NUREG-1431, Revision 5 (ADAMS No ML21259A155).
In Reference 3, FPL responded to the NRCs request for supplemental information provided in Reference 2.
In Reference 4, FPL submitted Revision 1 to the ITS conversion license amendment request (LAR) of Reference 1. Revision 1 of the LAR incorporated the supplemental information provided in Reference 3 along with other enhancements. Subsequently, during the NRC review of the ITS conversion LAR Revision 1, the NRC provided FPL with requests for additional information (RAIs).
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251 Page 2 of 4 to this letter provides the LAR changes resulting from self-identified items by FPL. The items listed in Attachment 1 do not include minor editorial and typographical corrections; rather, these items include the necessary administrative changes to support LAR approval.
contains the NRC staff RAIs and the associated FPL responses for each ITS section except for Section 3.3, Instrumentation. The NRC staff RAIs and the associated FPL responses associated with ITS Section 3.3 will be provided in a future LAR revision. Each RAI/response includes the question asked by the NRC staff reviewer, the FPL response, proposed changes to pages contained in the ITS LAR of Reference 4, supporting documentation as specified, and RAI closure documentation as of March 24, 2023.
The changes discussed in Attachments 1 and 2 are identified in Enclosure 2 with revision bars identifying them as LAR Revision 2 (i.e., R2) changes.
There are four enclosures provided with this submittal, as described below. To numerically align with the enclosures provided in LAR Revision 1 of Reference 4, the enclosures are numbered Enclosures 1, 2, 4, and 7.
No changes are proposed to Enclosures 3, 5, and 6 of LAR Revision 1 of Reference 4, and therefore, these unchanged enclosures are not repeated in this submittal.
Enclosures 1 and 4 supersede and replace Enclosures 1 and 4 of Reference 4. The volumes in Enclosure 2 supersede and replace the volumes in Enclosure 2 of Reference 4 except for the following:
Volume 4 - ITS Chapter 2.0, Safety Limits (SLs), is unchanged from Enclosure 2, Volume 4 of Reference 4 and therefore, is not included in this submittal Volume 15 - ITS Chapter 4.0, Design Features, is unchanged from Enclosure 2, Volume 15 of Reference 4 and therefore, is not included in this submittal Volume 8 - ITS Section 3.3, Instrumentation, of Enclosure 2, is not included in this submittal but will be provided in a future LAR revision.
is a new enclosure added to this application. Enclosure 7 contains proposed license condition changes to Turkey Point Operating Licenses DPR-31 and DPR-41 for Units 3 and 4, respectively. The proposed changes include adding license conditions related to the implementation of ITS. Enclosure 7 also includes proposed deletions of unrelated license conditions that FPL has since completed and includes a justification for acceptability for each deletion.
For ease of reference, an index of ITS Conversion LAR Revision 2 attachments and enclosures is provided in this letter.
The supplements included in this letter provide additional information that clarifies the application and should not change the NRC Staffs original proposed no significant hazards consideration determination as published in the Federal Register. Additional specific no significant hazards considerations evaluations are provided in the following volumes of Enclosure 2 of this submittal:
Volume 9 - ITS 3.4.16, RCS Specific Activity, and Volume 16 - ITS 5.2, Organization.
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251 Page 3 of 4 Should you have any questions regarding this submittal, please contact Michael Davis, Licensing Manager -
Nuclear Licensing Projects, at (319) 851-7032 or michael.j.davis@fpl.com.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 4th day of April 2023.
Sincerely, Dianne Strand General Manager Regulatory Affairs Cc:
Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Plant Senior Resident Inspector, USNRC, Turkey Point Plant Chief, Bureau of Radiation Control, Florida Department of Health
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251 Page 4 of 4 Attachment Index Attachment No.
Subject 1
Improved Technical Specifications Conversion License Amendment Request Self-Identified Administrative Changes 2
Improved Technical Specifications Conversion License Amendment Request NRC Request for Additional Information and FPL Responses Database Enclosures Index Enclosure No.
