View source for L-2002-027, Proposed License Amendments, Application for Technical Specification Improvement Regarding Missed Surveillance and Adoption of a Technical Specification Bases Control Program

{{Adams
| number = ML022400061
| issue date = 08/16/2002
| title = Proposed License Amendments, Application for Technical Specification Improvement Regarding Missed Surveillance and Adoption of a Technical Specification Bases Control Program
| author name = Mcelwain J
| author affiliation = Florida Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000250, 05000251
| license number = DPR-031, DPR-041
| contact person = 
| case reference number = L-2002-027
| document type = Letter type:L
| page count = 24
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:AUG 16 2002 FPL                                                                                       L-2002-027 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555 Re:      Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendments Application for Technical Specification Improvement Regarding Missed Surveillance and Adoption of a Technical Specifications Bases Control Program In accordance with the provisions of 10 CFR 50.90, Florida Power and Light Company (FPL) is submitting a request for an amendment to Technical Specifications (TS) for Turkey Point Units 3 and 4.
The proposed amendments would modify TS requirements for missed surveillances in TS Section 4.0.3 and, in conjunction with the proposed changes, add TS requirements for a Bases Control Program described in Section 5.5 of NUREG-1431, Rev. 2, "Standard Technical Specifications Westinghouse Plants" in Section 6.8.4. The proposed changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-358, Rev. 6. provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes and Attachment 3 provides the proposed, retyped technical specifications pages. provides a summary of the regulatory commitments made in the submittal. Attachment 5 provides the existing TS Bases pages marked up to show the proposed changes (for information only).
The proposed license amendments have been reviewed by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board. In accordance with 10 CFR 50.91(b), a copy of the proposed license amendments is being forwarded to the State Designee for the State of Florida.
FPL has no specific need date for these amendments. Please issue the amendment to be effective on the date of issuance and to be implemented within 60 days of receipt by FPL. If you should have any questions regarding this submittal, please contact Walter Parker at 305-246-6632.
Sincerely, Vice President Turkey Point Plant DRL Attachments cc:      Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Department of Health                                                               A an FPL Group company

L-2002-027 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed License Amendment Application for Technical Specification Improvement Regarding Missed Surveillance and Adoption of a Technical Specifications Bases Control Program STATE OF FLORIDA                 )
                                 ) ss.
COUNTY OF MIAMI-DADE             )
John P. McElwain being first duly sworn, deposes and says:
That he is Vice President, Turkey Point Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
;" John P. Mc        ,ain Subscribed and sworn to before me this
/.day of
* 2002.
OLGA HANEK
                                                     /74*     "MyMY EXPIRES:
COMMISSION     cC 92697o June 18,2004 Name of Notary Public (Type or Print)
John P. McElwain is personally known to me.

L-2002-027 Page 1 of 5 ATTACHMENT 1

==1.0       INTRODUCTION==

The proposed amendments would modify TS requirements for missed surveillances in TS Section 4.0.3 and, in conjunction with the proposed changes, add TS requirements for a Bases Control Program described in Section 5.5 of NUREG-1431, Rev. 2, "Standard Technical Specifications Westinghouse Plants" in Section 6.8.4.
The proposed changes would extend the delay time for declaring the Limiting Condition of Operation (LCO) not met if a surveillance test was not performed within its specified frequency. The changes would extend the delay time from up to 24 hours, to 24 hours or up to the surveillancefrequency, whichever is greater.The changes include requirements that a risk evaluation be performed for any surveillance delayed greater than 24 hours and that the risk impact be managed. The objective of these changes is to minimize the impact on plant risk resulting from the performance of a missed surveillance by allowing flexibility.
The proposed changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) STS change TSTF-358, Revision 6. The availability of this TS improvement was published in the Federal Register on September 28, 2001 as part of the TS Consolidated Line Item Improvement Process (CLUP). However, since Turkey Point uses traditional which do not match the STS line for line, the   incorporation of the changes as delineated in TSTF-358, Revision 6 require some of the wording to be moved to ensure completeness. Since this change involves changes to the TS beyond those described in TSTF-358, Revision 6, a license amendment is being submitted in lieu of the recommended CLIP.

