View source for NRC-2016-0009, License Amendment Request 2821 Modify the Wording of Surveillance Requirement 3.4.12.7 Associated with the Power-operated Relief Valves

{{Adams
| number = ML16070A118
| issue date = 03/10/2016
| title = License Amendment Request 2821 Modify the Wording of Surveillance Requirement 3.4.12.7 Associated with the Power-operated Relief Valves
| author name = Mccartney E
| author affiliation = NextEra Energy Point Beach, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000266, 05000301
| license number = DPR-024, DPR-027
| contact person = 
| case reference number = NRC-2016-0009
| document type = Letter type:NRC, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 14
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:NEXTeraM ENERGY~
                                                                           ~
March 10, 2016                                                                  . NRC 2016-0009 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Units 1 and 2 Docket Nos. 50-266 and 50-301 Renewed Facility Operating Licenses Nos. DPR-24 and DPR-27 License Amendment Request 2821 Modify the Wording of Surveillance Requirement 3.4.12. 7 Associated with the Power-operated Relief Valves In accordance with 10 CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby requests a license amendment to revise the technical specifications (TS) for Point Beach Units 1 and 2. The proposed change modifies the wording in surveillance requirement 3.4.12.7 associated with the power-operated relief valves.
The Enclosure to this letter provides NextEra's evaluation of the proposed change. to the enclosure provides a markup of the TS showing the proposed change, and  provides the proposed TS Bases change. The change to the TS Bases is provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment. Attachment 3 provides the revised TS page containing the proposed change.
As discussed in the evaluation, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. This change has been reviewed by the Point Beach Onsite Review Group.
In accordance with 10 CFR 50.91, a copy of this letter is being forwarded to the State of Wisconsin designee.
This letter contains no new or revised regulatory commitments.
I                                                        1 NextEra requests approval of the amendment by March 10, 2017, and implementation within 90 days.
Should you have any questions regarding this submittal, please contact Mr. Bryan Woyak, Licensing Manager, at 920-755-7599.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 10, 2016 Sincerely, NextEra Energy Point Beach, LLC Eric McCartney Site Vice President Enclosure cc:     Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Evaluation of the Proposed Change

==SUBJECT:==
License Amendment Request 282, Modify the Wording of Surveillance Requirement 3.4.12. 7 Associated with the Power-operated Relief Valves 1.0   

==SUMMARY==
DESCRIPTION 2.0   DETAILED DESCRIPTION

==3.0   TECHNICAL EVALUATION==

==4.0   REGULATORY EVALUATION==

4.1   Applicable Regulatory Requirements/Criteria 4.2   Significant Hazards Consideration 4.3   Conclusions

==5.0    ENVIRONMENTAL CONSIDERATION==

==6.0    REFERENCES==
  -Markup of Technical Specification Page - Markup of Technical Specification Bases - Revised Technical Specification Page Containing the Proposed Change 5 pages follow

1.0   

==SUMMARY==
DESCRIPTION NextEra Energy Point Beach, LLC (NextEra) requests a license amendment to revise the Technical Specifications (TS) for Point Beach Units 1 and 2. The proposed change modifies the wording in Surveillance Requirement (SR) 3.4.12.7 associated with the power-operated relief valves (PORVs).
2.0   DETAILED DESCRIPTION Proposed Change The proposed change modifies the wording in SR 3.4.12. 7 by replacing the words "gas bottles" with the word "supply" as shown below.
SR 3.4.12.7     Perform a complete cycle of each required PORV       In accordance with solenoid air control valve and check valve on the    the Surveillance nitrogen gas bottles supply.                         Frequency Control Program Reason for Change Nitrogen gas bottles currently provide a backup to the instrument air supply and provide a motive force for operation of the PORVs. The type of container that holds the nitrogen gas is irrelevant to performing the backup function for operation of the PORVs. This function can be accomplished when the PORVs are provided with an adequate nitrogen supply provided from any type of appropriately designed container.
The proposed change removes unnecessary detail from the SR. The revised wording makes no technical changes and is editorial in nature. Therefore, NextEra is proposing this change to SR 3.4.12.7 to replace the words "gas bottles" with the general term "supply".

