L-2024-173, Response to Requests for Additional Information Regarding Turkey Point License Amendment Request (278) to Facilitate a Transition to 24-Month Fuel Cycles

Response to Requests for Additional Information Regarding Turkey Point License Amendment Request (278) to Facilitate a Transition to 24-Month Fuel Cycles

ML24305A144
Person / Time
Site:	Turkey Point
Issue date:	10/31/2024
From:	Mack K Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2024-173
Download: ML24305A144 (1)

Text

{{#Wiki_filter:* F=PL. U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE: Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 October 31, 2024 L-2024-173 10 CFR 50.90 Response to Requests for Additional Information Regarding Turkey Point License Amendment Request (278) to Facilitate a Transition to 24-Month Fuel Cycles

References:

1.

Florida Power & Light Company letter L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, November 15, 2023 (ADAMS Accession No. ML23320A028, ML23320A029)

2.

Florida Power & Light Company letter L-2024-008, Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, February 9, 2024 (ADAMS Accession No. ML24040A190, ML24040A191)

3.

US Nuclear Regulatory Commission electronic memorandum dated October 8, 2024, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - Transition to 24-Month Fuel Cycles (L-2023-LLA-0161), (ADAMS Accession No. ML24282A672)

4.

Florida Power & Light Company letter L-2024-157, Response to Requests for Additional Information Regarding Turkey Point License Amendment Request (278) to Facilitate a Transition to 24-Month Fuel Cycles, October 3, 2024 (ADAMS Accession No. ML24278A038, ML24278A040) In Reference 1, as supplemented by Reference 2, Florida Power & Light Company (FPL) requested amendments to Subsequent Renewed Facility Operating Licenses (SRFOLs) Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point), respectively. The proposed license amendments revise the Turkey Point licensing basis by incorporating advanced fuel features (e.g., AXIOM cladding, ADOPT' fuel pellets, and a PRIME' fuel skeleton), extending Technical Specification (TS) surveillance intervals, modifying TS Allowable Values (AVs) and a Trip Setpoint, and conforming changes to the Updated Final Safety Analysis Report to facilitate a transition to 24-month fuel cycles. In Reference 3, the NRC requested additional information deemed necessary to complete its review. The enclosure to this letter provides FPL's response to the NRC request for additional information (RAI). to the enclosure provides the revised Turkey Point TS markup pages. Attachment 1 includes new and revised TS changes as a result of this RAI response and revises TS 5.5.16, Surveillance Frequency Control Program, from previously proposed in FPL's response to Reference 4 following NRC review. Attachment 2 to the enclosure provides the revised TS Bases markup pages. The revised TS markup and TS Bases markup pages supersede and replace the corresponding TS markup and TS Bases markup pages of References 1 and 4. The TS Bases markup pages are provided for information only and will be incorporated in accordance with the Turkey Point TS Bases Control Program upon implementation of the approved amendments. Attachment 3 contains proposed changes to Turkey Point Updated Final Safety Analysis Report, Section 7.2, as discussed in this RAI response. The UFSAR markups are provided for information only and will be incorporated into the Turkey Point licensing basis in accordance with 1 O Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Page 2 of 2 CFR 50.71(e) upon implementation of the approved amendments. Attachment4 contains relevant excerpts from Turkey Point maintenance procedure 4-SMl-071.02A, "Steam Generator 4A Level (Narrow Range) Protection Set 1 Loop L-474 Channel Calibration", as discussed in this RAI response. The information in this RAI response provides additional information that clarifies the application, does not expand the scope of the application as originally noticed, and should not change the NRC staff's originally proposed notice of determination of no significant hazards as published in the Federal Register. This letter contains no new or revised regulatory commitments. Should you have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of October 2024. Kennet A. ck Director, Li ensing and Regulatory Compliance Florida Power & Light Company cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. Clark Eldredge, Florida Department of Health

Enclosure:

Response to Request for Additional Information Attachments:

1.

Revised Technical Specification markup pages.

2.

Revised Technical Specification Bases markup pages.

3.

UFSAR Section 7.2 markup pages

4.

Turkey Point Maintenance Procedure, 4-SMl-071.02A excerpts

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Enclosure Page 1 of 8 In Reference 1, as supplemented by Reference 2, Florida Power & Light Company (FPL) requested amendments to Subsequent Renewed Facility Operating Licenses (SRFOLs) Nos. DPR-31 and DPR-41 for Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point), respectively. In Reference 3, the NRC requested additional information, as indicated below. FPL's response follows: EICB-RAl-1

a.

Please explain this apparent discrepancy (i.e., why are the values in the TS table different from the values in the WCAP-17283-P report immediately prior to issuance of WCAP-18888-P that purports to replace all previous WCAP reports) and describe what specific licensing basis document controls the establishment of the values that are listed in TS Tables 3.3.1-1, "Reactor Trip System Instrumentation," and 3.3.2-1, "ESFAS Instrumentation," for each of the TS setpoints and the AVs for reactor trip and engineered safety features actuation system functions listed in the proposed TS included in the LAR. FPL Response: WCAP-17283-P was not accepted as the setpoint methodology basis document by Turkey Point. Current Reactor Trip System and Engineered Safety Features Actuation System setpoints and allowable values follow the methodology of either WCAP-17070-P Revision 1, WCAP-127 45 Revision 0, or WCAP-12745 Revision 1.

b.

Since the WCAP-17283-P report states in the Introduction, in part: "This WCAP was prepared for Turkey Point personnel use only and as such is not prepared in a manner that would support transmittal to the Nuclear Regulatory Commission (NRC)." Therefore, immediately prior to the implementation of WCAP-18888-P,

i.

What technical basis document established the technical basis for the Nominal Trip Setpoint and the AV in the Technical Specifications for the Power Range Neutron Flux High Setpoint and other LSSS related functions? and, ii. What Turkey Point "personnel" use WCAP-17283-P and for what purpose do they use the WCAP-17283 report? FPL Response: Current Reactor Trip System and Engineered Safety Features Actuation System setpoints and allowable values follow the methodology of either WCAP-17070-P, Revision 1, WCAP-12745 Revision 0, or WCAP-12745 Revision 1. WCAP-17070-P, Revision 1, includes setpoint methodology, trip setpoints, and allowable values for a subset of the RTS/ESFAS functions. This document supersedes the methodology and values identified in WCAP-12745, Revision 0, and Revision 1 for this subset of functions. Turkey Point documents the trip setpoint, allowable value, and setpoint methodology bases documents for each RTS/ESFAS function on controlled drawings. WCAP-12745 Revision 1 provides the setpoint methodology for Containment Pressure - High and shows an allowable value of 5.5 psig for Containment Pressure - High, but the Technical Specification allowable value is < 4.5 psig. The Technical Specification allowable value is documented in Westinghouse Calculation Note CN-SCS-23-3. The WCAP-127 45 value was based on pressure switches which were replaced, resulting in recalculation of the allowable value and nominal trip setpoint. That recalculation resulted in the allowable value of 4.5 psig. The WCAP was not revised to reflect the value in the Calculation Note. The Turkey Point drawing identifies the engineering change number associated with this change. There are no other differences between the WCAP and Technical Specification Allowable Values and Trip Setpoints.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Enclosure Page 2 of 8 WCAP-17283 was prepared for Turkey Point but was not accepted as the setpoint methodology basis document.

c.

For each function listed in the RTS and ESFAS Technical Specification tables, which setpoint methodology(ies) govern(s) which process values that will be implemented in the RTS and the ESFAS function plant calibration procedures and then used as a basis for the calibration and functional test values derived and documented in the plant calibration and functional test procedures as TS surveillance test acceptance criteria and limiting values? FPL Response: WCAP-18888-P replaces all functions listed in WCAP-12745, Revision 0, "Westinghouse Setpoint Methodology for Protection Systems - Turkey Point Units 3 & 4," November 1990, WCAP-12745, Revision 1,"Westinghouse Setpoint Methodology for Protection Systems, Turkey Point Units 3 and 4, Thermal Up-rate Project", and WCAP-17070-P, Revision 3, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Power Uprate to 2644 MWt - Core Power)," January 2021. WCAP-17283-P, Revision 2, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Consolidation of WCAP-12745, Revisions O and 1 with WCAP-17070-P Revision 3)," September 2021, is a summary issued to provide one source of information in place of the three previous listed WCAPs. For each function listed in the RTS and ESFAS Technical Specification tables, WCAP-18888-P setpoint methodology governs process values that will be implemented in the RTS and the ESFAS function plant calibration procedures. WCAP-18888-P will then provide a basis for the calibration and functional test values derived and documented in the plant calibration and functional test procedures as TS surveillance test acceptance criteria and limiting values. EICB-RAl-2 Given that the methodology used in WCAP-18888-P has expanded its scope of applicability to incorporate all the reactor trip system and engineered safety features actuation system instruments and the method for establishing setpoints is consistent with the method applied in WCAP-17070:

a.

Please explain how this cited language in Subsections 4.1 and 4.2 is consistent, for all the related RTS and ESFAS instrument channels in WCAP-18888-P. Also describe how it conforms with the description in UFSAR Section 7.2 regarding technical specification task force (TSTF) - 493 Option A criteria for maintenance of setpoints for the related RTS and ESFAS instrument channels now that WCAP-18888-P uses and describes how the as-found and as-left tolerances will be used for all the instrument channels listed in the WCAP-18888-P report. FPL Response: Sections 4.1 and 4.2 both require an "as-found" value outside of the associated As Found Tolerance (AFT) to be recalibrated to within the As Left Tolerance (ALT). Section 4.1 summarizes that on rare occasions for a 95/95 function, an evaluation to determine if the "as-found" value outside of the AFT is due to a known cause such as the previous test equipment was out of tolerance, previous maintenance activities may have been to source an out of tolerance condition, or on rare occasion the out of tolerance condition may have no identifiable cause and is justified to be operable and returned to service as a one-out occurrence. In addition to the requirements of Section 4.1, Section 4.2 requires that the out of tolerance condition be monitored for past, present and future operability to ensure that the hardware is performing both within the equipment specifications and within the allowance in the uncertainty

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Enclosure Page 3 of 8 analysis. A channel found out of tolerance on multiple occasions must be evaluated to determine the cause with the appropriate corrective actions. The corrective actions may include further monitoring assuring the channel remains in tolerance by reducing the surveillance interval, repairing or replacing the suspect hardware, and if justification exists, to revise the uncertainty calculated channel CSA to include a larger allowance for the equipment. "WCAP-18888-P methodology is in accordance with the Westinghouse setpoint methodology of WCAP-17504-P-A, whereas the SER states in part, The methodology described in WCAP-17504-P/WCAP-17504-NP, Revision 1, for applying the AFT and ALT terms serves to constrain the adjusted setpoint to within a small deviation from the ideal analyzed setting, and provides an adequate basis for monitoring any deviation of this setpoint from its As-left condition, thus providing a means by which excessive deviation may be identified for corrective action. The NRG staff finds that the methodology and use of the terms for AFT and ALT as described within the WCAP-17504-PIWCAP-17504-NP, Revision 1, addresses the concerns noted in RIS 2006-17, is compatible with the guidance provided in TSTF-493 for Westinghouse plants, and is consistent with the requirements of 1 O CFR 50. 36." Furthermore, the SER concludes that the AFT and ALT being used to determine operability are justified. "Therefore, the WSM described in the WCAP-17504-PIWCAP-17504-NP, Revision 1, uses double-sided evaluation acceptance criteria bands. Figure 3-1 (above) and the relationships described above illustrate how the operability of the instrument loop is evaluated. Exceeding the AFT in either high or low direction may indicate degraded performance and inability of the instrument channel to meet its intended function. Not being able to reset the setpoint to within the ALT at the conclusion of a channel calibration process also may indicate degraded performance and inability of the instrument channel to meet its intended function." WCAP-18888-P is consistent with WCAP-17504-P-A and therefore, the operability includes the use of+/- ALT and+/- AFT for the channels listed in WCAP-18888-P. UFSAR Section 7.2 is being updated to be consistent with the methodology of WCAP-18888-P for those functions being revised for the 24-month fuel cycle. Changes to plant procedures to incorporate the requirements of WCAP-18888-P are included in the engineering packages which address the 24-month fuel cycle project. Those functions which do not require changes based on GL-91-04, safety analyses or plant modifications required to implement 24-month will remain per the existing plant methodology.

b.