Subject 1
Contents of the Turkey Point Nuclear Plant, Units 3 and 4, Improved Technical Specifications (ITS) Submittal, Revision 2 2
Turkey Point Nuclear Plant, Units 3 and 4, Improved Technical Specifications (ITS)
Submittal, Revision 2, Volumes 1, 2, 3, 5, 6, 7, 9, 10, 11, 12, 13, 14, and 16 3
Not included, refer to ITS Conversion LAR Revision 1 4
Disposition of Existing License Amendment Requests 5
Not included, refer to ITS Conversion LAR Revision 1 6
Not included, refer to ITS Conversion LAR Revision 1 7
Turkey Point Nuclear Plant, Units 3 and 4 Proposed Revisions to Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251 ATTACHMENT 1 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION LICENSE AMENDMENT REQUEST SELF-IDENTIFIED ADMINISTRATIVE CHANGES (5 TOTAL PAGES, INCLUDING COVER SHEET)
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251, Table 1 Page 1 of 4 Table 1 Improved Technical Specifications Conversion License Amendment Request Self-Identified Administrative Changes ITS Section Package Title Summary of Self-identified Administrative Changes 1.0 Use and Applications 1.2 Logical Connectors Changes made to ITS 1.3, page 1.3-1 to reference the correct Condition/Required Action of ITS 3.8.1, "AC Sources - Operating."
3.0 LCO and SR Applicability 3.0 SR Applicability Changed CTS Insert 6 to correctly reference DOC L02 in ITS Section 3.0.
3.1 Reactivity Control Systems 3.1.1 SDM Reference to CTS 3.1.1.2 was added to ITS 3.1.1 DOCs L01 and L02.
3.1.5 Shutdown Bank Insertion Limits DOC A04 Annotation was added to the ITS CTS Markup of the CTS 3.1.3.5 ACTION.
3.2 Power distribution Limits 3.2.3 Axial Flux Difference In ITS Section 3.2.3, changed DOC LA01 from relocating Axial Flux Difference (AFD) SRs to the COLR to relocating the AFD SRs to the TRM.
3.4 Reactor Coolant System 3.4.5 RCS Loops-MODES 3 The response to ITS 3.4.5, RAI MCH010, contained two DOC L04 changes. For the change associated with CTS 3.4.1.2 footnote * (boron concentration), DOC L04 has been changed to DOC L05.
3.4.6 RCS Loops-MODES 4
- In ITS Section 3.4.6, replaced DOC A02 (associated with two required RCS loops inoperable) with new DOC M03.
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251, Table 1 Page 2 of 4 ITS Section Package Title Summary of Self-identified Administrative Changes 3.4.7 RCS Loops-MODES 5, Loops Filled Changed reference to ITS 3.4.7, ACTION B, to ACTION C in ITS 3.4.7, DOC A02 and DOC A04.
3.4.9 Pressurizer A text box insert on ITS Bases page 3.4.9-4 was cut off such that all the words were not visible. The text box has been appropriately expanded to include the word inoperable..
3.4.10 Pressurizer Safety Valves Second paragraph of DOC L01 revised to include MODE 4 consistent with the discussion in the 1st paragraph of DOC L01.
In the first sentence of the Applicability section of the ITS 3.4.10 Bases markup, "LTOP" is changed to "OMS".
3.4.11 PORV Block Valves
3.4.14 RCS PIV Leakage ITS 3.4.14, DOC L01, is revised to include CTS 3.4.6.2, Action d, and to change ITS 3.4.1, Condition C, to Condition B.
3.4.15 RCS Leakage Detection Instrumentation Exchanged out CTS page 3/4 4-13 (Amendments 283/277) with correct CTS page 3/4 4-13 reflecting Amendments 293 (U3) and 286 (U4). As a result, references to ITS 3.4.15 DOCs L01 and L02 in CTS markup are deleted and DOCs L01 and L02 are changed to "Not Used."
ITS 3.4.15, DOC A02, is revised to change ITS 3.4.15 ACTION D to ACTION E.
In ITS Section 3.4.15, changed Required Action B.2.1 to Required Action B.2 because Required Action B.2.2 was not used.
3.4.16 RCS Specific Activity Changed XE-131 to I-131 in ITS 3.4.16, DOC A02.
3.5 ECCS 3.5.1 Accumulators
- Revised ITS Bases 3.5.1 to delete theNUREG-1431 deviation that added less than signs in the Applicable Safety Analyses section. These should be "" signs as shown in NUREG-1431 and consistent with 10 CFR 50.46.