==3.0  TECHNICAL EVALUATION==

Low Temperature Overpressure Protection (LTOP) Svstem The LTOP system provides a diverse means of relieving reactor coolant system (RCS) pressure during periods of solid water operation when the reactor is less than or equal to the LTOP enabling temperature. The LTOP system consists of two control trains. The trains incorporate two key-operated enabling switches and two valve control switches in the control room. Signals from pressurizer pressure instrumentation and RCS loop 'A' hot leg pressure instrumentation are used to control the PORVs. The pressurizer pressure instrumentation controls one PORV, while the reactor coolant pressure instrumentation controls the other PORV. With both circuits properly armed, each Page 1 of 5

PORV, with its valve control switch in the automatic position, will open if system pressure increases to the lift setpoint.
TS 3.4.12 requires an operable LTOP system in MODE 4 when any RCS cold leg temperature is less than or equal to the LTOP enabling temperature specified in the Pressure Temperature Limits Report, MODE 5, and MODE 6 when the reactor vessel head is on. The air-operated PORVs, which are part of the LTOP system, are supplied by instrument air with nitrogen gas bottles providing a backup to the pneumatic supply for operation of the PORVs. SR 3.4.12. 7 demonstrates operability of the PORVs for their LTOP function, in part, by performing a complete cycle of each PORV solenoid air control valve and check valve on the nitrogen gas bottles.
Proposed Change SR 3.4.12. 7 periodically cycles the PORV solenoid air control valves and check valves on the nitrogen supply to ensure the valves will actuate properly during a low temperature overpressure condition. The SR currently specifies that the valves are cycled on the nitrogen gas bottles; however, NextEra proposes to replace the words "gas bottles" with the general term "supply." The general term "supply" applies regardless of the type of container {bottle, vessel, cylinder, tank, accumulator, etc.) that holds the nitrogen supply. The proposed change to SR 3.4.12.7 would apply to the current configuration where the nitrogen gas supply is provided by bottles. Similarly, the revised SR would apply if NextEra implements a future design change that replaces the nitrogen gas bottles with accumulators or another type of appropriate container.
The proposed wording does not change the function, technical requirements, or purpose of the SR, PORVs, or the LTOP system. Nitrogen gas bottles currently provide a backup to the instrument air supply and provide a motive force for operation of the PORVs. The type of container that holds the nitrogen gas is irrelevant to performing the backup function for operation of the PORVs. This function can be accomplished when the PORVs are provided with an adequate nitrogen supply provided from any type of appropriately designed container.
The proposed change removes unnecessary detail from the SR. The revised wording makes no technical changes and is editorial in nature because it only replaces reference to a specific type of container, nitrogen gas bottles, with the more general term nitrogen supply.

==4.0 REGULATORY EVALUATION==

4.1    Applicable Regulatory Requirements/Criteria
* Point Beach GDC Criterion 34 requires in part that the reactor coolant pressure boundary shall be designed and operated to reduce to an acceptable level the probability of rapidly propagating type failures.
Point Beach is not licensed to the General Design Criteria (GOG) of 10 CFR 50 Appendix A. The Atomic Energy Commission (AEC) published proposed GOG for public comment in 1967, and the Atomic Industrial Forum (AIF) reviewed these proposed criteria and recommended changes. The Point Beach GOG as documented in the Page 2 of 5

UFSAR are similar in content to the AIF version of the 1967 proposed GDC.
* Appendix G to Part 50-Fracture Toughness Requirements
* 50.36, Technical Specifications, states that surveillance requirements are requirements relating to test, calibration, or inspection to assure 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.
The proposed revision to SR 3.4.12. 7 is consistent with the above requirements and has no impact on performance or testing of the LTOP system. To define permissible operating conditions, heat-up and cool-down limit curves are established in accordance with the methods of analysis and the margins of safety of the ASME Boiler and Pressure Vessel Code, Section XI, Appendix G. In addition, the LTOP system using the PORVs is activated whenever the reactor coolant system is not open to the atmosphere and the coolant temperature is less than criteria established by ASME Section XI. With the proposed revision, SR 3.4.12. 7 will continue to provide test requirements that demonstrate operability of the PORVs.
4.2 Significant Hazards Consideration NextEra proposes to modify the wording in surveillance requirement (SR) 3.4.12. 7 associated with the power-operated relief valves (PORVs). As required by 10 CFR 50.91(a), NextEra has evaluated the proposed change to the Point Beach TS using the criteria in 10 CFR 50.92 and 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. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change, which is editorial in nature, modifies SR 3.4.12. 7 by replacing the words "gas bottles" with the general term "supply". The proposed change does not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected. No actual facility equipment or accident analyses are affected by the proposed changes.
Therefore, the**proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No Page 3 of 5