Please explain the reason for the difference between Subsections 4.1 and 4.2 of WCAP-18888. Section

4.1 states

"Recalibration is explicitly required any time the "as found" condition of the device or channel is outside of the ALT." Section 4.2 states: "A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated." Please explain the process for evaluating whether the channel is "functioning as required" before recalibrating, and why this is not explicitly stated in Subsection 4.1. FPL Response: Section 4.1 provides the basic assumptions and premises for developing the instrument channel uncertainty calculations along with the plant procedural requirements for implementation in order to prove consistency between the uncertainty calculations and the plant procedures. The section addresses normal conditions expected in plant operation and instrument channel performance noting that even on a rare occasion a channel may exceed the AFT by a minimal amount and determined to be operable. Section 4.2 provides specific details on determining operability of the process racks providing additional conditions and actions required for process racks where a deviation beyond the ALT may be indicative of an incipient failure. The process for evaluating whether the channel is functioning as required to meet the ALT and AFT will differ based on the function, analysis requirements,

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Enclosure Page 4 of 8 specific hardware capabilities and the associated method utilized by the maintenance calibration and repair procedures. EICB-RAl-3 Please explain why the licensee has not adopted footnotes (b) and (c) for RTS Instrumentation and footnotes (g) and (h) for the ESFAS Instrumentation and instead relies on footnotes (f) and (g) for the RTS instrumentation and footnotes (b) and (c) for ESFAS Instrumentation that do not require the out of specification as-found measured value be evaluated to ensure the instrument channel is functioning as required. FPL Response: The footnote applicability for the evaluated RTS and ES FAS functions has been revised to be consistent with the functions where footnotes are currently applicable, by requiring any out of specification as-found measured value to be evaluated to ensure the operability of the instrument channel. The footnotes have been revised by removing from the TS change originally proposed in Reference 1, the strikeout in the second sentence of footnote (c) to TS 3.3.1, Table 3.3.1-1, and by removing footnotes (f) and (g) to TS 3.3.1, Table 3.3.1-1. This restores the evaluation requirement for instruments that do not meet the AFT and removes the footnotes applicable to the methodology of WCAP-127 45-P. EICB-RAl-4 Provide relevant portions of the operations and/or maintenance procedures that describe what actions the operator and maintenance personnel need to take when, "the as-found channel setpoint is outside its predefined as-found tolerance," to comply with UFSAR Section 7.2 regarding surveillance of RTS and ESFAS function setpoints, WCAP-18888-P, RIS 2006-17, and 10 CFR 50.36(c)(1)(ii)(a), "Technical specifications." FPL Response: Plant operations and maintenance procedures have not been revised for implementation at this time. The revised Technical Specification, Technical Specification Bases, and UFSAR mark-ups included in response to EICB-RAl-9 provide consistent operational and maintenance requirements when an as-found channel setpoint is outside of its pre-defined as-found tolerance. Steam Generator Level (RTS Function 11) is currently subject to the requirement in TS 3.3.1, Table 3.3.1-1 footnote (b). An excerpt from Turkey Point maintenance procedure 4-SMl-071.02A, Steam Generator 4A Level (Narrow Range) Protection Set 1 Loop L-474 Channel Calibration, showing how the requirement is implemented is provided in Attachment 4 to this RAI response. When an as-found value is out of tolerance, the SM/US/SRO designee is notified and a condition report is initiated requiring an engineering evaluation per plant procedure EN-AA-203-1001, Operability Determinations. The revised Technical Specification, Technical Specification Bases, and/or UFSAR mark-ups provide requirements and references to setpoint methodology bases documents the evaluating engineer would include in their review. EICB-RAl-5 Using the method described in WCAP 18888-P as a reference, please explain the licensee's apparent position as to why it believes it is acceptable for some RTS and ESFAS instruments to apply footnotes similar to those in TSTF-493 Option A and why some LSSS-related instruments do not apply the footnotes similar in composition to TSTF-493 footnotes.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 FPL Response: L-2024-173 Enclosure Page 5 of 8 As discussed in EICB-RAl-3 and EICB-RAl-7, TS 3.3.1, Table 3.3.1-1 for the RTS functions and TS 3.3.2, Table 3.3.2-1 for the ESFAS functions are revised from originally proposed in Reference 1 to assure consistency in the application of WCAP-18888-P and thereby TSTF-493, Option A. The proposed change deletes the existing footnotes associated with the WCAP-12745-P methodology and imposes the corresponding footnotes of WCAP-18888-P, which require an evaluation to verify the affected channel is functioning properly whenever the AFT is not met, etc. Removal of the footnotes associated with WCAP-12745-P from TS 3.3.1, Table 3.3.1-1 and TS 3.3.2, Table 3.3.2-1 assures consistent application of WCAP-18888-P for the RTS and ES FAS instrument functions. Attachment 1 to this RAJ response provides the revised TS markup pages. EICB-RAl-6 In the UFSAR mark-up paragraph that states, in part, (after the mark-up): Surveillance limits are established to verify that RTS and ESFAS instrumentation operates within the boundaries of applicable instrument uncertainty calculations. These limits are implemented in plant procedures in accordance with TS Notes [(a) and (b)J below which are consistent with the wording provided in TSTF-493 Rev 4. These notes specify operability criteria and require that out-of-tolerance conditions detected during surveillances be evaluated before returning the channel to service. [Notes (b) and (c)] [The notes] have been inserted into TS Table ~ [3.3.1-1], RTS instrumentation [Surveillance Requirements] and [Notes (g) and (h) have been inserted into] TS Table[~ [3.3.2-1] ESFAS Instrumentation [Surveillance Requirements]. The methods used to determine the NTS and AV values and summaries of the associated calculations are described in WCAP [17070 P] [18888-P] (Reference 5). Note (a) [or (g)] states: '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.' Note (b) [or (h)] states: 'The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTS) 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 settings) to confirm channel performance. The NTS and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2."' Are these letters the correct labels for these footnotes, or should this have been Notes (b) and (c)? Please explain. FPL Response: The Notes (a) and (b) should have been labeled as Notes (b) and (c) respectively. Attachment 3 to this RAI response provides the UFSAR Section 7.2 markup page correcting the notation labeling.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 EICB-RAl-7 L-2024-173 Enclosure Page 6 of 8

a.

Verify whether the staff's understanding regarding the use of the footnotes (b) and (c) is correct.

b.

If the staff's understanding is incorrect, please explain why the licensee believes it is acceptable to use footnotes that do not require an evaluation be conducted for certain instrument channels when the as-found measured value exceeds the AFT (i.e., the AV). FPL Response: The staffs understanding of the existing footnotes is correct. The footnotes applicable to the RTS and ESFAS instrument functions require identical plant responses and evaluation, and thereby identical implementing footnotes. For the ESFAS instrument functions, this RAI response revises TS 3.3.2, Table 3.3.2-1, by relocating existing footnotes (g) and (h) to become footnotes (b) and (c), i.e. similar to footnotes (b) and (c) of TS 3.3.1, Table 3.3.1-1 for the RTS instrument functions. Existing footnotes (b) and (c) of TS 3.3.2, Table 3.3.2-1, which are applicable to WCAP-12745-P and do not require an evaluation when the AFT is not met, are replaced with new footnotes (b) and (c), consistent with WCAP 18888-P Revision 0. Attachment 1 to this RAI response provides the revised TS markup pages. EICB-RAl-8

a.

Verify whether the staff's understanding regarding the use of the footnotes (g) and (h) is correct.

b.

If the staff's understanding is incorrect, please explain why the licensee believes it is acceptable to use footnotes that do not require an evaluation be conducted for certain instrument channels when the as-found measured value exceeds the AFT (i.e., the AV). FPL Response: The staff's understanding of the footnotes is correct and the footnotes which do not require an evaluation are removed in the revised TS markup pages of Attachment 1. EICB-RAl-9 Explain the licensee's understanding of why the text, as previously written and as proposed meets the requirements of 10 CFR 50.36 or any changes to the text that will be required so that the language complies with 10 CFR 50.36. FPL Response: Previously written text provided the bases for the existing setpoints established in accordance with the Regulatory Guide 1.105, Revision 2, Westinghouse methodology as detailed in WCAP-12745 Revision 0 and Revision 1, along with the differences with the updated methodology of WCAP-17070-P for the EPU updated setpoints. The proposed text is in accordance with the methodology of WCAP-17504-P-A, Revision 1, "Westinghouse Generic Setpoint Methodology" as documented in WCAP-18888-P for Turkey Point units 3 & 4. For the purposes of the 24-month fuel cycle all of the RTS and ESFAS functions identified in WCAP-18888-P, Revision 0, are based on the WCAP-17504-P-A, Revision 1, which specifically states that the Nominal Trip Setpoint is the LSSS requirement of 10 CFR 50.36. The ALT and AFT are then used to determine the function operability requirements where the non-conservative direction of the AFT is utilized as the TS Allowable Value (AV).

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Enclosure Page 7 of 8 Consistent with WCAP-18888-P, the Nominal Trip Setpoint is defined as the LSSS value in Section 7.2 of the UFSAR. Inconsistencies in the TS Bases and UFSAR discussion for the RTS and ESFAS instrument functions are resolved in the revised TS Bases markup pages provided in Attachment 2 and the revised UFSAR mark-up pages provided in Attachment 3 of this RAI response. EICB-RAl-10 In Section 2, Evaluation of Change in, "Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals, and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles," the markup of Table C1 (Enclosure 1, Page 4 of 6) the second row describes the surveillance requirement as "SR 3.3.1.1 O" and the Tech. Spec. Function as Table 3.3.1-1 Function 10 as "Perform CHANNEL Calibration, Pressurizer Pressure-High." However, the Function Number for Pressurizer Pressure-High is Function 8. Please explain the discrepancy and resolution of the issue. FPL Response: FPL agrees that the functional unit (FU) enumeration for the Pressurizer Pressure-High function in, Table C1 of Reference 2 is in error. The corrected Table C1 below supersedes and replaces the Enclosure 1, Table C1 of Reference 2, in its entirety. Table C1: Applicable Instrumentation (revised) Surveillance Tech Spec Model Number\\ Requirement Section/ Description Manufacturer Description Range Function SR 3.3.1.10 Table 3.3.1-1, Perform CHANNEL Calibration. Rosemount

• 3154NA6 1500 to 2500 Function 7 Pressurizer Pressure - Low psig SR 3.3.1.10 Table 3.3.1-1, Perform CHANNEL Calibration.

Rosemount

• 3154NA6 1500 to 2500 Function !! 4Q Pressurizer Pressure - High psig Table 3.3.2-1, Perform CHANNEL Calibration.

Safety Injection - Pressurizer Rosemount

• 3154NA6 1500 to 2500 SR 3.3.2.6 Function 1.d psig Pressure - Low
• Change: 1154SH9RB / 3154NA6 was replaced with 3154NA6.

EICB-RAl-11 In the "Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals, and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles," the marked-up pages of Table 3.3.1-1, Reactor Trip System Instrumentation, in Note (c) it states, in part, "The NTSP and the 'methodologies' used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2." Additionally, in the marked-up pages of Table 3.3.1-2 Engineered Safety Feature Actuation System Instrumentation, in Note (h) it states, in part, 'The NTSP and the 'methodologies' used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2." Please explain why the term '"methodologies" is used when only WCAP-18888-P appears to be the basis document as described in the supplement. Will other setpoint methodologies still be in use and if so, where are they described in the UFSAR?

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 FPL Response: L-2024-173 Enclosure Page 8 of 8 FPL agrees that the marked-up pages in Reference 2 for existing footnote (c) of TS 3.3.1, Table 3.3.1-1, Reactor Trip System Instrumentation, and footnote (h) of TS 3.3.2, Table 3.3.2-1, incorrectly refer to methodologies, implying more than one acceptable setpoint methodology for the subject RPS and ESFAS instrument functions. The footnotes should state "methodology" as applicable solely to WCAP-18888-P. As discussed in EICB-RAl-7, FPL is relocating existing footnotes (g) and (h) of TS 3.3.2, Table 3.3.2-1, to become footnotes (b) and (c) whereby existing footnotes (b) and (c) applicable to WCAP-12475-P are being removed. Accordingly, Attachment 1 of this RAI response provides the corrected TS markup pages changing "methodologies" to "methodology" in footnote (c) of TS 3.3.1, Table 3.3.1-1, and new footnote (c) of TS 3.3.2, Table 3.3.2-1. References

1.

Florida Power & Light Company letter L-2023-078, License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, November 15, 2023 (ADAMS Accession No. ML23320A028, ML23320A029)

2.

Florida Power & Light Company letter L-2024-008, Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, February 9, 2024 (ADAMS Accession No. ML24040A190, ML24040A191)

3.

US Nuclear Regulatory Commission electronic memorandum dated October 8, 2024, Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - Transition to 24-Month Fuel Cycles (L-2023-LLA-0161), (ADAMS Accession No. ML24282A672)

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Revised Turkey Point Units 3&4 Technical Specification Markup Pages ( 11 pages follow) L-2024-173

1.

2.

3.

4.

(a) (b) (c) (d) (e) (f) (g) RTS Instrumentation 3.3.1 Table 3.3.1-1 (page 1 of 10) Reactor Trip System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT Manual Reactor Trip 1,2 2 B SR 3.3.1.12 NA NA 3(a),4(a).s<a) 2 C SR 3.3.1.12 NA NA Power Range Neutron Flux

a.

High 1,2 4 D SR 3.3.1.1 s 108.6% RTP 108.0% RTP SR 3.3.1.2 SR 3.3.1. 7(b)(c) SR 3.3.1 _g(b)(c) j2s.6 j

b.

Low 1{dl,2 4 E SR 3.3.1.1 s 2'8% RTP s 25% RTP SR 3.3.1.8.(f}(g) !(b)(c) I SR 3.3.1.9(f)(g) !(b)(c) ! ~ 25.6 Intermediate Range 1(dl,2 2 F,G SR 3.3.1.1 s -3¥/o RTP s 25% RTP SR 3.3.1.~!(b)(cJ ! Neutron Flux SR 3.3.1.g(f)(g) !(bJ(cJ! !

1. 05 !

Source Range 2(e) 2 H,I SR 3.3.1.1 s M E5 cps s 1.0 E5 cps Neutron Flux SR 3.3.1.8.(f}(g) !(b)(c) I SR 3.3.1,g(f)(g) !(b)(c) ! ~ 1.05 3(a),4(a),5(a) 2 I, J SR 3.3.1.1

S M E5cps s 1.0 E5 cps SR 3.3.1.7(f)(g)~

SR 3.3.1,g(f)(g)!(b)(c) I With Rod Control System capable of rod withdrawal or one or more rods not fully insert. 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. 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 s oint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and th sed to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. Below the P-10 (Power Range Neutron Flux) interlocks. Below the P-6 (Intermediate Range Neutron Flux) interlocks. methodology Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence. If the iAstFumeAt shaAAel setpaiAt is less saAser:vafr,e th a A the /1.llawable Value, the setpaiAt shall be Feset GaAsisteAt with the TFifl Setf)aiAt aAEI withiA 12 haurs EleteFFRiAe the affeGteEI shaAAel is OPER.A,BbE; atheFWise, the shaAAel shall be EleslaFeEI iA8fleFable. !Deleted ! Turkey Point Unit 3 and Unit 4 3.3.1-11 Amendment Nos. 297 and 290

FUNCTION

5.

Overtemperature iff

6.

Overpower,H

7. Pressurizer Pressure

-Low

8. Pressurizer Pressure

- High

9.

Pressurizer Water Level-High

10. Reactor Coolant Flow-Low

a.

Single Loop APPLICABLE MODES OR OTHER Table 3.3.1-1 (page 2 of 10) Reactor Trip System Instrumentation RTS Instrumentation 3.3.1 SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT 1,2 3 E 1,2 3 E 1Ch) 3 L 1,2 3 L 3 L 3 per loop L SR 3.3.1.1 SR 3.3.1.3 SR 3.3.1.6 Refer to Note 2 Refer to Note 1 (Page 3.3.1-18) (Page 3.3.1-17) SR 3.3.1.7(b)(c) SR 3.3.1.1 o(b)(c) SR 3.3.1.1 Refer to Note 4 Refer to Note 3 SR 3.3.1. 7(b)(c) (Page 3.3.1-20) (Page 3.3.1-19) SR 3.3.1.1 o(b)(c) 11s30 1 SR 3.3.1.1 ~ 48-1-7 psig SR 3.3.1.7.(f)(g) !(b)(c) ! SR 3 3 1 10(1).(g) *.. (b'.!l:)(c::Ll t-=-::~:. 2390 SR 3.3.1.1

5 2403--psig SR 3.3.1. 7.(f)(g) !(b)(c) !