==2.0       DESCRIPTION==
AND JUSTIFICATION The proposed amendment would modify TS requirements for missed surveillances in TS 4.0.3. In the conjunction with the proposed change, TS requirements for a Bases Control Program, consistent with TS Bases Control Program described in Section 5.5 of NUREG-1431,         Rev. 2, "Standard  Technical Specifications Westinghouse Plants" (STS), will be incorporated into Section 6, Administrative Controls, of the Turkey Point TS.
STS The changes are consistent with Nuclear Regulatory Commission (NRC) approved industry TSTF change, TSTF-358, Revision 6. The availability of this TS improvement      was  published in the Federal Register on September 28, 2001 as part of the CLUP.
2.1     Detailed Description of Changes The following changes as shown in Attachment 2 are proposed:
TS
: 1.      The first and last sentences of Surveillance Requirement TS 4.0.3 will be moved to the end of 4.0.1.

L-2002-027 Page 2 of 5
: 2.        The wording of Surveillance Requirement 4.0.3 will be deleted and replaced with the wording provided in TSTF-358, Rev. 6.
: 3.        Administrative Controls TS 6.8.4 will be changed to add a new section 6.8.4.i to contain the requirements of the TS Bases Control Program as provided in TSTF-358, Rev. 6.
2.2       Justification The first and last sentences of Surveillance Requirements TS 4.0.3 will be moved to the end of TS 4.0.1 in order to ensure that the requirements remain in the TS and to conform with the form and intent of SR 3.0.1 of the STS.
The wording of Surveillance Requirement 4.0.3 will be deleted and replaced with the TSTF-358, Rev. 6 wording, which will conform to Surveillance Requirement SR 3.0.3 of the STS.
The addition of a TS Bases Control Program to the Administrative Controls section of TS is added in order to comply with the recommendations of TSTF-358, Rev. 6, which conforms to the Bases Control Program of the Programs and Manuals section of the STS.

==3.0       BACKGROUND==

Federal Register Notice 66FR32400, of June 14, 2001 requested comments from the industry for a model safety evaluation for a TS improvement to modify requirements regarding missed surveillances using the CLIUP process. The model provided background and justification for the proposed amendment as a STS change, and also provided guidance for plants which do not have STS. In the Federal Register of 2001, September 28, 2001, NRC issued a notice of availability for this model evaluation. On October 1, September    28,  2001 NRC approved TSTF-358, Rev. 6, which incorporated modifications noted in the to Federal Register Notice. Since Turkey Point does not have STS, and since other changes are required lieu make the TS consistent with STS, submittal is being made through the license amendment process in of the CLIP.
The regulations contained in 10 CYR 50.36, "Technical Specifications," require that TS include or surveillance requirements. Surveillance requirements are requirements relating to test, calibration, inspection to ensure that the necessary quality   of systems and components     is maintained,   that facility operation will be within safety limits, and that the limiting conditions for operation will be met. TS require surveillance tests to be performed periodically (e.g., weekly or monthly). The periodic test of interval defined in the TS is called the surveillance frequency or surveillance interval. The majority surveillance tests included in the TS are designed to ensure that standby safety systems will be operable when they are needed to mitigate an accident. By testing these components, failures that may have occurred since the previous test can be detected and corrected.
Current Turkey Point TS 4.0.3 requires that, if it is found that a surveillance test was not performed permit within its specified frequency, the ACTION requirements may be delayed for up to 24 hours to time limits of the   ACTION     requirements    are the completion of the surveillance when allowable outage The  proposed    change less than 24 hours from the time it was discovered that the test was not performed.
by allowing would extend the delay time for declaring the LCO not met and entering the required actions 4.0.3 to allow more time to perform the missed surveillance test. This will be achieved by modifying TS whichever   is  greater, to perform   a missed a delay period from 24 hours up to the surveillance frequency, add a  sentence  to TS 4.0.3 surveillance prior to having to declare the LCO not met. The change will also

