ML25085A134
| ML25085A134 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/26/2025 |
| From: | Mack K Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-25025-059 | |
| Download: ML25085A134 (1) | |
Text
l=PL.
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE: Turl<ey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250, 50-251 Subsequent Renewed Facility Operating Licenses DPR-31 and DPR-41 March 26, 2025 L-2025-059 10 CFR 50.90 License Amendment Request 281, Remove Pressurizer Heater Emergency Power Requirements
Reference:
- 1.
NUREG 1431, Revision 5, Standard Technical Specifications - Westinghouse Plants, Volume 1, Specifications (ADAMS Accession No. ML21259A155)
Pursuant to 10 CFR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Subsequent Renewed Facility Operating Licenses (SRFOL) Nos. DPR-31 and DPR-41 for Turkey Point Generating Station, Units 3 and 4 (Turkey Point), respectively. The proposed amendments revise Technical Specifications (TS) 3.4.9, Pressurizer, by removing the pressurizer heater group emergency power supply requirements. The proposed change is consistent with the Standard Technical Specifications (Reference
- 1) for facilities with two required pressurizer heater groups normally aligned to Class 1 E emergency power.
The enclosure to this letter provides FPL's evaluation of the proposed change. Attachment 1 to the enclosure provides the Turkey Point TS pages marked up to show the proposed change. Attachment 2 provides the Turkey Point TS Bases pages marked up to show the proposed change. The TS Bases changes are provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved license amendments.
FPL has determined that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the proposed change. The Turkey Point Onsite Review Group has reviewed the license amendment request.
In accordance with 10 CFR 50.91 (b)(1 ), a copy of the license amendment request is being forwarded to the State designee for the State of Florida.
FPL requests that the proposed changes are processed as a normal license amendment request, with approval within one year of the submittal date. Once approved, the amendment shall be implemented within 90 days.
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 261h day of March 2025, Kenneth A. Mack Director, Licensing and Regulatory Compliance Florida Power & Light Company Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 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:
Evaluation of the Proposed Change Attachments:
- 1.
Technical Specification pages (marked up)
- 2.
Technical Specification Bases pages (marked up)
L-2025-059 Page 2 of 2
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 EVALUATION OF THE PROPOSED CHANGE Turkey Point Nuclear Plant Unit 4 License Amendment Request 281, Remove Pressurizer Heater Emergency Power Requirements L-2025-059 Enclosure Page 1 of 8 1.0
SUMMARY
DESCRIPTION............................................................................................................. 2 2.0 DETAILED DESCRIPTION............................................................................................................. 2 2.1 Background......................................................................................................................... 2 2.2 Current Requirements......................................................................................................... 2
- 2. 3 Description of the Proposed Change.................................................................................. 3 2.4 Reason for the Proposed Change...................................................................................... 3
3.0 TECHNICAL EVALUATION
............................................................................................................ 3
4.0 REGULATORY EVALUATION
....................................................................................................... 5 4.1 Applicable Regulatory Requirements/Criteria..................................................................... 5 4.2 Precedent............................................................................................................................ 6 4.3 No Significant Hazards Consideration................................................................................ 6 4.4 Conclusion.......................................................................................................................... 8 5.0 ENVIRONMENT AL CONSIDERATION.......................................................................................... 8
6.0 REFERENCES
................................................................................................................................. 8 - Technical Specifications markup pages - Technical Specifications Bases markup pages
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 1.0
SUMMARY
DESCRIPTION L-2025-059 Enclosure Page 2 of 8 Florida Power & Light Company (FPL) requests amendments to Subsequent Renewed Facility Operating Licenses (SRFOL) Nos. DPR-31 and DPR-41 for Turkey Point Generating Station, Units 3 and 4 (Turkey Point), respectively. The proposed amendments revise Technical Specifications (TS) 3.4.9, Pressurizer, by removing the pressurizer heater group emergency power supply requirements. The proposed change is consistent with the Standard Technical Specifications (Reference 6.1) for facilities with two required pressurizer heater groups normally aligned to Class 1 E emergency power.