SR 3.3.1.1 o{l)(Ol!(b)(c) I SR 3.3.1.1 s 92.2% SR 3.3.1.7.(f)(g) !(b)(c) I SR 3.3.1.1 o{l)(Ol!(b)(c) ! SR 3.3.1.1 SR 3.3.1.7(b)(c) SR 3.3.1.1 o(b)(c) ~ 89.6% ~ 1835 psig s 2385 psig S92.0% 90.0% (b) 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. (c) 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 (f) (g) (h) (i) NTSP are acceptable provided that the as-found and as-left tolerances apply to the actua tpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the sed to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. !methodology r-1'1 w eleted i Cove tn P-7 (Low Power Reactor Trips Block) interlock. Above the P-8 (Power Range Neutron Flux) interlock. Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence. Turkey Point Unit 3 and Unit 4 3.3.1-12 Amendment Nos. 297 aflel 290

FUNCTION

10. Reactor Coolant Flow-Low (continued)

b. Two Loops

11. Steam Generator (SG) Water Level -

Low Low

12. SG Water Level-Low Coincident with Steam Flow/Feedwater Flow Mismatch

13. Undervoltage -

4.16 kV Buses A and B 14 Underirequency RCPs Breakers Open APPLICABLE MODES OR OTHER Table 3.3.1-1 (page 3 of 10) Reactor Trip System Instrumentation RTS Instrumentation 3.3.1 SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT 3 per loop L SR 3.3.1.1 ~89.6% 90.0% SR 3.3.1.7'b)(c) SR 3.3.1.1 o(b)(c) 1,2 3 per SG L SR 3.3.1.1 ~ 15.5% 16.0% SR 3.3.1.7(b)(c) SR 3.3.1.1 Q(b)(c) 1,2 2 perSG L SR 3.3.1.1 ~ 15.5% 16.0% SR 3.3.1.7'b)(cl SR 3.3.1.1 o(b)(c) 1,2 2 per SG L SR 3.3.1.1 s 20.7% 20.0% below SR 3.3.1. ?(b)(c) below rated rated steam SR 3.3.1.1 o(b)(c) steam flow flow 2 per bus SR 3.3.1.1 o(l).(g)!(b)(c)!~ 69% bus ~ 70% bus voltage voltage L 156.08 I 2 per bus N SR 3.3.1.10(1).(g) !(b)(c) !~ e&.9 Hz ~ 56.1 Hz (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that ii is functioning as required before returning the channel to service. (c) 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 actu etpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the sed to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. !methodology r-21 (f) Tl=le iAslFYmeAt sl=laAAel setpoiAI sl=lall be reset to a val1,1e witl=liA tl=le salibratioA toleraA s1,1rvoillaAse; etl:lei:wise, tl:le GR3AAOI sl:lall be deslared iAeperable. !Deleted I (g) (h) (j) Above the P-7 (Low Power Reactor Trips Block) interlock and below the P-8 (Pow r Range neutron Flux) interlock. Turkey Point Unit 3 and Unit 4 3.3.1-13 Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence. Amendment Nos. 297 aRel 290

RTS Instrumentation 3.3.1 Table 3.3.1-1 (page 4 of 10) Reactor Trip System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT

15. Turbine Trip

a. Emergency Trip 1(h) 3 L

SR 3.3.1.10(b)(cJ 2! 901 psig 1000 psig Header Pressure SR 3.3.1.13

b. Turbine Stop Valve 1(h) 2 L

SR 3.3.1.10 Fully Closed Fully Closed Closure SR 3.3.1.13

16. Safety Injection (SI) 1,2 2 trains 0

SR 3.3.1.12 NA NA Input from Engineered Safety Feature Actuation System (ESFAS)

17. Reactor Trip System Interlocks

a.

Intermediate 2(e) 2 p SR 3.3.1.g'ffl(§J!(b)(c)l 6E-11 amp Nominal Range Neutron SR3.3.1.11~ 1E-10 amp Flux, P-6

b.

Low Power Reactor Trips Block, P-7

1) P10 Input 4

Q SR 3.3.1.9~ !<b)(c\\ ~ 13% RTP Nominal SR3.3.1.11 ~ 10% RTP

2) Turbine Inlet Pressure.

1 2 Q SR 3.3.1.9ffl(sl !(b)(c{ I S 13% Nominal SR 3.3.1.11 (~ ine power 10% turbine power (b) 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. (c) 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. etpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual oint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and th used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. !methodology r21 (e) Below the P-6 (Intermediate Range Neutron Flux) interlocks. (f) Tile iAstnimeAt sllaAAel setpeiAt shall ee reset ta a tJa(ije witlliA tile salieratieA teleraAGe of tile T SetpeiAt at tile sempletieA of tile smveillaAse; etlle1wise, tile GllaAAel shall ea EleslareEI iASperaele. !Deleted I (g) If tl:le iAstrijmeAt sllaAAel setpeiAt is less GeAsewatitJe tllaA tile l'.llewael ~aAEI witlliA 12 ll8ijF6 EletermiAe tile affeGteEI GllaAAel is OPER,Cl,BlE; 8 Deleted ~------~-----~ (h) Above the P-7 (Low Power Reactor Trips Block) interlock. Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence. Turkey Point Unit 3 and Unit 4 3.3.1-14 Amendment Nos. 297 and 290

1.

(a) (b) (c) FUNCTION Table 3.3.2-1 (page 1 of 7) ESFAS Instrumentation 3.3.2 Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT Safety Injection

a.

b.

c.

d.

e.

Manual Initiation 1,2,3,4 2 B SR 3.3.2.5 NA NA Automatic 1,2,3,4 2 trains C SR3.3.2.2 NA NA Actuation Logic and Actuation Relays Containment 1,2,3 3 E SR 3.3.2.2 s 4.5 psig s 4.0 psig Pressure - High SR 3.3.2.6(b)(c) 11725 I Pressurizer 1,2,3(a) 3 E SR 3.3.2.1 2: 4742 psig 2: 1730 psig Pressure - Low SR 3.3.2.3(b)(c) SR 3.3.2.6(b)(c) 11011 High Differential 1,2,3(a) 3 per steam E SR 3.3.2.1 s 4-t4 psi s 100 psi Pressure line SR 3.3.2.3(b)(cJ Between Steam SR 3.3.2.6(b)(c) Line Header and any Steam Generator (SG) Above the P-11 (Pressurizer Pressure) interlock. The instrument channel setpoint shall be reset to a *,mlue within the calibration tolerance of the Trip Setpoint at the completiGA-ef--#le surveillance; otherwise, the channel shall be declared inoperable..- lf the instruR'lent channel setpoint is less conservati>1e than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours cleterR'line the affeetecl channel is OPERABLE; otherwise, the channel shall be cleclar:ecl inoperable. If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be eval ated to verify that it is functioning as required before returning the channel to service. 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 methodology used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. Turkey Point Unit 3 and Unit 4 3.3.2-7 Amendment Nos. 297 and 290

1.

FUNCTION Table 3.3.2-1 (page 2 of 7) ESFAS Instrumentation 3.3.2 Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT Safety Injection (continued)

f.

g.

Steam Line Flow - High Coincident with Tavg - Low Steam Line Flow - High Coincident with Steam Generator Pressure - Low 1,2,3(d) 2 per steam line 1,2,3(d) 1 per loop 1,2,3(d) 2 per steam line 1,2,3(d) 1 per SG E E E E SR 3.3.2.1 (e) SR 3.3.2.3(g)(h)!(b)(c) I SR 3.3.2.6(g)(h) j(b)(c)lj542_? ! SR 3.3.2.1 .? ~

• F SR 3.3.2.3(b)(c)

SR 3.3.2.6(b)(c) SR 3.3.2.1 (e) SR3.3.2.~ SR 3.3.2.6(GWJ}!(b)(c) ! SR 3.3.2.1 .? 607 psig(i) SR3.3.2.~ SR 3.3.2.~ !(b)(c) I (f) .? 543.0°F (f) 614 psig(i)

2.

Containment Spray (d) (e) (f)

a.

Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C SR 3.3.2.2 NA NA The instrument shannel setf)oint shall be Feset to a val1,1e within the salibration toleranse of the Trifl Setf)oint at the semf)letion of the swveillanse; otherwise, the shannel shall be deslared inof)erable:- If the instrument shannel setf)oint is less sonservative than the,A.llowable Val1,1e, the setf)oint shall be Feset sonsistent with the Trifl Setpoint and,.,..ithin 12 ho1,1rs determine the affected shannel is OPERABLE* otherwise the shannel shall be declared ir:ioperable Remove strikeout shown in original Above the (T avg - Low) interlock. LAR (ML23320A028, ML23320A029) from this sentence. Less than or equal to a function defined as 6P corresnm"l7111,n-,rrr:lln-;rv,;.-.:m:s1'tfflnmim"?:rrnro,;;--irrn:ic~ ffl'l'l,m"'rea ing linearly from 20% load to 114.4% steam flow at 100% load. Less than or equal to a function defined as 6P corresponding to 40.0% steam flow at 0% load, and increas ng linearly from 20% load to 114.0% steam flow at 100% load. (m ~ If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be eval ated to verify that it is functioning as required before returning the channel to service. W [§] The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the No

• I 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

~-----~ *e used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. methodology 1 ime constants used in the lead/lag controller are 11.? 50 seconds and t2 s 5 seconds. Turkey Point Unit 3 and Unit 4 3.3.2-8 Amendment Nos. 297 and 290

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 7) Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT

2.

Containment Spray (continued)

b. Containment 1,2,3 Pressure-High High Coincident with 1,2,3 Containment Pressure - High

3.

Containment Isolation

a. Phase A Isolation (1) Manual 1,2,3,4 Initiation (2) Automatic 1,2,3,4 Actuation Logic and Actuation Relays 3

E 3 E 2 8 2 trains C SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6(b)(cJ SR 3.3.2.2 SR 3.3.2.4 SR 3.3.2.6(b)(cJ SR 3.3.2.5 SR 3.3.2.2 ~ S ~ psig s 20.0 psig s 4.5 psig S4.0 psig NA NA NA NA (3) Safety Refer to Function 1 (Safety Injection) for all initiation functions and requirements. Injection

b.

Phase 8 Isolation (1) Manual 1,2,3,4 2 F SR 3.3.2.5 NA NA Initiation (2) Automatic 1,2,3,4 2 trains C SR 3.3.2.2 NA NA Actuation Logic and Actuation Relays (b) The instrument shannel setpoint shall be reset to a *,mlue within the salibration toleranse of the Trip Setpoint at the sompletion of the surveillanse; otherwise, the channel shall be declared inoperaele,. (c) If the instrument channel setpoint is less conseNali,..e than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours determine the affested shannel is OPERABLE; otherwise, the channel shall be declared inoperable. 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. 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 methodology used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2. ur ey om rn an rn men ment os.

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 4 of 7) Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT

3.

Containment Isolation

b. Phase B Isolation (continued) 120.7 I (3) Containment 1,2,3 3

SR 3.3.2.2 s ~ psig s 20.0 psig Pressure SR 3.3.2.4 High High SR 3.3.2.6Cb)(c) Coincident 1,2,3 3 SR 3.3.2.2 s 4.5 psig S4.0 psig with SR 3.3.2.4 Containment SR 3.3.2.6(b)(c) Pressure - High

4.

Steam Line Isolation

a.

Manual Initiation 1,20l,30l 1 per steam J SR 3.3.2.5 NA NA line

b.

Automatic 1,20l,3(i) 2 trains D SR 3.3.2.2 NA NA Actuation Logic and Actuation Relays 120.7 1

c.

Containment 1,20l,3(i) 3 SR 3.3.2.2 S ~ psig s 20.0 psig Pressure - High - SR 3.3.2.4 High SR 3.3.2.6(b)(c) Coincident with 1,2(i),30l 3 SR 3.3.2.2 Containment SR 3.3.2.4 s 4.5 psig s 4.0 psig Pressure - High SR 3.3.2.6(b)(c) (b) The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable. (c) If the instrument channel setpoint is less conservatii.*e than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable. i (j) Except when all MSIVs are closed and deactivated. 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. 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 methodology used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2 Turkey Point Unit 3 and Unit 4 3.3.2-10 Amendment Nos. 297 and 290

4.

FUNCTION Table 3.3.2-1 (page 5 of 7) ESFAS Instrumentation 3.3.2 Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT Steam Line Isolation (continued)

d.

Steam Line Flow 1,20J,3(i) -High Coincident with 1,20J,3(i) Tavg - Low

e. Steam Line Flow 1,2ul,3ul

-High Coincident with 1,2m,3ul Steam Generator Pressure - Low 2 per steam line 1 perloop E 2 per steam line 1 perSG SR 3.3.2.1,_.,k~ (e) SR3.3.2.3~ SR3.3.2.~ l542.7! SR 3.3.2.1 SR 3.3.2.3(b)(c) SR 3.3.2.6(b)(c) SR 3.3.2.1 (e) SR 3.3.2.3{g)(b)!(b)(c) I SR 3.3.2.~i(b)(c) I SR 3.3.2.1 ~ 607 psig(i) SR 3.3.2.~ i(b)(c) I SR 3.3.2.~ j(b)(c) I (f) ~ 543.0°F (f) 614 psig(i) (a) The iAstFl:lmeAt shaAAel setpoiAt shall be r:eset to a vall:le withiA the salibratioA toleraAse of the Trip SetpoiAt at the completion of the sYrveillance; otherwise, the channel shall be declared inoperable. (6) If the instrumeAt shaAAel setpoiAt is less coAservati'.*e thaA the Allowable \\lall:le, the setpoiAt shall be reset coAsisteAt with the Trip SetpoiAt aAd withiA 12 hol:lFS determiAe the affected chaAAel is OPERABLE; otherwise, the chaAAel shall be declared iAoperable. (e) Less than or equal to a function defined as 11P corresponding to 41.2% steam flow at 0% load, and increasing linearly from 20% load to 114.4% steam flow at 100% load. (f) Less than or equal to a function defined as 11P corresponding to 40.0% steam flow at 0% load, and increasing linearly from 20% load to 114.0% steam flow at 100% load. ffi) ~ 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. (A) [sill 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 t he actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. Th TSP and !methodology ~ ethedoloi;iies used to determine the as-found and as-left tolerances are specified in UFSAR Sec

• n 7.2.