L-2002-027 Page 3 of 5 that states, "A risk evaluation shall be performed for any surveillance delayed greater than 24 hours, and risk impact shall be managed."
The objective of the proposed change is to minimize the impact on plant risk resulting from the performance of a missed surveillance by allowing flexibility in considering the plant conditions and other plant activities without compromising plant safety. In addition, implementation of the proposed change would reduce the need for the licensee to apply for regulatory relief to delay the performance of missed surveillances.
Since TSTF-358 Revision 6 is written for STS, wording which was previously located in Turkey Point TS 4.0.3, must be moved to ensure that requirements are maintained intact and to make the wording and arrangement of the requirements conform to the TSTF incorporated STS. The requirement located in the first sentence of TS 4.0.3, "Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2 shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation." will be moved to TS 4.0.1. The requirement located in the last sentence of TS 4.0.3, "Surveillance Requirements do not have to be performed on inoperable equipment." will also be moved to TS 4.0.1. These changes will serve to clarify requirements incorporating the TSTF and make the TS Surveillance Requirements 4.0.1, 4.0.2, 4.0.3, and 4.0.4 conform to the STS.
Also conforming to the requirements of TSTF-358 Revision 6, a TS Bases Control Program, consistent with the TS Bases Control Program described in Section 5.5 of NUREG-1431, Rev. 2, "Standard Technical Specifications Westinghouse Plants" (STS), will be incorporated into Section 6, Administrative Controls, of the TS. The NRC staff states that the need for a Bases control program stems from the need for adequate regulatory control of some key elements of the proposal that are contained in the Bases for SR TS 4.0.3.

==4.0      REGULATORY ANALYSIS==

4.1      No Significant Hazards Consideration Determination DescriptionofAmendment Request: A change is proposed to technical specifications to allow a longer period of time to perform a missed surveillance per TSTF-358, Rev. 6. The time is extended from the current limit of up to 24 hours, to 24 hours or up to the limit of the specified frequency, whichever is greater.
Basisfor ProposedNo SignificantHazards ConsiderationDetermination:As required by 10 CFR 50.9 1(a), an analysis of the issue of no significant hazards is presented below, reflecting the no significant hazards consideration determination published in the federal register dated June 14, 2001.
The analysis also addresses the administrative relocation of TS 4.0.3 wording to conform with the form and intent of SR 3.0.1 of the STS.
Criterion 1- The ProposedChange Does Not Involve a SignificantIncrease in the Probabilityor Consequences of an Accident Previously Evaluated The proposed change relaxes the time allowed to perform a missed surveillance. The time between surveillances is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be operable and capable of performing the accident mitigation functions assumed in the accident

L-2002-027 Page 4 of 5 analysis. As a result, the consequences of any accident previously evaluated are not significantly affected. Any reduction in confidence that a standby system might fail to perform its safety function due to a missed surveillance is small and would not, in the absence of other unrelated failures, lead to an increase in consequences beyond those estimated by existing analyses. The addition of a requirement to assess and manage the risk introduced by the missed surveillance will further minimize possible concerns. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The relocation of two sentences from one specification to another in TS Section 4.0, and the addition of a TS Bases Control Program in TS Section 6.0, consistent with STS, is administrative in nature, does not affect the interpretation or execution of the TS, and has no effect on the probability or consequences of an accident previously evaluated.
Criterion2- The ProposedChange Does Not create the Possibility of a New or Different Kind of Accident FromAny Previously Evaluated The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. A missed surveillance will not, in and of itself, introduce new failure modes or effects and any increased chance that a standby system might fail to perform its safety function due to a missed surveillance would not, in the absence of other unrelated failures, lead to an accident beyond those previously evaluated. The addition of a requirement to assess and manage the risk introduced by the missed surveillance will further minimize possible concerns. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The relocation of two sentences from one specification to another in TS Section 4.0, and the addition of a TS Bases Control Program in TS Section 6.0, consistent with STS, is administrative in nature, does not affect the interpretation or execution of the TS, and does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion3- The ProposedChange Does Not Involve a SignificantReduction in the Margin of Safety The extended time allowed to perform a missed surveillance does not result in a significant reduction in the margin of safety. As supported by the historical data, the likely outcome of any surveillance is verification that the LCO is met. Failure to perform a surveillance within the prescribed frequency does not cause equipment to become inoperable. The only effect of the additional time allowed to perform a missed surveillance on the margin of safety is the extension of the time until inoperable equipment is discovered to be inoperable by the missed surveillance. However, given the rare occurrence of a missed surveillance on inoperable equipment would be very unlikely. This must be balanced against the real risk of manipulating the plant equipment or condition to perform the missed surveillance. In addition, parallel trains and alternate equipment are typically available to perform the safety function of the equipment not tested. Thus, there is confidence that the equipment can perform its assumed safety function and this change does not involve a significant reduction in a margin of safety.
The relocation of two sentences from one specification to another in TS Section 4.0, and the addition of a TS Bases Control Program in TS Section 6.0, consistent with STS, is administrative in nature, does not affect the interpretation or execution of the TS, and does not involve a significant reduction in a margin of safety.