2.0 DETAILED DESCRIPTION
2.1 Background
The pressurizer maintains the required reactor coolant pressure during steady-state operation, limits the pressure changes caused by coolant tht3rmal expansion and contraction during normal load transients, and prevents the pressure in the Reactor Coolant System (RCS) from exceeding the design pressure. The pressurizer contains replaceable direct immersion heaters, multiple safety and relief valves, a spray nozzle and interconnecting piping, valves and instrumentation. The pressurizer surge line, attached to the bottom of the pressurizer, connects the pressurizer to the RCS hot leg. The pressurizer spray system, fed from the RCS cold leg, provides a small continuous spray to assure the pressurizer liquid is homogeneous with the RCS and to prevent excess spray and surge line cooling. Pressurizer spray valves automatically limit the pressure during load transients but can also be operated manually from the control room. The Reactor Control System controls the pressurizer heaters, spray valves, and the power operated relief valves (PO RVs) to promote stable plant operation and preclude actuation of the Reactor Protection System.
The pressurizer heaters maintain RCS pressure by maintaining the water and steam within the pressurizer at saturation temperature and constant operating pressure. The system is comprised of 78 direct immersion straight sheath type heaters located in the lower section of the pressurizer vessel. The heaters are arranged as a control group and two (A and B) backup groups to provide uniform heating. The control group, powered by a variable power supply, consists of 24 heaters arranged in eight delta-connected subgroups for a total load of 400 K:JV. The two backup heater groups, switched on or off, consist of 27 heaters arranged in nine delta-connected subgroups for a total load of 450 KW each. The 1300 KW capacity results in an acceptable pressurizer heatup rate during startup consistent with system performance goals (50°F/hr to 100°F/hr).
The pressurizer heaters have no safety-related function but have a quality-related function, applicable to the backup heater groups, to maintain RCS pressure such that sub-cooling is maintained. The pressurizer heaters have the non-safety function of compensating for pressurizer heat losses to maintain a saturation temperature corresponding to the required operating pressure. The pressurizer heaters heat the pressurizer from atmospheric conditions at Cold Shutdown to "no load" conditions in Hot Standby. The pressurizer heaters are incapable of over-pressurizing the reactor coolant system.
During normal power operation, the three groups of pressurizer heaters are powered from 480-volt load centers connected to the emergency buses through safety-grade circuit breakers. In the event of a loss of off-site power, the heaters are tripped but can be re-energized from safety-grade 480-volt load centers powered by emergency diesel generators (EDGs).
Procedures have been established which instruct control room operators to reload the backup heaters onto energized emergency buses well within the time frame that would cause a potential loss of subcooling and degradation of natural circulation.
2.2 Current Requirements Turkey Point TS 3.4.9, Pressurizer, specifies the following requirements for the pressurizer heaters:
LCO 3.4.9, Pressurizer, states, in part, that the pressurizer shall be OPERABLE with:
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2025-059 Enclosure Page 3 of 8
- b.
Two groups of pressurizer heaters OPERABLE with the capacity of each group~ 125 kW and capable of being power from an emergency power supply.
LCO 3.4.9, ACTION C, requires for the condition of one required group of pressurizer heaters not capable of being powered from an emergency power supply, restoration of the emergency power supply capability to the required group of pressurizer heaters within 14 days.
LCO 3.4.9, SuNeillance Requirement (SR) 3.4.9.3, requires verification that the required pressurizer heaters are capable of being powered from an emergency power supply in accordance with the SuNeillance Frequency Control Program.
2.3 Description of the Proposed Change The proposed change would revise TS 3.4.9 as follows:
Revise LCO 3.4.9.b, by removing the phrase "and capable of being powered from an emergency power supply".
Delete LCO 3.4.9, ACTION C.
Delete LCO 3.4.9, SR 3.4.9.3.
2.4 Reason for the Proposed Change The proposed change would align TS 3.4.9 with the Standard Technical Specifications (Reference 6.1) for facilities with at least two pressurizer heater groups normally aligned to Class 1 E emergency power, thereby negating the need to verify emergency power connectivity. The proposed change would have the added benefit of facilitating implementation of a Risk Informed Completion Time for an inoperable emergency diesel generator in excess of the 14-day front-stop Completion Time [TS 3.8.1, ACTION C].