(i) Time constants used in the lead/lag controller are t1 ~ 50 seconds and t2 =,; 5 seconds.

0)

Except when all MSIVs are closed and deactivated. Turkey Point Unit 3 and Unit 4 3.3.2-11 Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence. Amendment Nos. 297 and 290

Table 3.3.2-1 (page 6 of 7) ESFAS Instrumentation 3.3.2 Engineered Safety Feature Actuation System Instrumentation FUNCTION

5.

Feedwater Isolation

a.

Automatic Actuation Logic and Actuation Relays

b.

SG Water Level - High High

c.

Safety Injection

6.

Auxiliary Feedwater

a.

Automatic Actuation Logic and Actuation Relays

b.

SG Water Level - Low Low

c.

Safety Injection

d.

Bus Stripping

e. Trip of all Main Feedwater Pumps Breakers APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE TRIP SETPOINT 2 trains D

SR 3.3.2.2 NA NA 3 perSG SR 3.3.2.1 ~ 80.5% SR 3.3.2.3(o){b}~ 80.0% SR 3.3.2.~ !(b)(c) ! Refer to Function 1 (Safety Injection) for all initiation functions and requirements. 1,2,3 2 trains D SR 3.3.2.2 NA NA 1,2,3 3 perSG SR 3.3.2.1 ~ 15.5% SR 3.3.2.3(o){b} !(b)(c) I 16.0% E SR 3.3.2.6(o){b} !(b)(c) I Refer to Function 1 (Safety Injection) for all initiation functions and requirements. 1,2,3 1,2 1 per bus 1 per breaker G H SR 3.3.2.4 SR 3.3.2.6 SR 3.3.2.4 NA NA See LCO 3.3.5, "LOP EDG Start Instrumentation," for Trip Setpoints NA ffi) ~ 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. ~ [@] 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 t e actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The N SP and .--------, th used to determine the as-found and as-left tolerances are specified in UFSAR Section 7 2. methodology Except when all MFIVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by manual valve. Remove strikeout shown in original LAR (ML23320A028, ML23320A029) from this sentence. Turkey Point Unit 3 and Unit 4 3.3.2-12 Amendment Nos. 297 aAd 290

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Control Room Envelope (CRE) Habitability Program ( continued) 5.5.16

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation with one CREVS train operating at the flow rate required by the VFTP, at a Frequency in accordance with the Surveillance Frequency Control Program. The results shall be trended and used as part of the assessment of the CRE boundary.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively. Surveillance Frequency Control Program The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

b.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1 oras specifically ...__ ____ approved C. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable by the to the Frequencies established in the Surveillance Frequency Control NRC. Program. Turkey Point Unit 3 and Unit 4 5.5-13 Amendment Nos. 297 and 290

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2024-173 Revised Turkey Point Units 3&4 Technical Specification Bases Markup Pages (24 pages follow)

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML23320A028, ML23320A029. RTS Instrumentation B 3.3.1 B 3.3 INSTRUMENTATION B 3.3.1 Reactor Trip System (RTS) Instrumentation BASES BACKGROUND The nominal trip setpoint provides the LSSS per Reference 7. The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and Reactor Coolant System (RCS) pressure boundary during anticipated operational occurrences (AOOs) and to assist the Engineered Safety Features (ESF) Systems in mitigating accidents. The protection and monitoring systems have been designed to assure safe operation of the reactor. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the RTS, as well as specifying LCOs on other reactor system parameters and equipment performance. Technical Specifications are required by 10 CFR 50.36 to include LSSS for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a sa e

• has been placed, the setting must be chosen so that automatic pro e
• ctions will correct the abnormal situation before a Safety Limit (SL) is excee The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur.

The Allowable Value specified in Table 3.3.1-1 is a predetermined limit for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. The Trip Setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the Trip Setpoint ensures that Sls are not exceeded between instrument calibrations. Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as "... being capable of performing its Turkey Point Unit 3 and Unit 4 B 3.3.1-1 Revision No. O

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 BASES BACKGROUND (continued) safety functions(s)." Relying solely on the Trip Setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as-found" value of a protection channel setting during a surveillance. To ensure the instrument is functioning as predicted, the change in the trip setting since the last test or calibration is verified to be within predefined limits (double-sided acceptance criteria band) and appropriate actions are WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 24-Month Fuel Cycle" r---.tak:en if the change is outside these limits. The acceptance criteria band WCAP-18888-P uses the setpoint methodology from WCAP-17504-P-A (Ref. 7). is derive et o*nt calculation based on the setpoint methodology described '.0.'CAP 1 ~74e, "'.O.'estiRSl=le1::1se S0t13eiRt Metl=leelelesy fer PretestieR Systems T1::1rk0y PeiRt URits -~ aRa 4" (R.ef: e), eF 'lvCAP 17070, "'A'estinghouse Setpoint Methodology for Protection Systems Turl<<3y Point Units a and 4" (Ref. 7), as a1313liea~l0. 161 If the trip setting exceeds the Allowable Varoe the channel is inoperable. If the change in the trip setting exceeds the predefined limits but the setting is conservative with respect to the Allowable Value, and during the surveillance the instrument channel is functioning as expected and can be reset to within the setting tolerance of the Trip Setpoint, then the channel may be returned to service and the condition entered into the corrective action program for further evaluation. However, if during the surveillance the change in the trip setting exceeds the predefined limits and it cannot be determined that the instrument channel is functioning as required, then the instrument is declared inoperable. Thus, verifying the trip setting is within the acceptance criteria band during test or calibration is part of the determination that an instrument is functioning as required. Therefore, the channel would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the channel within the established calibration tolerance around the Trip Setpoint to account for further drift during the next surveillance interval. During AOOs, which are those events expected to occur one or more times during the unit life, the acceptable limits are:

1.

The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the Safety Limit (SL) value to prevent departure from nucleate boiling (DNB),

2.

Fuel centerline melt shall not occur, and

3.

The RCS pressure SL of 2735 psig shall not be exceeded. Turkey Point Unit 3 and Unit 4 B 3.3.1-2 Revision No. O

BASES This page replaces revises the Bases markup page submitted in ADAMS Accession No. L23320A028, ML23320A029. RTS Instrumentation B 3.

3.1 BACKGROUND

(continued) Operation within the Sls of Specification 2.0, "Safety Limits (Sls)," also maintains the above values and assures that offsite dose will be within the 10 CFR 50 and 10 CFR 100 criteria during AOOs. Accidents are events that are analyzed even though they are not expected to occur during the unit life. The acceptable limit during accidents is that offsite dose shall be maintained within an acceptable fraction of 10 CFR 50.67 limits. Different accident categories are allowed a different fraction of these limits, based on probability of occurrence. Meeting the acceptable dose limit for an accident category is considered having acceptable consequences for that event. The RTS instrumentation is segmented into four distinct but interconnected modules as illustrated in Figure 7.2-3A, UFSAR, Chapter 7 (Ref. 2), and as identified below:

1.

Field transmitters or process sensors: provide a measurable electronic signal based upon the physical characteristics of the parameter being measured,

2.

Signal Process Control and Protection System, including Analog Protection System, Nuclear Instrumentation System (NIS), field contacts, and protection channel sets: provides signal conditioning, bistable setpoint comparison, process algorithm actuation, compatible electrical signal output to protection system channels, and control board/control room/miscellaneous indications,

3.

Reactor Protection System, including input, logic, and output bays: initiates proper unit shutdown and/or ESF actuation in accordance with the defined logic, and

4.

Reactor trip switchgear, including reactor trip breakers (RTBs) and bypass breakers: provides the means to interrupt power to the control rod drive mechanisms (CRDMs) and allows the rod cluster control assemblies (RCCAs), or "rods," to fall into the core and shut down the reactor. The bypass breakers allow testing of the RTBs at power. Field Transmitters or Sensors To meet the design demands for redundancy and reliability, more than one, and often as many as four, field transmitters or sensors are used to measure unit parameters. To account for the calibration tolerances and instrument drift, which are assumed to occur between calibrations, statistical allowances are provided in the Trip Setpoint and Allowable Turkey Point Unit 3 and Unit 4 B 3.3.1-3 Revision No. O

This page replaces revises the Bases markup page submitted in ADAMS Accession No. L23320A028, ML23320A029. RTS Instrumentation B 3.3.1 BASES BACKGROUND (continued) Value. The OPERABILITY of each transmitter or sensor is determined by either "as-found" calibration data evaluated during the CHANNEL CALIBRATION or by qualitative assessment of field transmitter or sensor as related to the channel behavior observed during performance of the CHANNEL CHECK. Signal Process Control and Protection System Generally, three or four channels of process control equipment are used for the signal processing of unit parameters measured by the field instruments. The process control equipment provides signal conditioning, comparable output signals for instruments located on the main control board, and comparison of measured input signals with Trip Setpoints derived from Analytical Limits established by the safety analyses. Analytical Limits are defined in UFSAR, Chapter 7 (Ref. 2), and Chapter 14 (Ref. 3). If the measured value of a unit parameter exceeds the predetermined setpoint, an output from a bistable is forwarded to the logic racks for decision evaluation. Channel separation is maintained up to and through the input bays. However, not all unit parameters require four channels of sensor measurement and signal processing. Some unit parameters provide input only to the logic racks, while others also provide input to the main control board, the unit computer, and one or more control systems. Generally, if a parameter is used only for input to the protection circuits, three channels with a two-out-of-three logic are sufficient to provide the required reliability and redundancy. If one channel fails in a direction that would not result in a partial Function trip, the Function is still OPERABLE with a two-out-of-two logic. If one channel fails, such that a partial Function trip occurs, a trip will not occur and the Function is still OPERABLE with a one-out-of-two logic. Generally, if a parameter is used for input to the SSPS and a control function, four channels with a two-out-of-four logic are sufficient to provide the required reliability and redundancy. The circuit must be able to withstand both an input failure to the control system, which may then require the protection function actuation, and a single failure in the other channels providing the protection function actuation. Again, a single failure will neither cause nor prevent the protection function actuation. These requirements are described in IEEE-279-1971 (Ref. 4). The actual number of channels required for each unit parameter is specified in Reference 2. Turkey Point Unit 3 and Unit 4 B 3.3.1-4 Revision No. O

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 BASES BACKGROUND (continued) Trip Setpoints (as enveloped by the as found tolerance in the non-conservative direction) Trip Setpoints (as enveloped by the as found tolerance in the non-conservative direction) Two logic channels are required to ensure no single random failure of a logic channel will disable the RTS. The logic channels are designed such that testing required while the reactor is at power may be accomplished without causing trip. Provisions to allow removing logic channels from service during maintenance are unnecessary because of the logic system's designed reliability. Allowable Values and Trip Setpoints 18888-P (Ref. 6) The trip setpoints used in the bistables are bas ~d on analytical limits specified in the safety analyses. The calculati in of the Trip Setpoint specified in Table 3.3.1-1 is such that adequa =- protection is provided when all sensor and processing time delays a *e taken into account. To allow for calibration tolerances, instrumentati n uncertainties, instrument drift, and severe environment errors for thos RTS channels that must unction in harsh environments as defined b 10 CFR 50.49 (Ref. 5), the ,".ll8W8Ble 'lsl~es specified in Table 3.3.1-1 *n the accompanying LCO are conservative with respect to the analytical Ii nits. A detailed description of the methodology used to calculate the Alla able Values and Trip Setpoint, including their explicit uncertainti.s, and as-left and as-found tolerance bands, is provided in Westingh e topical reports \\AiGAP 127 4 e (Ref. 6) sr~e WCAP-which incorporates all of the known uncertainties applicable to each channel. A summary description of and reference to the calibration tolerance methodology is provided in UFSAR Section 7.2 (Ref. 2). The magnitudes of these uncertainties are factored into the determination of each Trip Setpoint and corresponding Allowable Value. The trip setpoint entered into the bistable is more conservative than that specified by the Allowable Value to account for measurement errors detectable by the CHANNEL OPERATIONAL TEST (COT). The Allowable Value serves as the Technical Specification OPERABILITY limit for the purpose of the COT. The Trip Setpoint is the value at which the bistable is set and is the expected value to be achieved during calibration. The All8W8Ble \\,<sl~e i~ tl;;i9 beee s1-1 EI ensures the safety analysis limits are met during the surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as-left" Trip Setpoint value is within the calibration tolerance for CHANNEL CALIBRATION uncertainty allowance (i.e.,~ rack calibration s1-1 EI ee!'1~8F8~8F setting uncertainties). Trip Setpoints, in conjunction with the use of calibration tolerances, together with the requirements of the Allowable Value ensure that SLs are not violated during AOOs (and that the consequences of DBAs will be acceptable, providing the unit is operated from within the LCOs at the onset of the AOO or OBA and the equipment functions as designed). Turkey Point Unit 3 and Unit 4 B 3.3.1-5 Revision No. 0

BASES jThis page is for information only. No changes are proposed for this page. RTS Instrumentation B 3.

3.1 BACKGROUND

(continued) Note that the Allowable Values listed in Table 3.3.1-1 are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, COTs, or a TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT) that requires trip setpoint verification. Each channel of the process control equipment can be tested on line to verify that the signal or setpoint accuracy is within the specified allowance requirements of Reference 2. Once a designated channel is taken out of service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then tested, verified, and calibrated. SRs for the channels are specified in the SRs section. Logic Racks The Logic Racks equipment is used for the decision logic processing of outputs from the signal processing equipment bistables. To meet the redundancy requirements, two trains of Logic Racks, each performing the same functions, are provided. If one train is taken out of service for maintenance or test purposes, the second train will provide reactor trip and/or ESF actuation for the unit. If both trains are taken out of service or placed in test, a reactor trip will result. Each train is packaged in its own cabinet for physical and electrical separation to satisfy separation and independence requirements. The system has been designed to trip in the event of a loss of power, directing the unit to a safe shutdown condition. The Logic Racks perform the decision logic for actuating a reactor trip or ESF actuation, generates the electrical output signal that will initiate the required trip or actuation, and provides the status, permissive, and annunciator output signals to the main control room of the unit. The bistable outputs from the signal processing equipment are sensed by the Logic Racks equipment and combined into logic matrices that represent combinations indicative of various unit upset and accident transients. If a required logic matrix combination is completed, the system will initiate a reactor trip or send actuation signals via master and slave relays to those components whose aggregate Function best serves to alleviate the condition and restore the unit to a safe condition. Examples are given in the Applicable Safety Analyses, LCO, and Applicability sections of this Bases. Turkey Point Unit 3 and Unit 4 B 3.3.1-6 Revision No. O

This page is for information only. No changes are proposed for this page. BASES RTS Instrumentation B 3.