L-2002-027 Page 5 of 5 Based upon the reasoning presented above and the previous discussiofi 6f the amendment request, the requested change does not involve a significant hazards consideration.
3.2       Verification and Commitments As discussed in the notice of availability published in the Federal Register on September 28, 2001 for this TS improvement, plant-specific verifications were performed as follows:
FPL has established TS Bases for Specification 4.0.3 which state that use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances.
The modification will also include changes to the Bases for Specification 4.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that FPL is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65 (a) (4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, FPL will incorporate a Bases Control Program consistent with Section 5.5 of the STS in TS Section 6.8.4 i.
3.0      ENVIRONMENTAL EVALUATION The amendment changes a requirement with respect to a surveillance requirement. The amendment also changes recordkeeping, reporting, or administrative procedures and requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and c(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments. FPL has reviewed the amendments and concurs that they involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

APPLICABILITY SURVEILLANCE REQUIREMENTS Surveillance Requirements shall be met during the OPERATIONAL                  MODES or 4.0.1                                                                                           un)ess other conditions specified for individual Limiting Conditions for Operation otherwise stated in an individual Surveillance Requirement.
Requirement         be performed shall not               within the specified time with Surveillance interval Each 4.0.2             a aximum allowable     extension        to exceed 25% of the surveillance per . . .      I interval. If an ACTION item requires periodic performance on a once               after  the  initial basis, the above frequency extension applies to each performance       in    the  individual performance. Exceptions         to this Specification    are  stated Specifications.
        . J Failure to perform a Surveillance Requirement within constitute      the allowed surveillance interval, defined by Specification 4.0.2, shall                                for noncompliance with the OPERABILITY requirements for a Limiting Condition                at-the-time 0 eration.      ,                       e-AGMN-Iequirements are-appcable it  is         a 4~ntifed tht       S~veillncc    Rcuircm        ntsnt. beer, pcrformed..-The ACTION requiTremen        ma-  1b-e&#xf7;  y     or-t-O-                t.
t"ou. permi        . o th      thon-ef
   ;e--l* than 24 h&#xfd;ur .rSurveillance Requirements do not have to be performe on (inoperabl e equi pment.
Entry into an OPERATIONAL MODE or other specified condition shall                  not be 4.0.4                                                                         Limiting   Condition
*) made unless the Surveillance Requirement(s)           associated    with   a for Operation has been performed within the stated surveillance through         interval or as otherwise specified. This provision         shall  not  prevent    passage               or to OPERATIONAL MODES as required to comply         with  ACTION   requirements.
4.0.5     Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be applicable as follows:
: a. Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a.
AMENDMENT NOS. 189AND         183 TURKEY POINT - UNITS 3 & 4                3/4 0-3