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). The proposed change does not create any new failure modes for existing equipment or any new limiting single failures. Additionally, the proposed change does not involve a change in the methods governing normal plant operation, and all safety functions will continue to perform as previously assumed in the accident analyses. Thus, the proposed change does not adversely affect the design function or operation of any structures, systems, and components important to safety.
No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. The proposed change does not challenge the performance or integrity of any safety-related system.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated .
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The margin of safety associated with the acceptance criteria of any accident is unchanged. The proposed change will have no effect on the availability, operability, or performance of safety-related systems and components. The proposed revision to the wording of SR 3.4.12.7 will have no effect on the test requirements that demonstrate operability of the PORVs.
The proposed change will not adversely affect the operation of plant equipment or the function of equipment assumed in the accident analysis.
The proposed amendment does not involve changes to any safety analyses assumptions, safety limits, or limiting safety system settings. The change does not adversely impact plant operating margins or the reliability of equipment credited in the safety analyses.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based upon the above analysis, NextEra concludes that the proposed amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92(c), "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.
4.3 Conclusions ..
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.
Page 4 of 5

==5.0 ENVIRONMENTAL CONSIDERATION==

NextEra has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.
However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

==6.0 REFERENCES==

None Page 5 of 5

ATTACHMENT 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Markup of the Technical Specification Page 1 page follows

LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                      FREQUENCY SR 3.4.12.6  Perform CHANNEL CALIBRATION for each required           In accordance with PORV actuation channel.                                the Surveillance Frequency Control Program t
t SR 3.4.12.7  Perform a complete cycle of each required PORV         In accordance with solenoid air control valve and check valve on the      the Surveillance nitrogen gas bottles .                                 Frequency Control
                                ~                                         Program t
SR 3.4.12.8  Perform a complete cycle of each required PORV.        In accordance with the Surveillance Frequency Control Program
' } Point Beach                             3.4 .12-5           Unit 1 -Amendment No. ~
Unit 2- Amendment No. 2.5-7

ATTACHMENT 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Markup of the Technical Specification Bases 1 page follows

LTOP B 3.4.12 BASES SURVEILLANCE  This clarifies what is an acceptable CHANNEL OPERATIONAL TEST REQUIREMENTS  of a relay. This is acceptable because all of the other required contacts (continued)   of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will verify the setpoint is within the PTLR allowed maximum limits in the PTLR. PORV actuation could depressurize the RCS and is not required.
SR 3.4.12.6 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required to adjust the whole channel so that it       ~
responds and the valve opens within the required range and accuracy to known input. The Surveillance Frequency is controlled under the           y Surveillance Frequency Control Program.                                     'I SR 3.4.12.7 and SR 3.4.12.8 Operating the PORVs, th olenoid air control valves and the check valves on the nitrogen gas bottlss ensures the PORVs and PORV control system will actuate properly when called upon. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
t REFERENCES    1. 10 CFR 50, Appendix G.
: 2. Generic Letter 88-11.
: 3. ASME, Boiler and Pressure Vessel Code, Section Ill.
: 4. Technical Requirements Manual 2.2, Pressure Temperature Limits Report.
: 5. 10 CFR 50, Section 50.46 .
: 6. 10 CFR 50, Appendix K.
: 7. Generic Letter 90-06.
: 8. Engineering Evaluation 2001-0037, Rev 0, 12/13/01, Evaluation of Unbolted Head as an RCS vent path.
Point Beach                       B3.4.12-11               Unit 1 -Amendment No. 25J Unit 2 -Amendment No. 25.7

ATTACHMENT 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Revised Technical Specification Page Containing the Proposed Change 1 pages follows

LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                     FREQUENCY SR 3.4.12.6  Perform CHANNEL CALIBRATION for each required           In accordance with PORV actuation channel.                                the Surveillance Frequency Control Program SR 3.4.12.7  Perform a complete cycle of each required PORV         In accordance with solenoid air control valve and check valve on the      the Surveillance nitrogen supply.                                       Frequency Control Program SR 3.4.12 .8 Perform a complete cycle of each required PORV.        In accordance with the Surveillance Frequency Control Program I Point Beach                             3.4.12-5            Unit 1 -Amendment No . XXX Unit 2- Amendment No . XXX