3.1 BACKGROUND

(continued) APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY Reactor Trip Switchgear The RTBs are in the electrical power supply line from the control rod drive motor generator set power supply to the CRDMs. Opening of the RTBs interrupts power to the CRDMs, which allows the shutdown rods and control rods to fall into the core by gravity. Each RTB is equipped with a bypass breaker to allow testing of the RTB while the unit is at power. During normal operation voltage energizes the undervoltage coils in the RTBs and bypass breakers, if in use. When the required logic matrix combination is completed, the output voltage signal is removed, the undervoltage coils are de-energized, the breaker trip lever is actuated by the de-energized undervoltage coil, and the RTBs and bypass breakers are tripped open. This allows the shutdown rods and control rods to fall into the core. In addition to the de-energization of the undervoltage coils, each breaker is also equipped with a shunt trip device that is energized to trip the breaker open upon receipt of a reactor trip signal from the Logic Racks. Either the undervoltage coil or the shunt trip mechanism is sufficient by itself, thus providing a diverse trip mechanism. The decision logic matrix Functions are described in the functional diagrams included in Reference 2. In addition to the reactor trip or ESF, these diagrams also describe the various "permissive interlocks" that are associated with unit conditions. Each train has a built-in testing device that can automatically test the decision logic matrix Functions and the actuation channels while the unit is at power. When any one train is taken out of service for testing, the other train is capable of providing unit monitoring and protection until the testing has been completed. The testing device is semiautomatic to minimize testing time. The RTS functions to preserve the SLs during all AOOs and mitigates the consequences of DBAs in all MODES in which the Rod Control System is capable of rod withdrawal or one or more rods are not fully inserted. Each of the analyzed accidents and transients can be detected by one or more RTS Functions. The accident analysis described in Reference 3 takes credit for most RTS trip Functions. RTS trip Functions that are retained yet not specifically credited in the accident analysis are implicitly credited in the safety analysis and the NRC staff approved licensing basis for the unit. These RTS trip Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. They may also serve as backups to RTS trip Functions that were credited in the accident analysis. Turkey Point Unit 3 and Unit 4 8 3.3.1-7 Revision No. O

rack BASES RTS Instrumentation B 3.3.1 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses. These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur. Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy. tolerances The LCO requires all instrumentation performing an RTS Function, listed in Table 3.3.1-1 to be OPERABLE. The Allowable Value specified in Table 3.3.1-1 is the least conservative value of the as-found setpoint that the channel can have when tested, such that a channel is OPERABLE if the as-found setpoint is within the calibration tolerance and is conservative with respect to the Allowable Value during a CHANNEL CALIBRATION or COT. As such, the Allowable Value differs from the Trip Setpoint by an amount greater than or equal to the expected ins r channel uncertainties, such as drift, during the surveillance interval. In this manner, the actual setting of the channel Trip Setpoint will ensure that a SL is not exceeded at any given point of time as long as the channel has not drifted beyond expected tolerances during the surveillance interval. Note that, although the channel is OPERABLE under these circumstances, the trip setting must be left adjusted to a value within the calibration tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology, and confirmed to be operating within the statistical allowances of the uncertainty terms assigned. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the calibration tolerance, tRe channel is OPERABLE but degraded. The degraded condition of the channel will be further evaluated during performance of the SR. This evaluation will consist of resetting the channel setpoint to the Trip Setpoint (within the allowed tolerance), and evaluating the channel's response. If the channel is functioning as required and is expected to pass the next surveillance, then the channel is OPERABLE and can be restored to service at the completion of the surveillance. After the surveillance is completed, the channel as-found condition will be entered into the Corrective Action Program for further evaluation. Turkey Point Unit 3 and Unit 4 B 3.3.1-8 Revision No. O

BASES This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) A trip setpoint may be set more conservative than the Trip Setpoint as necessary in response to plant conditions. However, in this case, the OPERABILITY of this instrument must be verified based on the field setting and not the Trip Setpoint. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions. The LCO generally requires OPERABILITY of four or three channels in each instrumentation Function, two channels of Manual Reactor Trip in each logic Function, and two trains in each Automatic Trip Logic Function. Four OPERABLE instrumentation channels in a two-out-of-four configuration are required when one RTS channel is also used as a control system input. This configuration accounts for the possibility of the shared channel failing in such a manner that it creates a transient that requires RTS action. In this case, the RTS will still provide protection, even with random failure of one of the other three protection channels. Three OPERABLE instrumentation channels in a two-out-of-three configuration are generally required when there is no potential for control system and protection system interaction that could simultaneously create a need for RTS trip and disable one RTS channel. The two-out-of-three and two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing a reactor trip. Specific exceptions to the above general philosophy exist and are discussed below. Reactor Trip System Functions The safety analyses and OPERABILITY requirements applicable to each RTS Function are discussed below:

1.

Manual Reactor Trip The Manual Reactor Trip ensures that the control room operator can initiate a reactor trip at any time by using either of two reactor trip switches in the control room. A Manual Reactor Trip accomplishes the same results as any one of the automatic trip Functions. It is used by the reactor operator to shut down the reactor whenever any parameter is rapidly trending toward its Trip Setpoint. The manual actuating devices are independent of the automatic trip circuitry, and are not subject to failures which make the automatic circuitry inoperable. The LCO requires two Manual Reactor Trip channels to be OPERABLE. Each channel is controlled by a manual reactor trip switch. Each channel activates the reactor trip breaker in both trains. Two independent channels are required to be OPERABLE so that no single random failure will disable the Manual Reactor Trip Function. Turkey Point Unit 3 and Unit 4 B 3.3.1-9 Revision No. 0

BASES RTS Instrumentation B 3.3.1 SURVEILLANCE REQUIREMENTS (continued) are declared inoperable. This Surveillance is performed to verify the f(~I) input to the overtemperature ~ T Function. A Note modifies SR 3.3.1.6. The Note states that this Surveillance is required only if reactor power is > 75% RTP and that 24 hours is allowed for performing the first surveillance after reaching 75% RTP. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.7 SR 3.3.1. 7 is the performance of a COT. A COT is performed on each required channel to ensure the entire channel will perform the intended Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. Setpoints must be conservative with respect to the Allowable Values specified in Table 3.3.1-1. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology. The setpoint shall be left set consistent with the assumptions of the current unit specific setpoint methodology. The "as-found" and "as-left" values must also be recorded and reviewed for consistency with the assumptions of Reference +. SR 3.3.1. 7 is modified by a Note that provides a 4 ~ s delay in the requirement to perform this Surveillance for source range instrumentation when entering MODE 3 from MODE 2. This Note allows a normal shutdown to proceed without a delay for testing in MODE 2 and for a short time in MODE 3 until the RTBs are open and SR 3.3.1. 7 is no longer required to be performed. If the unit is to be in MODE 3 with the RTBs closed for> 4 hours this Surveillance must be performed prior to 4 hours after entry into MODE 3. Turkey Point Unit 3 and Unit 4 B 3.3.1-42 Revision No. 0

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 BASES SURVEILLANCE REQUIREMENTS (continued) and methodology of Reference 7 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.7 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in ccordance with safety analysis assumptions and the channel pe nee assumptions in the setpoint methodology. The purpose of the assess is to ensure confidence in the channel performance prior to returning the cha t service. For channels determined to be OPERABLE but degrade, ~ returning the channel to service the 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. ~Jatos (o), (f), and (g) require that the as-left setting for the channel be returned to wi in the calibration tolerance of the Trip Setpoint. Where a setpoint more c nservative than the Trip Setpoint is used in the plant surveillance proce res (field setting), the calibration tolerances, as applicable, will be appli d to the surveillance procedure setpoint. This will ensure that sufficient argin to the Safety Limit and/or Analytical Limit is maintained. If the as-ft channel setting cannot be returned to a setting within the calibration to ranee of the Trip Setpoint, then the channel shall be declared inoperable. Note (c) requires The Note (c) also requires that the nominal Trip Setpoint and the "ff*~36E**~* *' for calculating the as-left and the as-found tolerances be specified in Reference 2. SR 3.3.1.8 SR 3.3.1.8 is the performance of a COT as described in SR 3.3.1.7, except it is modified by a Note that this test shall include verification that the P-6 and P-10 interlocks are in their required state for the existing unit condition. This verification can be performed by observation of the permissive annunciator window. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test should also include verification of the High Flux at Shutdown Alarm Setpoint of Yz decade above the existing count rate. The Frequency is modified by a Note that allows this surveillance to be satisfied if it has been performed within the Turkey Point Unit 3 and Unit 4 B 3.3.1-43 Revision No. 0

and BASES This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 SURVEILLANCE REQUIREMENTS (continued) methodology of Reference 7 Frequency specified in the Surveillance Frequency Control Program. The Frequency of "prior to startup" ensures this surveillance is performed prior to critical operations and applies to the source, intermediate and power range low instrument channels. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.8 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in rdance with safety analysis assumptions and the channel perfor e assumptions in the setpoint methodology. The purpose of the assessme

• to ensure confidence in the channel performanc to returning the chan to service. For channels determined to b Note (c) requires OPERABLE but degraded, 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 ensure required review and documentation of the condition.

and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable. e Note (c) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be specified in Reference 2. SR 3.3.1.9 SR 3.3.1.9 is the performance of a CHANNEL CALIBRATION. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or Turkey Point Unit 3 and Unit 4 B 3.3.1-44 Revision No. O

and BASES This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 SURVEILLANCE REQUIREMENTS (continued) preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.9 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. 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 ,no-....:.i...,,essment is to ensure confidence in the channel performance prior to returning el to service. For channels determined to Y,....-------, OPERABLE but degrade, a#ef returning the channel to service Note (c) requires performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program wi ensure required review and documentation of the condition. and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the methodology of Reference 7 calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable. The Note (c) also requires that the nominal Trip Setpoint and the

---

~ n:1ethodologies for calculating the as-left and the as-found tolerances be specified in Reference 2.

SR 3.3.1.10 SR 3.3.1.10 is the performance of a CHANNEL CALIBRATION. This SR is modified by a Note stating that this test shall include verification of the RCS resistance temperature detector (RTD) bypass loop flow rate. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. Turkey Point Unit 3 and Unit 4 B 3.3.1-45 Revision No. O

and BASES This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RTS Instrumentation B 3.3.1 SURVEILLANCE REQUIREMENTS (continued) This test will verify the rate lag compensation for flow from the core to the RTDs. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.1.10 is modified by Notes as identified in Table 3.3.1-1. Note (b) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. 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 essment is to ensure confidence in the channel performance prior to returning nel to service. For channels determined to b Note (c) requires OPERABLE but degrade, 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 w*1 ensure required review and documentation of the condition. and (g) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable. methodology of Reference 7 The Note (c) also requires that the nominal Trip Setpoint and the L--------? methodologies for calculating the as-left and the as-found tolerances be specified in Reference 2. SR 3.3.1.11 SR 3.3.1.11 is the performance of a COT of RTS interlocks. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Turkey Point Unit 3 and Unit 4 B 3.3.1-46 Revision No. 0

BASES jThis page is for information only. No changes are proposed for this page. RTS Instrumentation B 3.3.1 SURVEILLANCE REQUIREMENTS (continued) SR 3.3.1.12 SR 3.3.1.12 is the performance of a TADOT of the Manual Reactor Trip, RCP Breaker Position, and the SI Input from ESFAS. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and Reactor Trip Bypass Breakers. The Reactor Trip Bypass Breaker test shall include testing of the automatic undervoltage trip. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The SR is modified by a Note that excludes verification of setpoints from the TADOT. The Functions affected have no setpoints associated with them. SR 3.3.1.13 SR 3.3.1.13 is the performance of a TADOT of Turbine Trip Functions. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This TADOT is as described in SR 3.3.1.4, except that this test is performed prior to exceeding the P-7 interlock whenever the unit has been in MODE 3. This Surveillance is not required if it has been performed within the previous 31 days. Verification of the Trip Setpoint does not have to be performed for this Surveillance. Performance of this test will ensure that the turbine trip Function is OPERABLE prior to exceeding the P-7 interlock. Turkey Point Unit 3 and Unit 4 B 3.3.1-47 Revision No. O

BASES This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. RT$ Instrumentation B 3.

3.1 REFERENCES

1.

Regulatory Guide 1.105, Revision 3, "Setpoints for Safety Related Instrumentation."

---

1

2.

UFSAR, Chapter 7.

3.

UFSAR, Chapter 14.

4.

IEEE-279-1971.

5.

1 O CFR 50.49. WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 24-Month Fuel Cycle", January 2024.

6.

WCAP 12746, Re11isieR Q, 11lA'estiRgl:ie1:1se Set1:1eim-Metl:i0elelegy feF PFetestieR Systeffls +1:1Fl~0y PeiRt URits a aREI 4 Tl:ieFfflal U1:1 Fate PFejest," ~evefflBBF 1 QQQ.

7. WCAP-17504-P-A, Revision 1, "Westinghouse Generic Setpoint Methodology," October 2016.

Turkey Point Unit 3 and Unit 4 B 3.3.1-48 Revision No. 0

This page replaces revises the Bases markup page submitted in ADAMS Accession No. Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 ML23320A028, ML23320A029. B 3.3 INSTRUMENTATION B 3.3.2 Engineered Safety Features Actuation System (ESFAS) Instrumentation BASES BACKGROUND The nominal trip setpoint provides the LSSS per Reference 14. The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to mitigate accidents. This is achieved by specifying limiting safety system settings (LSSS) in terms of parameters directly monitored by the ESFAS, as well as specifying LCOs on other reactor system parameters and equipment performance. Technical Specifications are required by 10 CFR 50.36 to include LSSS for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a et limit has been placed, the setting must be chosen so that automa 1c actions will correct the abnormal situation before a Safety Limit (SL) is excee The Analytical Limit is the limit of the process variable at which a protective action is initiated, as established by the safety analysis, to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The Allowable Value (AV) specified Table 3.3.2-1 is a predetermined limit for a protection channel chosen to ensure automatic actuation prior to the process variable reaching the Analytical Limit and thus ensuring that the SL would not be exceeded. The Trip Setpoint accounts for uncertainties in setting the channel (e.g., calibration), uncertainties in how the channel might actually perform (e.g., repeatability), changes in the point of action of the channel over time (e.g., drift during surveillance intervals), and any other factors which may influence its actual performance (e.g., harsh accident environments). In this manner, the Trip Setpoint ensures that SLs are not exceeded between instrument calibrations. Technical Specifications contain values related to the OPERABILITY of equipment required for safe operation of the facility. OPERABLE is defined in Technical Specifications as "... being capable of performing its safety functions(s)." Relying solely on the Trip Setpoint to define OPERABILITY in Technical Specifications would be an overly restrictive requirement if it were applied as an OPERABILITY limit for the "as-found" value of a protection channel setting during a surveillance. To ensure the instrument is functioning as predicted, the change in the trip setting since Turkey Point Unit 3 and Unit 4 B 3.3.2-1 Revision No. O

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.