INSERT 1 (Completely replaces existing Specification 4.0.3)
If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the Limiting Condition of Operation not met may be delayed, from the time of discovery, up to 24 hours or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours and the risk impact shall be managed.
If the surveillance is not performed within the delay period, the Limiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

ADMINISTRATIVE QC PROCEDURES AND PROGRAMS (Continued) maximum pathway leakage The combined As-left leakage rates determined on a than 0.60 La, prior to rate basis for all penetrations shall be verified to be less an outage or increasing primary coolant temperature above 200&deg;F following shutdown that included Type B and Type C testing only.
pathway leakage rate basis, The As-found leakage rates, determined on a minimum with  the  As-left minimum pathway for all newly tested penetrations when summed                        be less than 0.6 La, at all leakage rate leakage rates for all other penetrations         shall times when containment integrity is required.
L., when pressurized to Pa.
: 3)        Overall air lock leakage acceptance criteria is < 0.05 the apply to the test frequencies contained within "3-,if19            The provisions of Specification 4.0.2 do not Program.
: 2.            Containment Leakage Rate Testing to limit the working 6.8.5         Administrative procedures shall be developed and implemented         Senior   Operators, licensed e.g. licensed hours of plant staff who perform safety-related functions,                          personnel. The procedures maintenance Operators, health physicists, auxiliary operators, and key                      shift  coverage   is maintained adequate shall include guidelines on working hours that ensure that without routine heavy use of overtime for individuals.
by the applicable department "Anydeviation from the working hour guidelines shall be authorized with established procedures and with manager or higher levels of management, in accordance Controls shall be included in the procedures documentation of the basis for granting the deviation. by the Plant General Manager or his such that individual overtime shall be reviewed monthly assigned. Routine deviation from the designee to assure that excessive hours have not been working hour guidelines shall not be authorized.
6.9 REPORTING REQUIREMENTS ROUTINE REPORTS Title 10, Code of Federal 6.9.1         In addition to the applicable reporting requirements of                  Regulatory Commission, to  the  U.S. Nuclear Regulations, the following reports shall be submitted 10 CFR 50.4.
Document Control Desk, Washington, DC pursuant to STARTUP REPORT testing shall be submitted 6.9.1.1       A summary report of plant startup and power escalation license involving a planned to the following: (1) receipt of an Operating License, (2) amendment design or has been manufactured (3) installation of fuel that has  a  different increase in power level, may have significantly altered the nuclear, by a different fuel supplier, and (4) modifications that thermal, or hydraulic performance of the unit.
6-18                         AMENDMENT NOS. 218 AND 212 TURKEY POINT UNITS 3 AND 4

INSERT 2 (Addition to Procedures and Programs section of TS 6.8.4- Section i)
: i. Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.
: a.      Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
: b.      Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
: 1.       Change in the TS incorporated in the license or
: 2.      A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
: c.      The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
: d.      Proposed changes that meet the criteria of Specification 6.8.4 i. b. above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

ATTACHMENT 3 PROPOSED RETYPED TECHNICAL SPECIFICATION PAGES

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. Surveillance Requirements do not have to be performed on inoperable equipment.
4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval. If an ACTION item requires periodic the performance on a "once per..." basis, the above frequency extension applies to each performance after initial performance. Exceptions    to this Specification are stated in the individual Specifications.
4.0.3 If it is discovered that a Surveillance was not performed within its specified frequency, then compliance time of with the requirement to declare the Limiting Condition of Operation not met may be delayed, from the whichever  is greater. This delay  period discovery, up to 24 hours or up to the limit of the specified frequency, performed    for  any is permitted to allow performance of the Surveillance. A risk evaluation shall be Surveillance delayed greater than 24 hours and the risk impact shall be managed.
If the surveillance is not performed within the delay period, the Limiting Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting entered.
Condition of Operation must immediately be declared not met, and the applicable ACTION(s) must be 4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the the Surveillance Requirement(s) associated with a Limiting Condition for Operation has been performed within through  or to stated surveillance interval or as otherwise specified. This provision shall not prevent passage OPERATIONAL MODES as required to comply with ACTION requirements.
3 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and components shall be applicable as follows:
: a.        Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a.
3/4 0-3                           AMENDMENT NOS.            AND TURKEY POINT - UNITS 3 & 4