3.0 TECHNICAL EVALUATION
Requirement Basis The minimum capacity of the pressurizer heaters must be sufficient to maintain the RCS near normal operating pressure during MODES 1, 2 and 3. In the event of a loss of off-site power, the initial conditions give the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. In MODE 3, water-solid RCS operation is undesirable because it can lead to rapid pressure rises from operational perturbations such as reactor coolant pump startup.
In accordance with the Turkey Point TS Bases, LCO 3.4.9.3 requires two groups of OPERABLE pressurizer heaters, each with a capacity ;:: 125 kW, and capable of being powered from either the off-site power source or an emergency power supply. In the Standard Technical Specifications (STS) (Reference 6.1) the phrase
"... and capable of being powered from an emergency power supply" is enclosed in brackets, inferring that plant-specific information may be substituted as applicable. Similarly, brackets enclose the entirety of the STS SR 3.4.9.3 requirement to verify the required pressurizer heaters are capable of being powered from an emergency power supply. Further, in the STS Bases (Reference 6.2), the description of the SR 3.4.9.3 requirement is enclosed in brackets, stating "{This SR is not applicable if the heaters are permanently powered by 1 E power supplies.]" Hence, based on the STS, the pressurizer heater emergency power requirements apply to plants not having the required pressurizer heaters normally aligned to an emergency power source. For these facilities, the TS needs to establish requirements which assure for the requisite number of pressurizer heaters the capability to transfer power from the normal, non-Class 1 E power source to a Class 1 E onsite emergency power source to support RCS subcooling following a loss of off-site power.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 Requirement History L-2025-059 Enclosure Page 4 of 8 The requirement for pressurizer heater emergency power capability derives from the events of Three Mile Island (TMI) whereby NUREG-0578 (Reference 6.3) was issued to provide initial lessons learned and short-term recommendations for "substantial additional protection to public health and safety'. NUREG-0578, Item 2.1.1, Loss of Normal Power, stated in part, that the capability to align one group of pressurizer heaters to the emergency on-site power supply shall be provided. Though the NUREG acknowledged the role of the emergency core cooling system (ECCS) in maintaining subcooling, the availability of the pressurizer heaters upon a loss of off-site power was deemed necessary to reduce the frequency of ECCS challenges.
Following the events of Three Mile Island (TMI), NUREG-0578 (Reference 6.3) was published to document the initial lessons learned and short-term recommendations which provide "substantial additional protection to public health and safety'. NUREG-0578, Section 2.1.1, recommended that the capability be provided to align one group of pressurizer heaters to the emergency on-site power supply. While the NUREG acknowledged the ECCS as a means of maintaining natural circulation, the availability of the pressurizer heaters upon a loss of off-site power was deemed necessary to reduce the frequency of ECCS challenges.
In NUREG-0737 (Reference 6.4), the post-TMI requirements approved by the Commission for licensee implementation was based, in part, on the NUREG 0578 recommendations. In Section 11.E.3.1, NUREG-0737 specified the following with regard to pressurizer heater availability and controls.
(1)
The pressurizer heater power supply design shall provide the capability to supply, from either the off-site power source or the emergency power source (when off-site power is not available), a predetermined number of pressurizer heaters and associated controls necessary to establish and maintain natural circulation at hot standby conditions. The required heaters and their controls shall be connected to the emergency buses in a manner that will provide redundant power supply capability.
(2)
Procedures and training shall be established to make the operator aware of when and how the required pressurizer heaters shall be connected to the emergency buses. If required, the procedures shall identify under what conditions selected emergency loads can be shed from the emergency power source to provide sufficient capacity for the connection of the pressurizer heaters.
(3)
The time required to accomplish the connection of the preselected pressurizer heater to the emergency buses shall be consistent with the timely initiation and maintenance of natural circulation conditions.