3.2 BACKGROUND

(continued) WCAP-18888-P, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 24-Month Fuel Cycle" WCAP-18888-P uses the setpoint methodology from WCAP-17504-P-A (Ref. 14). the last test or calibration is verified to be within predefined limits and appropriate actions are taken if the change is outside these limits. The accep

• derived fr m the setpoint calculation based on the setpoint methodology described i 'A'CAP 1274a "'P!estiRgl=louse SetpoiAt Metl=loeology fer ProtestioA SysteFRs T1:1rkey PoiAt UAits 3 aAel 4,"

(Refs. 7 aAel 12) or WCAP 17070, "'.NestiAghouse SetpoiAt Methodology fer ProtestioA SysteFRs T1:1rkey PoiAt UAits 3 aAe 4," (Ref. 11) as applioable. If the trip setting exceeds the Allowable Value the channel is inoperable. If the change in the trip settings ~xceeds the predefined limits but the setting is conservative with respect to the Allowable Value, and during the surveillance the instrument channel is functioning as expected and can be reset to within the setting tolerance of the Trip Setpoint, then the channel may be returned to service, and the condition entered into the corrective action program for further evaluation. However, if during the surveillance the change in the trip setting exceeds the predefined limits and it cannot be determined that the instrument channel is functioning as required, then the instrument is declared inoperable. Thus, verifying the trip setting is within the acceptance criteria band during test or calibration is part of the determination that an instrument is functioning as required. Therefore, the channel would still be OPERABLE since it would have performed its safety function and the only corrective action required would be to reset the channel within the established calibration tolerance around the Trip Setpoint to account for further drift during the next surveillance interval. During Anticipated Operational Occurrences (AOOs), which are those events expected to occur one or more times during the unit life, the acceptable limits are:

1.

The Departure from Nucleate Boiling Ratio (DNBR) shall be maintained above the SL value to prevent departure from nucleate boiling (DNB),

2.

Fuel centerline melt shall not occur, and

3.

The RCS pressure SL of 2735 psig shall not be exceeded. Operation within the SLs of Specification 2.0, "Safety Limits (SLs)," also maintains the above values and assures that offsite dose will be within the 1 O CFR 50.67 criteria during AOOs. Turkey Point Unit 3 and Unit 4 B 3.3.2-2 Revision No. 0

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.

3.2 BACKGROUND

(continued) Trip Setpoints (as enveloped by the as found tolerance in the non-conservative direction) Trip Setpoints (as enveloped by the as found tolerance in the non-conservative direction) when all sensor and processing time delays are taken into account. To allow for calibration tolerances, instrumentation uncertainties, instrument drift, and severe environment errors for those ES FAS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 6), the Allowable 'Jalues specified in Table 3.3.2-1 in the accompanying LCO are conservative with respect to the analytical limits. A detailed description of the methodology used to calculate the Allowable Values and E~ p Setpoints including their explicit uncertainties, is provided in~ Westinghouse topical reports 'AIGAP 1274 6 and WCAP 17070 (Refs. 9-- iffie 11) which incorporates all of the known uncertainties applicable to each channel. A summary description of and reference to the calibration tolerance methodology is provided in UFSAR Chapter 7.2 (Ref. 2). The magnitudes of these uncertainties are factored into the determination of each ESFAS Trip Setpoint and corresponding Allowable Value. The nominal ESFAS setpoint entered into the bistable is n,ore oonservative than that specified by the Trip Setpoint to aooount for n,easuren,ent errors detestable by the GF4A~J~JEL OPER/\\TIOW\\L TEST (GOT). The Allowable Value serves as the Technical Specification OPERABILITY limit for the purpose of the COT. The Trip Setpoint is t e

• h the bistables are set and is the expected value to be achieved during calibra I The Allowable Value is the LSSS and ensures the safety analysis limits are met during the surveillance interval selected when a channel is adjusted based on stated channel uncertainties. Any bistable is considered to be properly adjusted when the "as-left" Trip Setpoint value is within the calibration tolerance for CHANNEL CALIBRATION uncertainty allowance (i.e.,+ rack calibration and comparator setting uncertainties).

Trip Setpoints, in conjunction with the use of calibration tolerances together with the requirements of the Allowable Value ensure that the consequences of Design Basis Accidents (DBAs) will be acceptable, providing the unit is operated from within the LCOs at the onset of the OBA and the equipment functions as designed. Note that the Allowable Values listed in Table 3.3.2-1 are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, COT, or a TADOT. Each channel can be tested on line to verify that the signal processing equipment and setpoint accuracy is within the specified allowance requirements of Reference 3. Once a designated channel is taken out of service for testing, a simulated signal is injected in place of the field instrument signal. The process equipment for the channel in test is then tested, verified, and calibrated. SRs for the channels are specified in the SR section. Turkey Point Unit 3 and Unit 4 B 3.3.2-5 Revision No. 0

BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) accidents. For example, Pressurizer Pressure - Low is a primary actuation signal for small loss of coolant accidents (LOCAs) and a backup actuation signal for steam line breaks (SLBs) outside containment. Functions such as manual initiation, not specifically credited in the accident safety analysis, are implicitly credited in the safety analysis and the NRC staff approved licensing basis for the unit. These Functions may provide protection for conditions that do not require dynamic transient analysis to demonstrate Function performance. These Functions may also serve as backups to Functions that were credited in the accident analysis (Ref. 4). Permissive and interlock setpoints allow the blocking of trips during plant startups, and restoration of trips when the permissive conditions are not satisfied, but they are not explicitly modeled in the Safety Analyses. These permissives and interlocks ensure that the starting conditions are consistent with the safety analysis, before preventive or mitigating actions occur. Because these permissives or interlocks are only one of multiple conservative starting assumptions for the accident analysis, they are generally considered as nominal values without regard to measurement accuracy. The LCO requires all instrumentation performing an ESFAS Function, listed in Table 3.3.2-1 in the accompanying LCO, to be OPERABLE. The Allowable Value specified in Table 3.3.2-1 is the least conservative value of the as-found setpoint that the channel can have when tested, such that a channel is OPERABLE if the as-found setpoint is within the calibration tolerance and is conservative with respect to the Allowable Value during the CHANNEL CALIBRATION or COT. As such, the Allowable Value I rack I differs from the Trip Setpoint by an amount greater thaA or equal to the ..... _______ _. expected instr m 1,e~ channel uAeertaiAties, such as drift, duriAg the ~ surveillaAee iAterval. In this manner, the actual setting of the channel Trip Setpoint will ensure that a SL is not exceeded at any given point of time .-!to_l_e_ra_n_c_e_s ___ as long as the channel has not drifted beyond expected tolerances during the surveillance interval. Note that, although the channel is OPERABLE under these circumstances, the trip setting must be left adjusted to a value within the calibration tolerance, in accordance with uncertainty assumptions stated in the referenced setpoint methodology, and confirmed to be operating within the statistical allowances of the uncertainty terms assigned. If the actual setting of the channel is found to be conservative with respect to the Allowable Value but is beyond the calibration tolerance band, the ehaAAel is OPERABLE, but degraded. The degraded condition ef the channel will be evaluated during performance of the SR. This Turkey Point Unit 3 and Unit 4 B 3.3.2-7 Revision No. O

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY (continued) and for meeting the 10 CFR 50.46 acceptance criteria (Ref. 12 and Ref. 13) evaluation will consist of resetting the channel setpoint to the Trip Setpoint (within the allowed tolerance) and evaluating the channel response. If the channel is functioning as required and expected to pass the next surveillance, then the channel can be restored to service at the completion of the surveillance. A trip setpoint may be set more conservative than the Trip Setpoint as necessary in response to plant conditions. However, in this case, the OPERABILITY of this instrument must be verified based on the field setting and not the Trip Setpoint. Failure of any instrument renders the affected channel(s) inoperable and reduces the reliability of the affected Functions. The LCO generally requires OPERABILITY of four or three channels in each instrumentation function and two channels in each logic and manual initiation function. The two-out-of-three and the two-out-of-four configurations allow one channel to be tripped during maintenance or testing without causing an ESFAS initiation. Two logic or manual initiation channels are required to ensure no single random failure disables the ESFAS. The required channels of ESFAS instrumentation provide unit protection in the event of any of the analyzed accidents. ESFAS protection functions are as follows:

1.

Safety Injection Safety Injection (SI) provides two primary functions:

1.

Primar

• e water addition to ensure maintenance or recovery of reactor vess level ( coverage of the active fuel for heat removal, clad integrity, and for liR'liting peak olad teR'lperature to

< 2200°r), and

2.

Boration to ensure recovery and maintenance of SOM (keff < 1.0). These functions are necessary to mitigate the effects of high energy line breaks (HELBs) both inside and outside of containment. The SI signal is also used to initiate other Functions such as: Phase A Isolation, Containment Ventilation Isolation, Reactor Trip, Turkey Point Unit 3 and Unit 4 B 3.3.2-8 Revision No. 0

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SURVEILLANCE REQUIREMENTS (continued) The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.3.2.3 is modified by Notes as identified in Table 3.3.2-1. Note (g) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. 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 i.::a:..:.:nd:_ _____ _Jr-_...,J;c..assessment is to ensure confidence in the channel performance prior methodology of Reference 14 to return1n el to service. For channels determined to be OPERABLE but degraded, a#eF returning the channel to service the Note (c) requires performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program w*11 ensure required review and documentation of the condition. ~Jotes (19), (o), and (h) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable. Note (h) also requires that the nominal Trip Setpoint and the methodologies for calculating the as-left and the as-found tolerances be in UFSAR Section 7.2. The SR is modified by a Note stating that testing of the alarm function for Functional Units 1.d, 1.e, 1.f, 1.g, 4.d, and 4.e, not required when alarm locked in. SR 3.3.2.4 SR 3.3.2.4 is the performance of a TADOT. This test is a check of the Bus Stripping Function. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. Turkey Point Unit 3 and Unit 4 B 3.3.2-36 Revision No. 0

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. BASES Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SURVEILLANCE REQUIREMENTS (continued) This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. SR 3.3.2.6 is modified by Notes as identified in Table 3.3.2-1. Note (g) requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. 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 land the assessment is to ensure confidence in the channel performance prior i.: ..:..:..::.... ______ _r-,t~u21~et~t1~FA~i~r:i~g~th~e~ ch~a~n~n~e:!__! I to service. For channels determined to be methodology of Reference 14 REFERENCES OPERABLE but degrade~ returning the channel to service the Note (c) requires performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program wil ensure required review and documentation of the condition. ~Jotes (b), (o), and (h) require that the as-left setting for the channel be returned to within the calibration tolerance of the Trip Setpoint. Where a setpoint more conservative than the Trip Setpoint is used in the plant surveillance procedures (field setting), the calibration tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the calibration tolerance of the Trip Setpoint, then the channel shall be declared inoperable. Note (h) also requires that the nominal Trip Setpoint and the ~

iefl~Je+E~* *' for calculating the as-left and the as-found tolerances be in UFSAR Section 7.2.

1.

Regulatory Guide 1.105, "Setpoint for Safety Related Instrumentation," Revision 3.

2.

UFSAR, Chapter 6.

3.

UFSAR, Chapter 7.

4.

UFSAR, Chapter 14.

5.

IEEE-279-1971.

6.

10 CFR 50.49. Turkey Point Unit 3 and Unit 4 B 3.3.2-38 Revision No. O

This page replaces revises the Bases markup page submitted in ADAMS Accession No. ML24040A190, ML24040A191. Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 BASES REFERENCES (continued) !Deleted.! WCAP-18888-P, "Westing house Setpoint Methodology for Protection Systems Turkey Point Units 3 and 4 24-Month Fuel Cycle", January 2024.

7.

VVGAP 12746, "'.'Vestinghouse Setpoint Methodology for Proteotion Systems Turkey Point Units 3 and 4."

8.

NRC Generic Letter 89-19, September 1989.

9.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010. 'JVCAP 17070 P, Revision 1, "VVestinghouse Setpoint Methodology for Proteotion Systems Turkey Point Units a and 4, (Power Uprate to 2644 MWt Gore Po*Ner)," June 2011.

12. 10 CFR 50.46.