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)
The combined As-left leakage rates determined on a maximum pathway leakage rate basis for all penetrations shall be verified to be less than 0.60 La, prior to increasing primary coolant temperature above 200&deg;F following an outage or shutdown that included Type B and Type C testing only.
The As-found leakage rates, determined on a minimum pathway leakage rate basis, for all newly tested penetrations when summed with the As-left minimum pathway leakage rate leakage rates for all other penetrations shall be less than 0.6 La, at all times when containment integrity is required.
: 3)       Overall air lock leakage acceptance criteria is _0.05 La, when pressurized to Pa.
The provisions of Specification 4.0.2 do not apply to the test frequencies contained within the Containment Leakage Rate Testing Program.
: i.      Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.
: a.       Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
: b.      Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
: 1.       Change in the TS incorporated in the license or
: 2.       Achange to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
: c.      The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
: d.      Proposed changes that meet the criteria of Specification 6.8.4 i.b. above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).
6.8.5 Administrative procedures shall be developed and implemented to limit the working hours of plantauxiliary  staff who perform safety-related functions, e.g. licensed Senior Operators, licensed     Operators,  health physicists, operators, and key maintenance personnel. The procedures shall include guidelines on working hours that ensure that adequate shift coverage is maintained without routine heavy use of overtime for individuals.
Any deviation from the working hour guidelines shall be authorized by the applicable department manager or for higher levels of management, in accordance with established procedures and with documentation of the             basis granting the deviation. Controls  shall be included  in the  procedures such  that individual overtime shall  be reviewed monthly by the Plant General Manager or his designee to assure that excessive hours have not been assigned. Routine deviation from the working hour guidelines shall not be authorized.
6-18                             AMENDMENT NOS.            AND TURKEY POINT - UNITS 3 & 4

ADMINISTRATIVE CONTROLS 6.9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, DC pursuant to 10 CFR 50.4.
STARTUP REPORT 6.9.1 .1 A summary report of plant startup and power escalation testing shall be submitted following: (1) receipt of an Operating License, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the unit.
The report shall address each of the tests identified in the FSAR and shall in general include a description of the measured values of the operating conditions of characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report. Subsequent Startup Reports shall address startup tests that are necessary to demonstrate the acceptability of changes and/or modifications.
Startup Reports shall be submitted within: (1) 90 days following completion of the Startup Test Program, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover all three events (i.e., initial criticality, completion of Startup Test Program, and resumption or commencement of commercial operation), supplementary reports shall be submitted at least every 3 months until all three events have been completed.
ANNUAL REPORTS*
6.9.1.2 Annual Reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year.
Reports required on an annual basis shall include:
: a.        A tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) for whom monitoring was required, receiving annual deep dose equivalent exposures greater than 100 mrem/yr and their associated man-rem exposure according to work and job functions** (e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling). The dose assignments to various duty functions may be estimated based on pocket dosimeter, thermoluminescent dosimeter (TLD), or film badge measurements. Small exposures totalling less than 20% of the individual total dose need not be accounted for. In the aggregate, at least 80% of the total deep dose equivalent received from external sources should be assigned to specific major work functions;
* A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station.
  **  This tabulation supplements the requirements of &sect;20.2206 of 10 CFR Part 20.
TURKEY POINT - UNITS 3 & 4                                   6-19                             AMENDMENT NOS.                AND