NEXTeraM ENERGY~
                                                                           ~
March 10, 2016                                                                  . NRC 2016-0009 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Units 1 and 2 Docket Nos. 50-266 and 50-301 Renewed Facility Operating Licenses Nos. DPR-24 and DPR-27 License Amendment Request 2821 Modify the Wording of Surveillance Requirement 3.4.12. 7 Associated with the Power-operated Relief Valves In accordance with 10 CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby requests a license amendment to revise the technical specifications (TS) for Point Beach Units 1 and 2. The proposed change modifies the wording in surveillance requirement 3.4.12.7 associated with the power-operated relief valves.
The Enclosure to this letter provides NextEra's evaluation of the proposed change. to the enclosure provides a markup of the TS showing the proposed change, and  provides the proposed TS Bases change. The change to the TS Bases is provided for information only and will be incorporated in accordance with the TS Bases Control Program upon implementation of the approved amendment. Attachment 3 provides the revised TS page containing the proposed change.
As discussed in the evaluation, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. This change has been reviewed by the Point Beach Onsite Review Group.
In accordance with 10 CFR 50.91, a copy of this letter is being forwarded to the State of Wisconsin designee.
This letter contains no new or revised regulatory commitments.
I                                                        1 NextEra requests approval of the amendment by March 10, 2017, and implementation within 90 days.
Should you have any questions regarding this submittal, please contact Mr. Bryan Woyak, Licensing Manager, at 920-755-7599.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 10, 2016 Sincerely, NextEra Energy Point Beach, LLC Eric McCartney Site Vice President Enclosure cc:     Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Evaluation of the Proposed Change

==SUBJECT:==
License Amendment Request 282, Modify the Wording of Surveillance Requirement 3.4.12. 7 Associated with the Power-operated Relief Valves 1.0   

==SUMMARY==
DESCRIPTION 2.0   DETAILED DESCRIPTION

==3.0   TECHNICAL EVALUATION==

==4.0   REGULATORY EVALUATION==

4.1   Applicable Regulatory Requirements/Criteria 4.2   Significant Hazards Consideration 4.3   Conclusions

==5.0    ENVIRONMENTAL CONSIDERATION==

==6.0    REFERENCES==
  -Markup of Technical Specification Page - Markup of Technical Specification Bases - Revised Technical Specification Page Containing the Proposed Change 5 pages follow

1.0   

==SUMMARY==
DESCRIPTION NextEra Energy Point Beach, LLC (NextEra) requests a license amendment to revise the Technical Specifications (TS) for Point Beach Units 1 and 2. The proposed change modifies the wording in Surveillance Requirement (SR) 3.4.12.7 associated with the power-operated relief valves (PORVs).
2.0   DETAILED DESCRIPTION Proposed Change The proposed change modifies the wording in SR 3.4.12. 7 by replacing the words "gas bottles" with the word "supply" as shown below.
SR 3.4.12.7     Perform a complete cycle of each required PORV       In accordance with solenoid air control valve and check valve on the    the Surveillance nitrogen gas bottles supply.                         Frequency Control Program Reason for Change Nitrogen gas bottles currently provide a backup to the instrument air supply and provide a motive force for operation of the PORVs. The type of container that holds the nitrogen gas is irrelevant to performing the backup function for operation of the PORVs. This function can be accomplished when the PORVs are provided with an adequate nitrogen supply provided from any type of appropriately designed container.
The proposed change removes unnecessary detail from the SR. The revised wording makes no technical changes and is editorial in nature. Therefore, NextEra is proposing this change to SR 3.4.12.7 to replace the words "gas bottles" with the general term "supply".