(4)
Pressurizer heater motive and control power interfaces with the emergency buses shall be accomplished through devices that have been qualified in accordance with safety-grade requirements.
The NRC staff's review of the actions taken at Turkey Point to satisfy the TMI Lessons Learned Category "A" items (Reference 6.5), concluded that the pressurizer heater groups are connected to the emergency 480-volt buses through safety grade circuit breakers and that FPL has "satisfied the implementation requirements of the position, emergency power supply for pressurizer heaters."
Turkey Point Design and Operation The Turkey Point units each have three banks of pressurizer heaters consisting of the Control Group (400 kW), Backup Group A (450 kW) and Backup Group B (450 kW), for a combined capability of 1300 kW. A minimum pressurizer heater capacity of 1000 kW is necessary during normal operation, and a minimum backup heater group capacity of 125 kW following a loss of off-site power, to maintain the reactor coolant subcooled at normal operating pressure when accounting for heat losses through the pressurizer insulation.
Though only one heater group is required to maintain natural circulation following a loss of off-site power condition, Backup Group A and Backup Group Beach have access to on-site emergency power sources.
Backup Group A is powered from the "A" 480 volt load center which is fed from the "A" 4160 volt bus which, under loss of off-site power conditions, would be powered by the "A" EDG. Backup Group B is powered
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2025-059 Enclosure Page 5 of 8 from the "D" 480 volt load center which is fed from the "B" 4160 volt Class 1 E bus which, under loss of off-site power conditions, would be powered by the "B" EOG. The 480 volt load centers and 4160 volt buses from which they are fed are all Class 1 E designated equipment. Both 'A' and 'B' backup heater groups are available for manual reinstatement well within the five to six hours available to prevent loss of primary system subcooling, and control room operator training and procedures establish when and how power to the backup heaters are to be established. Following the trip of all three heater groups in response to a loss of off-site power, the Backup Group A heaters would be reenergized by resetting a lockout relay in the electrical penetration room. Should the Backup Group A heaters fail to operate, procedures direct control room operators to override the trip signal to Backup Group B for use as an alternate. The EDGs have adequate capacity to provide power to the required heaters on both units, i.e. without load shedding of any emergency mitigating equipment. The SR 3.4.9.3 surveillance to verify emergency power supply capability is satisfied by examining the backup heater lockout relay in the 'A' 480-volt load center and the backup heater normal/emergency keylock switch on the 'D' 480-volt load center during operator daily rounds.
Summary The STS Bases establishes that the requirements for pressurizer heater group emergency power capability need not apply to facilities equipped with redundant required pressurizer heater groups normally aligned to an emergency power source. The requirements derive from the post-TM I regulatory position that the plant design provide the capability to supply from an emergency power source the pressurizer heaters necessary to establish and maintain natural circulation at hot standby conditions following a loss of off-site power. The NRC's assessment of the Turkey Point design in response to the regulatory position concluded that the pressurizer heater groups are normally aligned to emergency power through safety-grade equipment. The NRC's finding of compliance confirms the applicability of the exemption from the heater emergency power requirement implied in the STS Bases. Because both backup heater groups are normally aligned to an emergency power source, the current LCO requirement only affirms the permanent plant design, and the remedial action for a loss of emergency power capability would only be invoked by an equipment condition already subject to a TS remedial action. As such, these TS requirements add little value toward public health and safety. It should also be emphasized that while the availability of pressurizer heater emergency power is desirable, it is neither credited in the plant safety analysis nor essential for safe operation post reactor-trip. Should a loss of off-site power occur, the unavailability of the pressurizer heater function would not preclude orderly cooldown to levels supporting residual heat removal system operation.
Thereby, the proposed change to remove from LCO 3.4.9.b the phrase "and capable of being powered from an emergency power supply", delete ACTION C and SR 3.4.9.3 of TS 3.4.9, and conforming changes to the TS Bases is reasonable and appropriate. By eliminating the pressurizer heater emergency power requirements, the proposed change would have the added benefit of allowing a Risk Informed Completion Time for an inoperable EOG in excess of the 14-day front-stop Completion Time of TS 3.8.1, ACTION C, which is both operationally desirable and consistent with the plant licensing basis.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 4, Environmental and dynamic effects design bases, states, in part, that the reactor coolant system shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing and postulated accidents.