ADMINISTRATIVE CONTROLS ANNUAL REPORTS (Cont'd)
: b.      The results of specific activity analyses in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours prior to the first sample in which the limit was exceeded (in graphic and tabular format); (2) Fuel burnup by core region; (3) Clean-up flow history starting 48 hours prior to the first sample in which the limit was exceeded; (4) History of degassing operations, if any, starting 48 hours prior to the first sample in which the limit was exceeded; and (5) The time duration when the specific activity of the primary coolant exceeded 1.0 microcurie per gram DOSE EQUIVALENT 1-131.
ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT*
6.9.1.3 The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the Offsite Dose Calculation Manual (ODCM), and in (2) 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.
6.9.1.4      RADIOACTIVE EFFLUENT RELEASE REPORT**
The Radioactive Effluent Release Report covering the operation of the unit shall be submitted in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.
MONTHLY OPERATING REPORTS 6.9.1.5 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or safety valves, shall be submitted on a monthly basis to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC, no later than the 15th of each month following the calendar month covered by the report.
   *A single submittal may be made for a multiple unit station.
  **A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.
AMENDMENT NOS.          AND TURKEY POINT - UNITS 3 & 4                                6-20

ATTACHMENT 4 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by FPL in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Walter Parker at 305-246-6632.
Regulatory Commitments                                 Due Date/ Event FPL will establish the Technical Specification         To be implemented with amendment.
Bases for SR 4.0.3 as adopted with the applicable license amendment.
FPL will establish the Technical Specifications        To be implemented with amendment.
Bases Program as adopted with the applicable license amendment.

ATTACHMENT 5 PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARK-UP)
(submitted for information only)

3/4.0   APPLICABILITY BASES of each specification to Soecification 3.0.5 delineates the applicability Unit 3 and Unit 4 operation.
the general requirements applicable Specification 4.0.1 through 4.0.5 establish to Surveillance Requirements.      These requirements are based on the Surveillance Regulations, 10 CFR'50.36(c)(3):
Requirements stated in the Code of Federal relating to test, calibration "Surveillance requirements are requirements                                                is or inspection to ensure that the     necessary quality of systems and components be within safety limits,, and. that the
  -maintained, that facility operation will  be met."
limiting conditions of operation will that surveillances must be Specification 4.0.1 establishes the requirement or other conditions for which the performed during the OPERATIONAL MODES Operation apply unless otherwise requirements of the Limiting Conditions for                  The purpose of this stated in an individual Surveillance Requirement.
performed to verify the specification is to ensure that surveillances are and-that parameters are within operational status of systems and components facility when the plant is specified limits to ensure safe operation of the associated Limiting in a MODE or other specified condition for which the Conditions for Operation are applicable.       Surveillance Requirements do not MODE for which have to be performed when the facility is in an OPERATIONAL            operation     do not Condition       for the requirements of the associated Limiting                                      associated Requirements apply unless otherwise specified. The Surveillance the Special Test with a Special Test Exception are only applicable when                          of a Exception is used as an allowable exception       to  the    requirements
)  specification.                    %
time SDecification 4.0.2 establishes the conditions under which the specified             an allowable may  be  extended.        It   permits interval for Surveillance Requirements surveillance extension of the normal surveillance interval to facilitate of  plant  operating    conditions        that  may not be scheduling and consideration e.g.,   transient        conditions or other suitable for conducting the surveillance; ongoing surveillance or maintenance activities. The limits of Specification the most 4.0.2 are based on engineering judgment and the recognition that the verifica probable result of any particular surveillance being performed is Surveillance    Requirements.         These    provisions    are tion of conformance with the reliability    ensured     through      surveillance   activ sufficient to ensure that the ities is not significantly degraded beyond that obtained from the specified surveillance interval.
TURKEY POINT - UNITS 3 & 4            B 3/4 0-4             AMENDMENT N05.137 AND 132