13. WCAP-18546-P-A, March 2023.

14. WCAP-17504-P-A, Revision 1, "Westinghouse Generic Setpoint Methodology,"

October 2016. Turkey Point Unit 3 and Unit 4 B 3.3.2-39 Revision No. 0

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Revised Updated Final Safety Evaluation (UFSAR) Markup Pages (6 pages follow) L-2024-173

High Nuclear Flux (source Range) Trip This circuit trips the reactor when one of the two source range channels reads above the trip set-point. This trip, which provides protection during reactor startup can be manually bypassed when one of two intermediate range channels reads above the P6 setpoint value and is automatically reinstated when both intermediate range channels decrease below this value (P6). This trip is also bypassed by two out of four high power range signals (PlO). The trip function can also be reinstated below PlO by an administrative action requiring coincident manual actuation. The trip point is set between the administrative source range cutoff power level setpoint and the maximum source range power level. overtemperature ~T Trip The purpose of this trip is to protect the core against DNB. This trips the reactor on coincidence of two out of the three signals, with one set of temperature measurements per loop. The set point for this reactor trip is continuously calculated for each loop by solving the equation provided in secti eA 2.2 f the Technical Specifications. Table 3.3.1~1 Three of the four power range etectors provide input (one per channel) to the overtemperature AT trip function. Thus, a single failure neither defeats the function nor causes a spurious trip. changes inf (AI) can only lead to a decrease in trip setpoint. A rod stop is initiated when AT > ATrod stop where ATrod stop = ~Tsetpoint - Bp BP= a set point bias The setpoint bias is set to zero, effectively negating this rod stop. overpower AT Trip The purpose of this trip is to protect against excessive power level (fuel rod rating protection). This trips the reactor on coincidence of two out of the three signals, with one set of temperature measurements per loop. 7.2-21 Revised 04/17/2013

The set point for this reactor trip is continuously calculated for each channel by solving equations provided in secti on 2.2 f the Technical speci fi cations. Table 3.3.1-1 A similar rod stop function is provided for overpower protection. The setpoint bias is also set to zero, effectively negating this rod stop. Low Pressurizer Pressure Trip The purpose of this trip is to protect against excessive core steam voids which could lead to DNB. This trips the reactor on coincidence of two out of the three low pressurizer pressure signals. This trip is blocked when three of the four power range channels and two of two turbine inlet pressure ~ channels read below approximately 10% power (P7). High Pressurizer Pressure Trip The purpose of this trip is to limit the range of required protection from the overtemperature ~T trip and to protect against Reactor coolant system overpressure. The reactor is tripped on coincidence of two out of the three high pressurizer pressure signals. High Pressurizer water Level Trip This trip is provided as a backup to the high pressurizer pressure trip. The coincidence of two out of the three high pressurizer water level signals trips the reactor. This trip is blocked when three of the four power range channels and two of two turbine inlet pressure channels read below ~ approximately 10% power (P7). 7.2-22 Revised 04/17/2013

control Group Rod Insertion Monitor The control group rod insertion limits, ZLL, are calculated as a linear function of power and reactor coolant average temperature. The equation is: ZLL = A (AT)avg + B (Tavg) + C where A, Bare preset manually adjustable gains and c is a preset manually adjustable bias. The (AT)av9 and (Tav9) are the average of the individual temperature differences and the coolant average temperatures respectively measured from the reactor coolant hot leg and the cold leg. An insertion limit monitor with two alarm set points is provided for the control banks. A description of control and shutdown rod groups is provided in section 7.3. The "Low" alarm alerts the operator of an approach to a reduced shutdown reactivity situation requiring boron addition by following procedures with the chemical and volume control system. If the actuation of the "Low-Low" alarm occurs, the operator should take immediate action to add boron to the system. setpoint Methodology ~ The nominal trip setpoints (fff=S) for the re.* tor trip syste

• and safety features are provided in Table 7.2-

~ safety system setting (Lsss) values that re engineering the Limiting limits derived from the safety analyses and pr _ ess adjusted to account for the specific instrument un e rtai nti es. T *

• instrument uncertainties for the trip setpoint are based on the methodology described in WCAP-

, westinghou setpoint Methodology for Protection systems Turkey Point Units 3 and 4 -HJdV,ile-f'---Ht3ft'tt'@~a--,,~~-MW't---~ tare Powe~- (Reference 5). The guidance of Technical specification Task Force (TSTF) No. 493, Rev. 4, Option A, "clarify Application of setpoint Methodology for LSSS Functions," (Reference 6) =i-s applied to the Reactor Trip system (RTS) and Engineered safety Features Act a* (ESFAS) setpoints and surveillance requirements impacted by The RTS functions listed in Table 7.2-1 were evaluated per the requirements of GL91-04 for 24 month fuel cycles with the results documented in WCAP-18888-P, (Reference 5). 7.2-26 Revised 04/17/2013

Delete this text insertion 'The ESFAS functions listed in Table 7.2-1 were evaluated per the requirements of GL91-04 for 24 month fuel cycles with the results documented in WCAP-18888-P, (Reference 5). impacted--EsFAS fune-tt~+nelude safety injee1:'i-on on hi-gn-steam line flow -a>>fleideRt with low steam~PittOfL-J:tPesSttpe,s-t-eam-H-ne isolation on high steam liRe flow coiRciEleRt-witl=t low steam ifeffeFatoF pfleSSi!Fe, feeElwateF-isolati oR OR l=ti ~ - l=tigl=t steam QeAeFa-Wr water le*,el, aRd auxiHary feedwater-- act1::1atioR OR low -lew steam geRe~r water level (Table 7.21 items 19e, 22, ~6a,-~Sa, respeetivel y). The setpoint methodology establishes the N=F5 and Allowable value (AV) for each of the affected functions. The AVs at Turk Point are "performance based" and are determined by adding (or subtracting NTSP the rack calibration accuracy (RCA~)l;o~f~t~h~e~d~e~v~i~c~e~t~~~~~~~~~~lel__,_-i-___, operational Test (COT) to the N=F5 n tenon-conservative direction, i.e., toward or closer to the safety Analysis Limit (SAL) for the application. see Figure 7.2-Sg for an illustration of setpoint relationships between SAL, channel Statistical Allowance (-65A), RCA, As-Found Tolerance (AFT), and As-Left Tolerance (ALT) are shown an FT=ALT=RCA where the RCA uncertainty term is based one ui ment manufacturer's p formance specifications. 3.3.2-1.. 3.:f.1-1 CSA urveillance imits are established to verify tat RTS and ESFAS i trumentatio operates within the boundaries of applicable instrument unc tainty cal. lations. These limits are implemented in plant procedures rdance wit TS Notes,(a) a"d (b) below which are consistent with the These notes specify operability criteria and requi e that ou of-tolerance conditions detected during surveillances be evaluated 6 fore retu' ning the channel to service. have been inserted into T.S Tabl ~~ ~ RTS Instrumentation~ft=¥e+-~ lffE~~etw=il-flE!flleft'E,5-an TS Table ~ . ESFAS Instrumentation -5ttFt<e"i-+ficHH:e---ffeet:t~ !f!IE~5-7 thods used to determine the N=F5 and AV values and ibed in WCAP-17070 P (Referenc .7*-------.,-----,--,--..,...-:-r----, ~ ~ -Pff:H:@,.....+;iiH~States: NTSP ~ Notes (b) and (c) Note (b) Note (c) ~-----' ~---~ " *f the as-found channe 1 setpoi nt 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." ' he instrument channel setpoint shall be reset to a value that is

• within the as-1 eft tolerance around the Nominal Trip Setpoi nt (NTS) at the completion of the surveillance; otherwise, the channel shal be declared inoperable. setpoints more conservative than the N=F5 acceptable provided that the as-found and as-left toleran the actual setpoint implemented in the surveillance proc settings) to confirm channel performance. The ~

nd m used to determine the as-found and the as-left t ran es in UFSAR section 7.2." NTSP specified the methodology 7.2-27 Revised 04/17/2013

7.

2.7 REFERENCES

1.

NRC Generic Letter 89-19, "Request for Action Related to Resolution of unresolved safety Issue A-47,-safety Implication of control systems in LWR Nuclear Power Plants' Pursuant to 10 CFR 50.54(f)," dated September 20, 1989.

2.

FPL letter to the NRC L-93-276,"Proposed License Amendment - steam Generator overfill Protection (Generic Letter 89-19)," dated December 28, 1993.

3.

NRC letter to FPL,"Issuance of Amendments RE: steam Generator overfill Protection (TAC NO.s M88560 and M88561)," dated April 28, 1994.

4.

Based on Generic 1983.

5.

WCAP-V7i:, "Westinghouse setpoint Methodology for Protection systems Turkey Point Units 3 and 4 -{Pewer Uprate t o 2644 Mwt: core ~wer) " January 2811.. ~24 Month Fuel Cycle)" l

6.

Technical specification Task Force (TSTF) No. 493, Rev. 4, "clarify Application of setpoint Methodology for LSSS Functions," July 2009.

7.

Unit 3 PC/M No. 90-220, RTD Bypass Elimination Modification and Eagle 21 Installation, (EC 244881).

8.

unit 4 PC/M No. 90-221, RTD Bypass Elimination Modification and Eagle 21 Installation, (EC 244882).

9.

WCAP-12632, RTD Bypass Elimination Licensing Report for Turkey Point units 3 and 4, Revision 1, November 1990.

10. WCAP-12374, Topical Report Eagle-21 Microprocessor-based Process Protection system, Revision 1, December 1991.

11.

IEEE 603-1980, IEEE standard criteria for safety systems for Nuclear Power Generating stations.

12. Westinghouse Design specification 408A46, Eagle 21 Process Protection system Design Requirements, Revision l, January 1990. (Proprietary)

13.

IEEE 338-1977, IEEE Standard criteria for the Periodic Testing of Nuclear Power Generating station safety systems.

14.

EVAL-18-27, Turkey Point units 3 and 4 Addition to the Updated Final safety Analysis Report for Reactor Protective system surveillance Testing using the Eagle 21 system, March 2019.

15. NRC Regulatory Issue Summary 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," August 2006.

NOTE 3: (Continued) ~ T T" s f2 (t.I) TABLE 7.2-1 (Continued) TABLE NOTATIONS (Continued) [*]/°F for T > T" and K6 [*] for T,S T" As defined in Note 1; [*] °F (Indicated Loop Tavg at RATED THERMAL POWER); As defined in Note 1, and [*] Sheet 8 of 8 NOTE 4: The overpower t.T function A11owab1e value sha11 not exceed the nominal trip setpoint by more than 0.5% t.T span for the channel. No separate Allowable value is provided for Tave because this function is part of the t.T value. NOTE 5: Particulate (R-11) !,&,% * *' PM Gaseous (R-12) 9.0 x 1 Q-8 µCi/cc (1.11 x 1 o-3 µCi/cc) 9.~

• W', EPM, containment Gaseous Monitor setpoint =

C F ) g,; * *" PM. s: containment Gaseous Monitor Allowable value= C F ) where F = Actual Purge Flow Design Purge Flow (35,000 CFM) { (1.17 x 1 Q-3 µCi/cc) ] setpoint may vary according to current plant conditions provided that the release rate does not exceed allowable limits provided in the offsite Dose calculation Manual. Revised 04/17/2013 ~ ~ ~ ~

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Excerpts from Turkey Point Maintenance Procedure 4-SMl-071.02A, L-2024-173 Steam Generator 4A Level (Narrow Range) Protection Set I Loop L-474 Channel Calibration (14 pages follow)

FPL

Title:

TURKEY POINT UNIT 4 SURVEILLANCE MAINTENANCE PROCEDURE SAFETY RELATED CONTINUOUS USE Procedure No. 4-SMl-071.02A Revision No. 12 STEAM GENERATOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION Responsible Department: INSTRUMENT & CONTROL Special Considerations: This procedure is Environmentally Qualified. Revision 0 12 FOR INFORMATION ONLY Before use, verify revision and change documentation {if applicable) with a controlled index or document. DATE VERIFIED INITIAL. ___ Approved By Approval Date Don Cotter 07/16/09 Ron Gomez 03/12/24 UNIT# UNIT4 DATE DOCT PROCEDURE DOCN 4-SMl-071.02A SYS STATUS COMPLETED REV 12

1. OF PGS

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 5 of98 PROCEDURE NO.: 4-SMl-071.02A TURKEY POINT UNIT 4 1.0 PURPOSE AND SCOPE 1.1 PURPOSE

1.

This procedure provides instructions for the calibration of L-474 Steam Generator 4A Level Loop Protection Set I, and associated loop components.

2.

This procedure partially satisfies the calibration requirements of Technical Specifications: {CTS: Table 4.3-1, Items 11 and 12, CHANNEL CALIBRATION} {ITS: 3.3.1, Reactor Trip System (RTS) Instrumentation, SR 3.3.1.10 for Table 3.3.1-1, Functions 11 and 12} {CTS: Table 4.3-2, Items 5.c and 6.b, CHANNEL CALIBRATION} {ITS: 3.3.2, Engineered Safety Features Actuation System (ESFAS) Instrumentation, SR 3.3.2.6 for table 3.3.2-1, Functions 5.b and 6.b} {CTS: Table 4.3-4, Item 21, CHANNEL CALIBRATION} {ITS: 3.3.3, Post Accident Monitoring (PAM) Instrumentation, SR 3.3.3.2 for Table 3.3.3-1, Function 12}

3.

Procedure is written so that the transmitter and control rack sections can be performed at different times for a split loop calibration.

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 6 of98 PROCEDURE NO.: 4-SMl-071.02A TURKEY POINT UNIT 4 1.2 SCOPE

1.

This procedure has been written to allow split loop calibration to be performed in lieu of the procedure being performed in its entirety. The work authorizing document may specify individual sections to be performed as follows: A. If performing entire loop, then this procedure should be performed in MODE 5 or 6; however, with authorization from the Supervisor, it may be performed in any MODE. B. If performing Transmitter portion only, then Section 4.1 and Section 4.1, Step 17.B of this procedure should be performed in MODE 5 or 6; however, with authorization from the Supervisor, it may be performed in any MODE. C. If performing Protection Rack portion only, then Section 4.1 and Section 4.3 through Section 4.14 of this procedure may be performed in any MODE. Protection Loops NOT being tested must be clear of any abnormal conditions or alarms before placing loop in test.

2.

This procedure applies to the following loop components: LT-4-474, Steam Generator Level Transmitter LQ-4-474, Loop Power Supply LM-4-474, Signal Isolator Ll-4-474, Level Indicator LC-4-474, Signal Comparator LC-4-474A, Signal Comparator LC-4-4748, Signal Comparator DCS (ERDADS) Point L474_A

REVISION NO.: 12 PROCEDURE TITLE: PAGE: PROCEDURE NO.: 4-SMl-071.02A STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION TURKEY POINT UNIT 4 2.0 PRECAUTIONS AND LIMITATIONS 2.1 Precautions

1.

Control systems shall be in the Manual Control mode prior to changing position of any channel defeat/transfer switch. After switch lineup changes are completed, control system may be returned to Auto Control mode.

2.

The transmitter tested in this procedure provides input to AMSAC (ATWS Mitigating System Actuation Circuitry). Failure to place AMSAC in the single processor mode operating on Processor B prior to testing transmitter may result in inadvertent annunciator alarms or plant trip.

3.

When performing calibration of Rosemount transmitters using the transmitter test terminals, then the current measuring device used shall have an input impedance of less than 15 ohms.

4.

LT-4-474 is Environmentally Qualified under 10 CFR 50.49. Environmental Qualified parts shall be used on transmitter.

5.