==3.0  TECHNICAL EVALUATION==

Low Temperature Overpressure Protection (LTOP) Svstem The LTOP system provides a diverse means of relieving reactor coolant system (RCS) pressure during periods of solid water operation when the reactor is less than or equal to the LTOP enabling temperature. The LTOP system consists of two control trains. The trains incorporate two key-operated enabling switches and two valve control switches in the control room. Signals from pressurizer pressure instrumentation and RCS loop 'A' hot leg pressure instrumentation are used to control the PORVs. The pressurizer pressure instrumentation controls one PORV, while the reactor coolant pressure instrumentation controls the other PORV. With both circuits properly armed, each Page 1 of 5

PORV, with its valve control switch in the automatic position, will open if system pressure increases to the lift setpoint.
TS 3.4.12 requires an operable LTOP system in MODE 4 when any RCS cold leg temperature is less than or equal to the LTOP enabling temperature specified in the Pressure Temperature Limits Report, MODE 5, and MODE 6 when the reactor vessel head is on. The air-operated PORVs, which are part of the LTOP system, are supplied by instrument air with nitrogen gas bottles providing a backup to the pneumatic supply for operation of the PORVs. SR 3.4.12. 7 demonstrates operability of the PORVs for their LTOP function, in part, by performing a complete cycle of each PORV solenoid air control valve and check valve on the nitrogen gas bottles.
Proposed Change SR 3.4.12. 7 periodically cycles the PORV solenoid air control valves and check valves on the nitrogen supply to ensure the valves will actuate properly during a low temperature overpressure condition. The SR currently specifies that the valves are cycled on the nitrogen gas bottles; however, NextEra proposes to replace the words "gas bottles" with the general term "supply." The general term "supply" applies regardless of the type of container {bottle, vessel, cylinder, tank, accumulator, etc.) that holds the nitrogen supply. The proposed change to SR 3.4.12.7 would apply to the current configuration where the nitrogen gas supply is provided by bottles. Similarly, the revised SR would apply if NextEra implements a future design change that replaces the nitrogen gas bottles with accumulators or another type of appropriate container.
The proposed wording does not change the function, technical requirements, or purpose of the SR, PORVs, or the LTOP system. Nitrogen gas bottles currently provide a backup to the instrument air supply and provide a motive force for operation of the PORVs. The type of container that holds the nitrogen gas is irrelevant to performing the backup function for operation of the PORVs. This function can be accomplished when the PORVs are provided with an adequate nitrogen supply provided from any type of appropriately designed container.
The proposed change removes unnecessary detail from the SR. The revised wording makes no technical changes and is editorial in nature because it only replaces reference to a specific type of container, nitrogen gas bottles, with the more general term nitrogen supply.

==4.0 REGULATORY EVALUATION==

4.1    Applicable Regulatory Requirements/Criteria
* Point Beach GDC Criterion 34 requires in part that the reactor coolant pressure boundary shall be designed and operated to reduce to an acceptable level the probability of rapidly propagating type failures.
Point Beach is not licensed to the General Design Criteria (GOG) of 10 CFR 50 Appendix A. The Atomic Energy Commission (AEC) published proposed GOG for public comment in 1967, and the Atomic Industrial Forum (AIF) reviewed these proposed criteria and recommended changes. The Point Beach GOG as documented in the Page 2 of 5

UFSAR are similar in content to the AIF version of the 1967 proposed GDC.
* Appendix G to Part 50-Fracture Toughness Requirements
* 50.36, Technical Specifications, states that surveillance requirements are requirements relating to test, calibration, or inspection to assure 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.
The proposed revision to SR 3.4.12. 7 is consistent with the above requirements and has no impact on performance or testing of the LTOP system. To define permissible operating conditions, heat-up and cool-down limit curves are established in accordance with the methods of analysis and the margins of safety of the ASME Boiler and Pressure Vessel Code, Section XI, Appendix G. In addition, the LTOP system using the PORVs is activated whenever the reactor coolant system is not open to the atmosphere and the coolant temperature is less than criteria established by ASME Section XI. With the proposed revision, SR 3.4.12. 7 will continue to provide test requirements that demonstrate operability of the PORVs.
4.2 Significant Hazards Consideration NextEra proposes to modify the wording in surveillance requirement (SR) 3.4.12. 7 associated with the power-operated relief valves (PORVs). As required by 10 CFR 50.91(a), NextEra has evaluated the proposed change to the Point Beach TS using the criteria in 10 CFR 50.92 and 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. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change, which is editorial in nature, modifies SR 3.4.12. 7 by replacing the words "gas bottles" with the general term "supply". The proposed change does not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected. No actual facility equipment or accident analyses are affected by the proposed changes.
Therefore, the**proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No Page 3 of 5