10 CFR Part 50, Appendix A, GDC 17, Electric power systems, states, in part, that provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2025-059 Enclosure Page 6 of 8 (Note: The General Design Criterion (GDC) used during the licensing of Turkey Point were based on the 1967 Atomic Energy Commission Proposed General Design Criterion (1967 Proposed GDC) and predate 10 CFR Part 50, Appendix A 1967 Proposed GDC 2 states, in part, that systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or the mitigation of their consequences shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena.
1967 Proposed GDC 14, Core Protection Systems, states that the core protection system, together with associated equipment, shall be designed to act automatically to prevent or to suppress conditions that could result in exceeding acceptable fuel damage limits.
1967 Proposed GDC 24, Emergency Power for Protection Systems, states, in part, that in the event of loss of all power, sufficient alternate sources of power shall be provided to permit required functioning of the protection systems.
NUREG-0578 (Reference 6.3), Section 2.1.1, "Emergency Power Supply Requirements for the Pressurizer Heaters, Power-Operated Relief and Block Valves, and Pressurizer Level Indicators in PWR's," recommended, in part, that licensees provide redundant emergency power for the minimum number of pressurizer heaters necessary to maintain natural circulation conditions in the event of a loss of off-site power.
NUREG-0737 (Reference 6.4) Item 11.E.3.1, "Emergency Power Supply for Pressurizer Heaters,"
recommended, in part, that the pressurizer heater power supply design shall provide the capability to supply, from either the off-site power source or the emergency power source..., a predetermined number of pressurizer heaters and associated controls necessary to establish and maintain natural circulation at hot standby conditions. The required heaters and their controls shall be connected to the emergency buses in a manner that will provide redundant power supply capability, and each redundant group of heaters should have access to only one Class 1 E division power supply.
The proposed change does not involve a change to the pressurizer design or functionality. Therefore, conformance with the above 10 CFR 50, Appendix A GDCs, 1967 Proposed GDCs, and the NUREG-0737 Item 11.E.3.1 requirements is not impacted by the proposed change.
4.2 Precedent In Reference 6.7, the NRC issued Amendments 161 and 152 to San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, which deleted from their respective TS LCO 3.4.9.b, the phrase requiring two groups of pressurizer heaters "capable of being powered from an emergency power supply." Similar to this amendment request, the Staff noted as the basis for amendment issuance, the presence of two required pressurizer heater groups permanently installed on Class 1 E buses backed by emergency power.
4.3 No Significant Hazards Consideration Florida Power & Light Company (FPL) requests amendments to Subsequent Renewed Facility Operating Licenses (SRFOL) Nos. DPR-31 and DPR-41 for Turkey Point Generating Station, Units 3 and 4 (Turkey Point), respectively. The proposed amendments revise Technical Specifications (TS) 3.4.9, Pressurizer, by removing the pressurizer heater group emergency power supply requirements. The proposed change is consistent with the Standard Technical Specifications (Reference 1) for facilities with two required pressurizer heater groups normally aligned to emergency power.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2025-059 Enclosure Page 7 of 8 As required by 10 CFR 50.91(a), FPL has evaluated the proposed change using the criteria in 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration.
An analysis of the issue of no significant hazards consideration is presented below:
(1)
Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change would delete the phrase in Limiting Condition For Operation (LCO) 3.4.9.b that requires two groups of pressurizer heaters be "capable of being powered from an emergency power supply."