The use and storage of chemicals and compounds shall be in accordance with O-ADM-015.1, Chemical Control Program. 2.2 Limitations

1.

Any condition found during performance of this procedure which may affect a component's ability to perform its function may constitute a Limiting Condition for Operation (LCO) and shall be reported immediately to the Supervisor and SM/US/SRO Designee.

2.

When performing maintenance on Protection Channel instrumentation in OPERATIONAL MODE 1, 2, or 3, the redundant Protection Channel rack doors shall remain CLOSED and LOCKED, unless authorized by the SM/US/SRO Designee.

3.

This procedure may be performed only while the Unit is stable, in any normal OPERATIONAL MODE 1 through 6. When at POWER MODE 1, the procedure shall be performed during a steady load period. 7 of98

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 8 of98 PROCEDURE NO.: 4-SMl-071.02A TURKEY POINT UNIT 4 2.2 Limitations (continued)

4.

To ensure compliance with Technical Specifications channel redundancy minimum requirements and minimize chances of inadvertent entry into a Limiting Condition for Operation (LCO) or inadvertent automatic actuation of protective systems, the following limitations apply: A. With the Unit in OPERATIONAL MODE 1 or 2, Steam and Feedwater flow rates shall be steady and properly matched prior to performing this procedure. B. With the Unit in OPERATIONAL MODE 1, 2, or 3, only one of the three Protection Channels (I, II, or Ill) monitoring each Steam Generator Narrow Range Water Level shall be out of service, in Trip/Test mode. C. With the Unit in OPERATIONAL MODE 1, 2, or 3, performance of this procedure shall be halted immediately when an alarm condition develops in a redundant Channel. D. With the Unit in OPERATIONAL MODE 1, 2, or 3, only one Protection Channel shall be removed from service at any time, and all protective channels NOT under testing shall be in a normal OPERABLE condition. E. When abnormal process conditions which directly lead to an automatic protective action or cause entry into a Limiting Condition for Operation (LCO) are detected by the remaining Protection Channels or ascertained by the Reactor Operator (RO), this procedure shall be immediately halted; to be resumed only after proper evaluation has been made of the situation by appropriate Operations personnel.

5.

Any additional maintenance work or unusual conditions identified during performance of this procedure shall be identified in Section 5.2, Step 2 and reported to the Supervisor for additional work controls such as new WO package development or addendum to existing WO package.

6.

Optimization adjustment may be made to obtain minimum error even though component data is acceptable.

7.

LT-4-474 and Output 1 of LC-4-474, LC-4-474A and LC-4-474B should be adjusted to as close as possible to the desired voltages.

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERA TOR 4A LEVEL (NARROW RANGE) 9 of98 PROCEDURE NO.: PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 4-SMl-071.02A TURKEY POINT UNIT 4 2.2 Limitations (continued)

8.

If As Found Rack Accuracy is NOT within Acceptance Criteria, the channel shall be evaluated to verify it is functioning as required before returning the channel to service. [Section 8.1.3, Management Directive 2, CR 1895837-14 (CAPR): Evaluations not being performed prior to restoring RPS/ESFAS Instrumentation.]

9.

If As Found Rack Drift is NOT within Functional Criteria, the channel shall be evaluated to verify it is functioning as required by the Channel Uncertainty Calculation before returning the channel to service. [Section 8.1.3, Management Directive 2, CR 1895837-14 (CAPR): Evaluations NOT being performed prior to restoring RPS/ESF AS Instrumentation.]

10.

Supervisor must verify that any parts or materials required to be EQ per design documents are approved for EQ use.

11.

Whenever a transmitter cover is loosened, then cover 0-ring must be replaced per O-ADM-704, Environmental Qualification Maintenance Index.

12.

When a new module is installed into the rack, or a module that has been removed from the rack is being reinstalled, a 30 minute warm up time is recommended.

REVISION NO.: 12 PROCEDURE TITLE: STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION PROCEDURE NO.: 4-SMl-071.02A TURKEY POINT UNIT 4 3.0 3.1 PREREQUISITES AND INITIAL CONDITIONS General Prerequisites

1.

RECORD information below and on, Notification/Briefing Sheet. WO# Date

2.

IF rack calibration will be performed in MODES 1, 2, or 3, THEN VERIFY plant will remain in a steady load period during this test. A. RECORD As Left Rack Accuracy Trip Setpoint voltage from the most recently completed Channel Calibration or ACOT Surveillance: LC-4-474 (Output 1) voe I B. RECORD As Left Rack Accuracy Trip Setpoint voltage from the most recently completed Channel Calibration or ACOT Surveillance: LC-4-474A (Output 1) I voe I C. RECORD As Left Rack Accuracy Trip Setpoint voltage from the most recently completed Channel Calibration or ACOT Surveillance: LC-4-4748 (Output 1) I voe I

3.

IF transmitter Calibration will be performed (Section 4.2), THEN RECORD As Left L T-4-4 7 4 output voltages from the most recently completed Channel Calibration Surveillance into the As Left column of Table 2 in Section 4.2.6, Step 1. PAGE: 10 of 98 INITIAL

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERATOR 4A LEVEL (NARROW RANGE) 19 of 98 PROCEDURE NO.: PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 4-SMl-071.02A TURKEY POINT UNIT 4 INITIAL 4.2.2 Transmitter Calibration Check

1.

CONNECT DMM#1 (setfor VDC) to Test Point TP-4-474 (4QR3). NOTE Zero shift of transmitter has NOT been incorporated into the Table 1.

2.

ADJUST transmitter test pressure to Input values specified in Table 1, and RECORD As Found transmitter output voltage indicated on DMM#1. Table 1 LT-4-474 Output At TP-4-474 (VDC) Input As Found As Left Desired As Found Acceptance As Left Span (INWC) Acceptance Criteria Criteria 0 137.9 1.000 0.980 to 1.020 0.990 to 1.010 25 111.9 2.000 1.980 to 2.020 1.990 to 2.010 50 85.9 3.000 2.980 to 3.020 2.990 to 3.010 75 60.0 4.000 3.980 to 4.020 3.990 to 4.010 100 34.0 5.000 4.980 to 5.020 4.990 to 5.01 O 75 60.0 4.000 3.980 to 4.020 3.990 to 4.010 50 85.9 3.000 2.980 to 3.020 2.990 to 3.010 25 111.9 2.000 1.980 to 2.020 1.990 to 2.010 0 137.9 1.000 0.980 to 1.020 0.990 to 1.010

3.

IF any As Found values recorded in Table 1 are outside Acceptance Criteria, THEN NOTIFY Supervisor. Notification Person Notified Date Time Supervisor

PROCEDURE TITLE: REVISION NO.: 12 PROCEDURE NO.: 4-SMl-071.02A STEAM GENERATOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION TURKEY POINT UNIT 4 4.2.2 Transmitter Calibration Check (continued)

4.

IF any As Found values recorded in Table 1 are outside Acceptance Criteria, THEN Supervisor NOTIFY SM/US/SRO designee. Notification Person Notified Date Time SM/US/SRO designee

5.

IF As Found values recorded in Table 1 are outside Acceptance Criteria, THEN INITIATE a CR for Engineering Evaluation of LT 4 7 4 per EN-AA-203-1001.

6.

IF all As Found values recorded in Table 1 are within the As Left Acceptance Criteria, AND optimization is NOT desired, THEN: A. RECORD NAR in As Left column of Table 1.

8.

N/A Section 4.2.3 and Section 4.2.4. C. GO TO Section 4.2.5. PAGE: 20 of 98 INITIAL Supv

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERA TOR 4A LEVEL (NARROW RANGE) 26 of 98 PROCEDURE NO.: PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 4-SMl-071.02A TURKEY POINT UNIT 4 INITIAL 4.2.6 LT-4-474 Drift

1.

OBTAIN the As Found Output values (VDC) recorded in Table 1, and RECORD those values in the appropriate column of Table 2 below. Table 2 L T-4-474 Drift (VDC) As LeftVDC As FoundVDC Span From From DriftVDC Section 3.1, Step 3 Table 1 0 = 25 = 50 = 75 = 100 = 75 = 50 = 25 = 0 =

2.

SUBTRACT the As Found voe from the As Left voe, and RECORD the result in the Drift VDC Column of Table 2.

3.

IF any transmitter Drift voltage is NOT within functional criteria of (-0.044 to 0.000) voe or (o.ooo to 0.044) voe, THEN: A. NOTIFY SM/US/SRO designee. B. INITIATE a CR for Engineering Evaluation of LT-4-474 per EN-AA-203-1001.

4.

IF NO further testing is planned for this loop, THEN: A. N/A Section 4.3 through Section 4.12. B. GO TO Section 4.13.

REVISION NO.: PROCEDURE TITLE: PAGE: 12 STEAM GENERATOR 4A LEVEL (NARROW RANGE) 35 of 98 PROCEDURE NO.: PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION 4-SMl-071.02A TURKEY POINT UNIT 4 INITIAL 4.6 As Found Rack Accuracy

1.

ENSURE DMM#1 (set for VDC) is connected to TP-4-474.

2.

ADJUST transmitter simulator (at T J-4-474) until LC-4-474 #1 RESET indicator (green LED) in ON.

3.

VERIFY BS-4-474-1 proving light is ON (Reset).

4.

RAISE transmitter simulator until LC-4-474 #1 TRIP indicator (red LED) just turns OFF.

5.

VERIFY BS-4-474-1 proving light is OFF (Trip).

6.

RECORD the As Found trip value from DMM#1. LC-4-474 (Output 1)- HI HI Level TRIP (VDC) Action Desired Acceptance Criteria As Found Tech Spec ALLOWABLE Trip (inc.) 4.200 4.180 to 4.220

4.220 A.

IF As Found value is outside Acceptance Criteria, THEN NOTIFY Supervisor. Notification Person Notified Date Time Supervisor B. IF As Found value is outside the Tech Spec ALLOWABLE limit, THEN Supervisor NOTIFY SM/US/SRO designee. Supv Notification Person Notified Date Time SM/US/SRO designee C. IF As Found value is outside Acceptance Criteria, THEN INITIATE a CR for Engineering Evaluation of LC-4-474 per EN-AA-203-1001.

7.

ADJUST transmitter simulator (at T J-4-474) until LC-474A #1 RESET indicator (green LED) is ON.

8.

VERIFY BS-4-474A-1 proving light is ON (Reset).

REVISION NO.: 12 PROCEDURE TITLE: PROCEDURE NO.: 4-SMl-071.02A STEAM GENERATOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION TURKEY POINT UNIT 4 4.6 As Found Rack Accuracy (continued)

9.

LOWER transmitter simulator until LC-4-474A #1 TRIP indicator (red LED) just turn ON.

10.

VERIFY BS-4-474A-1 proving light is OFF (Trip).

11.

RECORD the As Found trip value from DMM#1. LC-4-474A (Output 1) - LO LO Level TRIP (VDC) Action Desired Acceptance Criteria As Found Trip (deer.) 1.640 1.620 to 1.660 Tech Spec ALLOWABLE ~ 1.620 A. IF As Found value is outside Acceptance Criteria, THEN NOTIFY Supervisor. Notification Person Notified Date Time Supervisor B. IF As Found value is outside the Tech Spec ALLOWABLE limit, THEN Supervisor NOTIFY SM/US/SRO designee. Notification Person Notified Date Time SM/US/SRO Designee C. IF As Found value is outside Acceptance Criteria, THEN INITIATE a CR for Engineering Evaluation of LC-4-474A per EN-AA-203-1001.

12.

ADJUST transmitter simulator (at T J-4-474) until LC-4-474B #1 RESET indicator (green LED) is ON.

13.

VERIRY BS-4-474B-1 proving light is ON (Reset).

14.

LOWER transmitter simulator until LC-4-474B #1 TRIP indicator (red LED) just turn ON.

15.

VERIFY BS-4-474B-1 proving light is OFF {Trip). PAGE: 36 of 98 INITIAL Supv

REVISION NO.: 12 PROCEDURE TITLE: PROCEDURE NO.: 4-SMl-071.02A STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION TURKEY POINT UNIT 4 4.6 As Found Rack Accuracy (continued)

16.

RECORD the As Found trip value from DMM#1. LC-4-4748 (Output 1)- LO Level TRIP (VDC) Action Desired Acceptance Criteria As Found Trip (deer.) 1.640 1.620 to 1.660 Tech Spec ALLOWABLE ~ 1.620 A. IF As Found value is outside Acceptance Criteria, THEN NOTIFY Supervisor. Notification Person Notified Date Time Supervisor B. IF As Found value is outside the Tech Spec ALLOWABLE limit, THEN Supervisor NOTIFY SM/US/SRO designee. Notification Person Notified Date Time SM/US/SRO Designee C. IF As Found value is outside Acceptance Criteria, THEN INITIATE a CR for Engineering Evaluation of LC-4-474B per EN-AA-203-1001. PAGE: 37 of 98 INITIAL Supv

REVISION NO.: 12 PROCEDURE TITLE: PAGE: PROCEDURE NO.: 4-SMl-071.02A STEAM GENERA TOR 4A LEVEL (NARROW RANGE) PROTECTION SET I LOOP L-474 CHANNEL CALIBRATION TURKEY POINT UNIT 4

4. 7 Rack Drift

1.

SUBTRACT the Trip voltage recorded in Section 4.6, Step 6 from the Trip voltage recorded in Section 3.1, Step 2.A to determine LC-4-474 Rack Drift. voe - voe = voe Section 3.1, Step 2.A Section 4.6, Step 6 Rack Drift

2.

SUBTRACT the Trip voltage recorded in Section 4.6, Step 11 from the Trip voltage recorded in Section 3.1, Step 2.B to determine LC-4-474A Rack Drift. voe - voe = voe Section 3.1, Step 2.8 Section 4.6, Step 11 Rack Drift

3.

SUBTRACT the Trip voltage recorded in Section 4.6, Step 16 from the Trip voltage recorded in Section 3.1, Step 2.C to determine LC-4-4748 Rack Drift. voe - voe = voe Section 3.1, Step 2.C Section 4.6, Step 16 Rack Drift

4.

IF any of the above Rack Drift voltage are NOT within functional criteria of (-0.020 to 0.000) VDC or (0.000 to 0.020) VDC, THEN: A. NOTIFY SM/US/SRO designee. B. INITIATE a CR for Engineering Evaluation of applicable comparator(s) per EN-AA-203-1001. 38 of 98 INITIAL}}