- Reference to the RCS pressure of 1000 psig is removed from ITS SR 3.5.1.5 since this value is part of the Applicability statement. This required changes to the associated CTS markup, adding a new DOC A04, deleting DOC M01, changes to the ITS and ITS Bases markups, adding a new ITS JFD 3, and adding a new ITS Bases JFD 4.
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251, Table 1 Page 3 of 4 ITS Section Package Title Summary of Self-identified Administrative Changes 3.5.2 ECCS - Operating ITS 3.5.2 DOC L01 is revised to add a sentence to 1st paragraph describing the ITS requirement consistent with the L-DOC structure.
Revised ITS Bases 3.5.2 to delete the NUREG-1431 deviation that added less than signs in the Applicable Safety Analyses section. These should be "" signs as shown in NUREG-1431 and consistent with 10 CFR 50.46.
3.6 Containment Systems 3.6.6 CS and Cooling System ITS 3.6.6 DOC L02 is revised to change the word containment "isolation" valve to containment "spray" valve to be consistent with the subject of the DOC and included a sentence stating the ITS SR 3.6.6.7 requirement in the 1st paragraph to be consistent with the L-DOC structure.
3.7 Plant Systems 3.7.5 AFW CTS 4.7.1.2.1.a.2 and SR 3.7.5.6 have been revised to delete the word "pressure" when referring to the turbine pressure valves. DOC A04 has been added to address the presentation preference change.
3.7.10 CREVS
- The response to RAI JMW056 did not add "in MODES 1, 2, 3, or 4" to the second part of new Condition J in Insert 3 of ITS 3.7.10, which has now been added.
3.8 Electrical Power Systems 3.8.7 Inverters -
Operating
- Deleted unnecessary words "designators and" from ITS 3.8.7, DOC LA01.
- Insert 3 is deleted from ITS 3.8.7 Bases, Required Actions B.1 and B.2, because Insert 3 is no longer applicable since the subject Note has been deleted from the ITS.
3.8.9 Distribution Systems -
Operating
- Added clarification of the applicable tables associated with Unit 3 and Unit 4 to the LCO section of the ITS 3.8.9 Bases.
- Deleted "or test conditions" from bus transfer examples of the swing load center from ITS 3.8.9 Bases, Insert 2A.
Turkey Point Nuclear Plant, Units 3 and 4 L-2023-043 Dockets 50-250 and 50-251, Table 1 Page 4 of 4 ITS Section Package Title Summary of Self-identified Administrative Changes 5.0 Administration Controls 5.2 Organization
- The ITS 5.2.1.a markup references the "FSAR/QA Plan". This reference is replaced with "Quality Assurance Topical Report and Updated Final Safety Analysis Report."
- ITS 5.2, revised DOC LA01 (associated with CTS 6.2.1.b) to include potential relocation of generic titles to QATR instead of relocation only to the UFSAR.
5.5 Programs and Manuals
- In ITS Section 5.5, references to ASTM standards are removed from the CTS 6.8.4.e markup (CTS page 6-7) and the ITS 5.5.10 markup since the standards are specified in the ITS 3.8.3 Bases. ITS 5.5, DOC LA05 has been added to support this removal of detail.
- In ITS Section 5.5, deleted the introductory sentence from CTS 6.8.4.l (CTS page 6-14) which stated that the SFCP provides controls for surveillance frequencies and added reference to DOC A01, consistent with the ISTS.
- ITS 5.5, The response to RAI CLA003 added a DOC A09; this has been updated as DOC A11 to accommodate other changes incorporated into the ITS 5.5 DOC section.
- Revised ITS 5.5.8 to remove requirements to test the compensatory filter as compensatory filter surveillance requirements are not specified in ITS 3.7.10.
Compensatory filter surveillance requirements are relocated to the Technical Requirements Manual. Footnote ** on CTS markup page 3/4 7-21 is marked to "See ITS 3.7.10" since this CTS requirement is addressed in ITS 3.7.10.
5.6 Reporting Requirements
Insert 2, incorporated PTN License Amendments 296 and 288, Unit 3 and Unit 4 respectively, associated with application of the full spectrum loss of coolant accident (FSLOCA) methodology.