The proposed change also deletes the associated LCO ACTION and surveillance requirement for the pressurizer heater emergency power supply. The pressurizer heaters are not credited in the Turkey Point safety analyses for any design basis accident, and thereby the proposed change cannot increase the consequences of an accident previously evaluated. The pressurizer heaters are not an event initiator of any design basis accident, and no physical change is proposed to the pressurizer heaters or the manner in which they are operated and maintained, and thereby the proposed change cannot increase the probability of an accident previously evaluated.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
(2)
Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change would delete the phrase from LCO 3.4.9.b requiring two groups of pressurizer heaters be "capable of being powered from an emergency power supply", and the associated LCO ACTION and surveillance requirement. No changes are proposed to the pressurizer heaters or the manner in which they are operated and maintained, and thereby the proposed change cannot create a different type of malfunction or accident. The proposed change does not create or revise any safety analysis inputs or projections and thereby cannot create new accident initiators or precursors.
Therefore, the proposed amendments do not create the possibility of a new or different kind of accident from any previously evaluated.
(3)
Do the proposed amendments involve a significant reduction in a margin of safety?
Response: No The proposed change would delete the phrase from LCO 3.4.9.b requiring two groups of pressurizer heaters be "capable of being powered from an emergency power supply", and the associated LCO ACTION and surveillance requirement. The proposed change does not alter the approach to any safety limits, limiting safety system settings, or safety analysis assumptions or inputs, and thereby cannot affect plant operating margins. The proposed change does not modify the design and capability of equipment credited in safety analyses, or introduce new energy sources, and thereby cannot affect the integrity of any radiological barrier.
Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.
Based upon the above, FPL concludes that the proposed license amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92, "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 4.4 Conclusion L-2025-059 Enclosure Page 8 of 8 In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENT AL CONSIDERATION The proposed amendments revise the Turkey Point Technical Specifications (TS) by removing the pressurizer heater group emergency power supply requirements. FPL has evaluated the proposed amendments for environmental considerations and determined that the proposed amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 1 O CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released off-site, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 1 O CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.
6.0 REFERENCES
6.1 NUREG 1431, Standard Technical Specifications - Westinghouse Plants, Volume 1, Specifications, Revision 5, (ADAMS Accession No. ML21259A155) 6.2 NUREG 1431, Standard Technical Specifications - Westinghouse Plants, Volume 1, Bases, Revision 5, (ADAMS Accession No. ML21259A159) 6.3 NUREG-0578, TMl-2 Lessons Learned Category A Items, Section 2.1.1, Emergency Power Supply Requirements for the Pressurizer Heaters, Power-Operated Relief and Block Valves, and Pressurizer Level Indicators in PWR's, July 1979, (ADAMS Accession No. ML090060030) 6.4 NUREG-0737, Clarification of TMI Action Plan Requirements, November 1980 (ADAMS Accession No. ML051400209) 6.5 U.S. Nuclear Regulatory Commission, Division of Operating Reactors, Operating Reactors Branch No. 1 letter dated April 7, 1990 (ADAMS Accession No. ML17339A962) 6.6 Florida Power & Light letter to U.S. Nuclear Regulatory Commission, L-80-79, Turkey Point Units 3 &
4, Docket Nos. 50-250 & 50-251, Short Term Lessons Learned, March 10, 1980 (ADAMS Accession No. ML17339A664)
- 6. 7 U.S. Nuclear Regulatory Commission letter dated November 22, 1999, Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 161 to Facility Operating License No. NPF-10 and Amendment No. 152 to Facility Operating License No. NPF-15, Southern California Edison Company San Diego Gas and Electric Company, the City of Riverside, California, the City of Anaheim, California (ADAMS Accession No. ML993330270)
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ATTACHMENT 1 Turkey Point Technical Specifications Page Markups (2 pages follow)
L-2025-059 Enclosure
3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Pressurizer LCO 3.4.9 The pressurizer shall be OPERABLE with:
- a.
Pressurizer water level s 92% and Pressurizer 3.4.9
- b.
Two groups of pressurizer heaters OPERABLE with the capacity of each group ~ 125 kW and oapable of being powered from an emergenoy pov1er supply.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A Pressurizer water level A.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> not within limit.
AND A.2 Fully insert all rods.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND A.3 Place Rod Control System 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in a condition incapable of rod withdrawal.
AND A.4 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> B. One required group of 8.1 Restore required group of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> pressurizer heaters pressurizer heaters to inoperable.
OPERABLE status.