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). The proposed change does not create any new failure modes for existing equipment or any new limiting single failures. Additionally, the proposed change does not involve a change in the methods governing normal plant operation, and all safety functions will continue to perform as previously assumed in the accident analyses. Thus, the proposed change does not adversely affect the design function or operation of any structures, systems, and components important to safety.
No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. The proposed change does not challenge the performance or integrity of any safety-related system.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated .
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The margin of safety associated with the acceptance criteria of any accident is unchanged. The proposed change will have no effect on the availability, operability, or performance of safety-related systems and components. The proposed revision to the wording of SR 3.4.12.7 will have no effect on the test requirements that demonstrate operability of the PORVs.
The proposed change will not adversely affect the operation of plant equipment or the function of equipment assumed in the accident analysis.
The proposed amendment does not involve changes to any safety analyses assumptions, safety limits, or limiting safety system settings. The change does not adversely impact plant operating margins or the reliability of equipment credited in the safety analyses.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based upon the above analysis, NextEra concludes that the proposed amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92(c), "Issuance of Amendment," and accordingly, a finding of "no significant hazards consideration" is justified.
4.3 Conclusions ..
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.
Page 4 of 5

==5.0 ENVIRONMENTAL CONSIDERATION==

NextEra has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.
However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

==6.0 REFERENCES==

None Page 5 of 5

ATTACHMENT 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Markup of the Technical Specification Page 1 page follows

LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                      FREQUENCY SR 3.4.12.6  Perform CHANNEL CALIBRATION for each required           In accordance with PORV actuation channel.                                the Surveillance Frequency Control Program t
t SR 3.4.12.7  Perform a complete cycle of each required PORV         In accordance with solenoid air control valve and check valve on the      the Surveillance nitrogen gas bottles .                                 Frequency Control
                                ~                                         Program t
SR 3.4.12.8  Perform a complete cycle of each required PORV.        In accordance with the Surveillance Frequency Control Program
' } Point Beach                             3.4 .12-5           Unit 1 -Amendment No. ~
Unit 2- Amendment No. 2.5-7

ATTACHMENT 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Markup of the Technical Specification Bases 1 page follows

LTOP B 3.4.12 BASES SURVEILLANCE  This clarifies what is an acceptable CHANNEL OPERATIONAL TEST REQUIREMENTS  of a relay. This is acceptable because all of the other required contacts (continued)   of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The COT will verify the setpoint is within the PTLR allowed maximum limits in the PTLR. PORV actuation could depressurize the RCS and is not required.
SR 3.4.12.6 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required to adjust the whole channel so that it       ~
responds and the valve opens within the required range and accuracy to known input. The Surveillance Frequency is controlled under the           y Surveillance Frequency Control Program.                                     'I SR 3.4.12.7 and SR 3.4.12.8 Operating the PORVs, th olenoid air control valves and the check valves on the nitrogen gas bottlss ensures the PORVs and PORV control system will actuate properly when called upon. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
t REFERENCES    1. 10 CFR 50, Appendix G.
: 2. Generic Letter 88-11.
: 3. ASME, Boiler and Pressure Vessel Code, Section Ill.
: 4. Technical Requirements Manual 2.2, Pressure Temperature Limits Report.
: 5. 10 CFR 50, Section 50.46 .
: 6. 10 CFR 50, Appendix K.
: 7. Generic Letter 90-06.
: 8. Engineering Evaluation 2001-0037, Rev 0, 12/13/01, Evaluation of Unbolted Head as an RCS vent path.
Point Beach                       B3.4.12-11               Unit 1 -Amendment No. 25J Unit 2 -Amendment No. 25.7

ATTACHMENT 3 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 282 Revised Technical Specification Page Containing the Proposed Change 1 pages follows

LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                     FREQUENCY SR 3.4.12.6  Perform CHANNEL CALIBRATION for each required           In accordance with PORV actuation channel.                                the Surveillance Frequency Control Program SR 3.4.12.7  Perform a complete cycle of each required PORV         In accordance with solenoid air control valve and check valve on the      the Surveillance nitrogen supply.                                       Frequency Control Program SR 3.4.12 .8 Perform a complete cycle of each required PORV.        In accordance with the Surveillance Frequency Control Program I Point Beach                             3.4.12-5            Unit 1 -Amendment No . XXX Unit 2- Amendment No . XXX}}