3/4.0       APPLICABILITY BASES
"*"vl wv't -I- S ecification 4.0 3                   lishes the failure to perform a Surveillance Requirement e a owe surv 1 ance interval, defined by the                             provisions of Specification 4.0.2. as 5* ,qo        a condition that constitutes                a  failure       to   meet  the    OPERABILITY requirements for a Limit lanc iner the provisions of this specificationf                                         systems and ing Condition for Op                                                                    Requirements              have       been satis components are assumed to be OPERABLE when                         Surveillance the      ecified Sp      thattime systems     or interval.           However.
components                   OPERABLE nothing are                in this  whenprothey/
factorily vision      is toperformed     within as implying be construed eil are found or known to be inoperable although stillmeeting the Surveillance Require-a einterv-,define                   ylsthero, sions of S ci                             .0.2.          mwas ar oation f the r*enr         ts*olimits           itheg      CTiOn    roequireme          tinapply       fromtt         e point e.1aBL                                                                                                and             at     the roi e itiftm t actifa                           sur.efllance hapnot been pelormed sur illance i erval                 wast   oceeded.        Capletion             of   toe      Surveilq      rance tot the aped iequiref wiea                   e allowt e outag e complane             i                          o       S the   .equirion ents     sta ACTION    ent       tie0qul5.re73na s         de2eSt&deg;n       Ti
                          &#xfd;the lep          is iSs          cincludg               .0gra po                           e      ip te la oed by T . Ifia T s                                                             Ope.          ion  thaet     iet*      Ubj*t*roey oERABiLirequirem               sT fnprhbted              CondiS m      ifor a Lciting ytepatsTcnalSifcatisn beuse it a condit                ddthen              is repora               a con ion rhi te byt                                          S enforcetio        atis e                                                                       su   eu          n         tis isreor          4een holhth s                         ec         is sions                                                                                                                       l          Jsm thata      daitiro              taed by the            eithed frverio                               imelonthante mhea                                                        y the plan          Techwnicalb.3    dafy            catih            ...
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                                                                                                                                                          - ur If/a surveill c i                      t        peted        *wthin          t*e Seci ication 4.0.4 s aloe.            of  th  iACTION        req   rmnsa                   apiala                      hi{ tim -*ZW n Zoxc, the ti               lI'its                                                           d he               _ei~l-l _ce_.
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B 3/4 0-5                                  AMENDMENT NOS.137 AND132 TURKEY POINT - UNITS 3 & 4

3/4.0   APPLICABILITY      -
BASES 3n~&      .2 Surveillance Requirements do not have to be performed on inoperable equipment 5ec. '1.0,      because the ACTION requirements define the remedial measures that apply.
        -J~~noperable However, theequipment   has been Surveillance   Requirements haveOPERABLE restored to     to be met to demonstrate that J .
status./
Speciflcation 4.0.4 establishes the requirement that all applicable surveil lances must be met before entry into an OPERATIONAL NODE or other condition of operation specified in the Applicability statement. The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a NODE or condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in OPERATIONAL MODES or other specified I        conditions associated with plant shutdown as well as startup.
Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage.
When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4.0.4 do not apply because this would delay placing the facility in a lower MODE of operation.
Specification 4.0.5 establishes the requirement that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a.
This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. This clarifica tion is provided to ensure consistency in surveillance intervals throughout the Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities.
Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda. The requirements of Specification 4.0.4 to perform surveillance activities before entry into an OPERATIONAL MODE or other specified condition takes precedence over the ASHE Boiler and Pressure TURKEY POINT - UNITS 3 & 4               S 3/4 0.-6               AMENDMENT N0S&#xfd;71 A0D165

Insert 3 (Completely replaces the existing Bases for Specificatiofi 4.0.3)
Specification 4.0 3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance requirement has not been completed within the specified frequency. A delay period of up to 24 hours or up to the limit of the specified frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4.0.2, and not at the time that the specified frequency was not met.
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance requirement before complying with required ACTION(s) or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
When a Surveillance with a frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, Specification 4.0.3 allows for the full delay period of up to the specified frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
Specification 4.0.3 provides a time limit for, and allowances for the performance of, a Surveillance that becomes applicable as a consequence of MODE changes imposed by required ACTION(s).
Failure to comply with the specified frequency for a Surveillance Requirement is expected to be an infrequent occurrence. Use of the delay period established by Specification 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours or the limit of the specified frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65 (a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. A missed Surveillance for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All cases of a missed Surveillance will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the required ACTION(s) for the applicable Limiting Condition of Operation begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the required ACTION(s) for the applicable Limiting Condition of Operation begin immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with Specification 4.0.1.}}