Turkey Point Unit 3 and Unit 4 3.4.9-1 Amendment Nos. 297 a19el 290
Pressurizer 3.4.9 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME Add "Deleted" Add "Deleted" Add "Deleted" C. GAe FeEfl::liFeel QF81::1p ef C.1 14 days pi:ess1::1Fii!eF 19eateFs Aet ea19aele ef eeiRg 19eweFeel freA'I aA Cl'l'leFgeAey 19ower Sl::lpply.
D. Required Action and D. 1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition B or C AND not met.
D.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SR 3.4.9.1 SR 3.4.9.2 SURVEILLANCE Verify pressurizer water level is s 92%.
Verify capacity of each required group of pressurizer heaters is ~ 125 kW.
FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program
.-'ft:-1--tA:...:d:::.:d::....'....::'D:.::e:.:.::le::.:te::::d:_"J-l _________ ~,'/F'l:Add "Deleted" I SR 3.4.9.3 Verify required prcssuri~er heaters are eapable of IA 0eeorel0F1ec beiRg po*uercd frol'l'I aA el'l'lergeAey peweF s1::1pply.
- uith the SurveillaAee FrequeRey Control Program Turkey Point Unit 3 and Unit 4 3.4.9-2 Amendment Nos. 297 aRd 290
Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 ATTACHMENT 2 Turkey Point Technical Specifications Bases Page Markups (2 pages follow)
L-2025-059 Enclosure
BASES Pressurizer B 3.4.9 APPLICABILITY (continued)
ACTIONS In MODES 1, 2, and 3, there is need to maintain the availability of pressurizer heaters, capable of being powered from an emergency power supply. In the event of a loss of offsite power, the initial conditions of these MODES give the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODE 4, 5, or 6, it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer when the Residual Heat Removal (RHR) System is in service, and therefore, the LCO is not applicable.
A.1, A.2, A.3, and A.4 Pressurizer water level control malfunctions or other plant evolutions may result in a pressurizer water level above the nominal upper limit, even with the plant at steady state conditions. Normally the plant will trip in this event since the upper limit of this LCO is the same as the Pressurizer Water Level - High Trip Setpoints.
If the pressurizer water level is not within the limit, action must be taken to bring the plant to a MODE in which the LCO does not apply. To achieve this status, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the unit must be brought to MODE 3 with all rods fully inserted and incapable of withdrawal. Additionally, the unit must be brought to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This takes the unit out of the applicable MODES.
The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
If one required group of pressurizer heaters is inoperable, restoration is required within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is reasonable considering the anticipation that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using normal station powered heaters.
!Add "Deleted" ~
- c. 1 If one reqblireci Qroblp of pressuri;l&r h&aters is not capable of being powered from an emergency power souree (i.e., not capable of being powered by an emergency diesel generator (EOG)), capability mYst be restored within 14 days. The Completion Time of 14 days is consistent with a single EOG inoperable.
Turkey Point Unit 3 and Unit 4 B 3.4.9-3 Revision No. 'R
BASES Pressurizer B 3.4.9 ACTIONS (continued)
D.1 and D.2 If one group of pressurizer heaters are inoperable and cannot be restored in the allowed Completion Time of Required Action 8.1, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.4.9.1 REQUIREMENTS This SR requires that during steady state operation, pressurizer level is maintained below the nominal upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR S
Truncate sentence 3.4.9.2 andR 3.4.9.3
!This SR is... k and with a period(.)
REFERENCES These SRs aFe satisfied when the power. uppl es are demonstrated to be capable of producing the minimum powe the ssociated pressurizer heaters are verified to be at their design ratin and the pressurizer heateFs are veFif.ieEI te 19e capal91e ef acing ener=gizeEI using the asseeiateEI eentrel rnem eentrol s*witeh. This, in part, may be done by testing the power supply output and by performing an electrical check on heater element continuity and resistance.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
- 1.
UFSAR, Chapter 14.
- 2.
NUREG-0737, November 1980.
Turkey Point Unit 3 and Unit 4 B 3.4.9-4 Revision No. '8-.